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 ! relatively straightforward. In my view, a public hearing clearly is nevertheless the preferred vehicle for its resolution. Incidentally, while I'm on this subject, I got some help today from the New York Law Journal from two professors who write that a hearing is — let me tell you exactly what they said. They say, in part, that this is an odd moment for transparency in a criminal case. I think that is an odd sentence to hear about, transparency in a criminal case. They go on to say that normally, if a prosecutor seeks to dismiss an indictment for such an obviously worthy reason, the court would simply grant the request. As to that statement, I respectfully say it is incorrect as a matter of law. They go on to say the judge would not schedule a hearing and he definitely would not allow the victims to speak. If he did hold a hearing, whatever informational interests the victims may have would be served by affording them a chance to attend the hearing, not by giving them a speaking role. I read it. It was incredulous. I'm still incredulous. I don't quite understand at all. There is a suggestion in the article that the reason they are making these suggestions has to do with minimization of drama in this case. In the Jeffrey Epstein case, there has not been much a minimization of drama, and what little drama might happen SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000923 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 relatively straightforward. In my view, a public hearing clearly is nevertheless the preferred vehicle f~r its resolution. Incidentally, while I'm on this subject, I got some help today from the New York Law Journal from two professors who write that a hearing is -- let me tell you exactly what they said. They say, in part, that this is an odd moment for transparency in a criminal case. I think that is an odd sentence to hear about, transparency in a criminal case. 4 They go on to say that normally, if a prosecutor seeks to dismiss an indictment for such an obviously worthy reason, the court would simply grant the request. As to that statement, I respectfully say it is incorrect as a matter of law. They go on to say the judge would not schedule a hearing and he definitely would not allow the victims to speak. If he did hold a hearing, whatever informational interests the victims may have would be served by affording them a chance to attend the hearing, not by giving them a speaking role. I read it. It was incredulous. I'm still incredulous. I don't quite understand at all. There is a suggestion in the article that the reason they are making these suggestions has to do with minimization of drama in this case. In the Jeffrey Epstein case, there has not been much a minimization of drama, and what little drama might happen SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000923 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 ; today, I don't think it would be very significant. On a somewhat more serious note, don't; quote me on this, but it is my understanding that one of this authors of that article is himself counsel in one of the Epstein-related cases. I was surprised to learn that very recently. I'm certain it is true. I was also surprised that that aspect was not disclosed in the Law Journal. But in any event, I think you know where I'm heading. I respectfully disagree with the Law Journal piece. I was saying that the government's motion is relatively straightforward, and in my view, a public hearing is clearly, nevertheless, the preferred vehicle for its resolution. I'm still convinced of that. A few may differ on this, but public hearings are exactly what judges do. Hearings promote transparency and they provide the court with insights and information which the court may not otherwise be aware of. The victims have been included in the proceeding today both because of their relevant experiences and because they should always be involved before rather than after the fact. Indictment 19 CR 490 charges Jeffrey Epstein with sex trafficking and with conspiracy to commit sex trafficking. The U.S. Attorney, on August 19, 2019, requested that the court approve the government's proposed order of nolle prosequi. I think that's a rough justice. That means nolle prosequi, SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 ' CA/Aronberg-000924 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 today, I don't think it would be very significa~t. On a somewhat more serious note, don't: quote me on I this, but it is my understanding that one of the authors of i ' 5 that article is himself counsel in one of the Epstein-related cases. I was surprised to learn that very recently. I'm certain it is true. I was also surprised that that aspect was not disclosed in the Law Journal. But in any event, I think you know where I'm heading. I respectfully disagree with the Law Journal piece. I was saying that the government's motion is relatively straightforward, and in my view, a public hearing is clearly, nevertheless, the preferred vehicle for its resolution. I'm still convinced of that. A few may differ on this, but public hearings are exactly what judges do. Hearings promote transparency and they provide the court with insights and information which the court may not otherwise be aware of. The victims have been included in the proceeding today both because of their relevant experiences and because they should always be involved before rather than after the fact. Indictment 19 CR 490 charges Jeffrey Epstein with sex trafficking and with conspiracy to commit sex trafficking. The U.S. Attorney, on August 19, 2019, requested that the court approve the government's proposed order of nolle prosequi. I think that's a rough justice. That means nolle prosequi, I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000924 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 6 J8RsEPSl discontinuance by the prosecutor of all or of a part of the i case that he or she has commenced. ; i The government in its motion concludes' that Epstein's death abates these proceedings. In accordance with Federal Rule of Criminal Procedure 57(b), I determined to hold a public hearing and I notified the victims that they would be given the opportunity to be heard before any final action on the motion. That is the purpose also of today's proceeding. I would do that every time. Also, recognized that Epstein, Mr. Epstein died before any judgment of conviction against him had been obtained, and that the government's proposed order appears, in form and substance, to be appropriate. Federal Rule of Criminal Procedure 48(a) codifies the nolle prosequi process. It is entitled dismissal, and it states in relevant part that the government may, with leave of the court, dismiss an indictment, information, or complaint, and that leave of the court proviso, you should know, was added as an amendment to the original draft of Rule 48, which had originally provided for automatic dismissal upon the motion of the government. This proviso, in my judgment, is clearly directed toward an independent judicial assessment of the public interest in dismissing the indictment. Thus, even whereas, in this case, the standard of court review is deferential, the SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 CA/Aronberg-000925 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPSl discontinuance by the prosecutor of all or of a, part of the I case that he or she has commenced. 6 The government in its motion concludesi that Epstein's death abates these proceedings. In accordance with Federal Rule of Criminal Procedure 57(b), I determined to hold a public hearing and I notified the victims that they would be given the opportunity to be heard before any final action on the motion. That is the purpose also of today's proceeding. I would do that every time. Also, recognized that Epstein, Mr. Epstein died before any judgment of conviction against him had been obtained, and that the government's proposed order appears, in form and substance, to be appropriate. Federal Rule of Criminal Procedure 48(a) codifies the nolle prosequi process. It is entitled dismissal, and it states in relevant part that the government may, with leave of the court, dismiss an indictment, information, or complaint, and that leave of the court proviso, you should know, was added as an amendment to the original draft of Rule 48, which had originally provided for automatic dismissal upon the motion of the government. This proviso, in my judgment, is clearly directed toward an independent judicial assessment of the public interest in dismissing the indictment. Thus, even whereas, in this case, the standard of court review is deferential, the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000925 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 I court must still make its own independent determination. A conclusory statement from the government that dismissal is l appropriate does not satisfy the court's obligations. It is also, in my view, required that the court consider the views of the victims in the case at the hearing and before deciding whether to grant the motion. This is being done here both as a matter of law and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense against a young victim. Although I should point out, very importantly, that that defendant was still alive, which distinguishes it from our case. Nevertheless, I think it is irrelevant because in evaluating the Rule 48 motion, then district Judge Paul G. Cassell — who is now a law professor at the University of Utah and is regarded to be a noted expert in victims' rights — concluded that under the Crime Victims' Rights Act, victims have broad rights that extend to a court's decision whether to grant a government motion to dismiss under Rule 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 i i CA/Aronberg-000926 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 I court must still make its own independent determination. A ' conclusory statement from the government that dismissal is I appropriate does not satisfy the court's I obliga;tions. It is also, in my view, required that the court consider the views of the victims in the case at the hearing 7 and before deciding whether to grant the motion. This is being done here both as a matter of law and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense against a young victim. Although I should point out, very importantly, that that defendant was still alive, which distinguishes it from our case. Nevertheless, I think it is irrelevant because in evaluating the Rule 48 motion, then district Judge Paul G. Cassell -- who is now a law professor at the University of Utah and is regarded to be a noted expert in victims' rights concluded that under the Crime Victims' Rights Act, victims have broad rights that extend to a court's decision whether to grant a government motion to dismiss under Rule 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000926 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 1 the court's responsibility, and manifestly within its purview, to ensure that the victims in this case are treated fairly and with dignity. The fundamental substantive principle which applies in considering the government's motion is termed the rule of abatement. This principle originated in the English common law. It was adopted by most U.S. federal courts, but more recently, it has faced some appropriate criticism. The rule of abatement is best explained in the Second Circuit case of U.S, v. Wright. In that Wright case, two defendants had pled guilty to embezzlement and tax evasion. Both defendants appealed, but one of the defendants died while his appeal was pending in the Second Circuit. The Court of Appeals rule that under the rule of abatement, the judgment of conviction against the deceased defendant was required to be vacated and the indictment was to be dismissed. The Wright court held that when a convicted defendant dies while his direct appeal as of right is pending, his death abates not only the appeal, but also proceedings had during the course of the prosecution. The Second Circuit incidentally has also held that when a criminal conviction abates upon the death of a defendant, any restitution ordered as a result of that conviction must also abate, and it is also ruled the same with respect to associated forfeiture orders. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 ! CA/Aronberg-000927 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 8 J8RsEPS1 the court's responsibility, and manifestly with~n its purview, to ensure that the victims in this case are treated fairly and I with dignity. The fundamental substantive principle which applies in considering the government's motion is termed the rule of abatement. This principle originated in the English common law. It was adopted by most U.S. federal courts, but more recently, it has faced some appropriate criticism. The rule of abatement is best explained in the Second Circuit case of U.S. v. Wright. In that Wright case, two defendants had pled guilty to embezzlement and tax evasion. Both defendants appealed, but one of the defendants died while his appeal was pending in the Second Circuit. The Court of Appeals rule that under the rule of abatement, the judgment of conviction against the deceased defendant was required to be vacated and the indictment was to be dismissed. The Wright court held that when a convicted defendant dies while his direct appeal as of right is pending, his death abates not only the appeal, but also proceedings had during the course of the prosecution. The Second Circuit incidentally has also held that when a criminal conviction abates upon the death of a defendant, any restitution ordered as a result of that conviction must also abate, and it is also ruled the same with respect to associated forfeiture orders. SOUTHERN DISTRICT REPORTERS, P.y. (212) 805-0300 I CA/Aronberg-000927 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM J8RsEPSl 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 This latter application of the rule of1 abatement regarding forfeiture has not been universally accepted among federal courts, but it certainly is the law in this circuit. Some of you may be interested to know that some United States courts, state courts, have criticized the rule of abatement, particularly in the face of growing recognition of victims' rights in the criminal justice system, including the Crime Victims' Rights Act. It has been written and contended in the Brooklyn Law Review — I can give you the cite later — that when courts abate criminal convictions, they reimpose a burden on victims that legislatures intended to alleviate through these victim rights statutes. The state Supreme Court has even concluded that the expansion and codification of victims' rights provides the changed conditions needed for overruling the rule of abatement. It has also been stated that Alaska's statute and its constitution now require the criminal justice system to accommodate the rights of crime victims. Further, that the abatement of criminal convictions has important implications for these rights. But coming back to our case, which is what you are concerned about and I am as well, it is appropriate to conclude that if the rule of abatement applies to a convicted defendant as in the Wright case, it should also apply a fortiori in the Epstein case, which was still in the pretrial phase when SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000928 i FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • J8RsEPSl This latter application of the rule of: abatement regarding forfeiture has not been universally accepted among federal courts, but it certainly is the law in this circuit. Some of you may be interested to know that some United States courts, state courts, have criticized the rule of abatement, particularly in the face of growing recognition of victims' rights in the criminal justice system, including the Crime Victims' Rights Act. 9 It has been written and contended in the Brooklyn Law Review -- I can give you the cite later -- that when courts abate criminal convictions, they reimpose a burden on victims that legislatures intended to alleviate through these victim rights statutes. The state Supreme Court has even concluded that the expansion and codification of victims' rights provides the changed conditions needed for overruling the rule of abatement. It has also been stated that Alaska's statute and its constitution now require the criminal justice system to accommodate the rights of crime victims. Further, that the abatement of criminal convictions has important implications for these rights. But coming back to our case, which is what you are concerned about and I am as well, it is appropriate to conclude that if the rule of abatement applies to a convicted defendant as in the Wright case, it should also apply a fortiori in the Epstein case, which was still in the pretrial phase when SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000928 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 I Mr. Epstein died, when there had been no conviction. So that's just some background I wanted to share with you. At this point in time, I would like to turn to the government prosecutors to hear from them in support of their Rule 48 application to dismiss the Epstein indictment. MS. COMEY: Thank you, your Honor. Would you like me to address the court from the podium? THE COURT: If you wouldn't mind. MS. COMEY: Thank you, your Honor. I believe your Honor has accurately summarized the state of the law, as set forth in our papers, in light of the clear Second Circuit law, that upon the death of a defendant before a final entry of a judgment of conviction, all proceedings must be abated. In light of that clear law, the government is legally obligated to seek dismissal of the pending indictment against Jeffrey Epstein, and we respectfully submit, likewise, that the entry of the proposed order is similarly required by law. A few notes to make about that, though, your Honor. To be very clear, dismissal of this indictment as to Jeffrey Epstein in no way prohibits or inhibits the government's ongoing investigation into other potential coconspirators, nor does it prevent the bringing of a new case in the future or the prosecution of new defendants. 10 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000929 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 10 J8RsEPSl I i Mr. Epstein died, when there had been no convic~ion. So that's just some background I wanted to share with I you. At this point in time, I would like to turn to the government prosecutors to hear from them in support of their Rule 48 application to dismiss the Epstein indictment. podium? MS. COMEY: Thank you, your Honor. Would you like me to address the court from the THE COURT: If you wouldn't mind. MS. COMEY: Thank you, your Honor. I believe your Honor has accurately summarized the state of the law, as set forth in our papers, in light of the clear Second Circuit law, that upon the death of a defendant before a final entry of a judgment of conviction, all proceedings must be abated. In light of that clear law, the government is legally obligated to seek dismissal of the pending indictment against Jeffrey Epstein, and we respectfully submit, likewise, that the entry of the proposed order is similarly required by law. A few notes to make about that, though, your Honor. To be very clear, dismissal of this indictment as to Jeffrey Epstein in no way prohibits or inhibits the government's ongoing investigation into other potential coconspirators, nor does it prevent the bringing of a new case in the future or the prosecution of new defendants. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000929 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 It also does nothing to prevent the government from continuing to explore the possibility of seeking civil forfeiture of any assets that were used to facilitate the crimes charged in this indictment. Indeed, as has been stated publicly, investigations into those matters have been ongoing, remain ongoing, and will continue following dismissal of the indictment here. I would also like to note that, as the government has previously mentioned, this dismissal in no way lessens the government's resolve to stand up for the victims in this case, both those who have come forward and those who have yet to do so. We agree with your Honor's sentiment that those victims should be respected, and we appreciate your Honor's recognition of that. One housekeeping matter that I did want to reference for your Honor. The protective order in this case requires destruction or return of any and all discovery material upon conclusion of the case. We have been in communication with defense counsel, who have confirmed that they have returned all physical copies that they have of discovery that the government has produced to date, and they are in the process of deleting any copies that they may have made. So the parties are in compliance with the protective order. Finally, I just wanted to say a word about the victims in this case, and particularly those who are here in court SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 I CA/Aronbe rg-000930 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 11 J8RsEPSl It also does nothing to prevent the government from continuing to explore the possibility of seeking civil forfeiture of any assets that were used to facilitate the crimes charged in this indictment. Indeed, as has been stated publicly, investigations into those matters have been ongoing, remain ongoing, and will continue following dismissal of the indictment here. I would also like to note that, as the government has previously mentioned, this dismissal in no way lessens the government's resolve to stand up for the victims in this case, both those who have come forward and those who have yet to do so. We agree with your Honor's sentiment that those victims should be respected, and we appreciate your Honor's recognition of that. One housekeeping matter that I did want to reference for your Honor. The protective order in this case requires destruction or return of any and all discovery material upon conclusion of the case. We have been in communication with defense counsel, who have confirmed that they have returned all physical copies that they have of discovery that the government has produced to date, and they are in the process of deleting any copies that they may have made. So the parties are in compliance with the protective order. Finally, I just wanted to say a word about the victims in this case, and particularly those who are here in court SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/ Aron be rg-000930 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 1 I i today. I'll note that in light of the court's order indicating that the victims and their counsel would be permitted to be heard in court here today, the government has endeavored to provide notice to all known victims of today's proceeding. We did so either directly where a victim was not represented by counsel or through counsel where a victim is represented by an attorney. The government does not know exactly how many victims or their attorneys are here today and we do not know how many of them or their counsel would like to speak. To the extent any individuals do wish to speak, we do not know the substance of what they would like to say. We have left that entirely up to the individual decisions of the victims and their attorneys. I will note, though, that throughout this case, the government has endeavored and done our utmost to fulfill our obligations under the Crimes Victims' Rights Act. We have done so by trying to keep as many victims as we are aware of up to date about the ongoing case and about any developments in the case. We will continue to provide services and offer services to any of the victims in this case, even after the indictment is dismissed. Both the U.S. Attorney's office and the FBI have been in touch with all known victims or have attempted to be in touch with all known victims, either again directly where victims are not represented by counsel or SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000931 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 12 J8RsEPSl I i today. I I'll note that in light of the court's prder indicating that the victims and their counsel would be permitted to be heard in court here today, the government has endeavored to provide notice to all known victims of today's proceeding. We did so either directly where a victim was not represented by counsel or through counsel where a victim is represented by an attorney. The government does not know exactly how many victims or their attorneys are here today and we do not know how many of them or their counsel would like to speak. To the extent any individuals do wish to speak, we do not know the substance of what they would like to say. We have left that entirely up to the individual decisions of the victims and their attorneys. I will note, though, that throughout this case, the government has endeavored and done our utmost to fulfill our obligations under the Crimes Victims' Rights Act. We have done so by trying to keep as many victims as we are aware of up to date about the ongoing case and about any developments in the case. We will continue to provide services and offer services to any of the victims in this case, even after the indictment is dismissed. Both the U.S. Attorney's office and the FBI have been in touch with all known victims or have attempted to be in touch with all known victims, either again directly where victims are not represented by c~unsel or SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000931 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 through counsel where they have attorneys. We have expressed I to them that services are available for those who wish to take advantage of them. Unless the court has any questions for me, the government will otherwise rest on its papers. THE COURT: I just have one question. The protective order, is that self-executing or do I need to do something? MS . COMEY: It is self-executing, your Honor THE COURT: Thanks very much, Ms. Comey. MS. COMEY: Thank you, your Honor. THE COURT: Yes. I'll turn to counsel for the defense at this time. Mr. Weingarten, I'm happy to hear from you. MR. WEINGARTEN: Thank you. Your Honor, I think it is an understatement of the year to say the world looks and feels differently today than it did the last time I was before you. For us, the elephant in the room is what happened to our client. I would like to tell you how we see the world and where we are on that subject. We start with the Attorney General's statements, public statements, that there were very serious improprieties in the jail. We obviously read the press. We see that the warden has been taken out. We see that the guards on duty at the time have been put on leave. We understand guards are SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000932 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 13 J8RsEPS1 through counsel where they have attorneys. We rave expressed to them that services are available for those who wish to take advantage of them. Unless the court has any questions for me, the government will otherwise rest on its papers. THE COURT: I just have one question. The protective order, is that self-executing or do I need to do something? MS. COMEY: It is self-executing, your Honor. THE COURT: Thanks very much, Ms. Corney. MS. COMEY: Thank you, your Honor. THE COURT: Yes. I'll turn to counsel for the defense at this time. Mr. Weingarten, I'm happy to hear from you. MR. WEINGARTEN: Thank you. Your Honor, I think it is an understatement of the year to say the world looks and feels differently today than it did the last time I was before you. For us, the elephant in the room is what happened to our client. I would like to tell you how we see the world and where we are on that subject. We start with the Attorney General's statements, public statements, that there were very serious improprieties in the jail. We obviously read the press. We see that the warden has been taken out. We see that the guards on duty at the time have been put on leave. We understand guards are SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000932 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 | refusing to cooperate with the investigation. We have heard allegations that people at the time who had responsibility for protecting our client falsified information. We understand that there were orders out there that Jeffrey Epstein was never to be left alone and that the orders were ignored by many of the employees of the prison. In a word, yikes. In addition, obviously we followed the medical examiner's report, or we haven't followed the report, we haven't seen it, but heard conclusions, initially not enough evidence to come to a conclusion, wanted to see more. We assumed she was talking about the videotapes, but then came to the conclusion that it was suicide. We report to the court that — THE COURT: Suicide by hanging — MR. WEINGARTEN: Yes. THE COURT: — was her conclusion? MR. WEINGARTEN: Yes. And we report to the court that we had a doctor there at the time, and we also have been in receipt of a tremendous amount of medical and scientific evidence volunteered to us opining that the injuries suffered, as reported, were far more consistent with assault than with suicide, and we are happy to supply the court with all the information that we have. Now, in addition, as the court noted, we were underway with our pretrial motions, and as the court obviously SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 i CA/Aronberg-000933 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 14 J8RsEPS1 1 I I I refusing to cooperate with the investigation. We have heard allegations that people at the time who had responsibility for protecting our client falsified information. We understand that there were orders out there that Jeffrey Epstein was never to be left alone and that the orders were ignored by many of the employees of the prison. In a word, yikes. In addition, obviously we followed the medical examiner's report, or we haven't followed the report, we haven't seen it, but heard conclusions, initially not enough evidence to come to a conclusion, wanted to see more. We assumed she was talking about the videotapes, but then came to the conclusion that it was suicide. We report to the court that -- THE COURT: Suicide by hanging MR. WEINGARTEN: Yes. THE COURT: -- was her conclusion? MR. WEINGARTEN: Yes. And we report to the court that we had a doctor there at the time, and we also have been in receipt of a tremendous amount of medical and scientific evidence volunteered to us opining that the injuries suffered, as reported, were far more consistent with assault than with suicide, and we are happy to supply the court with all the information that we have. Now, in addition, as the court noted, .we were underway with our pretrial motions, and as the court obviously SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CNAronberg-000933 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 ' understands, the NPA and the role of the NPA was going to be critically important. And I would simply like to report that we went pretty far along. We interviewed all of the relevant lawyers on the defense side who participated in the NPA, and we were satisfied that we had a very strong argument that every one of those lawyers believed with an objective basis that the deal was global. That is, at the time — THE COURT: I'm sorry, that? MR. WEINGARTEN: The deal of the NPA was global. That is, more specifically, at the time, the Florida prosecutors and agents knew of conduct in New York, and that no competent defense counsel negotiating in good faith with the prosecutors would have ever agreed to a deal back then that allowed New York prosecutors to indict for precisely the same conduct in the future, which, of course, is what happened. In addition, we have come up with very powerful evidence, we believe, that Florida prosecutors, who participated in the deal, steered the victims and the alleged victims to New York on more than one occasion because they did not want to suffer the sleights of attacks against them. So we have advanced the ball on this very subject and we are prepared to completely report to the court as to where we are and what we've done. Another point. We obviously had contact with our SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000934 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 understands, the NPA and the role of the NPA was going to be critically important. And I would simply like to report that we went pretty far along. 15 We interviewed all of the relevant lawyers on the defense side who participated in the NPA, and we were satisfied that we had a very strong argument that every one of those lawyers believed with an objective basis that the deal was global. That is, at the time -- THE COURT: I'm sorry, that? MR. WEINGARTEN: The deal of the NPA was global. That is, more specifically, at the time, the Florida prosecutors and agents knew of conduct in New York, and that no competent defense counsel negotiating in good faith with the prosecutors would have ever agreed to a deal back then that allowed New York prosecutors to indict for precisely the same conduct in the future, which, of course, is what happened. In addition, we have come up with very powerful evidence, we believe, that Florida prosecutors, who participated in the deal, steered the victims and the alleged victims to New York on more than one occasion because they did not want to suffer the sleights of attacks against them. So we have advanced the ball on this very subject and we are prepared to completely report to the court as to where we are and what we've done. Another point. We obviously had contact with our SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CNAronberg-000934 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 16 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 i client at or around the time of his death, and obviously the attorney-client privilege survives death and we; are not going to forfeit the privilege, but we will report to the court, with as much specificity as the court may want, that at or around the time of his death, we did not see a despairing, despondent suicidal person. Details to follow, if the court wishes. The 800-pound gorilla, for us, of course, are the video surveillance tapes. Obviously we assume there is a tape that leads directly to the door where Jeffrey Epstein was housed. If that tape reports for 12 hours before his death that no one went in and out of that room, then the suggestion that there was something other than a suicide seems preposterous. But there is no such evidence that has surfaced to date. Just the opposite. We have heard, and we actually read in the press, that the tapes were either corrupted or not functioning. Talk about a yikes. If, in fact, the system was broken for six months before Jeffrey Epstein was housed, I mean, that would be stunning incompetence. If it was allowed to continue to be inoperative when Jeffrey Epstein was housed, it would be incompetence times ten. But what if the tapes only broke down or were inoperative or were corrupted on the day he was killed or the day he died? Then we're in a completely different situation. So where does this lead? I think where it leads, SOUTHERN DISTRICT REPORTERS, P.d. (212) 805-0300 CA/Aronberg-000935 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • 16 J8RsEPS1 ' I client at or around the time of his death, and bbviously the attorney-client privilege survives death and we are not going to forfeit the privilege, but we will report to the court, with as much specificity as the court may want, that at or around the time of his death, we did not see a despairing, despondent suicidal person. Details to follow, if the court wishes. The 800-pound gorilla, for us, of course, are the video surveillance tapes. Obviously we assume there is a tape that leads directly to the door where Jeffrey Epstein was housed. If that tape reports for 12 hours before his death that no one went in and out of that room, then the suggestion that there was something other than a suicide seems preposterous. But there is no such evidence that has surfaced to date. Just the opposite. We have heard, and we actually read in the press, that the tapes were either corrupted or not functioning. Talk about a yikes. If, in fact, the system was broken for six months before Jeffrey Epstein was housed, I mean, that would be stunning incompetence. If it was allowed to continue to be inoperative when Jeffrey Epstein was housed, it would be incompetence times ten. But what if the tapes only broke down or were inoperative or were corrupted on the day he was killed or the day he died? Then we're in a completely different situation. So where does this lead? I think where it leads, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CN Aron berg-000935 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 Judge, is there are incredibly important questions that remain open. The public interest in this matter is obvious from this courtroom. There are conspiracy theories galore. We are all for finding the truth. We believe this court has an indispensable role to play. Whether or not this indictment is dismissed, I think this court has the inherent authority to find out what happened on its watch. Obviously, when the court detained Jeffrey Epstein, the court did not anticipate that weeks later he would be dead in his cell. I think given the inherent authority of the court, the court should make inquiry. This could come in many forms. Obviously the court made inquiry as to what happened in the first incident. When there was an allegation of an attempted suicide, the court made inquiry. The court obviously was interested. I recall your language. You talked about that being one of the several open questions indicating an interest on the court for the others as well. Obviously, the ultimate question is what happened to the client. THE COURT: You're talking about the July 23, 2019 incident? MR. WEINGARTEN: Yes. The court obviously could hold hearings. The court could assign a lawyer to help the court. I think this is an area where there is intense public interest. We have complete 17 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000936 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 17 J8RsEPSl Judge, is there are incredibly important questions that remain open. The public interest in this matter is obvious from this courtroom. There are conspiracy theories galore. We are all for finding the truth. We believe this court has an indispensable role to play. Whether or not this indictment is dismissed, I think this court has the inherent authority to find out what happened on its watch. Obviously, when the court detained Jeffrey Epstein, the court did not anticipate that weeks later he would be dead in his cell. I think given the inherent authority of the court, the court should make inquiry. This could come in many forms. Obviously the court made inquiry as to what happened in the first incident. When there was an allegation of an attempted suicide, the court made inquiry. The court obviously was interested. I recall your language. You talked about that being one of the several open questions indicating an interest on the court for the others as well. Obviously, the ultimate question is what happened to the client. THE COURT: You're talking about the July 23, 2019 incident? MR. WEINGARTEN: Yes. The court obviously could hold hearings. The court could assign a lawyer to help the court. I think this is an area where there is intense public interest. We have complete SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000936 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 confidence in the prosecutors in the Southern District and the FBI to do a competent investigation. But these are allegations I against serious components of the United States1 Department of Justice. Sometimes the appearance of justice is just as important as justice itself. I think the court supervising, or at least keeping an interest in this proceeding, is incredibly important for the public to have confidence in the ultimate findings, and certainly for us to have confidence in the ultimate findings. One more issue, Judge. The conditions of the jail, in a word, they were dreadful. Not just for Jeffrey Epstein, but for many of the prisoners over there. This is a prison within the shadows of this courthouse. The situation is rife with vermin. The abuse and the conditions in that prison, in a word, are a disgrace and everybody knows it. A person with authority told us, someone with knowledge, that the prisoners in Guantanamo — and he spoke with personal knowledge — are treated better than the prisoners right across the way. The feds certainly know how to run a disciplined, clean prison. I've been in 20 of them. They know how to do it just fine. And the question is, why in the world does it not happen down the road? I think that is a perfectly legitimate subject for the court to make inquiry. In a word, we want the court to help us find out what happened. The court has a role to play. It is the institution SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 ■ i i i CA/Aronberg-000937 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 I • .I J8RsEPSl I 18 confidence in the prosecutors in the Southern Dlstrict and the I FBI to do a competent investigation. But thes~J are allegations I against serious components of the United Statesl Department of Justice. Sometimes the appearance of justice is just as important as justice itself. I think the court supervising, or at least keeping an interest in this proceeding, is incredibly important for the public to have confidence in the ultimate findings, and certainly for us to have confidence in the ultimate findings. One more issue, Judge. The conditions of the jail, in a word, they were dreadful. Not just for Jeffrey Epstein, but for many of the prisoners over there. This is a prison within the shadows of this courthouse. The situation is rife with vermin. The abuse and the conditions in that prison, in a word, are a disgrace and everybody knows it. A person with authority told us, someone with knowledge, that the prisoners in Guantanamo -- and he spoke with personal knowledge -- are treated better than the prisoners right across the way. The feds certainly know how to run a disciplined, clean prison. I've been in 20 of them. They know how to do it just fine. And the question is, why in the world does it not happen down the road? I think that is a perfectly legitimate subject for the court to make inquiry. In a word, we want the court to help us find out what happened. The court has a role to play. It is the institution SOUTHERN DISTRICT REPORTERS, P.~. (212) 805-0300 CA/Aronberg-000937 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • JSRsEPSl that most people have confidence in in these very troubled times. ; So whether or not you dismiss the indictment, to us, is beside the point. We want you to stay on the case, we want you to conduct an investigation, and we want to know what happened here. Thank you, your Honor. THE COURT: Just so it is clear, so your view on the motion directly on its merits of the nolle prosequi order and application by the U.S. Attorney, do you have a view on that? MR. WEINGARTEN: I think if the court felt that the case had to stay alive for the court to continue, we would oppose it. I think — THE COURT: I'm sorry, if what? MR. WEINGARTEN: If the issue, if you took the position for you to conduct the investigation or lead the investigation or participate in the investigation, then we want, the role we want you to play, if the indictment has to be alive, we would oppose the motion. I don't think you need to do that. I think you can dismiss the indictment. THE COURT: So you're suggesting that you support the government's motion, just viewed in the context of — MR. WEINGARTEN: Yes, of course. THE COURT: Great. 19 SOUTHERN DISTRICT REPORTERS, P.G. (212) 805-0300 : CA/Aronberg-000938 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 that most people have confidence times. • 19 in in these very troubled ! : So whether or not you dismiss the indictment, to us, is beside the point. We want you to stay on the case, we want you to conduct an investigation, and we want to know what happened here. Thank you, your Honor. THE COURT: Just so it is clear, so your view on the motion directly on its merits of the nolle prosequi order and application by the U.S. Attorney, do you have a view on that? MR. WEINGARTEN: I think if the court felt that the case had to stay alive for the court to continue, we would oppose it. I think THE COURT: I'm sorry, if what? MR. WEINGARTEN: If the issue, if you took the position for you to conduct the investigation or lead the investigation or participate in the investigation, then we want, the role we want you to play, if the indictment has to be alive, we would oppose the motion. I don't think you need to do that. I think you can dismiss the indictment. THE COURT: So you're suggesting that you support the government's motion, just viewed in the context of MR. WEINGARTEN: Yes, of course. THE COURT: Great. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000938 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 20 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 I i MR. WEINBERG: Judge, if I can just supplement? THE COURT: Absolutely. ’ MR. WEINBERG: Thank you, sir. Thank you, as an out-of-town lawyer for the privilege to appear in front of you, your Honor. THE COURT: It's my pleasure. MR. WEINBERG: First, as to the conditions, we think your Honor trusted the government, the Bureau of Prisons, to keep our client safe and keep him in civilized conditions. The government will again ask, as to other defendants, that they be detained at the MCC, some subset of them will end up in the SHU unit. It is a horrific. I've called it medieval. There's vermin on the floor. There is wet from the plumbing. There is no sunlight. There is limited exercise. It is simply conditions that no pretrial detainee — and I would go farther as a criminal defense lawyer — no United States defendant should be subjected to. Certain judges have taken views of the conditions. We would urge your Honor, the government talks about and we talk about transparency, to see what kind of conditions there exist within 50 or 100 yards of one of the great United States district courts. Second, in terms, we have a profound problem with the conclusions of the medical examiner. There are for three SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000939 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • ' ' MR. WEINBERG: Judge, if I can just ! ! supplement? ! THE COURT: Absolutely. MR. WEINBERG: Thank you, sir. 20 Thank you, as an out-of-town lawyer for the privilege to appear in front of you, your Honor. THE COURT: It's my pleasure. MR. WEINBERG: First, as to the conditions, we think your Honor trusted the government, the Bureau of Prisons, to keep our client safe and keep him in civilized conditions. The government will again ask, as to other defendants, that they be detained at the MCC, some subset of them will end up in the SHU unit. It is a horrific. I've called it medieval. There's vermin on the floor. There is wet from the plumbing. There is no sunlight. There is limited exercise. It is simply conditions that no pretrial detainee -- and I would go farther as a criminal defense lawyer -- no United States defendant should be subjected to. Certain judges have taken views of the conditions. We would urge your Honor, the government talks about and we talk about transparency, to see what kind of conditions there exist within 50 or 100 yards of one of the great United States district courts. Second, in terms, we have a profound problem with the conclusions of the medical examiner. There are for three SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CNAronberg-000939 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 i reasons, your Honor. One is the timing of Mr. Epstein's demise. It was on I August 10. On August 12, a bail pending appeal motion was being filed in the Second Circuit. On August 12 or 13, the United States Attorneys were going to respond to our request for the preservation and production of documents that would have facilitated and furthered our efforts to demonstrate communications between the Southern District of Florida, the Northern District of Georgia, which was standing in the shoes of the Southern District of Florida main justice and the Southern District. In other words, we were beginning the process discharging our responsibilities. There had been no new evidence that Mr. Epstein had committed any offense against a minor after 2005. The subject matter of the New York prosecution was squarely within the heartland of the Florida NPA. We had a significant motion to dismiss. This was not a futile, you know, defeatist attitude. Third, we had all the discovery motions that your Honor had scheduled. So the timing for a pretrial detainee to commit suicide on August 10, when his bail pending appeal motion is being filed on August 12, strikes us as implausible. Second, we had an independent doctor who was present at the autopsy which occurred on August 11. On August 11, the city medical examiner's findings were inconclusive. We are SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 21 CA/Aronberg-000940 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 21 J8RsEPS1 reasons, your Honor. One is the timing of Mr. Epstein's demise. It was on I August 10. On August 12, a bail pending appeal motion was being filed in the Second Circuit. On August 12 or 13, the United States Attorneys were going to respond to our request for the preservation and production of documents that would have facilitated and furthered our efforts to demonstrate communications between the Southern District of Florida, the Northern District of Georgia, which was standing in the shoes of the Southern District of Florida main justice and the Southern District. In other words, we were beginning the process discharging our responsibilities. There had been no new evidence that Mr. Epstein had committed any offense against a minor after 2005. The subject matter of the New York prosecution was squarely within the heartland of the Florida NPA. We had a significant motion to dismiss. This was not a futile, you know, defeatist attitude. Third, we had all the discovery motions that your Honor had scheduled. So the timing for a pretrial detainee to commit suicide on August 10, when his bail pending appeal motion is being filed on August 12, strikes us as implausible. Second, we had an independent doctor who was present at the autopsy which occurred on August 11. On August 11, the city medical examiner's findings were inconclu~ive. We are SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/ Aron be rg-000940 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 22 J8RsEPSl 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 told by a very experienced forensic pathologist that the broken bones in Mr. Epstein's neck, in his larynx, are more consistent with external pressure, with strangulation, with homicide, if you will, than with suicide. It doesn't exclude suicide, but the pure medical forensic evidence creates profound issues about what happened to him. Also the time of death. Our medical examiner's opinion is it occurred at least 45 minutes and probably hours before 6:30 a.m. on August 10, when he was first found, if you will, according to the reports. Yet he was moved, something that is not ordinary in these circumstances. I would also — THE COURT: Excuse me. He was moved? MR. WEINBERG: Instead of having the cell in the condition it was found, if he had been dead for 45 minutes or two hours or four hours, there were efforts to move him and, therefore, make it more difficult to reconstruct whether or not he died of suicide or some other cause. I spoke to Stacey Richmond, who is a responsible member of this court who represents the family of Mr. Epstein. She spoke to the medical examiner on the Friday after Mr. Epstein's death and asked why, if the conclusion was made late in the afternoon on Friday that week. She specifically asked about what extrinsic nonmedical evidence caused the medical examiner to go from uncertain to suicide, and she was SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000941 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 22 J8RsEPS1 told by a very experienced forensic pathologist that the broken bones in Mr. Epstein's neck, in his larynx, are more consistent with external pressure, with strangulation, with homicide, if you will, than with suicide. It doesn't exclude suicide, but the pure medical forensic evidence creates profound issues about what happened to him. Also the time of death. Our medical examiner's opinion is it occurred at least 45 minutes and probably hours before 6:30 a.m. on August 10, when he was first found, if you will, according to the reports. Yet he was moved, something that is not ordinary in these circumstances. I would also _'_ THE COURT: Excuse me. He was moved? MR. WEINBERG: Instead of having the cell in the condition it was found, if he had been dead for 45 minutes or two hours or four hours, there were efforts to move him and, therefore, make it more difficult to reconstruct whether or not he died of suicide or some other cause. I spoke to Stacey Richmond, who is a responsible member of this court who represents the family of Mr. Epstein. She spoke to the medical examiner on the Friday after Mr. Epstein's death and asked why, if the conclusion was made late in the afternoon on Friday that week. She specifically asked about what extrinsic nonmedical evidence caused the medical examiner to go from uncertain to suicide, and she was SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000941 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 i told that the medical examiner had seen nine minutes of one video which was on a stairwell between floors at the MCC. She i was told that the principal video that would have showed the whole hall was corrupted. It was in DC with the FBI to see if they can reconstruct it. And I asked the same questions that my co-counsel did, you know, was the dysfunction of the critical pivotal video, in the most secure prison east of Florence, out in Colorado known to the MCC before August 10, or was this corruption occurring on August 10, which would again cause us to be skeptical of the servitude of the medical examiner's conclusions that this was suicide rather than some other cause. So with my co-counsel, we ask your Honor, it is not a question of trust or not trust. They ask you to detain people and you trust the Bureau of Prisons. And it is within your inherit authority, your Honor, to find out what happened to our client. We are angry about the conditions he was held in. And we're also angry, quite frankly, your Honor, that the only source of information that we get as to what happened to him is through the media rather than through the United States Attorney's office. We've made requests informal. We have made Touhy requests. We've been told there is a pending investigation. But we trust your Honor and the judiciary, and with SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 i CA/Aronberg-000942 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 23 J8RsEPS1 told that the medical examiner had seen nine miputes of one video which was on a stairwell between floors at the MCC. She I was told that the principal video that would haye showed the whole hall was corrupted. It was in DC with the FBI to see if they can reconstruct it. And I asked the same questions that my co-counsel did, you know, was the dysfunction of the critical pivotal video, in the most secure prison east of Florence, out in Colorado known to the MCC before August 10, or was this corruption occurring on August 10, which would again cause us to be skeptical of the servitude of the medical examiner's conclusions that this was suicide rather than some other cause. So with my co-counsel, we ask your Honor, it is not a question of trust or not trust. They ask you to detain people and you trust the Bureau of Prisons. And it is within your inherit authority, your Honor, to find out what happened to our client. We are angry about the conditions he was held in. And we're also angry, quite frankly, your Honor, that the only source of information that we get as to what happened to him is through the media rather than through the United States Attorney's office. We've made requests informal. We have made Touhy requests. We've been told there is a pending investigation. But we trust your Honor and the judiciary, and with SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 I CA/Aronberg-000942 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 i all due respect, we believe there is an inherent and central role, a pivotal role in your Honor to find out what happened to a defendant in a case before the court, whether or not the court grants the nolle pros today or whether it holds it pending an investigation into Mr. Epstein's death. We're not here without significant doubts regarding the conclusion of suicide. We are not here to say what happened. We don't know what happened. But we deeply want to know what happened to our client. Thank you, sir. THE COURT: And you, as Mr. Weingarten, have the same view of the nolle prosequi motion? MR. WEINBERG: Yes, your Honor. THE COURT: OK. MS. COMEY: Your Honor, may I respond to some of those points? THE COURT: Sure. MS. COMEY: Thank you, your Honor. Just briefly. With the exception of the noting that the defense does not have an objection to the government's motion, virtually everything else that defense counsel just argued, respectfully is completely irrelevant to the purposes of today's proceeding and to the motion that is pending before your Honor. As an initial matter, the question — 24 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 i CA/Aronberg-000943 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 all due respect, we believe there is an • I I inherent and central I I 24 role, a pivotal role in your Honor to find out what happened to a defendant in a case before the court, whether or not the court grants the nolle pros today or whether it holds it pending an investigation into Mr. Epstein's death. We're not here without significant doubts regarding the conclusion of suicide. We are not here to say what happened. We don't know what happened. But we deeply want to know what happened to our client. Thank you, sir. THE COURT: And you, as Mr. Weingarten, have the same view of the nolle prosequi motion? points? MR. WEINBERG: Yes, your Honor. THE COURT: OK. MS. COMEY: Your Honor, may I respond to some of those THE COURT: Sure. MS. COMEY: Thank you, your Honor. Just briefly. With the exception of the noting that the defense does not have an objection to the government's motion, virtually everything else that defense counsel just argued, respectfully is completely irrelevant to the purposes of today's proceeding and to the motion that is pending before your Honor. As an initial matter, the question SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CNAronberg-000943 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 I • • I J8RsEPSl { I THE COURT: Well, it may be. Well, I ‘don't know. You say irrelevant. ; i It is a public hearing, and I think it, is fair game for defense counsel to raise its concerns. MS. COMEY: Certainly, your Honor. But it is irrelevant to whether or not the motion should be granted. THE COURT: Right. I get that. MS. COMEY: I would also note that the question of Mr. Epstein's death is the subject of an ongoing and active investigation, as has been publicly noted, by a separate team of Assistant United States Attorneys from the Southern District of New York, separate from the team who is handling this prosecution, as well as a separate team of FBI agents. There is an ongoing and active grand jury investigation into the circumstances surrounding Mr. Epstein's death. It is the function of a grand jury and of the Federal Bureau of Investigation to investigate crimes in the federal court system. It is not the purview, respectfully, of the court to conduct an investigation into uncharged matters. So respectfully, we disagree with defense counsel's suggestion that the court has some authority to conduct an independent investigation. To the extent any other defendants who are detained in the MCC have concerns about the conditions or believe that the conditions are relevant to a future or current bail determination, it is for those defendants and SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 ; ! CA/Aronberg-000944 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 • • 25 J8RsEPSl THE COURT: Well, it may be. Well, I ~on't know. You say irrelevant. It is a public hearing, and I think it! is fair game for defense counsel to raise its concerns. MS. COMEY: Certainly, your Honor. But it is irrelevant to whether or not the motion should be granted. THE COURT: Right. I get that. MS. COMEY: I would also note that the question of Mr. Epstein's death is the subject of an ongoing and active investigation, as has been publicly noted, by a separate team of Assistant United States Attorneys from the Southern District of New York, separate from the team who is handling this prosecution, as well as a separate team of FBI agents. There is an ongoing and active grand jury investigation into the circumstances surrounding Mr. Epstein's death. It is the function of a grand jury and of the Federal Bureau of Investigation to investigate crimes in the federal court system. It is not the purview, respectfully, of the court to conduct an investigation into uncharged matters. So respectfully, we disagree with defense counsel's suggestion that the court has some authority to conduct an independent investigation. To the extent any other defendants who are detained in the MCC have concerns about the conditions or believe that the conditions are relevant to a future or current bail determination, it is for those defendants and SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000944 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 26 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 their counsel to raise those arguments and for the judges hearing those arguments to evaluate those claims. It is not I relevant to today's proceedings. Thank you, your Honor. THE COURT: In those other cases, Ms. Comey, judges do have authority to investigate, but don't here? MS. COMEY: Not to investigate, your Honor, but to hear arguments about the conditions of confinement in the MCC as they may relate to any bail determination. I believe that was the argument that was made. The bigger picture here, your Honor, is that the focus of today's proceeding, as we understand it, is to allow the victims who have gathered here today to be heard and to comment upon the case and to comment upon the motion that is pending, and to bring this case to a close. THE COURT: Got it. MR. WEINGARTEN: May I? THE COURT: Sure. MR. WEINGARTEN: We obviously saw this as, perhaps, the last opportunity to be before you, and we wanted to take advantage of the opportunity to say our peace and thank you for allowing us. There is precedent here. Ted Stevens, the Senator from Alaska case in Washington, DC, Judge Emmet Sullivan ordered an independent investigation by a private lawyer when I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000945 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPSl i I I their counsel to raise those arguments and for the judges I I hearing those arguments to evaluate those relevant to today's proceedings. Thank you, your Honor. l . I c aims. I I It is not 26 THE COURT: In those other cases, Ms. Corney, judges do have authority to investigate, but don't here? MS. COMEY: Not to investigate, your Honor, but to hear arguments about the conditions of confinement in the MCC as they may relate to any bail determination. I believe that was the argument that was made. The bigger picture here, your Honor, is that the focus of today's proceeding, as we understand it, is to allow the victims who have gathered here today to be heard and to comment upon the case and to comment upon the motion that is pending, and to bring this case to a close. THE COURT: Got it. MR. WEINGARTEN: May I? THE COURT: Sure. MR. WEINGARTEN: We obviously saw this as, perhaps, the last opportunity to be before you, and we wanted to take advantage of the opportunity to say our peace and thank you for allowing us. There is precedent here. Ted Stevens, the Senator from Alaska case in Washington, DC, Judge Emmet Sullivan ordered an independent investigation by a private lawyer when i SOUTHERN DISTRICT REPORTERS, P.C. (212) so5-o3oo I CA/Aronberg-000945 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very I familiar with it. It is analogous. It is a situation where there was tremendous controversy over what happened in the case and whether or not the prosecutors went off the reservation. Judge Sullivan — and there were three or four independent — not independent, DOJ inquiries into the very same matter. But Judge Sullivan wanted his own opportunity to make a judgment with his own independent investigation. THE COURT: OK. MR. WEINBERG: If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S, v. Fleming, when the conditions at Walpole, which is a state prison where federal prisoners were being held — we don't have a federal MCC in Boston — went to the prison, stayed in the prison to determine whether or not the complaints about the conditions were authentic. I think your Honor has the inherent authority to go to the ninth floor and see how the MCC houses pretrial detainees. Thank you. THE COURT: Are you saying that whether or not the motion is granted that is pending before us? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000946 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 ! he was deeply troubled by the alleged Brady vioiations. I I represented the prosecutors in that case, so I'm very, very familiar with it. 27 It is analogous. It is a situation where there was tremendous controversy over what happened in the case and whether or not the prosecutors went off the reservation. Judge Sullivan -- and there were three or four independent -- not independent, DOJ inquiries into the very same matter. But Judge Sullivan wanted his own opportunity to make a judgment with his own independent investigation. THE COURT: OK. MR. WEINBERG: If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federal prisoners were being held -- we don't have a federal MCC in Boston -- went to the prison, stayed in the prison to determine whether or not the complaints about the conditions were authentic. I think your Honor has the inherent authority to go to the ninth floor and see how the MCC houses pretrial detainees. Thank you. THE COURT: Are you saying that wheth~r or not the motion is granted that is pending before us? SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000946 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 28 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 I J8RsEPSl MR. WEINBERG: Yes, your Honor. ' I think, like when appeals are taken, bail issues I remain before the district court. Jurisdiction! is not completely divested. Your Honor issued a pretrial detention order and your Honor has the power, the inherent authority, they are not going to refuse to allow you to go look at the ninth floor. They are going to count on you to make decisions in the future. I just trust that the executive branch is not going to prevent the judicial branch from looking into the death of Jeffrey Epstein or the conditions in the SHU unit at the MCC, sir. THE COURT: Great. Thank you. MS. COMEY: May I, your Honor? Just very briefly, your Honor. I would note that upon the dismissal of the indictment, which I believe the parties agree is appropriate in this case, there would be no case. There would be no jurisdiction for the court to conduct any sort of inquiry, even if the court had such authority. THE COURT: Right. OK. I think we've heard enough. It is at this point in the hearing that I would like to call upon victims' counsel, plural, for any remarks they may have and they may wish to make. Also, to introduce their clients, those of them who wish to be heard. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 I CA/Aronberg-000947 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • MR. WEINBERG: Yes, your Honor. I think, like when appeals are taken, bail issues I remain before the district court. Jurisdiction! is not 28 completely divested. Your Honor issued a pretrial detention order and your Honor has the power, the inherent authority, they are not going to refuse to allow you to go look at the ninth floor. They are going to count on you to make decisions in the future. I just trust that the executive branch is not going to prevent the judicial branch from looking into the death of Jeffrey Epstein or the conditions in the SHU unit at the MCC, sir. THE COURT: Great. Thank you. MS. COMEY: May I, your Honor? Just very briefly, your Honor. I would note that upon the dismissal of the indictment, which I believe the parties agree is appropriate in this case, there would be no case. There would be no jurisdiction for the court to conduct any sort of inquiry, even if the court had such authority. THE COURT: Right. OK. I think we've heard enough. It is at this point in the hearing that I would like to call upon victims' counsel, plural, for any remarks they may have and they may wish to make. Also, to introduce their clients, those of them who wish to be heard. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/ Aron be rg-00094 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 29 J8RsEPSl 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 It would be helpful if, in doing that,1 if counsel — I Mr. Edwards and I see and I see Mr. Boise as well — I know they are counsel to several, at least several of the victims. It would be helpful if whoever is speaking, both Mr. Edwards and Mr. Boise, would indicate to the court whether or not they have discussed the pending motion with their clients, that is to say and the rule of abatement, etc., etc. with them prior to today's hearing. Are we going to hear from Mr. Edwards first, is that right? MR. EDWARDS: Thank you, your Honor. THE COURT: You bet. It would be helpful, Mr. Edwards, if you would state and spell your name for the court reporter. If you are going to introduce someone else, which I trust that you are, if you could state and spell their name as well. MR. EDWARDS: Yes, your Honor. May it please the court. Brad Edwards, B-r-a-d E-d-w-a-r-d-s, with the law firm of Edwards Pottinger. I have in the courtroom today 15 victims that I represent and have represented over the years. There are at least 20 more who didn't make this hearing today for a multitude of reasons, some out of fear of public exposure, others because the way in which this case ended will never SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 CA/Aronberg-000948 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 J8RsEPSl • It would be helpful if, in doing that, 1 if counsel -- 1 Mr. Edwards and I see and I see Mr. Boise as well -- I know they are counsel to several, at least several of the victims. 29 It would be helpful if whoever is speaking, both Mr. Edwards and Mr. Boise, would indicate to the court whether or not they have discussed the pending motion with their clients, that is to say and the rule of abatement, etc., etc. with them prior to today's hearing. Are we going to hear from Mr. Edwards first, is that right? MR. EDWARDS: Thank you, your Honor. THE COURT: You bet. It would be helpful, Mr. Edwards, if you would state and spell your name for the court reporter. If you are going to introduce someone else, which I trust that you are, if you could state and spell their name as well. MR. EDWARDS: Yes, your Honor. May it please the court. Brad Edwards, B-r-a-d E-d-w-a-r-d-s, with the law firm of Edwards Pottinger. I have in the courtroom today 15 victims that I represent and have represented over the years. There are at least 20 more who didn't make this hearing today for a multitude of reasons, some out of fear of public exposure, others because the way in which this case endeq will never SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000948 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 30 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 , bring full justice, and they decided it was best for them not to talk today. I Some of my clients are going to address the court that are here today. Others are not. Some are going to use their names, and have in the past, and others wish to remain anonymous. And I have instructed each of them to inform the court reporter that they will be proceeding as Jane Doe so that the court reporter can take them down. THE COURT: For those who wish to remain anonymous? MR. EDWARDS: Exactly, your Honor. THE COURT: And that is satisfactory, as far as I am concerned. MR. EDWARDS: Before we do that, I would like to address a couple of the things that have occurred this morning. First of all, whether relevant or not, I personally, and on behalf of my clients, do appreciate the presentation that Mr. Weingarten made and Mr. Marty Weinberg made. I have tremendous respect for Mr. Weinberg. I've worked with him through this and related cases for years, and I understand the reason why they made the presentation that they made. There is two things of interest to our clients in that respect. One is, because of the tragic ending, that none of my clients wanted, nor did I, nor did anyone else,, if there is some civil rights violation and there is some civil remedy for SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000949 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 bring full justice, and they decided it was best for them not to talk today. 30 Some of my clients are going to address the court that are here tod~y. Others are not. Some are going to use their n~mes, and have in the past, and others wish to remain anonymous. And I have instructed each of them to inform the court reporter that they will be proceeding as Jane Doe so that the court reporter can take them down. THE COURT: For those who wish to remain anonymous? MR. EDWARDS: Exactly, your Honor. THE COURT: And that is satisfactory, as far as I am concerned. MR. EDWARDS: Before we do that, I would like to address a couple of the things that have occurred this morning. First of all, whether relevant or not, I personally, and on behalf of my clients, do appreciate the presentation that Mr. Weingarten made and Mr. Marty Weinberg made. I have tremendous respect for Mr. Weinberg. I've worked with him through this and related cases for years, and I understand the reason why they made the presentation that they made. There is two things of interest to our clients in that respect. One is, because of the tragic ending, that none of my clients wanted, nor did I, nor did anyone else,. if there is some civil rights violation and there is some civil remedy for SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000949 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 31 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 J8RsEPSl i Mr. Epstein that goes to the estate, certainly the victims are I interested in that as they might help to repair, the damage done. Second, Mr. Epstein's untimely death, the timing is curious to us. But more so, it makes it absolutely impossible for the victims to ever get the day in court that they wanted in court and to get full justice. That now can never happen. I know that Mr. Epstein's attorneys say he wanted it, and they know, we did too. And there are a lot of people here today that are very sad by the way that this ended for both Mr. Epstein and the fact that full justice was robbed from them, once again. The second issue I wanted to address was the Law Review or the Law Journal article that your Honor referenced, which is troubling because the opinion seems to say that transparency is not appropriate in the criminal system and is not appropriate at this point in time. That's tough to swallow, especially in this case, given the long history of this case. Personally, it is tough to swallow, and on behalf of my clients, I can say that is very concerning. Transparency is the only way that the justice system works. We know this because there was a similar investigation of Mr. Epstein many years ago, from 2005 to 2008. My personal involvement in this case was because a young female came into my office named Courtney Wild, and she SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000950 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 31 J8RsEPS1 Mr. Epstein that goes to the estate, certainly the victims are interested in that as they might help to repair! the damage done. Second, Mr. Epstein's untimely death, the timing is curious to us. But more so, it makes it absolutely impossible for the victims to ever get the day in court that they wanted in court and to get full justice. That now can never happen. I know that Mr. Epstein's attorneys say he wanted it, and they know, we did too. And there are a lot of people here today that are very sad by the way that this ended for both Mr. Epstein and the fact that full justice was robbed from them, once again. The second issue I wanted to address was the Law Review or the Law Journal article that your Honor referenced, which is troubling because the opinion seems to say that transparency is not appropriate in the criminal system and is not appropriate at this point in time. That's tough to swallow, especially in this case, given the long history of this case. Personally, it is tough to swallow, and on behalf of my clients, I can say that is very concerning. Transparency is the only way that the justice system works. We know this because there was a similar investigation of Mr. Epstein many years ago, from 2005 to 2008. My personal involvement in this case was because a young female came into my office named Courtney Wild, and she SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CNAronberg-000950 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 i came to me not asking to file a lawsuit against|Jeffrey I Epstein, but simply asking for the government to talk to her. She was cooperating in an FBI investigation and wanted the government to speak with her, and I thought that was going to be an easy task. It was only a few months later that we learned that this investigation that was represented to my client in written form, that it would be a long investigation, and to be patient. Basically, to hang tight. It was resolved by way of a secret deal that never allowed any of the more than 30 victims who had been identified of Mr. Epstein's abuse in Florida to ever participate in a single hearing. There was a hearing. They were never notified. I then went on to represent many of them in civil cases and also in extensive pro bono work. And I can tell your Honor that while Jeffrey Epstein's abuse of them hurt them and harmed them for many years, the feelings they had was aggravated exponentially by the facts that they had no rights in the criminal justice system, by the fact that they were treated as if they didn't matter. They were not allowed their rights under the Crime Victims' Rights Act to meaningfully confer with prosecutors, to be treated with fairness, to be treated with dignity. That is what this is supposed to be about, and to have notice of hearings. So I do want to thank your Honor, and 'especially the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000951 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • J8RsEPSl • ' ' came to me not asking to file a lawsuit againstiJeffrey I Epstein, but simply asking for the government to talk to her. She was cooperating in an FBI investigation and wanted the government to speak with her, and I thought that was going to be an easy task. 32 It was only a few months later that we learned that this investigation that was represented to my client in written form, that it would be a long investigation, and to be patient. Basically, to hang tight. It was resolved by way of a secret deal that never allowed any of the more than 30 victims who had been identified of Mr. Epstein's abuse in Florida to ever participate in a single hearing. There was a hearing. They were never notified. I then went on to represent many of them in civil cases and also in extensive pro bono work. And I can tell your Honor that while Jeffrey Epstein's abuse of them hurt them and harmed them for many years, the feelings they had was aggravated exponentially by the facts that they had no rights in the criminal justice system, by the fact that they were treated as if they didn't matter. They were not allowed their rights under the Crime Victims' Rights Act to meaningfully confer with prosecutors, to be treated with fairness, to be treated with dignity. That is what this is supposed to be about, and to have notice of hearings. So I do want to thank your Honor, and 1especially the SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/ Aron be rg-000951 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 33 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 prosecutors who have worked this investigation and this case, which is very different in experience for all of my clients and the other Epstein victims in this case, because they were allowed to be a part of the process. While some of them elected not to be here today, that opportunity should always be allowed for them. In 2008, we filed that case under the Crime Victims' Rights Act because our clients' rights were violated, and as your Honor knows, a federal judge has ruled in our clients' favor that their rights were violated. So this hearing today means a lot to them. The fact that they may never get their chance to speak in court, they may never get complete closure, and all of us have to wonder, if their rights had been afforded them the first time, would any of us be here right now. Or wouldn't it more likely be the case that everyone, including Jeffrey Epstein, would have turned out better for it? Today, I have not only represented, but met and become very close with many of these victims. Many of these survivors. They are very strong people. They are people who have persevered through a lot of adversity. It's been a roller coaster of emotions that has led us to where we are today. And while they have all been cast over the years because of the secrecy of the first investigation, in the shadow as victims, you can't put them all in one bucket and say one size fits all. They are each individual people who were harmed differently and SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000952 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 33 J8RsEPSl prosecutors who have worked this investigation and this case, which is very different in experience for all of my clients and the other Epstein victims in this case, because they were allowed to be a part of the process. While some of them elected not to be here today, that opportunity should always be allowed for them. In 2008, we filed that case under the Crime Victims' Rights Act because our clients' rights were violated, and as your Honor knows, a federal judge has ruled in our clients' favor that their rights were violated. So this hearing today means a lot to them. The fact that they may never get their chance to speak in court, they may never get complete closure, and all of us have to wonder, if their rights had been afforded them the first time, would any of us be here right now. Or wouldn't it more likely be the case that everyone, including Jeffrey Epstein, would have turned out better for it? Today, I have not only represented, but met and become very close with many of these victims. Many of these survivors. They are very strong people. They are people who have persevered through a lot of adversity. It's been a roller coaster of emotions that has led us to where we are today. And while they have all been cast over the years because of the secrecy of the first investigation, in the shadow as victims, you can't put them all in one bucket and say one size fits all. They are each individual people who were harmed differently and SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/ Aron be rg-000952 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 | I i distinctly through not only the abuse, but the system. And on behalf of all of them, I would like to thank your Honor for the fairness with which they've been treated, and the United States Attorney's office for the way in which you have handled this investigation, and especially how you have treated the victims in this case. Like I said, I have many who want to speak. Some that can't. This is a very difficult day for them. But we appreciate the opportunity and the invitation. The first client that I have that is going to address your Honor is the one who walked into my office in 2008 asking just to be heard, Courtney Wild. THE COURT: Hold on one second. Did you all want to be seated? You don't need to be standing. Whatever is more comfortable until you're ready to give some comments. It's up to you. Ms. Wild, if you could spell your name for the court reporters, please. MS. WILD: Courtney, C-o-u-r-t-n-e-y, last name Wild, W-i-l-d. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 I CA/Aronberg-000953 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPSl I distinctly through not only the abuse, but the system. I And on behalf of all of them, I would like to thank I your Honor for the fairness with which they've been treated, and the United States Attorney's office for the way in which you have handled this investigation, and especially how you have treated the victims in this case. 34 Like I said, I have many who want to speak. Some that can't. This is a very difficult day for them. But we appreciate the opportunity and the invitation. The first client that I have that is going to address your Honor is the one who walked into my office in 2008 asking just to be heard, Courtney Wild. THE COURT: Hold on one second. Did you all want to be seated? You don't need to be standing. Whatever is more comfortable until you're ready to give some comments. It's up to you. Ms. Wild, if you could spell your name for the court reporters, please. MS. WILD: Courtney, C-o-u-r-t-n-e-y, last name Wild, W-i-1-d. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000953 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 ; i MS. WILD: My name is Courtney Wild, and I'm a victim of Jeffrey Epstein. Jeffrey Epstein sexually abused me for I years, robbing me of my innocence and mental health. Jeffrey Epstein has done nothing but manipulate our justice system, where he has never been held accountable for his actions, even to this day. Jeffrey Epstein robbed myself and all the other victims of our day in court to confront him one by one, and for that he is a coward. I want to thank the U.S. Attorney's for seeking justice that has been long over due, and most importantly, given us, the victims, our day in court to speak our peace and find some sort of closure. I feel very angry and sad that justice has never been served in this case. Thank you. THE COURT: Thanks very much. MR. EDWARDS: I believe my next client who is going to speak is probably going to speak as Jane Doe. JANE DOE NO. 1: Yes, Jane Doe. THE COURT: We'll say Jane Doe No. 1, just for the record. JANE DOE NO. 1: Okay. Thank you for allowing us to speak today. I've shifted what I want to say in hearing what's already been said, and just about the question of Jeffrey's death. I don't know what the relevance is to this hearing, but I do know that it is profoundly relevant to my SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000954 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 • • 35 J8RPEPS2 MS. WILD: of Jeffrey Epstein. My name is Courtney Wild, ahd I'm a victim Jeffrey Epstein sexually abused me for I I years, robbing me of my innocence and mental health. Jeffrey Epstein has done nothing but manipulate our justice system, where he has never been held accountable for his actions, even to this day. Jeffrey Epstein robbed myself and all the other victims of our day in court to confront him one by one, and for that he is a coward. I want to thank the U.S. Attorney's for seeking justice that has been long over due, and most importantly, given us, the victims, our day in court to speak our peace and find some sort of closure. I feel very angry and sad that justice has never been served in this case. Thank you. THE COURT: Thanks very much. MR. EDWARDS: I believe my next client who is going to speak is probably going to speak as Jane Doe. JANE DOE NO. 1: Yes, Jane Doe. THE COURT: We'll say Jane Doe No. 1, just for the record. JANE DOE NO. 1: Okay. Thank you for allowing us to speak today. I've shifted what I want to say in hearing what's already been said, and just about the question of Jeffrey's death. I don't know what the relevance is to this I hearing, but I do know that it is profoundly relevant to my SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000954 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 36 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 • • J8RPEPS2 ! life, as a victim. I don't like that word, but' I still feel like I am learning the ways that he's impacted me as a complex I situation, but he was also a major part of my life. As destructive as that relationship was and as much of a villain as we have created him to be — based on facts we've created him to be a villain — he's a complex villain and actually all of that is irrelevant. Anybody deserves — an investigation is the right thing to do. Like, we do need to know how he died. It felt like a whole new trauma all over again, and I don't know why, you know, because I — I'm trying to defend myself against him at this point in my life, but it still does not feel good. It didn't feel good to wake up that morning and find out that he had allegedly committed suicide. Okay. But I also wanted to say to the press, I'm reading — I read my story in the paper. I read so many other girls' stories that are so similar to my own, and everything that's been focused on is not the most important part of it. There was — the problem with focusing on these, the facts of the situation, that were out of the ordinary and like because he was such a grand person, and it was just a unique situation. I know that that's the more interesting side of the story, but I don't want to be used as entertainment. And the problem, the fundamental problem of the whole situation is the element of exploitation and coercion, and these are things that so many girls can relate to. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 > CA/Aronberg-000955 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 36 J8RPEPS2 i life, as a victim. I don't like that word, but; I still feel like I am learning the ways that he's impacted me as a complex ! situation, but he was also a major part of my life. As destructive as that relationship was and as much of a villain as we have created him to be -- based on facts we've created him to be a villain -- he's a complex villain and actually all of that is irrelevant. Anybody deserves an investigation is the right thing to do. Like, we do need to know how he died. It felt like a whole new trauma all over again, and I don't know why, you know, because I I'm trying to defend myself against him at this point in my life, but it still does not feel good. It didn't feel good to wake up that morning and find out that he had allegedly committed suicide. Okay. But I also wanted to say to the press, I'm reading -- I read my story in the paper. I read so many other girls' stories that are so similar to my own, and everything that's been focused on is not the most important part of it. There was -- the problem with focusing on these, the facts of the situation, that were out of the ordinary and like because he was such a grand person, and it was just a unique situation. I know that that's the more interesting side of the story, but I don't want to be used as entertainment. And the problem, the fundamental problem of the whole situation is the element of exploitation and coercion, and these are things that so many girls can relate to. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/ Aron be rg-000955 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 ; And even though this Jeffrey Epstein brought it to a grand scale, on some level, a lot of girls could relate to the trauma that we are talking about, and even though this whole situation sucks, I would like to think that it may be possibly a catalyst for change because, obviously, as we're seeing with the "Me Too" movement, change needs to happen and it's — what I'm seeing in the papers is not a common story, but it's so much more common than you realize. That's all. Thank you. THE COURT: Thank you very much. MR. EDWARDS: I believe that the next client is going to also be a Jane Doe; so I think for the purposes of the record it will be Jane Doe 2. THE COURT: Yes. JANE DOE NO. 2: Good morning, your Honor. THE COURT: Good morning. How are you? JANE DOE NO. 2: Doing okay. I hadn't prepared any words to speak today, but there is something that was on my mind this morning when I got here. It's been on my mind in reading through the press and through the people that I've spoken to about it, friends, family. It's something that's bothered me because I think it has a lot of blame in it, as well, a little bit of what my friend, who was up here, was speaking about. I think that a lot of people asked why we spent so much time, why we stayed. It's an experience that's really 37 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000956 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 • • 37 J8RPEPS2 And even though this Jeffrey Epstein brought it to a grand scale, on some level, a lot of girls could relate to the trauma that we are talking about, and even though this whole situation sucks, I would like to think that it may be possibly a catalyst for change because, obviously, as we're seeing with the "Me Too" movement, change needs to happen and it's -- what I'm seeing in the papers is not a common story, but it's so much more common than you realize. That's all. Thank you. THE COURT: Thank you very much. MR. EDWARDS: I believe that the next client is going to also be a Jane Doe; so I think for the purposes of the record it will be Jane Doe 2. THE COURT: Yes. JANE DOE NO. 2: Good morning, your Honor. THE COURT: Good morning. How are you? JANE DOE NO. 2: Doing okay. I hadn't prepared any words to speak today, but there is something that was on my mind this morning when I got here. It's been on my mind in reading through the press and through the people that I've spoken to about it, friends, family. It's something that's bothered me because I think it has a lot of blame in it, as well, a little bit of what my friend, who was up here, was speaking about. I think that a lot of people asked why we spent so much time, why we stayed. It's an experience ihat's really SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CNAronberg-000956 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 38 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 • • J8RPEPS2 hard to explain to people who haven't gone through it. I think there's a writer, Thomas Nagel, who wrote an essay called "What is it like to be a bat?" And.I think that he touches on it pretty strongly and if you haven't experienced something, it's very hard to fully understand why someone makes the decisions they do and what the circumstances were. I don't want to speak for all of the victims. I think each of us has a different story and different circumstances for why we stayed in it, but for me, I think he was really strategic in how he approached each of us. Things happened slowly over time. We didn't — it almost was like, putting it like that analogy of a frog being in a pan of water and slowly turning the flame up. You didn't realize it was happening, and it just — I don't think anyone can fully understand the experience, but I just — the blame feels very strong. There's a lot of support as well, but I just want people to try and understand that we aren't bad people. We weren't trying to — it wasn't a situation where we were trying to extort money from someone. A lot of us were in very vulnerable situations and in extreme poverty, circumstances where we didn't have anyone on our side, to speak on our behalf, and that's really scary. You start to blame yourself because, at first, you don't tell anyone what's happening, and it becomes your deep, dark secret that you tried to keep from everyone. And I didn't SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 ; I CA/Aronberg-000957 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 38 J8RPEPS2 hard to explain to people who haven't gone through it. I think there's a writer, Thomas Nagel, who wrote an es~ay called "What is it like to be a bat?" And.I think that he touches on it pretty strongly and if you haven't experienced something, it's very hard to fully understand why someone makes the decisions they do and what the circumstances were. I don't want to speak for all of the victims. I think each of us has a different story and different circumstances for why we stayed in it, but for me, I think he was really strategic in how he approached each of us. Things happened slowly over time. We didn't -- it almost was like, putting it like that analogy of a frog being in a pan of water and slowly turning the flame up. You didn't realize it was happening, and it just -- I don't think anyone can fully understand the experience, but I just the blame feels very strong. There's a lot of support as well, but I just want people to try and understand that we aren't bad people. We weren't trying to it wasn't a situation where we were trying to extort money from someone. A lot of us were in very vulnerable situations and in extreme poverty, circumstances where we didn't have anyone on our side, to speak on our behalf, and that's really scary. You start to blame yourself because, at first, you don't tell anyone what's happening, and it becomes your deep, dark secret that you tried to keep from everyone. And I didn't SOUTHERN DISTRICT REPORTERS, P.G. (212) 805-0300 CA/Aronberg-000957 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 39 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 • • J8RPEPS2 even know I was a victim until I spoke with my lawyers. I had i no idea. I had so much self-hatred and doubt and just guilt 1 for everything. I still do. I still don't feel like I deserve to say I'm a victim, and I think that's a big problem with our society right now, that people are still blaming victims, and I think that does need to change. I hope that today people understand that each of us has a story, has a past, has a family and just give us a chance to — you know, that's basically all I just wanted to say. THE COURT: Thank you so much. JANE DOE NO. 2: Thank you so much. THE COURT: Okay. MR. EDWARDS: Okay. I think that the next person who is going to speak is also going to be speaking as Jane Doe; so for the purpose of the record, Jane Doe No. 3. JANE DOE NO. 3: Thank you for allowing us to speak today. I came to New York City 15 years ago to pursue modeling from a small town. I signed on with an agency and was excited to pursue my passion and my dream. Several months later, I met a female who told me about Mr. Epstein. She portrayed him as an amazing man who genuinely cared for people and that he was going to be able to help me in a modeling career. I was excited to meet him, after hearing her talk about him. He sounded like an amazing person. An introduction was made at his New York home, and it is there that I was SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000958 ' FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 39 J8RPEPS2 even know I was a victim until I spoke with my ~awyers. I had i no idea. I had so much self-hatred and doubt and just guilt I ! for everything. I still do. I still don't feel like I deserve to say I'm a victim, and I think that's a big problem with our society right now, that people are still blaming victims, and I think that does need to change. I hope that today people understand that each of us has a story, has a past, has a family and just give us a chance to -- you know, that's basically all I just wanted to say. THE COURT: Thank you so much. JANE DOE NO. 2: Thank you so much. THE COURT: Okay. MR. EDWARDS: Okay. I think that the next person who is going to speak is also going to be speaking as Jane Doe; so for the purpose of the record, Jane Doe No. 3. JANE DOE NO. 3: Thank you for allowing us to speak today. I came to New York City 15 years ago to pursue modeling from a small town. I signed on with an agency and was excited to pursue my passion and my dream. Several months later, I met a female who told me about Mr. Epstein. She portrayed him as an amazing man who genuinely cared for people and that he was going to be able to help me in a modeling career. I was excited to meet him, after hearing her talk about him. He sounded like an amazing person. An introduction was made at his New York home, and it is there'that I was SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/ Aron be rg-000958 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 40 J8RPEPS2 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 sexually assaulted. I left his home, after he threw me, basically put money on the table, and I was ashamed. I was embarrassed. This was not the way I was brought up, and I couldn't believe this had happened to me. I left and my world kind of spiraled after that. I stopped going on modeling castings. I gained weight. I became depressed. I stopped going out with my friends, and only five months after I had been in New York City to pursue my dream, I left. I left the modeling industry, and I left New York City, and I totally switched my career paths. I buried this deep within me, and all of the new occurrences that have come up in the media is what brought it back up for me. And I feel sickened and saddened that it took so many years, and God knows how many victims, for this to finally come out, but I'm thankful it did. And I'm just angry that he's not alive anymore to have to pay the price for his actions. So I thank you for your time. THE COURT: You're very welcome. MR. EDWARDS: Your Honor, Jane Doe No. 4, I believe, is going to speak now. JANE DOE NO. 4: Good morning, your Honor. THE COURT: Good morning. JANE DOE NO. 4: I just have something very short to say. I met Jeffrey Epstein at a very vulnerable place in my life, and whatever the outcome is with everything, I just SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000959 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 sexually assaulted. I left his home, after he threw me, basically put money on the table, and I was ashamed. I was embarrassed. This was not the way I was brought up, and I couldn't believe this had happened to me. 40 I left and my world kind of spiraled after that. I stopped going on modeling castings. I gained weight. I became depressed. I stopped going out with my friends, and only five months after I had been in New York City to pursue my dream, I left. I left the modeling industry, and I left New York City, and I totally switched my career paths. I buried this deep within me, and all of the new occurrences that have come up in the media is what brought it back up for me. And I feel sickened and saddened that it took so many years, and God knows how many victims, for this to finally come out, but I'm thankful it did. And I'm just angry that he's not alive anymore to have to pay the price for his actions. So I thank you for your time. THE COURT: You're very welcome. MR. EDWARDS: Your Honor, Jane Doe No. 4, I believe, is going to speak now. JANE DOE NO. 4: Good morning, your Honor. THE COURT: Good morning. JANE DOE NO. 4: I just have something very short to say. I met Jeffrey Epstein at a very vulnerable place in my life, and whatever the outcome is with everything, I just SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000959 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 41 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 • • J8RPEPS2 wanted to express that we, the victims, we will always carry irreparable damage and pain throughout our lives after this. It's something that's never going to go away. You know, whoever we marry in our life, whatever future we have in our life, it's always going to be something that's always there for us. And I'm very nervous right now. And Jeffrey Epstein, he took away the chance I had at having the future I had envisioned for myself as a young girl, and I think many of us here today will never fully heal from that pain and the heartache that we'll continue carrying with us. So I just wanted to say that. It's something that it's irreparable. I can't even really use a better word to describe that. So thank you for hearing us today. THE COURT: You're very welcome. MR. EDWARDS: Your Honor, Jane Doe No. 5 would like to speak. JANE DOE NO. 5: This is a letter that I wrote; so it's going to be: Dear Jeffrey, I think you are a mentally disturbed human being. You used your power to make me believe at a young age that I could have my dreams of being a model. You paid for your freedom. You violated my rights. You should have to pay for them, just as anyone else. You got a plea deal that no one else would have been able to get. You used your money to get out of paying the price for your actions. Also, as a victim, I never got to see what the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000960 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 • • J8RPEPS2 wanted to express that we, the victims, we will always carry irreparable damage and pain throughout our lives after this. It's something that's never going to go away. You know, whoever we marry in our life, whatever future we have in our life, it's always going to be something that's always there for us. And I'm very nervous right now. And Jeffrey Epstein, he took away the chance I had at having the future I had envisioned for myself as a young girl, and I think many of us here today will never fully heal from that pain and the heartache that we'll continue carrying with us. So I just wanted to say that. It's something that it's irreparable. I can't even really use a better word to describe that. So thank you for hearing us today. THE COURT: You're very welcome. 41 MR. EDWARDS: Your Honor, Jane Doe No. 5 would like to speak. JANE DOE NO. 5: This is a letter that I wrote; so it's going to be: Dear Jeffrey, I think you are a mentally disturbed human being. You used your power to make me believe at a young age that I could have my dreams of being a model. You paid for your freedom. You violated my rights. You should have to pay for them, just as anyone else. You got a plea deal that no one else would have been able to get. You used your money to get out of paying the price for your actions. Also, as a victim, I never got to see what the SOUTHERN DISTRICT REPORTERS, P.C. (212j 805-0300 CNAronberg-000960 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. V28/2023 2:27:00 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 • • J8RPEPS2 agreement was or why the special treatment got approved. I think you should have been in jail for several years in population and live like everyone else that is mentally disturbed like you. You paid for yourself to get special treatment while you were in jail. I don't even think you spent a day in a jail as a normal human being. You had investigators come to my house and also went to my friend's house to question them. I will never be able to over — I will never be able to get over the overwhelming emotions and embarrassment I experienced from that trauma. I needed therapy several times a week and had high stress and anxiety levels. You paid your way to make the public think that the girls had nothing in life going on for them. You wanted to try and blame that we were lower class and that was the problem with the girls. I was from a middle class family and did well in school. I lived the American girl dream — or the American girl life. I went on family vacations around the world, grew up in a good city, and my parents are still married to this day. Basically, everything you said that we didn't have in our life, I did. It all came down to I was told I was making $200 in an hour. Being young, that was a lot of money, and I didn't know any better. Sadly, you were the one with an illness that you should have to go and see a doctor and also have a mentor group SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000961 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 42 J8RPEPS2 agreement was or why the special treatment got approved. I think you should have been in jail for several years in population and live like everyone else that is mentally disturbed like you. You paid for yourself to get special treatment while you were in jail. I don't even think you spent a day in a jail as a normal human being. You had investigators come to my house and also went to my friend's house to question them. I will never be able to over -- I will never be able to get over the overwhelming emotions and embarrassment I experienced from that trauma. I needed therapy several times a week and had high stress and anxiety levels. You paid your way to make the public think that the girls had nothing in life going on for them. You wanted to try and blame that we were lower class and that was the problem with the girls. I was from a middle class family and did well in school. I lived the American girl dream -- or the American girl life. I went on family vacations around the world, grew up in a good city, and my parents are still married to this day. Basically, everything you said that we didn't have in our life, I did. It all came down to I was told I was making $200 in an hour. Being young, that was a lot of money, and I didn't know any better. Sadly, you were the one with an illness that you should have to go and see a doctor and also have a mentor group SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000961 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 43 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 J8RPEPS2 for the sickness you have. I will continue with writing my book about that secret life, with all the newspaper articles of the case, my high school agenda book of official dates. I'm basing that proof that I deposited cash after leaving Jeffrey's. I still have all of the information, articles that I collected over the years. You mentally and physically traumatized me. I went to therapy, and it was the best thing I did for myself. If anyone only learns one thing from this case, I hope is that money should not let you buy your way free. A crime is a crime and a victim is a victim. Thank you. THE COURT: Thank you. Thank you very much. MR. EDWARDS: Your Honor, my next client is Chauntae Davies, C-h-a-u-n-t-a-e, Davies, D-a-v-i-e-s. MS. DAVIES: I met Jeffrey Epstein through my first massage teacher, a man who took me in as his apprentice to teach me a practice I wanted to learn while in desperate search to find a cure for a debilitating neurological disorder that I have, which manifests into violent vomiting attacks, largely triggered by stress. It's called Cyclic Vomiting Syndrome. I was recruited by Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000962 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • 43 J8RPEPS2 for the sickness you have. I will continue with writing my book about that secret life, with all the newsp~per articles of the case, my high school agenda book of official dates. I'm basing that proof that I deposited cash after leaving Jeffrey's. I still have all of the information, articles that I collected over the years. You mentally and physically traumatized me. I went to therapy, and it was the best thing I did for myself. If anyone only learns one thing from this case, I hope is that money should not let you buy your way free. A crime is a crime and a victim is a victim. Thank you. THE COURT: Thank you. Thank you very much. MR. EDWARDS: Your Honor, my next client is Chauntae Davies, C-h-a-u-n-t-a-e, Davies, D-a-v-i-e-s. MS. DAVIES: I met Jeffrey Epstein through my first massage teacher, a man who took me in as his apprentice to teach me a practice I wanted to learn while in desperate search to find a cure for a debilitating neurological disorder that I have, which manifests into violent vomiting attacks, largely triggered by stress. It's called Cyclic Vomiting Syndrome. I was recruited by Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000962 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 44 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 J8RPEPS2 had only dreamt of and made me feel as though L had become a part of their family, another thing I was desperately searching for . But on my third or fourth time meeting them, they brought me to Jeffrey's island for the first time, and on the first night there, Sarah Kellen came tapping on my door late at night to inform me Jeffrey was ready for another massage. My instincts told me this didn't feel right, but I got up and followed her to a villa I hadn't yet seen. Jeffrey and Ghislaine's villa. I began my massage, trying not to let him smell my fear and obvious discomfort, but before I knew what was happening, he grabbed onto my wrist and tugged me towards the bed. I tried to pull away, but he was unbuttoning my shorts and pulling my body onto his already naked body faster than I could think. I was searching for words but all I could say was meek, "No, please stop," but that just seemed to excite him more. He continued to rape me, and when he was finished, he hopped off and went to the shower. I pulled my shorts up, and I ran as fast as I could back to my own villa, my feet bloodied from the rocks. I cried myself to sleep that night. I spent two weeks vomiting, almost to death, in a Los Angeles hospital after that first encounter. Jeffrey's abuse would continue for the next three years, and I allowed it SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000963 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 44 J8RPEPS2 had only dreamt of and made me feel as though I 1 had become a part of their family, another thing I was desperately searching for. But on my third or fourth time meeting them, they brought me to Jeffrey's island for the first time, and on the first night there, Sarah Kellen came tapping on my door late at night to inform me Jeffrey was ready for another massage. My instincts told me this didn't feel right, but I got up and followed her to a villa I hadn't yet seen. Jeffrey and Ghislaine's villa. I began my massage, trying not to let him smell my fear and obvious discomfort, but before I knew what was happening, he grabbed onto my wrist and tugged me towards the bed. I tried to pull away, but he was unbuttoning my shorts and pulling my body onto his already naked body faster than I could think. I was searching for words but all I could say was meek, "No, please stop," but that just seemed to excite him more. He continued to rape me, and when he was finished, he hopped off and went to the shower. I pulled my shorts up, and I ran as fast as I could back to my own villa, my feet bloodied from the rocks. I cried myself to sleep that night. I spent two weeks vomiting, almost to death, in a Los Angeles hospital after that first encounter. Jeffrey's abuse would continue for the next three years, and I allowed it SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/ Aron berg-000963 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 J8RPEPS2 to continue because I had been taken advantage of my entire life and had been conditioned to just accept it. It took me a long time to come forward, too long maybe, and all it took to bring — and all that it took to bring this man to justice has been robbed by his death. Every day, every week I've spent in the hospital since, I've suffered and he has won. Every job offer that's been offered to me and then retracted because of my connection to this case, I have suffered and he has won. Every public humiliation I have endured, I have suffered and he has won. Every relationship that I've had to end because of the abuse that I have endured by the hands of this man, I have suffered and he has won. Every woman sitting in this room today, and all of the women who have yet come forward and who have not yet to come forward and whose lives have been affected by Jeffrey Epstein's sick abuse of young girls, we have all suffered, and he is still winning in death. I refuse to let this man win in death. I couldn't fight back when Jeffrey Epstein sexually abused me because I hadn't yet found my voice. Well, I have found my voice now, and while Jeffrey may no longer be here to hear it, I will not stop fighting, and I will not be silenced anymore. I needed him to hear the pain he's caused, what I've gone through because of him. I wrote a 350-page book of all the pain that I have endured at the hands of this man that I really needed him SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000964 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 to continue because I had been taken advantage bf my entire life and had been conditioned to just accept it. It took me a long time to come forward, too long maybe, and all it took to bring and all that it took to 45 bring this man to justice has been robbed by his death. Every day, every week I've spent in the hospital since, I've suffered and he has won. Every job offer that's been offered to me and then retracted because of my connection to this case, I have suffered and he has won. Every public humiliation I have endured, I have suffered and he has won. Every relationship that I've had to end because of the abuse that I have endured by the hands of this man, I have suffered and he has won. Every woman sitting in this room today, and all of the women who have yet come forward and who have not yet to come forward and whose lives have been affected by Jeffrey Epstein's sick abuse of young girls, we have all suffered, and he is still winning in death. I refuse to let this man win in death. I couldn't fight back when Jeffrey Epstein sexually abused me because I hadn't yet found my voice. Well, I have found my voice now, and while Jeffrey may no longer be here to hear it, I will not stop fighting, and I will not be silenced anymore. I needed him to hear the pain he's caused, what I've gone through because of him. I wrote a 350-page book of all the pain that I have endured at the hands of this man that I really needed him SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/ Aron be rg-000964 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 to hear. His death has robbed me of that justice. Please don't rob us of justice again. Thank you. THE COURT: Thank you. MR. EDWARDS: Your Honor, I think I have one more client that is going to speak today, Anouska De Georgiou. THE COURT: Would you spell that? MS. DE GEORGIOU: Good morning, your Honor. THE COURT: Good morning. MS. DE GEORGIOU: My name is spelled A-n-o-u-s-k-a, D-e, space, G-e-o-r-g-i-o-u. Thank you, your Honor, for giving us the opportunity to be heard this morning. THE COURT: Sure. MS. DE GEORGIOU: When I was introduced to Jeffrey Epstein, I was young and full of hope and the foolishness of a teenager. I was idealistic, and I saw the good in people. Jeffrey Epstein manipulated me, coerced me and sexually abused me. Something I think is very important to communicate is that loss of innocence, trust and joy is not recoverable. The abuse, spanning several years, was devaluing beyond measure and affected my ability to form and maintain healthy relationships, both in my work and my personal life. He could not begin to fathom what he took from us, and I say "us" because I am every girl he did this to, and they're all me. And today we stand SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000965 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 to hear. His death has robbed me of that justice. Please don't rob us of justice again. Thank you. THE COURT: Thank you. MR. EDWARDS: Your Honor, I think I have one more client that is going to speak today, Anouska De Georgiou. THE COURT: Would you spell that? MS. DE GEORGIOU: Good morning, your Honor. THE COURT: Good morning. MS. DE GEORGIOU: My name is spelled A-n-o-u-s-k-a, D-e, space, G-e-o-r-g-i-o-u. Thank you, your Honor, for giving us the opportunity to be heard this morning. THE COURT: Sure. 46 MS. DE GEORGIOU: When I was introduced to Jeffrey Epstein, I was young and full of hope and the foolishness of a teenager. I was idealistic, and I saw the good in people. Jeffrey Epstein manipulated me, coerced me and sexually abused me. Something I think is very important to communicate is that loss of innocence, trust and joy is not recoverable. The abuse, spanning several years, was devaluing beyond measure and affected my ability to form and maintain healthy relationships, both in my work and my personal life. He could not begin to fathom what he took from us, and I say "us" because I am every girl he did this to, and they're all me. And today we stand SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000965 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 47 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 J8RPEPS2 together, those that are present and those that; aren't. I was a victim, and it has taken me many, many years to stand here and say, yes, it was me. I was a victim, but I will not remain a victim and be silent for one more day. Although I think it's tragic when anybody dies before their time, I'm extremely relieved that Jeffrey Epstein will not be in a position to hurt anymore children or anymore women, and I'm glad to be part of a group of women who are now bonded forever in the trauma that we endured at the hands of this man. Thank you. THE COURT: Thank you. MR. EDWARDS: Your Honor, we had one client who was not able to be here but sent a message through a letter. Her name is Michelle Licata, M-i-c-h-e-l-l-e; last name, L-i-c-a-t-a. And Brittany Henderson, of my office, is going to read her letter as instructed. THE COURT: Sure. MS. HENDERSON: Thank you, your Honor. THE COURT: Yup. MS. HENDERSON: What happened to me occurred many years ago when I was in high school, but it still effects my life. I was told then that Jeffrey Epstein was going to be held accountable, but he was not. In fact, the government worked out a secret deal and didn't tell me about it. The case ended without me knowing what was going on, without him being SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000966 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 together, those that are present and those that: aren't. I was a victim, and it has taken me many, many years to stand here and say, yes, it was me. I was a victim, but I will not remain a victim and be silent for one more day. Although I think it's tragic when anybody dies before their time, I'm extremely relieved that Jeffrey Epstein will not be 47 in a position to hurt anymore children or anymore women, and I'm glad to be part of a group of women who are now bonded forever in the trauma that we endured at the hands of this man. Thank you. THE COURT: Thank you. MR. EDWARDS: Your Honor, we had one client who was not able to be here but sent a message through a letter. Her name is Michelle Licata, M-i-c-h-e-1-1-e; last name, L-i-c-a-t-a. And Brittany Henderson, of my office, is going to read her letter as instructed. THE COURT: Sure. MS. HENDERSON: Thank you, your Honor. THE COURT: Yup. MS. HENDERSON: What happened to me occurred many years ago when I was in high school, but it still effects my life. I was told then that Jeffrey Epstein was going to be held accountable, but he was not. In fact, the government worked out a secret deal and didn't tell me about it. The case ended without me knowing what was going on, without him being SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/ Aron berg-000966 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 48 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 J8RPEPS2 held responsible, without any explanation and without a chance for my voice to be heard. I was treated like I; did not matter. Many years later, he was arrested again. These investigators and attorneys representing the United States have been completely different. I am still mad, concerned and confused about how he committed suicide and escaped responsibility again, but I know it is not the fault of the judge or the government attorneys. I was allowed to be a part of the process this time. My attorney was able to tell me what was going on at every stage because they kept him informed. Thank you for inviting me. It means more to me than you can ever know. I was not able to be here this time, but I know that I was allowed to be and I had the chance to attend this hearing, which is helping me in my healing process. The fact that I mattered this time and the other victims mattered is what counts. For that, I am grateful. THE COURT: Thank you. MR. EDWARDS: Your Honor, finally, in 2008 when I filed the case under the Crime Victims Rights Act, it wasn't me alone. I did it with Paul Cassell and Jay Howell. Paul Cassell is here today, and I think your Honor even cited to a piece of — an opinion of his from when he was on the bench, and he has some remarks to make. Once again, your Honor, I really do believe that this SOUTHERN DISTRICT REPORTERS, P.G. (212) 805-0300 CA/Aronberg-000967 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 48 J8RPEPS2 held responsible, without any explanation and without a chance i for my voice to be heard. I was treated like I! did not matter. I Many years later, he was arrested again. These investigators and attorneys representing the United States have been completely different. I am still mad, concerned and confused about how he committed suicide and escaped responsibility again, but I know it is not the fault of the judge or the government attorneys. I was allowed to be a part of the process this time. My attorney was able to tell me what was going on at every stage because they kept him informed. Thank you for inviting me. It means more to me than you can ever know. I was not able to be here this time, but I know that I was allowed to be and I had the chance to attend this hearing, which is helping me in my healing process. The fact that I mattered this time and the other victims mattered is what counts. For that, I am grateful. THE COURT: Thank you. MR. EDWARDS: Your Honor, finally, in 2008 when I filed the case under the Crime Victims Rights Act, it wasn't me alone. I did it with Paul Cassell and Jay Howell. Paul Cassell is here today, and I think your Honor even cited to a piece of -- an opinion of his from when he was on the bench, and he has some remarks to make. Once again, your Honor, I really do believe that this SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000967 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 49 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 J8RPEPS2 is a model for how victims should be treated in a criminal process, and we really do appreciate it. Thank you. THE COURT: Thank you. MR. CASSELL: I'll be very brief because I know there are others that want to speak here. I'm Paul Cassell, C-a-s-s-e-1-1, previously served as a federal judge at the District of Utah, currently a law professor, where I teach crime victims rights at the University of Utah, College of Law. I just wanted to take one minute to address some suggestion that there would be no need for a hearing this morning. I think, having heard already from these powerful victims and recognizing how important giving those statements will be in the trajectory of their lives, makes clear that your Honor has followed exactly the right path. Legally, there is one precedent, which is U.S. v. Heaton, a case that you cited that I wrote about a decade ago, and as explained in that opinion, victims have important interests in the criminal justice system that can only be recognized if they're given their day in court. With all due respect to other law professors that have recently written an article, I think transparency is one of the overriding objectives in our criminal justice system, and the one substantive action that I would urge your Honor to take today is to publish your remarks as a published opinion. The Heaton case is, to my knowledge, the only reported decision on SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 | CA/Aronberg-000968 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 is a model for how victims should be treated in' a criminal process, and we really do appreciate it. Thank you. THE COURT: Thank you. 49 MR. CASSELL: I'll be very brief because I know there are others that want to speak here. I'm Paul Cassell, C-a-s-s-e-1-1, previously served as a federal judge at the District of Utah, currently a law professor, where I teach crime victims rights at the University of Utah, College of Law. I just wanted to take one minute to address some suggestion that there would be no need for a hearing this morning. I think, having heard already from these powerful victims and recognizing how important giving those statements will be in the trajectory of their lives, makes clear that your Honor has followed exactly the right path. Legally, there is one precedent, which is U.S. v. Heaton, a case that you cited that I wrote about a decade ago, and as explained in that opinion, victims have important interests in the criminal justice system that can only be recognized if they're given their day in court. With all due respect to other law professors that have recently written an article, I think transparency is one of the overriding objectives in our criminal justice system, and the one substantive action that I would urge your Honor to take today is to publish your remarks as a published opinion. The Heaton case is, to my knowledge, the only reported decision on SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000968 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 ; this particular issue, even though it's more than a decade old and, yet, we can see today that these problems recur in many I other cases. Your remarks today, I think, should be published so that they can serve as a guide for other judges around the country. I would encourage you to add into your remarks a reference to the Crime Victims Rights Act. The Crime Victims Right Act promises victims the right to be treated with fairness, dignity and respect, and the process that we see unfolding this morning is a clear example of how victims can be treated with fairness, dignity and respect. So I know that your Honor is wondering what is the appropriate action here. Unfortunately, it seems like there are no other legal options, but there was a legal option for you to decide to exercise, which was to allow these victims to come forward. And if there's been one positive thing that has come out of the tragedies, the abuse, the other events of this case, it's been your decision to allow these victims to be heard this morning, and I encourage you to publish your decision and to encourage other judges to follow what is clearly a model for crime victims rights and is clearly an example that should be followed in other cases down the road. THE COURT: Thank you very much. I appreciate your being here. I had no idea that you would be here when I wrote the remarks, but it was clear from the literature that you are 50 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000969 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • 50 J8RPEPS2 this particular issue, even though it's more than a decade old I and, yet, we can see today that these problems recur in many I I other cases. Your remarks today, I think, should be published so that they can serve as a guide for other judges around the country. I would encourage you to add into your remarks a reference to the Crime Victims Rights Act. The Crime Victims Right Act promises victims the right to be treated with fairness, dignity and respect, and the process that we see unfolding this morning is a clear example of how victims can be treated with fairness, dignity and respect. So I know that your Honor is wondering what is the appropriate action here. Unfortunately, it seems like there are no other legal options, but there was a legal option for you to decide to exercise, which was to allow these victims to come forward. And if there's been one positive thing that has come out of the tragedies, the abuse, the other events of this case, it's been your decision to allow these victims to be heard this morning, and I encourage you to publish your decision and to encourage other judges to follow what is clearly a model for crime victims rights and is clearly an example that should be followed in other cases down the road. THE COURT: Thank you very much. I appreciate your being here. I had no idea that you would be here when I wrote the remarks, but it was clear from the literature that you are SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000969 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 51 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 • • J8RPEPS2 the leading expert formerly of the District Court of Utah, I believe, and it's a pleasure to have you here today. MR. CASSELL: Thank you, your Honor. THE COURT: Thanks. Mr. Boies? MR. BOIES: Thank you, your Honor. David Boies of Boies Schiller Flexner. We have with us today five of the victims that we represent. There are a number of additional victims who either were unable to attend or are still unwilling to come forward publicly. This has been an enormously traumatic aspect of their lives, something that, as you've already heard and will hear more today, is something that they can never entirely escape from. I want to, as prior counsel have, commend both the Court and counsel for the Department of Justice for the consideration and respect and attention that they have paid to the victims. We believe that that is not only right, as a matter of human dignity, but we think that is exactly what the law requires and intends. I will be more blunt than the Court has been, or Professor Cassell has been about Professor Green's article. That is an article that cites no authority, and I believe there is no authority for his proposition. I entirely respect his right to advocate on behalf of his client Alan Dershowitz, who has retained him in connection with litigation that we've SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 i CA/Aronberg-000970 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • el J8RPEPS2 the leading expert formerly of the District Court of Utah, I believe, and it's a pleasure to have you here today. MR. CASSELL: Thank you, your Honor. THE COURT: Thanks. Mr. Boies? 51 MR. BOIES: Thank you, your Honor. David Boies of Boies Schiller Flexner. We have with us today five of the victims that we represent. There are a number of additional victims who either were unable to attend or are still unwilling to come forward publicly. This has been an enormously traumatic aspect of their lives, something that, as you've already heard and will hear more today, is something that they can never entirely escape from. I want to, as prior counsel have, commend both the Court and counsel for the Department of Justice for the consideration and respect and attention that they have paid to the victims. We believe that that is not only right, as a matter of human dignity, but we think that is exactly what the law requires and intends. I will be more blunt than the Court has been, or Professor Cassell has been about Professor Green's article. That is an article that cites no authority, and I believe there is no authority for his proposition. I entirely respect his right to advocate on behalf of his client Alan Dershowitz, who has retained him in connection with litigation that we've SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000970 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 52 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 J8RPEPS2 brought against Mr. Dershowitz, but I would have expected that the Law Journal or Professor Green himself would have disclosed that connection, which I think is a conflict. But regardless of the appropriateness of his disclosure, or lack of disclosure, I think that his article opposing allowing the victims to have a voice in this proceeding is inconsistent not only with the policy that underlies the Crime Victim Rights Act and the very statute that Mr. Epstein is being prosecuted under, but it ignores the actual language of those statutes, and many other statutes, in which Congress has made clear that the purpose of the criminal law is no longer simply to punish the individual defendant, but it is to find some way of trying to mitigate the damage that has been done to the victims through restitution and economic mitigation, but also through the ability to confront and to have the court system and the justice system and the prosecutors treat these victims as they are victims, as they are human beings, and they are entitled to the respect that our society needs to give every human being. So I think that this is not only commendable, but I think it is what the Law requires. In response to the question the Court asked, I have discussed this hearing with my clients. I have told them that, under the applicable law, the government has no alternative but to move to dismiss this case, and I believe under the SOUTHERN DISTRICT REPORTERS, (212) 805-0300 P.C. CA/Aronberg-000971 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 • • 52 J8RPEPS2 brought against Mr. Dershowitz, but I would have expected that the Law Journal or Professor Green himself would have disclosed that connection, which I think is a conflict. But regardless of the appropriateness of his disclosure, or lack of disclosure, I think that his article opposing allowing the victims to have a voice in this proceeding is inconsistent not only with the policy that underlies the Crime Victim Rights Act and the very statute that Mr. Epstein is being prosecuted under, but it ignores the actual language of those statutes, and many other statutes, in which Congress has made clear that the purpose of the criminal law is no longer simply to punish the individual defendant, but it is to find some way of trying to mitigate the damage that has been done to the victims through restitution and economic mitigation, but also through the ability to confront and to have the court system and the justice system and the prosecutors treat these victims as they are victims, as they are human beings, and they are entitled to the respect that our society needs to give every human being. So I think that this is not only commendable, but I think it is what the law requires. In response to the question the Court asked, I have discussed this hearing with my clients. I have told them that, under the applicable law, the government has no alternative but to move to dismiss this case, and I believe under the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/ Aronberg-000971 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 53 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 J8RPEPS2 applicable law in this circuit, the Court has no alternative but to grant that motion. I think the current law is outdated, as the Court suggested in some of its remarks. I think there will come a time when either an Appellate court or the Congress will make clear that, just as it's possible to continue civil cases against someone after they have deceased, it is possible, at least for purposes of things like restitution, to continue criminal cases, but we are not there now. And, fortunately, in this case, there are other ways and perhaps even more efficient ways to vindicate the interests of the victims here. We greatly appreciate the remarks of the representative of the Department of Justice today, and we, too, on behalf of the victims, are not going to stop when we walk out of this courtroom. We are going to continue to seek vindication against Mr. Epstein's estate and, in some senses, perhaps even more important, against the people who worked with him and enabled him. As you have already heard, and will hear more, Mr. Epstein did not act alone. He could not have done what he did, on the scope and the scale of what he did, for as many years as he did it without the activities and support and the co-conspirator activity of a number of other key individuals, and those individuals also need to bear their share of responsibility, and those people need to have a reckoning as SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000972 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 • • J8RPEPS2 applicable law in this circuit, the Court has np alternative but to grant that motion. I think the current law is outdated, as the Court suggested in some of its remarks. I think there will come a 53 time when either an Appellate court or the Congress will make clear that, just as it's possible to continue civil cases against someone after they have deceased, it is possible, at least for purposes of things like restitution, to continue criminal cases, but we are not there now. And, fortunately, in this case, there are other ways and perhaps even more efficient ways to vindicate the interests of the victims here. We greatly appreciate the remarks of the representative of the Department of Justice today, and we, too, on behalf of the victims, are not going to stop when we walk out of this courtroom. We are going to continue to seek vindication against Mr. Epstein's estate and, in some senses, perhaps even more important, against the people who worked with him and enabled him. As you have already heard, and will hear more, Mr. Epstein did not act alone. He could not have done what he did, on the scope and the scale of what he did, for as many years as he did it without the activities and support and the co-conspirator activity of a number of other key individuals, and those individuals also need to bear their share of responsibility, and those people need to have a reckoning as SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CN Aron be rg-000972 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • s, J8RPEPS2 , well. My partner Sig McCawley, who's been working with me for more than five years on this case, is going to, with the Court's permission, introduce five of our clients who will speak briefly to your Court. Thank you very much. THE COURT: Thank you very much, Mr. Boies. Pleasure to have you here. MS. McCAWLEY: Thank you, your Honor, the first victim that would like to speak today is Theresa J. Helm. THE COURT: Can we have the spelling of your name? MS. McCAWLEY: Sure. Sigrid, S-i-g-r-i-d, and the last name is M-c-C-a-w-l-e-y, and I'm a partner at Boies Schiller Flexner. THE COURT: Thank you. MS . HELM: Good morning. THE COURT: Good morning. MS . HELM: Thank you, prosecutors and Judge, and the Court. My name is Theresa Helm. I note today I do feel respected and listened to; so I appreciate that, and I have to say that I commend the boldness of the New York prosecutors for pursuing a man that has, you know — and others, that have clearly taken a lot from a lot of people. 17 years ago I knew him only as "Jeffrey." I was recruited and brought from California to New York, and that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000973 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 well. My partner Sig Mccawley, who's been working with me for more than five years on this case, is going to, with the Court's permission, introduce five of our clients who will speak briefly to your Court. Thank you very much. 54 THE COURT: Thank you very much, Mr. Boies. Pleasure to have you here. MS. McCAWLEY: Thank you, your Honor, the first victim that would like to speak today is Theresa J. Helm. THE COURT: Can we have the spelling of your name? MS. McCAWLEY: Sure. Sigrid, S-i-g-r-i-d, and the last name is M-c-C-a-w-1-e-y, and I'm a partner at Boies Schiller Flexner. THE COURT: Thank you. MS. HELM: Good morning. THE COURT: Good morning. MS. HELM: Thank you, prosecutors and Judge, and the Court. My name is Theresa Helm. I note today I do feel respected and listened to; so I appreciate that, and I have to say that I commend the boldness of the New York prosecutors for pursuing a man that has, you know -- and others, that have clearly taken a lot from a lot of people. 17 years ago I knew him only as "Jeffrey." I was recruited and brought from California to New York, and that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000973 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 J8RPEPS2 experience for the last 17 years has been a dark corner in my story, in my life, in my life story and that has been definitely made worse by my own self-shame and that — and anger for normalizing all of the red flags. I feel like we are conditioned to do that, and that's something that needs to change. So I'm here today, you know, I'm coming forward because it is time to bring light to that darkness, and it's time to replace that darkness with light. And I am a survivor of this, and I do aim to progress further from being a survivor, you know. I feel I've worked hard, guite hard, to get to where I'm at now, and I'm definitely at a place in my life where I will no longer cover up. I'11 no longer cover up what needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and Sarah Kellen, and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a system. So they need to be held accountable, all of them, and I would like to see that, certainly on behalf of myself and for everyone here. Thank you. THE COURT: Thanks so much. MS. McCAWLEY: Our next client, who is going to speak this morning, is Virginia Roberts Giuffre. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000974 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 experience for the last 17 years has been a dark corner in my story, in my life, in my life story and that has been definitely made worse by my own self-shame and that and 55 anger for normalizing all of the red flags. I feel like we are conditioned to do that, and that's something that needs to change. So I'm here today, you know, I'm coming forward because it is time to bring light to that darkness, and it's time to replace that darkness with light. And I am a survivor of this, and I do aim to progress further from being a survivor, you know. I feel I've worked hard, quite hard, to get to where I'm at now, and I'm definitely at a place in my life where I will no longer cover up. I'll no longer cover up what needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and Sarah Kellen, and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a system. So they need to be held accountable, all of them, and I would like to see that, certainly on behalf of myself and for everyone here. Thank you. THE COURT: Thanks so much. MS. McCAWLEY: Our next client, who is going to speak this morning, is Virginia Roberts Giuffre. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-00097 4 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 56 J8RPEPS2 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 MS. GIUFFRE: Good morning, your Honor; THE COURT: Good morning. How are you? MS. GIUFFRE: Okay. Thank you. My name is Virginia Roberts Giuffre, that's V-i-r-g-i-n-i-a, Roberts, R-o-b-e-r-t-s, Giuffre, G-i-u, double F, for Fred, -r-e. I am a victim of Jeffrey Epstein and Ghislaine Maxwell in the dark and cruel and criminal acts they committed against me and hundreds of other girls and young women for years and years and years, unstopped. Thank you for allowing me to address the Court and speak the truth. I commend the prosecutors from the Southern District of New York for the ongoing investigation and its pursuit of justice for us victims. It has given me hope, and I will not let go of that hope. When I was recruited by Ghislaine Maxwell at Mar-a-Lago, just before I was 17, I thought I was given a big break, and I'd be able to reset my life and become an actual real massage therapist. My hopes were quickly dashed, and my dreams were stolen. Jeffrey Epstein is no longer alive, but this is not about how he died. This is about how he lived. He will not have his day in court, but the reckoning of accountability has begun, supported by the voices of these brave and beautiful women in this courtroom today. The reckoning must not end. It must continue. He did not act alone and we, the victims, know that. We trust the government SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000975 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 J8RPEPS2 • • MS. GIUFFRE: Good morning, your Honor. THE COURT: Good morning. How are you? MS. GIUFFRE: Okay. Thank you. My name is Virginia Roberts Giuffre, that's V-i-r-g-i-n-i-a, Roberts, R-o-b-e-r-t-s, Giuffre, G-i-u, double F, for Fred, -r-e. 56 I am a victim of Jeffrey Epstein and Ghislaine Maxwell in the dark and cruel and criminal acts they committed against me and hundreds of other girls and young women for years and years and years, unstopped. Thank you for allowing me to address the Court and speak the truth. I commend the prosecutors from the Southern District of New York for the ongoing investigation and its pursuit of justice for us victims. It has given me hope, and I will not let go of that hope. When I was recruited by Ghislaine Maxwell at Mar-a-Lago, just before I was 17, I thought I was given a big break, and I'd be able to reset my life and become an actual real massage therapist. My hopes were quickly dashed, and my dreams were stolen. Jeffrey Epstein is no longer alive, but this is not about how he died. This is about how he lived. He will not have his day in court, but the reckoning of accountability has begun, supported by the voices of these brave and beautiful women in this courtroom today. The reckoning must not end. It must continue. He did not act alone and we, the victims, know that. We trust the government SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000975 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 is listening and that the others will be brought to justice. Thank you, your Honor. THE COURT: Thank you very much. MS. McCAWLEY: The next client of ours that will be speaking this morning is Sarah Ransome. MS. RANSOME: Thank you, your Honor. My name is Sarah Ransome, R-a-n-s-o-m-e. I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the other victims. I would also like to acknowledge and extend my gratitude to the prosecutors from the Southern District of New York for pursuing justice on behalf of the victims. Please, please finish what you have started. I struggled to find the words to adequately say how important your work is to us . For a very long time Jeffrey Epstein gamed the system at every level, and when he realized he couldn't do that any longer, he showed the world what a depraved and cowardly human being he is by taking his own life. But we, the victims, are still here, prepared to tell the truth, and we all know he did not act alone. We are survivors, and the pursuit of justice should not abate. Thank you, your Honor. THE COURT: You're very welcome. MS. McCAWLEY: Our next client who is going to be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000976 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 57 J8RPEPS2 is listening and that the others will be brought to justice. Thank you, your Honor. THE COURT: Thank you very much. MS. McCAWLEY: The next client of ours that will be speaking this morning is Sarah Ransome. MS. RANSOME: Thank you, your Honor. My name is Sarah Ransome, R-a-n-s-o-m-e. I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the other victims. I would also like to acknowledge and extend my gratitude to the prosecutors from the Southern District of New York for pursuing justice on behalf of the victims. Please, please finish what you have started. I struggled to find the words to adequately say how important your work is to us. For a very long time Jeffrey Epstein gamed the system at every level, and when he realized he couldn't do that any longer, he showed the world what a depraved and cowardly human being he is by taking his own life. But we, the victims, are still here, prepared to tell the truth, and we all know he did not act alone. We are survivors, and the pursuit of justice should not abate. Thank you, your Honor. THE COURT: You're very welcome. MS. McCAWLEY: Our next client who is going to be SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000976 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 58 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 • • J8RPEPS2 speaking this morning is Annie Farmer. MS. FARMER: Good morning, your Honor. THE COURT: Good morning. MS. FARMER: Annie, A-n-n-i-e, Farmer, F-a-r-m-e-r. I had the opportunity to speak at Jeffrey Epstein's bail hearing, and I really appreciate that you heard me and listened to me that day. I am so sorry that others will not have the opportunity to stand before him the way that I did. But I'm here today to speak on behalf of my sister, Maria Farmer, who could not be here. Jeffrey Epstein, Ghislaine Maxwell not only assaulted her, but as we're hearing from so many of these brave women here today, they stole her dreams and her livelihood. She risked her safety in 1996, so many years ago, to report them, to no avail, and it is heartbreaking to her and to me that all this destruction has been wrought since that time. We were deeply disappointed and disturbed by Epstein's death and the fact that that was allowed to happen while he was in the government's custody, and I'm encouraged to hear that there will be a full investigation as to how that was allowed to happen. But it is extremely important, as others are saying, that he did not act alone and that the other people that were a part of what he did are held accountable and that that investigation continues. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000977 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 speaking this morning is Annie Farmer. MS. FARMER: Good morning, your Honor. THE COURT: Good morning. MS. FARMER: Annie, A-n-n-i-e, Farmer, F-a-r-m-e-r. I had the opportunity to speak at Jeffrey Epstein's bail hearing, and I really appreciate that you heard me and listened to me that day. I am so sorry that others will not have the opportunity to stand before him the way that I did. But I'm here today to speak on behalf of my sister, Maria Farmer, who could not be here. 58 Jeffrey Epstein, Ghislaine Maxwell not only assaulted her, but as we're hearing from so many of these brave women here today, they stole her dreams and her livelihood. She risked her safety in 1996, so many years ago, to report them, to no avail, and it is heartbreaking to her and to me that all this destruction has been wrought since that time. We were deeply disappointed and disturbed by Epstein's death and the fact that that was allowed to happen while he was in the government's custody, and I'm encouraged to hear that there will be a full investigation as to how that was allowed to happen. But it is extremely important, as others are saying, that he did not act alone and that the other people that were a part of what he did are held accountable and that that investigation continues. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000977 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RPEPS2 I believe that we have a real problem in this country with perpetrators of sexual abuse and sexual assault being held accountable. There are so many roadblocks to victims being heard, to cases being investigated thoroughly, and then to those cases being prosecuted. And so I think this is a really important signal to send a message to victims out there that people will take you seriously, people will follow through, and that even those in power, as we have unfortunately seen, that has not been often are able to escape that, that even those in power will be held accountable. Thank you. THE COURT: Thanks so much. MS. McCAWLEY: Our next client, who's going to address the Court is Marijke Chartouni. She says it much more beautifully than I do; so I'll let her say it. MS. CHARTOUNI: My first name is spelled, M-a-r-i-j-k-e; last name is C-h-a-r-t-o-u-n-i. My name is Marijke Chartouni, and I am a victim of Jeffrey Epstein and the sophisticated sex trafficking operation he ran, where he allegedly was to be a financier. I was 20 and previously modeled and was living in the West Village. I met a young woman named Rena through a mutual friend. We were friends for a few months. She was an amazing artist and liked to party. One day she called me and asked if I was interested in meeting a friend of hers. She told me he wanted to meet me and really liked blonds, and I thought he was SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 CA/Aronberg-000978 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • 59 J8RPEPS2 I believe that we have a real problem in this country with perpetrators of sexual abuse and sexual assault being held accountable. There are so many roadblocks to victims being heard, to cases being investigated thoroughly, and then to those cases being prosecuted. And so I think this is a really important signal to send a message to victims out there that people will take you seriously, people will follow through, and that even those in power, as we have unfortunately seen, that has not been often are able to escape that, that even those in power will be held accountable. Thank you. THE COURT: Thanks so much. MS. McCAWLEY: Our next client, who's going to address the Court is Marijke Chartouni. She says it much more beautifully than I do; so I'll let her say it. MS. CHARTOUNI: My first name is spelled, M-a-r-i-j-k-e; last name is C-h-a-r-t-o-u-n-i. My name is Marijke Chartouni, and I am a victim of Jeffrey Epstein and the sophisticated sex trafficking operation he ran, where he allegedly was to be a financier. I was 20 and previously modeled and was living in the West Village. I met a young woman named Rena through a mutual friend. We were friends for a few months. She was an amazing artist and liked to party. One day she called me and asked if I was interested in meeting a friend of hers. She told me he wanted to meet me and really liked blonds, and I thought he was SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000978 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 60 J8RPEPS2 ; i i i our age and liked to do the same things we did at that age; so I agreed. I On a sunny, crisp day, we took the train together to the Upper East Side. She then began to talk a little bit about him on our way to his house. I was at his house. I was sexually assaulted by both Rena and Jeffrey Epstein in his mansion. It left me feeling both disgusted and betrayed. As we walked home to the subway afterwards, she continued to tell me about the man who had just abused me with her participation. She seemed exhilarated from the horrific experience. I was shocked and in a daze. This is a few things that she had told me. She told me he went to Cooper Union. He was a mathematical genius. That he had favorite girls that he would take to Chanel for 15-minute, all-you-can-buy shopping trips. She told me his right-hand person had connection to the arts and the fashion world, and she could help me. This is not my complete story. I'll stop here. I'm in a good, stable place in my life, and I had decided to come forward to be a voice to the victims who may not be able to tell their story, or at least not yet. I feel like I am a survivor. Thank you, Judge Berman, for inviting victims to speak today before you. We hope the government is listening very closely to the words we are saying. THE COURT: Thank you very much. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000979 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • J8RPEPS2 I •I I I I I 60 our age and liked to do the same things we did ?t that age; so I agreed. On a sunny, crisp day, we took the train together to the Upper East Side. She then began to talk a little bit about him on our way to his house. I was at his house. I was sexually assaulted by both Rena and Jeffrey Epstein in his mansion. It left me feeling both disgusted and betrayed. As we walked home to the subway afterwards, she continued to tell me about the man who had just abused me with her participation. She seemed exhilarated from the horrific experience. I was shocked and in a daze. This is a few things that she had told me. She told me he went to Cooper Union. He was a mathematical genius. That he had favorite girls that he would take to Chanel for 15-minute, all-you-can-buy shopping trips. She told me his right-hand person had connection to the arts and the fashion world, and she could help me. This is not my complete story. I'll stop here. I'm in a good, stable place in my life, and I had decided to come forward to be a voice to the victims who may not be able to tell their story, or at least not yet. I feel like I am a survivor. Thank you, Judge Berman, for inviting victims to speak today before you. We hope the government is listening very closely to the words we are saying. THE COURT: Thank you very much. SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000979 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM J8RPEPS2 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 MR. BOIES: Your Honor, just very briefly. THE COURT: Sure. MR. BOIES: I would like to express to: the Court how proud I am of all of these women who have come forward. It's taken an enormous amount of strength and courage for them to do so. Thank you. THE COURT: Thanks, Mr. Boies. Hold on one second. (Pause) MS. LERNER: Thank you, your Honor. My name is Kimberly Lerner, of Lerner and Lerner, and your Honor, with your permission, I would like my client, Jennifer Aroz, to stand next to me. THE COURT: Sure. MS. LERNER: Would that be okay? THE COURT: Absolutely. MS. LERNER: Your Honor, I would like to begin by saying that I am in awe of all of these beautiful women. I just want to let you know, on behalf of Jennifer and myself, we admire you, we respect you, and we applaud you, and you are brave survivors. And Jennifer's heart is with all of you, and we thank you so much for coming forward. Jennifer, when she went public, she thought she was one of the only ones, and to see all of these faces is, I know, amazing for her. Jeffrey Epstein was a predator, a pedophile and a sick SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000980 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 J8RPEPS2 • • MR. BOIES: Your Honor, just very briefly. THE COURT: Sure. 61 MR. BOIES: I would like to express to the Court how proud I am of all of these women who have come forward. It's taken an enormous amount of strength and courage for them to do so. Thank you. THE COURT: Thanks, Mr. Boies. Hold on one second. (Pause) MS. LERNER: Thank you, your Honor. My name is Kimberly Lerner, of Lerner and Lerner, and your Honor, with your permission, I would like my client, Jennifer Aroz, to stand next to me. THE COURT: Sure. MS. LERNER: Would that be okay? THE COURT: Absolutely. MS. LERNER: Your Honor, I would like to begin by saying that I am in awe of all of these beautiful women. I just want to let you know, on behalf of Jennifer and myself, we admire you, we respect you, and we applaud you, and you are brave survivors. And Jennifer's heart is with all of you, and we thank you so much for coming forward. Jennifer, when she went public, she thought she was one of the only ones, and to see all of these faces is, I know, amazing for her. Jeffrey Epstein was a predator, a pedophile and a sick SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000980 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 62 J8RPEPS2 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 individual. However, he was also a thief. He stole Jennifer's childhood dreams, her innocence and her self-confidence. She was 14 years old. What he could not buy, he forcibly took. Why? Because he surrounded himself with a network of powerful people who not only looked the other way, but also actively facilitated and participated in his sexual abuse of children. Jeffrey Epstein thought he was above the law, and essentially he was until now. The system let Jennifer and the other victims down, but it does not have to end here. We ask the U.S. Attorney's Office and the FBI to bring all of Epstein's enablers and co-conspirators to justice. It has taken Jennifer 18 years to find her voice, and again, Jeffrey Epstein has tried to silence her. While she will never have her chance to face him in court, he no longer has any power over her. Today, this brave survivor will be heard. MS. AROZ : Thank you for allowing me to be able to have my chance in court today, to be able to tell you what this horrific man did to my life. You can't even imagine how much it affected my childhood, all the way through my adult life. He robbed me of my dreams. He robbed me of my chance to pursue a career I always adored. He stole my chance at really feeling love because I was so scared to trust anyone for so many years that I had such severe anxiety. I didn't want to leave my house let alone my bed. SOUTHERN DISTRICT REPORTERS (212) 805-0300 p.c. CA/Aronberg-000981 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 62 J8RPEPS2 individual. However, he was also a thief. He stole Jennifer's childhood dreams, her innocence and her self-confidence. She was 14 years old. What he could not buy, he forcibly took. Why? Because he surrounded himself with a network of powerful people who not only looked the other way, but also actively facilitated and participated in his sexual abuse of children. Jeffrey Epstein thought he was above the law, and essentially he was until now. The system let Jennifer and the other victims down, but it does not have to end here. We ask the U.S. Attorney's Office and the FBI to bring all of Epstein's enablers and co-conspirators to justice. It has taken Jennifer 18 years to find her voice, and again, Jeffrey Epstein has tried to silence her. While she will never have her chance to face him in court, he no longer has any power over her. Today, this brave survivor will be heard. MS. AROZ: Thank you for allowing me to be able to have my chance in court today, to be able to tell you what this horrific man did to my life. You can't even imagine how much it affected my childhood, all the way through my adult life. He robbed me of my dreams. He robbed me of my chance to pursue a career I always adored. He stole my chance at really feeling love because I was so scared to trust anyone for so many years that I had such severe anxiety. I didn't want to leave my house let alone my bed. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000981 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 63 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 J8RPEPS2 The fact that he felt entitled to take:away my innocence, the fact that he felt that he could do whatever he wanted, regardless of the laws, hurts me so very much. It took me years to tell anyone what Epstein did to me because I was so ashamed and embarrassed at what people would say or think of me until I found out there were other victims, girls just like me. I knew I could no longer keep my silence no matter how ruthless and powerful Epstein was, and still is even after his death. The fact I will never have a chance to face my predator in court eats away at my soul. Even in death, Epstein is trying to hurt me. I had hoped to at last get an apology, but this evil man had no remorse or caring for what he did to anyone. I felt let down by the people who were supposed to watch him in prison. They let this man kill himself and kill the chance of justice for so many others in the process, taking away our ability to speak. Out of all the damages and side effects that Epstein caused by his heartless and selfish acts, it's very hard to put my feelings and emotions into words, trying to let his horrendous actions go and attempting to forgive him, has been so difficult for me. Yet, as hard as it's been to come so publicly forward, I refuse to let Epstein take me as a victim anymore. I am a survivor. The many that stand before me here today that have shared the horrific experiences with this SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000982 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 63 J8RPEPS2 The fact that he felt entitled to take: away my innocence, the fact that he felt that he could do whatever he wanted, regardless of the laws, hurts me so very much. It took me years to tell anyone what Epstein did to me because I was so ashamed and embarrassed at what people would say or think of me until I found out there were other victims, girls just like me. I knew I could no longer keep my silence no matter how ruthless and powerful Epstein was, and still is even after his death. The fact I will never have a chance to face my predator in court eats away at my soul. Even in death, Epstein is trying to hurt me. I had hoped to at last get an apology, but this evil man had no remorse or caring for what he did to anyone. I felt let down by the people who were supposed to watch him in prison. They let this man kill himself and kill the chance of justice for so many others in the process, taking away our ability to speak. Out of all the damages and side effects that Epstein caused by his heartless and selfish acts, it's very hard to put my feelings and emotions into words, trying to let his horrendous actions go and attempting to forgive him, has been so difficult for me. Yet, as hard as it's been to come so publicly forward, I refuse to let Epstein take me as a victim anymore. I am a survivor. The many that stand before me here today that have shared the horrific experiences with this SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/ Aron be rg-000982 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3128/2023 2:27:00 PM 64 J8RPEPS2 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 deplorable human being, because even though this weak, evil coward tried to steal all of our childhoods, tried to steal all I of our innocence and tried to steal all of our means of justice, he will never steal our inner strength, and he will never, ever, ever steal our voice. Thank you so much. THE COURT: You're welcome. MS. GIBBS: Good morning, your Honor. Teri Gibbs, T-e-r-i, G-i-b-b-s. For the record, I am a California attorney. I'm not admitted to the New York State bar. I am here to make a statement on behalf of New York attorney, Lisa Bloom. I work for her firm, The Bloom Firm. Lisa Bloom represents four of Jeffrey Epstein's victims, Jane Doe 6, for the record, Jane Doe 7 and Jane Doe 8. I am so proud of all of you victims who are here today and are able to voice yourselves today. I will not and cannot comment on the criminal case, or Ms. Bloom's communications with her clients. Ms. Bloom would like to share three of her client's statements for the record. Here are the statements. Statement of Jane Doe 6. To the Honorable Richard M. Berman. Jeffrey Epstein stole my innocence. He gave me a life sentence of guilt and shame. I do not consider myself a victim. I see myself a survivor. The abuse that I endured cannot continue. Let's stop this before it happens to other young women. Jane Doe. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000983 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 64 J8RPEPS2 deplorable human being, because even though this weak, evil coward tried to steal all of our childhoods, tried to steal all I of our innocence and tried to steal all of our means of justice, he will never steal our inner strength, and he will never, ever, ever steal our voice. Thank you so much. THE COURT: You're welcome. MS. GIBBS: Good morning, your Honor. Teri Gibbs, T-e-r-i, G-i-b-b-s. For the record, I am a California attorney. I'm not admitted to the New York State bar. I am here to make a statement on behalf of New York attorney, Lisa Bloom. I work for her firm, The Bloom Firm. Lisa Bloom represents four of Jeffrey Epstein's victims, Jane Doe 6, for the record, Jane Doe 7 and Jane Doe 8. I am so proud of all of you victims who are here today and are able to voice yourselves today. I will not and cannot comment on the criminal case, or Ms. Bloom's communications with her clients. Ms. Bloom would like to share three of her client's statements for the record. Here are the statements. Statement of Jane Doe 6. To the Honorable Richard M. Berman. Jeffrey Epstein stole my innocence. He gave me a life sentence of guilt and shame. I do not consider myself a victim. I see myself a survivor. The abuse that I endured cannot continue. Let's stop this before it happens to other young women. Jane Doe. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000983 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 65 J8RPEPS2 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 Statement of Jane Doe 7. To the Honorable Richard M. Berman. I used to be relatively carefree, inquisitive, hopeful and excited about life, but my life changed because of Jeffrey Epstein. My perspective on life became very dark when I was unknowingly recruited by one of his agents. Jeffrey Epstein ruined me. His recruiter ruined me. The far-reaching consequences of that day ruined my family's lives. I've chosen to remain anonymous in order to protect my family from unwanted media attention. I was just trying to figure out my path in life when I encountered Jeffrey Epstein in his New York City mansion. I cannot even begin to summarize the many detriments this experience of sexual assault has had on my life. Immediately following the incident, I was unable to function and be around other people. My parents had to rescue me and bring me home, where I became a recluse for years. I was changed forever and buried my assault deep down, where the darkness couldn't hurt me anymore, but of course, it has always been here, lingering and affecting me unconsciously. At the time, I was mired in shame, guilt and humiliation. I had somehow tricked myself into thinking that I had allowed the assault to happen, that I did it to myself, that I don't deserve to be alive or to be loved. I believed that I was a disgusting, shameful person who does not deserve to ever be happy. These are the thoughts I've lived with on a daily SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000984 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 65 J8RPEPS2 Statement of Jane Doe 7. To the Honorable Richard M. Berman. I used to be relatively carefree, inquisitive, hopeful and excited about life, but my life changed because of Jeffrey Epstein. My perspective on life became very dark when I was unknowingly recruited by one of his agents. Jeffrey Epstein ruined me. His recruiter ruined me. The far-reaching consequences of that day ruined my family's lives. I've chosen to remain anonymous in order to protect my family from unwanted media attention. I was just trying to figure out my path in life when I encountered Jeffrey Epstein in his New York City mansion. I cannot even begin to summarize the many detriments this experience of sexual assault has had on my life. Immediately following the incident, I was unable to function and be around other people. My parents had to rescue me and bring me home, where I became a recluse for years. I was changed forever and buried my assault deep down, where the darkness couldn't hurt me anymore, but of course, it has always been here, lingering and affecting me unconsciously. At the time, I was mired in shame, guilt and humiliation. I had somehow tricked myself into thinking that I had allowed the assault to happen, that I did it to myself, that I don't deserve to be alive or to be loved. I believed that I was a disgusting, shameful person who does not deserve to ever be happy. These are the thoughts I've lived with on a daily SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000984 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 66 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 • • J8RPEPS2 basis. Furthermore, because I couldn't tell anyone, out of fear of judgment, blame or retaliation, keeping this secret completely hindered my ability to uncover why these issues existed for me, which could have led to a path of healing over the years . It is time for those of power to do the right thing. It is time for compassion toward our fellow human beings to reign over money, power and greed. We need to protect our most vulnerable to allow them a chance at a normal life, and nothing should come in the way of that. I believe that for future generations, including my own children, this case will set a precedent that victims must no longer suffer in silence on our own or be shamed for coming forward to seek protection. This case should demonstrate to those who want to harm others that there will be a reckoning, and they will pay dearly for the harm they inflict on innocent people. Judge Berman, I thank you for from the bottom of my heart for this forum and opportunity. To all of those survivors who came before me, I commend your bravery. There is no way I could have done this without you. Thank you to the public following this story, for your outrage and desire for answers, which will hopefully move this case forward so that victims can stop having to relive their SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000985 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 66 J8RPEPS2 basis. Furthermore, because I couldn't tell anyone, out of fear of judgment, blame or retaliation, keeping this secret completely hindered my ability to uncover why these issues existed for me, which could have led to a path of healing over the years. It is time for those of power to do the right thing. It is time for compassion toward our fellow human beings to reign over money, power and greed. We need to protect our most vulnerable to allow them a chance at a normal life, and nothing should come in the way of that. I believe that for future generations, including my own children, this case will set a precedent that victims must no longer suffer in silence on our own or be shamed for coming forward to seek protection. This case should demonstrate to those who want to harm others that there will be a reckoning, and they will pay dearly for the harm they inflict on innocent people. Judge Berman, I thank you for from the bottom of my heart for this forum and opportunity. To all of those survivors who came before me, I commend your bravery. There is no way I could have done this without you. Thank you to the public following this story, for your outrage and desire for answers, which will hopefully move this case forward so that victims can stop having to relive their SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CNAronberg-000985 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • ® J8RPEPS2 experiences every day and move on to begin to heal. God bless the victims, their families, the investigators and public servants working so diligently to find those answers and to right all these wrongs. Jane Doe 7. (Continued on next page) 67 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000986 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 67 J8RPEPS2 experiences every day and move on to begin to heal. God bless the victims, their families, the investigators and public servants working so diligently to find those answers and to right all these wrongs. Jane Doe 7. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000986 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 68 J8RsEPS3 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 THE COURT: Thanks very much. ; MS. GIBBS: One more. Statement of Jane Doe 8. In the past few weeks, I have had to reflect on my interaction with Jeffrey Epstein and realized that, though I have yet to put it all behind me, I am still a victim. I say this because I have to come to terms with it in an effort to truly get past the abuse I suffered at the hands of Epstein. Pursuing criminal penalties against him and having an opportunity to address the egregious crimes he committed against me and other young woman would have helped my recovery process. This all came to an abrupt halt when he took his own life. This point of disclosure is lost. I cannot say that I am pleased he committed suicide, but I am at peace knowing he will not be able to hurt anyone else. However, a sad truth remains. I, along with other people, will never have an answer as to why. I will never have an apology for the wrongdoing. And most importantly, Epstein will not be justly sentenced for his crimes. Now I sit in my home questioning the well-being of those girls like myself. In choosing death, Epstein denied everyone justice. Any efforts made to protect Epstein's name and legacy send a message to the victims that he wins and that he is untouchable. I understand his case may be dismissed or closed, but this makes me feel as though I, and anyone else who fell pry to his hands, simply do not matter. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000987 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • J8RsEPS3 THE COURT: Thanks very much. MS. GIBBS: One more. Statement of Jane Doe 8. In the past few weeks, I have had to reflect on my interaction with Jeffrey Epstein and realized that, though I have yet to put it all behind me, I am still a victim. I say this because I have to come to terms with it in an effort to truly get past the abuse I suffered at the hands of Epstein. 68 Pursuing criminal penalties against him and having an opportunity to address the egregious crimes he committed against me and other young woman would have helped my recovery process. This all came to an abrupt halt when he took his own life. This point.of disclosure is lost. I cannot say that I am pleased he committed suicide, but I am at peace knowing he will not be able to hurt anyone else. However, a sad truth remains. I, along with other people, will never have an answer as to why. I will never have an apology for the wrongdoing. And most importantly, Epstein will not be justly sentenced for his crimes. Now I sit in my home questioning the well-being of those girls like myself. In choosing death, Epstein denied everyone justice. Any efforts made to protect Epstein's name and legacy send a message to the victims that he wins and that he is untouchable. I understand his case may be dismissed or closed, but this makes me feel as though I, and anyone else who fell pry to his hands, simply do not matter. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000987 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 J8RsEPS3 I ask that you very seriously consider the final decision, because it will undoubtedly affect all other facets of this case, including any future charges brought against the recruiters or third parties to his crimes. I do not want the narrative to be, Those poor girls. I want to send a message to anyone who would consider engaging in similar acts to think twice beforehand. I want some sort of closure for those of us who relive those horrible moments where we were assaulted, abused, and taken advantage of by Epstein. You have the opportunity to help us seek that closure. I appreciate your time and consideration and ask for your continued support in dealing with this case to illustrate that we, Epstein's victims, do matter. Sincerely, Jane Doe 8. On behalf of Lisa Bloom and The Bloom Firm, thank you, your Honor. THE COURT: Thank you, Ms. Gibbs. Did we have any other victim's counsel or victims? Ms. Allred. MS. ALLRED: Good morning, your Honor. THE COURT: Good morning. How are you? MS. ALLRED: Fine. Thank you. Allred, Maroko & Goldberg by Gloria Allred, G-l-o-r-i-a A-l-l-r-e-d. Your Honor, thank you so much for this opportunity to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000988 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • J8RsEPS3 I ask that you very seriously consider the final decision, because it will undoubtedly affect ali other facets 69 of this case, including any future charges brought against the recruiters or third parties to his crimes. I do not want the narrative to be, Those poor girls. I want to send a message to anyone who would consider engaging in similar acts to think twice beforehand. I want some sort of closure for those of us who relive those horrible moments where we were assaulted, abused, and taken advantage of by Epstein. You have the opportunity to help us seek that closure. I appreciate your time and consideration and ask for your continued support in dealing with this case to illustrate that we, Epstein's victims, do matter. Sincerely, Jane Doe 8. On behalf of Lisa Bloom and The Bloom Firm, thank you, your Honor. THE COURT: Thank you, Ms. Gibbs. Did we have any other victim's counsel or victims? Ms. Allred. MS. ALLRED: Good morning, your Honor. THE COURT: Good morning. How are you? MS. ALLRED: Fine. Thank you. Allred, Maroko & Goldberg by Gloria Allred, G-1-o-r-i-a A-1-1-r-e-d. Your Honor, thank you so much for this opportunity to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CNAronberg-000988 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 70 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 J8RsEPS3 afford the victims their voice, because many of' them have never spoken before. They never spoke in Florida. They never spoke anywhere. They never told their mother. They never told their father. They never told their family members. This is an opportunity for them to be heard. We thank you for that. Your Honor, for 43 years my firm has been the leading women's rights private law firm in the United States. We have helped thousands of victims. And I, as an officer of the court, and as a believer in the system, have tried to encourage the victims to have confidence in the system that should provide them access to justice that should help them to assert and vindicate their rights in a court of law. It has been increasingly difficult in this case for me to say to my clients that they should have confidence in the system of justice given what has occurred in this case, People v. Jeffrey Epstein. Having said that, I am encouraged by the fact that this court, essentially, in an unprecedented situation where the defendant is deceased, is still affording these victims an opportunity to be heard. So we thank you for that. It is some encouragement. Your Honor, you also asked do our clients wish to be heard in reference to some of the issues that have been raised this morning, including what should happen into this case. Your Honor, there has been a suggestion that the court should investigate the circumstances of the death of Mr. Epstein. I'm SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000989 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 70 J8RsEPS3 afford the victims their voice, because many of them have never spoken before. They never spoke in Florida. T~ey never spoke anywhere. They never told their mother. They never told their father. They never told their family members. This is an opportunity for them to be heard. We thank you for that. Your Honor, for 43 years my firm has been the leading women's rights private law firm in the United States. We have helped thousands of victims. And I, as an officer of the court, and as a believer in the system, have tried to encourage the victims to have confidence in the system that should provide them access to justice that should help them to assert and vindicate their rights in a court of law. It has been increasingly difficult in this case for me to say to my clients that they should have confidence in the system of justice given what has occurred in this case, People v. Jeffrey Epstein. Having said that, I am encouraged by the fact that this court, essentially, in an unprecedented situation where the defendant is deceased, is still affording these victims an opportunity to be heard. So we thank you for that. It is some encouragement. Your Honor, you also asked do our clients wish to be heard in reference to some of the issues that have been raised this morning, including what should happen into this case. Your Honor, there has been a suggestion that the court should investigate the circumstances of the death of Mr. Epstein. I'm SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000989 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 71 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 • • J8RsEPS3 not going to repeat the arguments made by counsel, but I would say that if there is jurisdiction, and I know that is a legal issue which has been previously argued, that certainly it would increase the confidence of my clients. Not just my clients, but victims all over, and some are, by the way, located in other parts of the world, to have the court oversee the investigation. We are encouraged by the sensitivity of the attorneys for the United States Attorney's office for the Southern District of New York and the investigation that is going on with the separate team. However, and, of course, the defense is also conducting its own investigation. But I do think the greatest confidence would be if the court in some way would be able to oversee an investigation because the court is a neutral party. And although the court certainly has a stake in finding out what happened to defendants who are in the custody of the federal system and who should be there to face the prosecutors and the charges against them, but now are not because clearly the system has failed. And the United States Attorney has admitted that, and even before he admitted that, everybody knows the system failed. Failed the victims, failed the court, failed everyone. In any event, your Honor, having seen so many thousands of victims of gender violence, sex harassment, sexual assault, I've dealt with child sex trafficking, child SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000990 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 • • 71 J8RsEPS3 not going to repeat the arguments made by counsel, but I would say that if there is jurisdiction, and I know that is a legal issue which has been previously argued, that certainly it would increase the confidence of my clients. Not just my clients, but victims all over, and some are, by the way, located in other parts of the world, to have the court oversee the investigation. We are encouraged by the sensitivity of the attorneys for the United States Attorney's office for the Southern District of New York and the investigation that is going on with the separate team. However, and, of course, the defense is also conducting its own investigation. But I do think the greatest confidence would be if the court in some way would be able to oversee an investigation because the court is a neutral party. And although the court certainly has a stake in finding out what happened to defendants who are in the custody of the federal system and who should be there to face the prosecutors and the charges against them, but now are not because clearly the system has failed. And the United States Attorney has admitted that, and even before he admitted that, everybody knows the system failed. Failed the victims, failed the court, failed everyone. In any event, your Honor, having seen so many thousands of victims of gender violence, sex harassment, sexual assault, I've dealt with child sex trafficking, child SOUTHERN DISTRICT REPORTERS, P.G. (212) 805-0300 CA/Aronberg-000990 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 72 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 J8RsEPS3 molesters, I mean, this is a unique case because there are so many victims and so many failures of the system. At this point, what we would really ask for is not just words, but words have been helpful, but deeds, and that is very important. In addition, I would like to say, throughout this case is the running theme of the betrayal of trust. Betrayal of trust by Jeffrey Epstein. Betrayal of trust by the system. And betrayal of trust to the victims who had a right to justice. And the Crime Victims' Act should not just be words, it should have meaning and it should be enforced. In essence, we are asking, although you may need to, of course, grant this motion to dismiss, I think because the court has shown sensitivity to victims and victims' needs, if there is a way to at least keep the record open so that victims who have not been able to be physically present in the courtroom today and who have not been able to submit to the court any letters, victim impact, and who have not been able to secure attorneys or speak to attorneys yet — so, for example, I'll still hearing from victims who I have not been able to meet with yet because they just recently are now contacting me — so if they could submit, at least for the record, their victim impact statements, that, I think, would be a very important assistance to them. So that would be, at least they would know that what they are sharing is on the record. So, in summary, I would say that they are looking SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000991 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPS3 molesters, I mean, this is a unique case because there are so many victims and so many failures of the system. At this 72 point, what we would really ask for is not just words, but words have been helpful, but deeds, and that is very important. In addition, I would like to say, throughout this case is the running theme of the betrayal of trust. Betrayal of trust by Jeffrey Epstein. Betrayal of trust by the system. And betrayal of trust to the victims who had a right to justice. And the Crime Victims' Act should not just be words, it should have meaning and it should be enforced. In essence, we are asking, although you may need to, of course, grant this motion to dismiss, I think because the court has shown sensitivity to victims and victims' needs, if there is a way to at least keep the record open so that victims who have not been able to be physically present in the courtroom today and who have not been able to submit to the court any letters, victim impact, and who have not been able to secure attorneys or speak to attorneys yet -- so, for example, I'll still hearing from victims who I have not been able to meet with yet because they just recently are now contacting me -- so if they could submit, at least for the record, their victim impact statements, that, I think, would be a very important assistance to them. So that would be, at least they would know that what they are sharing is on the record. So, in summary, I would say that they are looking SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CNAronberg-000991 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPS3 forward to the very serious investigation by the United States Attorney of who may have conspired in this case, and that is very hopeful, and we're hoping that everyone who may have a role to this criminal prosecution will submit that evidence. This is about power. This is about many victims having lived in fear — fear of the rich, the powerful, the famous, fear that the system will not afford them justice. So fear of not coming forward. And fear, of course, is a weapon that the rich, powerful, famous, and sexual predators used to silence the victims. But that is gone for a lot of victims because they refuse to suffer in silence. Finally, it does take courage to speak truth to power. We thank this honorable court for giving these victims a voice. We thank them, even after the death of the defendant, for showing respect for the victims, allowing them dignity, allowing them a voice. We do want truth, we do want justice, we do want accountability, and we do want those conspirators to face the justice system. Your Honor, right now we have two of our clients who would like to address the court. THE COURT: Sure. MS. ALLRED: Then I have a couple of statements on victims who do not wish to address the court. As they come up, we'll give them the opportunity to say either their name or Jane Doe. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 73 CA/Aronberg-000992 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • •• 73 J8RsEPS3 forward to the very serious investigation by the United States Attorney of who may have conspired in this case, and that is very hopeful, and we're hoping that everyone who may have a role to this criminal prosecution will submit that evidence. This is about power. This is about many victims having lived in fear -- fear of the rich, the powerful, the famous, fear that the system will not afford them justice. So fear of not coming forward. And fear, of course, is a weapon that the rich, powerful, famous, and sexual predators used to silence the victims. But that is gone for a lot of victims because they refuse to suffer in silence. Finally, it does take courage to speak truth to power. We thank this honorable court for giving these victims a voice. We thank them, even after the death of the defendant, for showing respect for the victims, allowing them dignity, allowing them a voice. We do want truth, we do want justice, we do want accountability, and we do want those conspirators to face the justice system. Your Honor, right now we have two of our clients who would like to address the court. THE COURT: Sure. MS. ALLRED: Then I have a couple of statements on victims who do not wish to address the court. As they come up, we'll give them the opportunity to say either their name or Jane Doe. SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000992 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 74 J8RsEPS3 By the way, thank you, your Honor, for allowing some of these victims to be called Jane Doe. What number the court affords to them, we'll accept whatever that is. Thank you. THE COURT: We're up to nine. MS. ALLRED: Thank you. MS. DAVIES: Hello. My name is Teala Davies. That is T-e-a-l-a D-a-v-i-e-s. I was going to start this statement by saying that I was a victim of Jeffrey Epstein. But that's not the case. I'm still a victim of Jeffrey Epstein. I'm still a victim because the fear of not being heard stopped me from telling my story for so many years. This lingering fear almost stopped me from attending this monumental movement of strength and power. I'm still a victim because I am fearful for my daughters and everyone's daughters. I'm fearful for their future in this world, where there are predators in power, a world where people can avoid justice if their pockets run deep enough. I'm still a victim because the 17-year-old Teala was manipulated into thinking she had found someone who cared, someone who wanted to help. Jeffrey knew I had nowhere to go. He knew I was vulnerable, and he took advantage of that poor girl, who will never be the same. I cannot eat at the thought that Jeffrey Epstein — I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000993 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 74 J8RsEPS3 By the way, thank you, your Honor, for allowing some of these victims to be called Jane Doe. What number the court affords to them, we'll accept whatever that is. Thank you. THE COURT: We're up to nine. MS. ALLRED: Thank you. MS. DAVIES: Hello. My name is Teala Davies. That is T-e-a-1-a D-a-v-i-e-s. I was going to start this statement by saying that I was a victim of Jeffrey Epstein. But that's not the case. I'm still a victim of Jeffrey Epstein. I'm still a victim because the fear of not being heard stopped me from telling my story for so many years. This lingering fear almost stopped me from attending this monumental movement of strength and power. I'm still a victim because I am fearful for my daughters and everyone's daughters. I'm fearful for their future in this world, where there are predators in power, a world where people can avoid justice if their pockets run deep enough. I'm still a victim because the 17-year-old Teala was manipulated into thinking she had found someone who cared, someone who wanted to help. Jeffrey knew I had nowhere to go. He knew I was vulnerable, and he took advantage of that poor girl, who will never be the same. I cannot eat at the thought that Jeffrey Epstein -- I SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/ Aron be rg-000993 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 75 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 J8RsEPS3 cannot eat at the thought of Jeffrey Epstein not serving the time he needed to realize the pain and suffering he caused so many vulnerable young girls. He thought he was untouchable, and honestly, so did I. I thought he was the most powerful person I would ever meet. But the end is here and here I stand becoming more powerful than he will ever be. Thank you. THE COURT: Thank you. JANE DOE: Jane Doe. Um, in 2004, when I was 15 years old, I flew on Jeffrey Epstein's plane to Zorro Ranch, where I was sexual molested by him for many hours. What I remember most vividly was him explaining to me how beneficial the experience was for me and how much he was helping me to grow. Yikes. I remember feeling so small and powerless, especially after he positioned me by laying me on his floor so that I was confronted by all the framed photographs on his dresser of him smiling with wealthy celebrities and politicians. After he finished with me, he told me to describe in detail how good my first sexual experience felt. That was the first of many lies I was forced to carry for him, the weight of which proliferated my trauma. I felt powerless not merely because one man wanted to strip me of my innocence, but because I was the victim of a system that just enfranchises human beings, making them vulnerable to pedophilic exploitation. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000994 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPS3 cannot eat at the thought of Jeffrey Epstein no~ serving the time he needed to realize the pain and suffering he caused so many vulnerable young girls. He thought he was untouchable, and honestly, so did I. I thought he was the most powerful person I would ever meet. But the end is here and here I stand becoming more powerful than he will ever be. Thank you. THE COURT: Thank you. JANE DOE: Jane Doe. 75 Urn, in 2004, when I was 15 years old, I flew on Jeffrey Epstein's plane to Zorro Ranch, where I was sexual molested by him for many hours. What I remember most vividly was him explaining to me how beneficial the experience was for me and how much he was helping me to grow. Yikes. I remember feeling so small and powerless, especially after he positioned me by laying me on his floor so that I was confronted by all the framed photographs on his dresser of him smiling with wealthy celebrities and politicians. After he finished with me, he told me to describe in detail how good my first sexual experience felt. That was the first of many lies I was forced to carry for him, the weight of which proliferated my trauma. I felt powerless not merely because one man wanted to strip me of my innocence, but because I was the victim of a system that just enfranchises human beings, making them vulnerable to pedophilic exploitation. SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CNAronberg-000994 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPS3 : As unjust as what happened to me was, I believe that experience to be a symptom of insidious and pathological violence that extreme wealth yields, a violence which ultimately stays hidden through channels of extreme power that serve it. I first identified with this feeling the night after I was molested by Epstein, when another girl and I took out two of his ATVs and raised them across the mesa. I crashed mine and expressed my concern to the other girl of getting in trouble, which she replied to me, Don't worry, no one gets in trouble for anything here. Even as a child, I understood, in a sad and precocious way, what I hoped we have the ability of changing now. Even though Epstein is dead, there is still justice to be brought for the crimes we felt powerless against concealing for him and the system that supported him for all these years. Thank you. THE COURT: You're very welcome. MS. ALLRED: Thank you. Your Honor, may it please the court. I would like to read a statement for Jane Doe, my client, who is present in court, but requested that I read it. We only have one opportunity at childhood. One opportunity to develop. One opportunity to find direction for our lives. Jeffrey Epstein robbed and denied me at each SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000995 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 76 J8RsEPS3 As unjust as what happened to me was, I believe that experience to be a symptom of insidious and pathological violence that extreme wealth yields, a violence which ultimately stays hidden through channels of extreme power that serve it. I first identified with this feeling the night after I was molested by Epstein, when another girl and I took out two of his ATVs and raised them across the mesa. I crashed mine and expressed my concern to the other girl of getting in trouble, which she replied to me, Don't worry, no one gets in trouble for anything here. Even as a child, I understood, in a sad and precocious way, what I hoped we have the ability of changing now. Even though Epstein is dead, there is still justice to be brought for the crimes we felt powerless against concealing for him and the system that supported him for all these years. Thank you. THE COURT: You're very welcome. MS. ALLRED: Thank you. Your Honor, may it please the court. I would like to read a statement for Jane Doe, my client, who is present in court, but requested that I read it. We only have one opportunity at childhood. One opportunity to develop. One opportunity to find direction for our lives. Jeffrey Epstein robbed and denied me at each SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-000995 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 77 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 J8RsEPS3 opportunity he had. I came from a small Texas town, not far from the New Mexico border. My mother died when I was 11, after suffering from cancer for many years. My father was devastated, as were my siblings and I. My father was saddled with debt. My only hope for college was to get a scholarship. When I was 15, I was.a blossoming freshman in high school and was trying to carry on my mother's dream. She wanted me to master the violin. After school, I would often go to a mall in a nearby city. A lady approached me and saw I had a violin case with me and asked if I was any good. We talked about the violin, my family, and why I had clothes that looked like hand-me-downs. The lady told me she works for a very rich man who had a home close by and that he would pay to hear me play. I was told that if I could get away, she could arrange for transportation to and from his place and have me back before anyone knew I was gone. After some hesitation, I agreed. This decision was the beginning of the end of my childhood. The man who only identified himself as J or Jeff had asked if I would give him a massage, and over four visits, eventually progressed to forced oral copulation. The money he gave me further placed my young soul into a perverse sense of hell. I was so utterly disgusted with myself and what he did SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 ! CA/Aronberg-000996 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 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 • • 77 J8RsEPS3 opportunity he had. I came from a small Texas town, not fat from the New Mexico border. My mother died when I was 11, after suffering from cancer for many years. My father was devastated, as were my siblings and I. My father was saddled with debt. My only hope for college was to get a scholarship. When I was 15, I was.a blossoming freshman in high school and was trying to carry on my mother's dream. She wanted me to master the violin. After school, I would often go to a mall in a nearby city. A lady approached me and saw I had a violin case with me and asked if I was any good. We talked about the violin, my family, and why I had clothes that looked like hand-me-downs. The lady told me she works for a very rich man who had a home close by and that he would pay to hear me play. I was told that if I could get away, she could arrange for transportation to and from his place and have me back before anyone knew I was gone. After some hesitation, I agreed. This decision was the beginning of the end of my childhood. The man who only identified himself as J or Jeff had asked if I would give him a massage, and over four visits, eventually progressed to forced oral copulation. The money he gave me further placed my young soul into a perverse sense of hell. I was so utterly disgusted with myself and what he did SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000996 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPS3 to me that I stopped going to see him. I had documented the events with a Texas rape crisis center about the man I know now as Jeffrey Epstein. Epstein targeted and took advantage of me, a young girl, whose mother had recently died a horrific death and whose family structure had deteriorated. His actions placed me, a young girl, into a downward spiral to the point where I purchased a gun and drove myself to an isolated place to end my suffering. A voice that could only have been from my mother told me, quote, I am not the victim, I am the victor, and I dare not pull the trigger." I returned the gun days later. Epstein is a coward. He lived his life leaching off the souls of inspiring, young girls due to the fact that he could never know how it feels inspired to live. Like a leach, once Epstein had his fill, he would unlatch and seek out another victim. The only sense of justice I had hoped to see was Epstein being sentenced. However, Epstein died as he lived, taking the easy way out without any responsibility. Your Honor, the next statement is also a statement of a Jane Doe. May it please the court. I was a 16-year-old virgin when Jeffrey Epstein first raped me. I was naive and gullable. He was a pillar of finance and a giant in the world that I was an insignificant 78 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000997 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 78 J8RsEPS3 to me that I stopped going to see him. I had documented the events with a Texas rape crisis center about the man I know now as Jeffrey Epstein. Epstein targeted and took advantage of me, a young girl, whose mother had recently died a horrific death and whose family structure had deteriorated. His actions placed me, a young girl, into a downward spiral to the point where I purchased a gun and drove myself to an isolated place to end my suffering. A voice that could only have been from my mother told me, quote, I am not the victim, I am the victor, and I dare not pull the trigger." I returned the gun days later. Epstein is a coward. He lived his life leaching off the souls of inspiring, young girls due to the fact that he could never know how it feels inspired to live. Like a leach, once Epstein had his fill, he would unlatch and seek out another victim. The only sense of justice I had hoped to see was Epstein being sentenced. However, Epstein died as he lived, taking the easy way out without any responsibility. Your Honor, the next statement is also a statement of a Jane Doe. May it please the court. I was a 16-year-old virgin when Jeffrey Epstein first raped me. I was naive and gullable. He was a pillar of finance and a giant in the world that I was an insignificant SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 ' ' \ CA/ Aron be rg-000997 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 J8RsEPS3 part of. I was so impressed that this great man would even talk to me and impart any of his wisdom on me. I gladly jumped at the chance to meet him again, when he told me how impressed he was with my personal story and maturity for my age. When I was in his presence, he made an effort to call celebrities and influential people on speakerphone, like Academy Award-winning actresses and super models, who always answered his calls. Sadly, I was impressed. He was friends with former and future heads of states and every other fixture in the New York social scene and beyond. He knew important people in my own world that I looked up to and revered, but he spoke about them like they were sweet distractions far beneath his stature. He could easily reach down from his position and influence the people directly involved with my daily life and future prosperity. I was the perfect victim. My whole life was extremely turbulent. But one of my mother's greatest wishes was that all her children would graduate from respectable universities. He promised me that he would write me a letter of recommendation for Harvard if I got the grades and scores needed for admission. His word was worth a lot, he assured me, as he was in the midst of funding and leading Harvard's studies on the human brain, and the president was his friend. The fact that all of you already know these next SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 , CA/Aronberg-000998 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 79 J8RsEPS3 part of. I was so impressed that this great mah would even talk to me and impart any of his wisdom on me. I gladly jumped at the chance to meet him again, when he told me how impressed he was with my personal story and maturity for my age. When I was in his presence, he made an effort to call celebrities and influential people on speakerphone, like Academy Award-winning actresses and super models, who always answered his calls. Sadly, I was impressed. He was friends with former and future heads of states and every other fixture in the New York social scene and beyond. He knew important people in my own world that I looked up to and revered, but he spoke about them like they were sweet distractions far beneath his stature. He could easily reach down from his position and influence the people directly involved with my daily life and future prosperity. I was the perfect victim. My whole life was extremely turbulent. But one of my mother's greatest wishes was that all her children would graduate from respectable universities. He promised me that he would write me a letter of recommendation for Harvard if I got the grades and scores needed for admission. His word was worth a lot, he assured me, as he was in the midst of funding and leading Harvard's studies on the human brain, and the president was his friend. The fact that all of you already know these next SOUTHERN DISTRICT REPORTERS, P. C .. ( 212) 805-0300 CA/Aronberg-000998 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 80 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 J8RsEPS3 details, which I'll share, should ignite fire instead of induce the complacency they did in the past, when heard repeatedly over the years, but yes, an innocent massage turned sexual almost immediately. "Here, come. Come help me with a kink in my shoulder while we finish our discussion." A large vibrator and a couple of hundred dollars, disgust and dirty secret, more praise and imparted wisdom from a godlike figure, a deliberate diabolical depression of grooming and submission for his pleasure and release. Even if I resisted, I was no match for him. I felt powerless, ashamed, and embarrassed. I wanted to vomit remembering these moments. What I learned in those depraved sessions, staring up at the dome ceiling in his private massage room, tore a violent hole through any normal sexual awakening. I'm haunted forever, having learned everything there is to know about sex through a vile criminal. Every time a new molestation would bring a new lesson, the progressive and constant unwinding. I was nothing more than a teenage prostitute. I was his slave. I had never even kissed a boy before I met him, and never throughout the horrific abuse did Jeffrey Epstein kiss me even once. When he stole my virginity, he washed my entire body compulsively in the shower and then told me, "If you're not a virgin, I will kill you." And then I wasn't a virgin anymore. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000999 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 80 J8RsEPS3 details, which I'll share, should ignite fire instead of induce the complacency they did in the past, when heard repeatedly over the years, but yes, an innocent massage turned sexual almost immediately. "Here, come. Come help me with a kink in my shoulder while we finish our discussion." A large vibrator and a couple of hundred dollars, disgust and dirty secret, more praise and imparted wisdom from a godlike figure, a deliberate diabolical depression of grooming and submission for his pleasure and release. Even if I resisted, I was no match for him. I felt powerless, ashamed, and embarrassed. I wanted to vomit remembering these moments. What I learned in those depraved sessions, staring up at the dome ceiling in his private massage room, tore a violent hole through any normal sexual awakening. I'm haunted forever, having learned everything there is to know about sex through a vile criminal. Every time a new molestation would bring a new lesson, the progressive and constant unwinding. I was nothing more than a teenage prostitute. I was his slave. I had never even kissed a boy before I met him, and never throughout the horrific abuse did Jeffrey Epstein kiss me even once. When he stole my virginity, he washed my entire body compulsively in the shower and then told me, "If you're not a virgin, I will kill you." And then I wasn't a virgin anymore. SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/ Aron berg-000999 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 81 J8RsEPS3 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 He forcefully penetrated me. I was numb. There was pain, but his use of the vibrator and his fingers in previous sessions with me had left a black hole-like void between my legs. I protested, but he forced my face into the bed to stifle my cries. That was my first time. I got a few hundred dollars, as usual, as he led me out of his mansion with assurances that I was on the right path guided by him. I lied to myself and tried to believe him. I became a hollow shell. If I missed an appointment, he threatened me and let me know who was in charge. "Do you know how important my time is? I'll bury you. I owe this — I won't say the word — F'ing town." He would hang up. I would stand there frozen in the street, terrified that his assistant would call to reschedule. I made sure to stay in line and not disobey him. I was in complete denial. Being paid after every scheduled meeting felt routine and disgusting. He was the master of the universe and the world bent to his will. He would eventually brag to his assistants about my ability to please him sexually right in front of me, leaving me feeling grotesque and worthless. Everything in my outside life was falling apart. I distanced myself from friends and grew further away from my family. I felt less human after each ordeal. My psyche broke down completely and wouldn't let me continue. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-001000 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPS3 He forcefully penetrated me. I was numb. There was pain, but his use of the vibrator and his finge~s in previous sessions with me had left a black hole-like void between my legs. I protested, but he forced my face into the bed to stifle my cries. That was my first time. I got a few hundred dollars, as usual, as he led me 81 out of his mansion with assurances that I was on the right path guided by him. I lied to myself and tried to believe him. I became a hollow shell. If I missed an appointment, he threatened me and let me know who was in charge. "Do you know how important my time is? I'll bury you. I owe this won't say the word -- F'ing town." He would hang up. I I would stand there frozen in the street, terrified that his assistant would call to reschedule. I made sure to stay in line and not disobey him. I was in complete denial. Being paid after every scheduled meeting felt routine and disgusting. He was the master of the universe and the world bent to his will. He would eventually brag to his assistants about my ability to please him sexually right in front of me, leaving me feeling grotesque and worthless. Everything in my outside life was falling apart. I distanced myself from friends and grew further away from my family. I felt less human after each ordeal. My psyche broke down completely and wouldn't let me continue. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-001000 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 i 82 J8RsEPS3 One day I walked out of his residence and passed a girl similar to myself. When I turned around, she was entering Jeffrey's residence. He no longer even tried to schedule his appointments with other girls in secrecy from me. Maybe he never did. I was too stupid to see. My world shattered. I had been so naive. I had an epiphany in a calvary of desperation. I realized I was just one of many young girls he had in rotation come to perform for him for money. I went into a deep depression and never lifted completely. I wanted to inflict pain on myself. I was humiliated, angry, and suicidal. I locked myself away from everything. I cut myself off forever from the world I had known. I endured the daily agony of knowing my life would never be the same. I could never go back to New York City and the wonderful life I had taken for granted before I met this demon named Jeffrey Epstein. This creature had manipulated and outwitted the whole system, including some of the most intelligent scientists, political people, prosecutors, and power players. How easy was it to manipulate a 16-year-old virgin who never had a boyfriend and came from a background of hardship with no parental guidance or support. I went to therapy and was given antidepressants for severe anxiety and depression. My only solace, years later, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-001001 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 82 J8RsEPS3 One day I walked out of his residence and passed a girl similar to myself. When I turned around, she was entering Jeffrey's residence. He no longer even tried to schedule his appointments with other girls in secrecy from me. Maybe he never did. I was too stupid to see. My world shattered. I had been so naive. I had an epiphany in a calvary of desperation. I realized I was just one of many young girls he had in rotation come to perform for him for money. I went into a deep depression and never lifted completely. I wanted to inflict pain on myself. I was humiliated, angry, and suicidal. I locked myself away from everything. I cut myself off forever from the world I had known. I endured the daily agony of knowing my life would never be the same. I could never go back to New York City and the wonderful life I had taken for granted before I met this demon named Jeffrey Epstein. This creature had manipulated and outwitted the whole system, including some of the most intelligent scientists, political people, prosecutors, and power players. How easy was it to manipulate a 16-year-old virgin who never had a boyfriend and came from a background of hardship with no parental guidance or support. I went to therapy and was given antidepressants for severe anxiety and depression. My only solace, years later, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-001001 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPS3 was my desire to succeed on my own terms. I emersed myself into my studies and was accepted to every college I applied to, graduating from a top university. To this day, there is still an ache in my being that I did not apply to Harvard in fear of his influence there. They say you never forget your first. I'm in a never-ending nightmare trying to do just that. I'm forever suffering because everything reminds me of that horror. This new wave of worldwide publicity only worsens my despair. It was only many years later that I was finally intimate with a man again, and those moments were marred by my actions as a child with Jeffrey Epstein. Even now is impossible to separate his treachery from any care of a good man. For one brief moment there was elation when he was recently arrested. I would finally get my chance to see him again face to face and show him what I had become, that I had succeeded on my own, that I was worth something in spite of his abuse, and that I had surmounted the monumental obstacles he laid before me throughout my entire life since falling prey to him. I had hoped humanity would prevail, but it seems to me that he outsmarted everyone so far, and his ghost is still laughing at us. I appeal to all of those just and true that his evil legacy and his death not stand in the way of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 83 CA/Aronberg-001002 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • 83 J8RsEPS3 was my desire to succeed on my own terms. I I em,ersed myself into my studies and was accepted to every college I applied to, graduating from a top university. To this day, there is still an ache in my being that I did not apply to Harvard in fear of his influence there. They say you never forget your first. I'm in a never-ending nightmare trying to do just that. I'm forever suffering because everything reminds me of that horror. This new wave of worldwide publicity only worsens my despair. It was only many years later that I was finally intimate with a man again, and those moments were marred by my actions as a child with Jeffrey Epstein. Even now is impossible to separate his treachery from any care of a good man. For one brief moment there was elation when he was recently arrested. I would finally get my chance to see him again face to face and show him what I had become, that I had succeeded on my own, that I was worth something in spite of his abuse, and that I had surmounted the monumental obstacles he laid before me throughout my entire life since falling prey to him. I had hoped humanity would prevail, but it seems to me that he outsmarted everyone so far, and his ghost is still laughing at us. I appeal to all of those just and true that his evil legacy and his death not stand in the way of SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CNAronberg-001002 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • • J8RsEPS3 ; i I resolution and justice for all of his underagedl victims. Thank you, your Honor. . And then just one last one, and this is much shorter. Statement of Jane Doe, also my client. I was a model in another country when I came to the United States. I was told by a booker that I needed to meet with a man named Jeffrey Epstein, who was the owner of Victoria's Secret. The booker told me that Mr. Epstein could help me get into Victoria Secret's world. It was my childhood dream to be a Victoria's Secret model. So I went one day in the afternoon and I met Mr. Epstein in his office in his mansion in New York. A woman introduced herself and suggested to me that I should be extremely nice to Mr. Epstein, because if he liked me, he would probably have photographers shooting photos of me right away. The told me to go upstairs and directed me to Jeffrey Epstein's office. Mr. Epstein had a white robe on and we chatted very briefly. I had my portfolio of photos, but he didn't even look at it. Suddenly, he took his robe off and got close to me. I got up to leave, but the door was locked. I didn't know what was going on. It was my first official meeting to be cast in the United States. I was a young girl and confused. He got very close to me, and I had a skirt on. He started to touch my genitals. I refused him. Then he went to the massage table and showed me the vibrator. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 i 84 CA/Aronberg-001003 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • J8RsEPS3 • I I resolution and justice for all of his underaged1 victims. Thank you, your Honor. 84 And then just one last one, and this is much shorter. Statement of Jane Doe, also my client. I was a model in another country when I came to the United States. I was told by a booker that I needed to meet with a man named Jeffrey Epstein, who was the owner of Victoria's Secret. The booker told me that Mr. Epstein could help me get into Victoria Secret's world. It was my childhood dream to be a Victoria's Secret model. So I went one day in the afternoon and I met Mr. Epstein in his office in his mansion in New York. A woman introduced herself and suggested to me that I should be extremely nice to Mr. Epstein, because if he liked me, he would probably have photographers shooting photos of me right away. The told me to go upstairs and directed me to Jeffrey Epstein's office. Mr. Epstein had a white robe on and we chatted very briefly. I had my portfolio of photos, but he didn't even look at it. Suddenly, he took his robe off and got close to me. I got up to leave, but the door was locked. I didn't know what was going on. It was my first official meeting to be cast in the United States. I was a young girl and confused. He got very close to me, and I had a skirt on. He started to touch my genitals. I refused him. Then he went to the massage table and showed me the vibrator. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-001003 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 85 J8RsEPS3 I took it and threw it at him. At that point, I ran to the door again and figured out how to get out of there. A girl outside asked me where I was going and she said to be careful. She said that Mr. Epstein knew a lot of powerful people, including Bill Clinton, and that if I didn't do what Mr. Epstein wanted, I would not be able to have any job in the industry. I was so scared. I couldn't wait to get out of there, and I left. I took the train home. I had spent all of my savings getting Victoria's Secret lingerie to prepare for what I thought would be my audition. But instead, it seemed like a casting call for prostitution. I felt like I was in hell. Thank you, your Honor. Thank you. THE COURT: Thank you, Ms. Allred. Was there anybody else, any victim's counsel or any of the other victims who have not been heard and wish to be heard? Well, OK then. All I have to say, really, is thank you, all of you, for your participation in today's remarkable hearing. I think everybody has benefited greatly from your input, and especially from the testimony of victims here today and who have had the courage to come forward. We have also benefited throughout these proceedings, however brief altogether, from the attorneys' legal advocacy and their written and oral submissions. I'm grateful to them SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-001004 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • J8RsEPS3 I took it and threw it at him. I •' 85 At that point, I ran to the door again and figured out how to get out of there. A girl outside asked me where I was going and she said to be careful. She said that Mr. Epstein knew a lot of powerful people, including Bill Clinton, and that if I didn't do what Mr. Epstein wanted, I would not be able to have any job in the industry. I was so scared. I couldn't wait to get out of there, and I left. I took the train home. I had spent all of my savings getting Victoria's Secret lingerie to prepare for what I thought would be my audition. But instead, it seemed like a casting call for prostitution. I felt like I was in hell. Thank you, your Honor. Thank you. THE COURT: Thank you, Ms. Allred. Was there anybody else, any victim's counsel or any of the other victims who have not been heard and wish to be heard? Well, OK then. All I have to say, really, is thank you, all of you, for your participation in today's remarkable hearing. I think everybody has benefited greatly from your input, and especially from the testimony of victims here today and who have had the courage to come forward. We have also benefited throughout these proceedings, however brief altogether, from the attorneys' legal advocacy and their written and oral submissions. I'm grateful to them SOUTHERN DISTRICT REPORTERS, P.C. ( 212) 805-0300 CA/Aronberg-001004 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 86 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 J8RsEPS3 ; i i as well, both for the government and the defense and those representing the victims. j Finally, we're also grateful to the press for their very diligent coverage of seemingly every detail of this case. That concludes our work for today and we stand adjourned. Thanks. (Adjourned) SOUTHERN DISTRICT REPORTERS, P.G. (212) 805-0300 I CA/Aronberg-001005 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 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 • J8RsEPS3 as well, both for the government and the representing the victims. • i I I defensi2 I ! 86 and those Finally, we're also grateful to the press for their very diligent coverage of seemingly every detail of this case. That concludes our work fo~ today and we stand adjourned. Thanks. (Adjourned) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-001005 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Appendix 12 CA/Aronberg-001006 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • Appendix 12 CA/Aronberg-001006 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The Balm Beach Post REALNEWSSlAMS HERL ■ The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and underage girls By Andrew Marra Posted Jul I?’ 2019 at 6:02 AM From the archives: When Palm Beach detectives started asking questions and teenage girls started talking, a wave of legal resistance followed. Editor s Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after Jeffrey Epstein's arrestin Palm Beach County on a charge offelony solicitation ofprostitution. WINGED GARGOYLES guarded the gate atJeffrey Epstein’s Palm Beach mansion. Inside, hidden cameras trolled two rooms, while the girls came and went. For thepolice detectives, who sifted through the garbage outside and kept records ofvisitors, it was the lair of a troubling target. Epstein, one of the most mysterious of the country’s mega-rich, was known as much for his secrecy as for his love of fine things: magnificent homes, private jets, beautiful women, friendships with the world’s elite. But at Palm Beach police headquarters, he was becoming known for something else: the regular arrival of teenage girls he hired to give him massages and, police say, perform sexual favors. Epstein,was different from most sexual abuse suspects; he was far more powerful. He counted among hisfriends former President Bill Clinton, Donald Trump and Prince Andrew, along with some of the most prominent legal, scientific and.business minds in the country. When detectives started asking questions and teenage girls started talking, a wave of legal resistance followed. CA/Aronberg-00.1007 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • 'The· .:Ma n,::.who ;Had ,iEver. 7:th'in•· . : -J ef:frtr : E ----stein :cr;aved:•ibl ··; .. , ... ~- - - . . ... - . .. ,Y. .. . - ,8 . .. ...... Y ,It . -. . . .__ . , . ... . . g homes; elileJri.ends .:and:::tntd·e~agp•,;girls By:Andre~ Marra Posted Jul ff201·9.at 6:02 AM From the _archives: When Palm Bea.ch detectives started asking questions .and teenage girls started talking·; a wave of legal resistance followed. Editor's.Note: This article appeared iri 'the Palm B_each Post on August 14, 2006, three weeks after Jeffrey Epstein's arrestiri Palm Beach County on a charge. offelony solicitation of prostitution. WING ED GARGOYLES guarded the _gate at Jeffrey Ep~tein' s- Palrp. Beach J!la11si9n, Inside, hidden cameras trolled two roorns, while.th~, girls came and went. :For the·pohce dete_ctives. who sifted through the garbage outside·and kep~ records of visitors, it was the lair ofa troubling target. Epstein, one of the most mysterious of the cchmtry's mega-rich, was'known as much for his secrecy as for hi_s lovl:! 0Jfi\1e things: :magpifi<;:ent homes, privc1te jets, beall.tiflll vyom~n, friendships with.the: world's elite . . But at Palm Beach p_olice headquarters, he was becoming: known for something else: the regular arrival of teenage girls he .hired tq give him ma,mlges and, police say, perform sexual favors .. Epstein was different from most sexual abuse suspects; he was far more powerful. He. counted among his,friends former President B'ill Clinton, Donald Trump and Prince Andrew, along with some·ofthe most prominentlegaJ, sc:ientific and business minds in t_he country. When detectives started.askin:g questions and teena,ge:girls started talking, a wave oflega.l resistance followed. CA/Aronberg-00.1007 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM » NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work- release If Palm Beach police didn’t know quite who Jeffrey Epstein was, they found out soon enough. Epstein, now 53, was a quintessential .man ofmystery. He amassed his fortune and friends quietly, always in the background as he navigated New York high society; When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In.a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love,” the British Mail on Sunday tabloid laid out speculative stories that the socialite’s beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?” the newspaper wondered. “Like Maxwell, Epstein is both flamboyant and intensely private.’’ The media frenzy did not begin in full until a decade later. In September 2002, Epstein was flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to Africa on his private jet. I Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair published lengthy profiles. The New'York Post listed him as one of the city's most eligible bachelors and began describing him in.its gossip columns with adjectives such as “mysterious” and “reclusive.” Although Epstein gave no interviews, the broad strokes of his past started to come into focus. Building a life ofextravagance He was born blue-collar in 195'3, the son of a New York City parks department employee, and raised in Brooklyn’s Coney Island neighborhood. He left college without a bachelor's degree butbecame a math teacher at the prestigious Dalton School in Manhattan. The story goes that the father of one of Epstein’s students was so impressed with the man that he put him in touch with a senior partner at Bear Stearns, the global investment bank and securities firm. CA/Aronberg-00.1008 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • » NEW: JeffreyEpstein: Lawyer said financier had sex with woman duringwork- .,··.·.-.--.----···•···· .. ,·-:i-• .. ,.. ~-,-· , .. _ . .,. ........ -....!"·~•-:4. ~-:,,_• •.. ~--·'!'"'.' .... ""!">-.2'.- ~-C'•·•.-.- ✓, ;-• .• , .. _,._.: •• ~·--~----. • .. •·-i"""!'°.-~- '. ... ;0 ..... - release IfP;i_hn Beach polic_e didn't know quite who Jeffrey Epstein was, they fou11d out soon. enough. Epstein, now SJ, was a quintessential.man of mystery. He amassed his -fortune and friends quietly, always in the background.as he navigated New York high society. When he flr~tattr.i,cted notice in the early 19.90s, itwas on account of the woman he was dating: Cihislaille.Maxwell,da\lght_er of the l;i.te J3ritish media tycoon Robert Maxwell, In.a len~thy article, headlined 'The Mystery of Ghislaine Maxwelfs-SecretLove," the British Mail ort Sunday tabloid laid out speculative stories that the socialite's beau was a CIA spook, a ·math tea~her, a concertpianist or a corporate headhunter, "But what is the truth about him?" th~ newspaper wondered .. "Lik~ Maxwell, Epstein is. both flamboyartt .and intensely private." The media freniy did not begin in full until a decade later: Ih September 2002-, Epstein was flungt~to the limelight when hefle\V Clinton and actors Kevin Spacey and Chri~ Tucker to Africa on his private jet. Suddenly everyone wanted fo know who Epstein was. New York magazine and Vanity Fair pt1.J:>Jt~~9:L~n.~J'D.YJ>i:.<?files. The New-York Post listed him as 6ne ofthe city's most'eHgible bachelors a,1,1d bega11 descdbi11g him in.its _gossip columns whh adjectiy:es such as "mysterious" ·and "reclusive." Although Ep·stein ~ave~ointerviews, the·.broad'strokes of his past started to come into focus; Building a life of extravagance He was born blue-collar '.in 195J, the son ofa New York City parks department employee, and raised in Brooklyn's Coney island neighborhood. He feft college without a bachelor's degree but became a math teach et at the prestigious' Dalton 'School. in Manhattan. The story goes that the father of orie of Epstein's students was so impressed with the man that he pud;1imfo toµch whh a seruqr p~:rtne.r at Bear St~arns, the global_jn.ve~tmeIJ.t bank and secur'ities firm. CA/Aronberg-00.1008 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J. Epstein and Co. That is when he began making:his. millions in earnest. Little is known or said about Epstein’s business except this: He manages money for the extremely wealthy. He is said to handle accounts only of $1 billion or greater. It has been estimated he has roughly 15 clients, but their identities are the Subject of only speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a former Palm Beacher who is said to have been a mentor to Epstein. Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a block on Manhattan’s Upper East Side. It is reported to have, among its finer features, closed- circuit television and :a heated sidewalk to melt away fallen snow. That townhouse, thought to be the largest private residence in Manhattan, is only a piece of the extravagant world Epstein built over time. In New Mexico, he constructed a 27,OOO-square-foot hilltop mansion on.a 10,000-acre ranch outside Santa Fe. Many believed it to be the largest home in the state. In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre private island in the Virgin, Islands. » PHOTOS: The players in the Jeffrey Epstein saga Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at the highest echelons of power. This includes not only socialites but also business tycoons, media moguls, politicians; royalty and Nobel Prize-winning scientists whose research he often funds. "Just like other people collect art, he collects scientists," said Martin Nowak, who directs the Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of a $30 million research donation from Epstein. Epstein is said to have befriended former Harvard President Larry Summers) prominent law Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort Zuckerman. CA/Aronberg-00.1009 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • . . . . . I In 1976, Epstein left Dalton.for ajob at Bear Stearns. By·the early 1980s, ~e had started]. Epstein and Co. That is when he 'began making his. millions in earnest. Little·is known or said abo.ut Epstein;s b.usin:ess except this: He manages m:oneyfor the extremely wealthy. Heis said to handle accounts only:of$J billion or greater. It has been estimated he has-roughly 15 clients, but :their identities are the subject of only speculation. All except-for one:Leslie, Wexne,r,fot!nder ofThe Limited retail chain and.a former Palm Beacher who is said tOhave·been a mentor to Epstein•. W exner sold Epstein o:ne of his most lavish-reside:n·ces: a: massive townhouse that dominates a: block on Manh<!ttan's Uppei:- East Side,. Jt is reported to h.J,,ve, ~un.ong·its. finer features! dosed- circuit television and;a heated sidewalk to melt awayfallen snow. That townhouse, thought to be the largest :private r-esidence in Manhattan, is only a piece of the-extravagant world Epstein built over time. In New Mexico, he constructed a.27,noo-square-foothilltop mansion on.a· lO!0QQ..,acreranch qutside Santa Fe. Many l>elievedjt tQ be0the largest home In the state, in Palm Beach, hebought a waterfront hom·e on E1Brilio Way. And he owns a 100-acre ·private· island:inthe Virgin Islands. Perhaps as remarlcable as his tav1.sh homes is_ hts extensive network of fdends and as.sociates at the highest echelons of power. This includes not only s.o:cialites but also business tycqons, media moguls, politicians; royalty and Nobel Prize-'Winhing scientists whos·e research he often fon~s. "Justlike o_ther people coH<:!ct:,1rt, 11e cc,llects scientists," said Martin Nowak, wh9 directs the Program for Evolutionary Dynamics at Harvard University and ·was r~p:ottedly·the rec~pient of .a $30 million ,research donation from Epstein . .Epstejn :is said t9 have btJrien,ded former Barvard President Larry S~inmers, ·prominent I_aw 'Professor Alan Dershowitz, Donald Trump and.New York Daily News Publisher-Mort Zt1ckerinan. CA/Aronberg-001009 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM And yet he managed for decades to maintain a low profile. He. avoids eating out and was rarely photographed. "The odd thing is I never met him/’ said Dominick Dunne, the famous chronicler of the trials and tribulations of the very rich. “I wasn’t even aware of him/’ except fpi; a Vanity Fair article.. Epstein’s friendship with Clinton has attracted the most attention. Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become close friends until after Clinton left the Oval Office and moved to New York. Epstein-has donated more than $1 00,000 to Democratic candidates’ campaigns, including John Kerry’s presidential bid, the reelection campaign of New Mexico Gov. Bill Richardson and the Seriate bids ofJoe Lieberman, Hillary Rodham Clinton, Christopher Dodd and Charles Schumer. Powerful friends and enemies A Vanity Fair profile found cracks in the veneer of Epstein’s fife story. The 2003 article said he left Bear Stearns in the wake of a federal probe and a possible Securities arid Exchange Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20 million loan. The article suggested that one of his business mentors arid previous employers was Steven Hoffenberg, riow serving a prison term after "bilking investors out ofmore than $450 million in one ofthe largest Ponzi schemes in American history." As he amassed his wealth, Epstein made enemies in disputes both large and small He sued the man' who in 1990 sold him his multimillion-dollar Palin. Beach home over a dispute about less than $16,000 in furnishings. A former friend claimed Epstein backed out of a promise to reimburse him hundreds of thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein owed him nothing. » Jeffrey Epstein: Model prisoner who swept, mopped floors, official says CA/Aronberg-00.1010 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • And yet he managed for decades to maintain a low profile. He.avoids eath1g out and was rareiy 'Photographed. "The odd:thinJ:l; is I never met him," said Dominick Durtile, the famous chronicler of the trials and tribul,ations ofthe·very rich'. <fl wasn't eve;n aware of him," except for; a Vanity Fair arti<:le., Epstein's friendsh~pwith Clinton has attra_cted the mostattention. Ep~tei,1 met Clinton as early :is 199 5, when he paid: .tens o:f thousands of dollars to join him at ail'iiltimatefond-:raising dfort·er iriPalrri Beach. But from all appearances,theydid not become close friends until afrer'C:linton left the Qv<1,l Office and mqyed to New York. Epstein:has qo_nat_ed more than $100,0Q0 to Democratic,candidatef c_ampa:igns1includingJohn - • . . K'er-r-y's presidential bicl; the reelection campaign of New Mexico Gov. Bill Richardson and the Se hate ·bids of Joe Lieberman, Hillary Rodhain Clinton, ChristopherJ)odd, and Charles Schumer, P9werfql friends_ ~nd enemi~s A Vanity Fair profile found cracks :in the veneer of Epstein!s life ·story. The· '2003 article said he left'B;;;st;;;o";iri"t:he Wake ,of a federal probe and a .possible Securities artd Exchange Commis,sion violation. It ~lso pointed out that Gtiba,;nk 01;1ce sJJJ;~d him for defaulting on ;i, $20 million lo,an. The a:rtide suggested that one of his business mentors ·and previous employers was Steven Hoff en berg, riow serving a prison term after "bilking investors out of more than $450mill.ion in one of th_e la_rgest Ppnzi ,schemes in A:merlcan hfstory." As he amassed his wealth, Epstein made enemies in disputes both large and smalL He sued the man· who in 1990 sold him his-multimillion-dollar Palm Beach home over a dispute about'less than $16,000 in furnishings. A foi:m~r friend cJaJmed Epst~in ,bac:ked~ qpt of a promise to reimburse him hundreds of thousands of dollars_ atter their failed.investment in Texas oil wells. A judge decided Epstein owed him nothing. » Jeffrey Epstein: M~deJ prisoner ':Y:ho,s-yv-ept, lll_opped:f19(}rs, ofijci~l, s~y~ ••• ,.;, .......... , ••• - • • •v - • - •••• - ,.:.: : - •• • •••••• • - • •• ••• - • ,.-.~..:.: .. :;:,;.;.;,-...::~ ...... ~.: •• ;.:;.:.:._;_ ·-·- _,. -_. -.-,--. - , - ·.-•• : •• ;..:.:. ;.: • ...:..~;~..:..:.,!:.:.:.: .•. :-..::C .. "'~:..;i .... ·.~:::~:;"~!-.,..,:. CA/Aronberg-00.1010 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM “It’s a bad memory. I would rather not have ever met Jeffrey Epstein,"said Michael Stroll, the retired former president ofWilliams Electronics and Sega Corp. “Suffice it to say I have nothing good to say about him.” Among the characteristics most attributed to Epstein is a penchant for women. He has been linked to Maxwell, a fixture on the high-society party circuits in both New York and London. Previous, girlfriends are: said to include a former Ms. Sweden and a Romanian model. "He’s a lot of fun to be with,” Donald Trump told New Yorkmagazine in.2002. “It is even said that he likes beautiful women,as much as I do, and many of them are on the younger side. No. doubt about it, Jeffrey enjoys his social life.” Investigation leads to Epstein Although he was not a frequenter of the Palm, Beach social scene, he made his presence felt. Among his charitable donations, he gave 590,000 to the Palm Beach Police Department and $ 100)000 to Ballet Florida. In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a green Harley-Davidson,. His jet waited at a hangar at.Palm Beach International Airport. At home,,a private chef and a small staff stood at the ready. From a window in his mansion, he could look out on the Intracoastal Waterway and the West Palm. Beach skyline. He seemed to be a man who had everything. But extraordinary wealth can fuel extraordinary desires. >> Epstein wants to leave jail for mansion in sex-trafficking case In March 2005, a worried mother contacted Palm Beach police. She said another parent had overheard a conversation between their children. Now the mother was afraid her 14 year-old daughter had been molested by a man on the island. The phone call triggered an extensive investigation, one that would lead detectives to Epstein but leave them frustrated. CA/Aronberg-001011 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • "It's;abad memory, I wol!ld:r_ath_er:npt have ever metJeffrey'Epstein," said Michael Stroll, the • ' retired former president of Williams. Electronics and. Sega Corp. "Suffice; it"to sayl have nothing good to say about him." Among the characteristics most attributed to .Epstein is a peri.diantfor women. He has been Hilk~d to _M,rxweU, ;,1 fixtµre op the high,-society p,arty cJ.r:cuit_s in both New York and London. Previous girlfriends are. said 'fo in dude a former Ms. :Sweden and a Romanian model. "He's a lot of fun to be with," Donald Trump told New York:magazine in 2002. "It is even said .,, ... , .. that h!:? lik~s beautifµl women as_ mµc;:h as I po·~ ~q._ II1any qf \hem are on t_he yoµnger sid_e. No, doubt about it,Jeffrey enjoys his social life;" lnvesti~atioh leads to Epstein Although he was not a frequenter of the Palm Beach social scene, he made his presence felt. Among his ch;irit;ible donatio_ns;. he gave $90,0Q0 to the Pa,lm B!;?c:1.Gh PoHc;e Dep;ir,t:ment and . .. $100,QOO· to Ballet_ Florida. 1h Palm ,Beach, he liv:ed in luxury. Three black Mercedes sat in his garage; alongside a green Harley-Davidson,, His jet waited at a hangar at .Palm Beach International Airport Athome,, a pdvate chef and a small staff stood atthe ready. From a, window 111. _his mansion, he could lo.ok out on thl:! Intracoasta1' Waterway and ,the West Palm. B.each skyline. He seemed to be a man who had everything. But extraordinary w~al-tli can fuel extrc:1.ordinc:1.ry desires. » ~pstein wantst_ole_avejail.for_mansion m.sex-traffickingcase :-:: ...... --:::.,:: -~· -~- -•;- -_ : ••. : :-:-::: ·'.--:::. <: :-: :: '.:. ... ; ~.: :,,. ' •.. :--, .. , .. :,, =·--•' .••. -:_-.... • ~-........... ·- ... '.~: .•: . _,_ - •• • -',, ... _··:. >:·. _.::-.:-✓ -_: r.. .' __ -:.,-. ____ .-· --· _·_ In March 2005, a worried mother contacted Palm Beach police. She said another parent had overheard a conversation between their children. Now'tl:i~ mofher yvas:afraid h~r 14-year-old daughter had been DJ.oksted by a Inan 011, the island. The phone cail triggered a:n extensive investigation, ·one that would lead detectives to Epst¢in but leave them frustrated. CA/Aronberg-001011 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Palm Beach police and the state attorney's office have declined to discuss the: case,. But a Palm Beach police report.detailing the criminal probe.offers a window into what detectives faced as they sought to close in on Epstein. Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to perform a massage. She said the: friend told her to say she was 18 if asked. At-the house, she said she was paid $300 after stripping to her panties and massaging the: man while he masturbated. Police interview 5 alleged victims The: investigation began, in full after the girl identified Epstein in a photo as the man who had paid her. Police arranged for garbage trucks to set aside Epstein’s trash so police could sift through it. They set up a video camera to record the comings and goings at his home. They monitored an airport hangar for signs of his private jet’s arrivals and,departures. They quickly learned that the woman who took the 14-year-old girl to Epstein’s house was Haley Robson, a Palm Beach Community College student from Loxahatchee. In a sworn statement at police headquarters. Robson, then 18, admitted she had taken at least six girls to visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said. During the drive back to her house, Robson told detectives, “I'm like a Heidi Fleiss." Police interviewed five alleged victims and 17 witnesses. Their report:shows some of the girls said they had been instructed to have sex with another woman in front of Epstein, and one said she had direct intercourse with him. In October, police searched the Palm Beach mansion. They discovered photos of naked, young- looking females, just as several of the girls had described in interviews. Hidden cameras,were found in the garage area and inside a clock on Epstein's desk, alongside a girl’s high school transcript. Two of Epstein's former employees:told investigators that young-looking girls showed up to perform massages two or three times a day when Epstein was in town. They said the girls were permitted many indulgences. A chef cooked for them. Workers gave them rides and handed out hundreds of dollars at a time. CA/Aronberg-00.1012 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • . I - Palm Beach police and the· state attorney'.s office have deqlined to discuss 1;he. case .. But a Palm I Beach police reportdetailing·the criminal probe offers a window into what _detectives faced as they·sought to close in on Epstein. Detectives, i_ntemewed the gir:l, w_ho told th_em a friend had invjted her to a rich man's house to perform a massage. She said the: friend told he_r to say she was 18 if asked. At- the house, she said she. was ·paid $300 after Stripping to her-panties and massaging the: man while he ma~turbated. Police interview:5 alleged victim~ The investigation began. in foll after the gid identified Epstein in a photo as the man who had paid her: Police artangedfor garbage trucks to set aside Epstein's trash so:police.could sift th,roµgh iJ. They set µp a videp camera lQ record the comings and goings at his home. They monitored an airport:ha.ngar for signs ofhis privatejet's arrivals and,departures. They quickly learned that the Woman who took the 14-year-old girl to Epstein's house wa·s Haley Robson, a Palm Beath Comm.unify College student from Loxahatchee. In· a sworn st;itement at pohc:e ;he;iciqua.rters, Robson, tl:ien 18, admitted she had taken at least six girls to visitEpstein, all between the ages of14 andl6. Epstein paid.her f,oreach.visit,aShe said. During the drive back to her house,Robson told detectiv.es, ;'I'm like a Heidi Fleiss." Police interviewed five alleged victims and 17 Witnesses: Their repor.t shows some of the girls said they had beeninsJn1cted tohaye sexwithanother woman in front of Epstein, and one said she had direct intercourse with him. In October, police seat.che_d the Palm Beach mansion. They discovered photos of naked, young- looking females, just as several of the g"irls had,desttibed in interviews. Hidden cameras.were found in the garage area aJ1d insid!:! -<! dqck cH:i Eps~eh:i's d\:!sk, alongsic:le. a., gi,rl's_ "high ~chool transcript. Two of Epstein's former employees told investigators that young-,looking ~ids showed up to perform massages two or three times a day when Epstein was irit6Wh. They said the girls-wer~ permitted ma_nyfodulgenc_es. A chef cooked for them. Workers gave them rides and.handed out hundreds of dollars ata time. CA/Aronberg-00.1012 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM One employee told detectives he was told to send a dozen roses to One teenage girl after a high school drama performance. Others were given rental cars. One, according to police, received a -$200 Christmas bonus. The cops moved to cement their case. But as they tried to tighten the noose, they encountered other forces at work. In Orlando they interviewed a possible victim who told them nothing inappropriate had happened, between her and Epstein. They asked her whether she had spoken to anyone else. She said yes, a private investigator had asked her the same questions. » Jeffrey Epstein: Acosta, Krischer trade barbs oyer sweetheart deal When they subpoenaed one of Epstein’s former employees, he told them the same thing. He and a private eye had met at a restaurant days earlier to go over what the man would tell investigators. Detectives received complaints that private, eyes were posing as police officers. When they told Epstein’s local attorney, Guy Eronstin, he said the investigators worked for Roy Black, the high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William Kennedy Smith. While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law professor, traveled to West,Palm Beach with information about the girls. From their own profiles on the popular Web site.MySpace.com, he obtained copies of their discussions about their use of alcohol and, marijuana. He took his research to a meeting with prosecutors in early 2006, where he sought to cast doubt on the teens' reliability. The private eyes had dug up enough dirt on the,girls to make prosecutors skeptical. Not only did some of the girls have issues with drugs or alcohol but also some had criminal records and other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she told police she was younger than 18 when she started performing massages for Epstein, After the meeting, prosecutors postponed their decision to take the case to a grand jury. CA/Aronberg-001013 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • • ' One em,ployee told detectives he was told to send a dozen roses to one te·e'nage gi:rlaftet a high • I school drama performance. Others were given rental car's. Orte, accordin~ to police, received a '$200 Christmas b9nlls.. The cops .moved t9 cemenJ their case. But as they tried to tighten the noose, they .encountered other forces. at work. In Orlando they interviewed a possible victim who told them nothing inappropriate had happened. between her and Epstein. They askecl her whether she ba~ spoken to anyone else. She s.aid yes, a private inyestigator:had asked her the same qu_estions. » Jeffrey Epstein: Acosta, Krischer trade barbs over.sweetheart deal ,.,;.~';;.::;;:~_:,~.':.·•·~--,_.;.f;",:,::;.;: .. ..;.,',"/.';.!:~,"";,~;;-.~_::~!,;,;;.!:;h' •••• --_•--•·•~.•,_.., ,.>•-··-~;~:_',;_;._-_,---,.;;;;:/- •••••• ·-~ - :··-~·-· .,, ••.•• ·.,-.<·, :•··.•• .... ,.,,,..,.~_-,'. •• :-· • •~~~~-~·.:.:.';-.:•,,:~.-:.'.. When they subpoenaed one of Epstein's former employees, he told ·them the same thing. He and a, private eye _had, met at a restaur;mt. days earlier to go over what the m;m would tell investigatofs. Dete¢tives received compia:ints that private eyes were posing as police officers. When they told Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the· high-p~Jv,ered M1arni lawyer who has defended the 1ikes ofRush Limbaugh 1and William Kennedy Smith. While the private eyes were conducting .a parallel investigation, Dershowitz, the Harvard law professor, tr'aveledtb WestPalrh Beach with information about .the ,girls. From their own profiles on the popular Web site IvlySpace.com, he obtained copies of thei'r discussions about their use of aicohol arid, marijuana. He took his research to a meeting with prosecutors. in early 2006, ,vhere he soughuo cast doubt qnthe teens' i:eliability .. Tbe. private ~yes had d1,1g ·up. enough dirt o.n the, g·irl_s to make proseq1tors skepticaL Not only did some of the giris 'haye issues·with drugs or a:kohol but a:lso some .had criminal records a'nd other troubles, Epstein's le$al team claimed. And at least one of them, they said, lied when ,she told police she w::i.s younger th~i:i 1.8 w}.J.en she st~rted performing ma~sag~s for Epstein. After the meeting, prosecutors postponed their decision to take the case to a grand jur-y, CA/Aronberg-001013 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM In the following weeks, police received complaints that two of the victims or their families had. been harassed or threatened. Epstein s legal team maintains that its private investigators did nothing illegal or unethical during their research. By then, relations between police and prosecutors were fraying. At a key meeting with prosecutors and the defense, Detective Joseph Recarey, the lead, investigator, was a no-show, according to Epsteins attorney. "The embarrassment on the.prosecutor’s face was evident when the police officer never showed up for the meeting,” attorneyJack Goldberger said. Later in April, Recarey walked into a prosecutor’s office at the state attorney’s office and learned the case was taking an unexpected turn. The prosecutor, Lanna Belohlavek, told Recarey the state attorney’s office had offered Epstein a plea deal that would not require him to serve jail time or receive a felony conviction. Recarey told her he disapproved ofthe plea offer. The deal never came to pass, however. Future unclear after charge On May 1, the department, asked prosecutors to approve warrants to arrest Epstein on four counts ofunlawful sexual activity with a minor and to charge his personal assistant, Sarah Kellen, now 27, for her alleged role in arranging the visits. Police officials also wanted to charge Robson, the self-described Heidi Fleiss, with lewd and lascivious acts. By then, the department was frustrated with the way the state attorney’s office had handled the case. On the same day the warrants were requested, Palm Beach Police ChiefMichael Reiter wrote a.letter to State Attorney Barry Krischer suggesting he disqualify himselffrom the case if he would not act. Two weeks later, Recarey was told that prosecutors had decided once again to take; the: case to the grand jury. CA/Aronberg-00.1014 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • Ju, the following weeks, police receive.cl complaints that two of the VIctJ.ms or their fami11es h<!d been harassed or threatened. Epstein's legal team .maintains that its privat'.e investigators did 1:i.oth111g HlegaJ or unethical during their research. By then, relation~ between p9li~e and prosecutors were fraying. At a key meeting with prosecutors and the defense, Detective Joseph Recarey, the 1eadjnvl:!stigator, was .a no-show:, according to.Epstein's attorney. "The emparrass_ment on the.prosecutor's face was e:videntwhen the.police officer never showed up for the meeting," at_torney Jack Gqldberger sajd. Later in April, Recarerwalked into a prosecutor's office.at the stateattorney'.s 9ffice and leani.ed the case was takih& ari unexpected turn. The prosecutor, Lanna Belohlavek, told.Recarey'the state attorney's office had offered Epstein a plea deal that would, not req11ire him to serve jc1il time or receive ,c1 felony conviction. Recarey told her he disapproved of the plea offer, The .deal never came to pass, however. Future unclear after charge On May 11 the department asked prosecutors to approve warrants to arrest Epstein on four counts of unlawful sexu.al actiyity witl_l a minor .a11d to ch~rge his person41 a~sistant, Sarah Kellen, n·ow 27, for her alleged role in arranging the visits. Police officials also wanted to charge Robson, the self.:describe·d.Heidi Pleiss, with lewd and lascivious acts. By:·the11, the department was frustrated with the way the state attorney's office had handled th·e case. On the same day the warr;:mts were requested, P·:ilm Beach Police Chief Michael Reiter wrote ·a.letter to State Attorney Barry Kris ch er suggesting he disqualify·himself from the case if he, woul.d ;not act, Two weeks ,la,ter, R:e_carey was. t_olci th.at pro~ect1tors had decided :once again to take. the case to the grand jury. CA/Aronberg-00.1014 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM It is not-known how many of the girls testified before the grand jury. ButEpstein's defense team said one girl who was subpoenaed- the one who said she had sexual intercourse with Epstein - never showed up. ’ The grand jury’s indictment was handed down in July. It was not the one the police department had wanted. Instead ofbeing slapped with a charge of unlawful sexual activity with a minor, Epstein was charged with one count of felony solicitation ofprostitution, which carries a maximum penalty of five years in prison. He was booked into the Palm Beach CountyJail earlyJuly 23 and released hours later. Epstein’s legal team ''doesn’t dispute that he had girls over for massages,” Goldberger said. But he said their claims that they had sexual encounters with him lack credibility, "They are incapable of being, believed,” he said. “They had criminal records. They had accusations of theft made against them by their employers. There was evidence ofdrug use by some of them.” What remains for Epstein is yet to be seen. The Palm Beach Police Department has asked the FBI to investigate the case. It also has returned the $90,000 Epstein donated in 2004. In New York, candidates for governor and state attorney general have vowed to return a total of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein’s powerful friends haye.remained silent as tabloids and Internet blogs feast on the public details ofthe police investigation. Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future plea deal, He insists Epstein will emerge in the end with his reputation untarnished, “He will recover from this,” he said. Staff writer Larry Keller and staff researchers: Bridget Bulger, Angelica Cortez, Amy Hanaway and Melanie Mena contributed to this story. [email protected] I I CA/Aronberg-001015 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • It is not known l10wmany of the girls testified before the grand jury. But;:gpstein's defense team said one girl who was subpoenaed. - the one who said she had sex:ual intercourse with Epstein - never showed up. The graJ}d j.uris indictroent was handed down, iJ1 Jµly. It was not the one the police department had wa,nted. Instead of being slapped with a charge ofunlawful sexual activity with a minor, Epsteinwas charged with. one count of felony scilicitatiori of prostitution, which carrie~ a maxiroum penaJty of fiye yeax~ jn prison. liew11s bqoJced int.a tlwPal111 Bea:ch Cg.unty J.1.il early July 23 and released hours lateL Epstein's legal team''doesn't dispute that he.had girls oveYfor massa_ges," Goldberger said. But he ·said their clai'ms that they had. sexual encounters wit:h hiITI lack credibility .. ''They are• incapable of being. believed," he said. ''They had crimfn~ :records. They had accusations of theft made against them by their: employers. There was evidence of drug use by some of them." What remains for Epstein is yet to be seen. The Palm Beach Police Department has asked the. FBlto investig_ate the cas.e. It also has ret11rned the $90,00Q Epstein donated in. 2004. In New York, candidates for governor and state attorney general have vowed:to return a total ofatleast $60,000 :in campaign contributions from Epstein. Meanwhile; Epstein's powerful friends haye remained silen1 as ta,blqids, c1.nd Internet biogs fe_ast on tl}e public. details of the police investigation. Goldberger maintains Epstein's innocence but says the legal team has hot ruled out a: future plea deal.He insists Epstein will emerge in the end with:his reputatiqp. urgar:nished. "He wiH recover frgm thi~," he $aid. Staff writer Larry Ke/ler a.ncl staff researchers Bridget Bulger; Angeli.ca Cortez, ,Amy Hanaway and Me'Ianie Mena contributed to .this story. amarra@pbpost;com ...................................................... _ ... , ......... . CA/Aronberg-001015 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM @AMarraPBPost CA/Aronberg-00.1016 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • @AMarraPBPost CA/ Aronberg-0O1016 w lfLij:. • FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 273 / 278 - Tuesday, November 16, 2004 Edition:- FINAL Section: A SECTION Page: 1A Source: By PAUL OWERS Palm Beach Post Staff Writer Illustration: PHOTO (C & 2 B&W):& MAP (B&W) Memo: Ran all editions. Dateline: WEST PALM BEACH TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION When it came time to bid Monday for the palatial Palm Beach digs ofAbe Gosman, The Donald was not about to be trumped. "Nobody was going to outbid me," the brash developer-turned-TV-personality said from his New York office. Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along the storied "Raider's. Rovz." But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at 513 N. County Road. He wants to. - what else? - sell it and make more money. The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super luxury house" that would be the "finest anywhere in the United States?' He might build another house before .flipping the entire package. "I've known about this house for quite some time," Trump said. "It's probably the best piece of land in Florida - and probably the country - for luxury real estate." Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith said she's not worried about Trump’s plans. "He's been a very good property owner in the town of Palm Beach," she said. "He does his projects very well. He's a perfectionist." Monday's auction took place at U.S. Bankruptcy Court in West Palm.Beach as part of Gosman's Chapter 7 bankruptcy case. Proceeds, from the sale;will go into escrow for eventual distribution to creditors. The: auction began at. exactly noon after Judge Steven Friedman dismissed an objection from an attorney representing money manager. Jeffrey Epstein. The lawyer argued unsuccessfully that Trump was not a qualified bidder .because .his contract stipulated that he would.not close on the sale unless title insurance was in place beforehand. With Trump listening via conference call, Epstein began the bidding at $37.25 million. - $250,000 higher than Trump's initial offer. Mark Pulte, son of the founder-of home-building giant Pulte Homes, passed when his turn came, letting lawyers forTrump; and Esptein bid against each other untilthe pricehit $38.85 million. Pulte then bid $39.1 million, briefly raisi'ng the ire of Trump,. who believed that Pulte had given up his right to bid by passing the; first time. CA/Aronberg-00.1017 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • 273 / 278 -Tuesday, November 16, 2004 Edition:- FINAL Section: A SECTION Page: lA Source: By PAUL b\1/ERSPalm Beach Post Staff Writer Illustration: PHOTO(C& 2 B&W):& MAP·(B&W) Memo: Ran all e.ditions., Dateline: WEST PALM BEACH TRUMP SNAGS GOSMAN ESTATE FOR $41:MILLION • When it came time to bid Monday fodhe palatial Palm Beach digiHJf Abe Gosman, The Donald was not about to be trumped:. '!Nobody was going to outbid rrie,'' the brash developer-tumed-TV-petsohality·said ·from .his New York offke. , • Trump bested two othetbiddets with a- 0$41.35 million .offer for the 43;00'0-square-foot, seven-bedroom estate on 6 oceanfront:acres along the storied "Raid~r's Row:11 But Trump, .5 8, proud possessor of.Mar-a-Lago, has, no plans to live in the Gosman home at 513°,N. CountyR:oad, He wants to. -what el~e? - s_ell it and make more money. The star ofthe·mega-fot The Apprentice said he intends to redevelop the site into a '"super luxury h911se" thatwpuld be the "finest anywhere in.the United States;" He might build· another ha.use before ;flipping the entire package. "I've known aboµtthis house for quite s.ometime," Trump said. "It:s probably the best piece ofla:ndin Florida ... and probably the couritry - fot luxury teal-estate." Although Trump. said he co:uld subdivide the property into nine lots, Palm Beach Mayor Lesly Smith sa:idzohing regulations allow for only two houses --and maybe a third. Smith saig she's not worrieci .about Trump'.s plans; "He!s been a very good property owner in the town of Palni Beach/' she said. "He does his projects veryweil. His a pe1'fectioriist." Monday's auctiorrtook place at U.S. Bankruptcy co-urt,in West Palm.Beach as part of Gosman's Ch Apter 7 bankrnpJcy case. Pr.oceecls from the· sakwiil go- into escrow for eventual distribution to creditors. The auction began at exactly_noon ,after Judge Steven Friedman dismissed an-:objection,from an atto111ey reptesehtihg rnoney rnanaget. Jeffrey Epstein. The lawy~r ~rgµeci unsl,lcces!lfuHy that Trump· was .not a qt.ialified bi cider .beca_use .his contract stipulat~d that he would.not close on the sale unless title insurance was in place beforehand. With. Trump listening via conference call, Epstein began the bidding at$3 7.25 mill ion. - $250,000 higher than Trump's initial offer. MarkPulte, son of the founder-of home-building-giant Pulte Homes, passed when his tum came, letting lawyers for Trump;anc:l EspteiI1 bid against eac_h other unti1 1the pric:e:hit $38.85 million. • Pulte then bid $39 .1 million, briefly ra~sing·tl}e ire of Trump,,who: _believed that Pulte hacl given up his right to bid by passing the: first time. CA/Aronberg-001017 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM But Friedman allowed the offer to stand, and Pulte and Trump went back? and forth until Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at $38.6 million. Friedman closed the bidding 10 minutes after it started, leaving Trump with the fight.to buy the 29,000-square-foot home (a typical Palm Beach County single-family house is about 2,200 square feet). The property .also has a tennis house, a pool house and 1930s-era service quarters. The closing.could take place within a week but probably won't happen until next month. Trustee Joe Luzinski and creditors said they were pleased with the outcome, "We knew we were dealing with some substantial people . ,. who were going to bid it up a bit," Luzinski said. "The system worked," said Charles Tatelbaumj a lawyer for creditor JPMorgan Chase Bank. "In bankruptcy court, the idea is to get the-most for creditors, and that's what happened;" The auction proved to be a bonanza for creditors, Luzinski said, noting that,the highest offer former listing agent Sotheby's International Realty received was $32 million, Sotheby's won't receive a commission, he said. Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday, "I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said. Pulte said Gosman asked him before the auction -whether he would be willing to.let him. stay in the mansion alter the closing until he decides where he wants to move. Trump and Luzinski said they have had no such discussions with Gosman. Gosman, 75, had the house built after paying $12.1 million for the land in 1986. The former health-care magnate declined interview requests before and after the auction Monday. He was at the courthouse but left before the auction took place. The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm Beach home and guest house but falls short of the $45 million that Virginia home builder Dwight Schar paid for Ron Perelman's 26,000-squarc-foot cstate, Casa Apava, a designated landmark, Schar also paid $18.6 million for a lakefront lot across the street'from the .main house, for a total of $63.6 million. Insiders say Schar spent a total of $70 million for his new property, making.it the priciest residential sale in U.S. history. Gosman once had a fortune that Forbes magazine estimated at $480 million. He voluntarily filed for Chapter 11. bankruptcy protection in 2001, listing assets of $250 million and liabilities of $233.6 million. When ajudge ruledthat Gosman had to give up all of his exempt assets to creditors if he wanted to reorganize under Chapter 11, Gosman converted the: case to Chapter 7 liquidation. Last year, U.S. Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is invalid,because Florida law does riot recognize a Dominican Republic divorce that Lin Gosman tried to obtain from another man, Michael Castre, The judge's decision was.a huge,victory for creditors because it prevents.Abe Gosman from protecting assets by claiming joint ownership with his wife. Gosman's assets, which include an extensive collection of artwork, Could total as much as $70 million and will be sold later. Without Lessen's ruling, Luzinski would have had a.much harder time selling Gosman's estate, said David Cimo, special counsel for the trustee. "We would have been thwarted ,.. or at least, substantially impaired," Cimo said. CA/Aronberg-001018 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • But Friedman allowec! the offer to ·stancl, ami 'I>ulte ani;LTi;ump went b,;1cki i:tnd forth t1ritil Puite dropped out at $41.1 million. Epstein,, a part-,time Palm Beach resident, bowed out at $}8.6 million. Frie.dman closed the bidding] 0 minutes after it started, leaving Trump with the rightto buy the 29,000"square~foot home (a typical Palm Beach Coupty singlec.family hp1,1se is. ~pout 2,200 square feet); Thewoperty_also has a tennis hQuse, a pool house and 1930s-era service qtuirters. The closing, could take place within ,a week but probably wori't happen: uri.til next month. Trustee J ge Luzinski and creditors, ~aid they were ple~ed with tl1e ou.tc01:ne .. "We knew we were dealing with some substantial people, .. who were goingto bid itup a bit,'' Luzinski said. • "The system Worked;'' said,Chades Tatelbaum, a lawyer for creditor-JPMorgan.Chase Bank. "In bal;ll9'uptcy court, the idea is to get the' most for creditors, arid th.at's, what happened." The ,auction pro:ved to 'be a bonanza for·creditors, Luzinski said, noting that the highest offer former lisiing age11t Sotl1eby's lnterna.ti9nal RJ!alty re~ejyec;I w::is $32 million. Sotlieby's won't receive a commission, he said. Pulte, 42·, of Boca R;;i.ton, said he fig1.1red Tru111p woµlcln't ha Gk clown Monday. "I got the feeling he was willing to go a lot higher, and Ldidn't want to .chase. it,,'' Pulte Said. P1,1lte <Said dos.ma11 .. asked him befote the auction ,whether fie wollld be willing to let him stay in the mansion after the dosing -imtil he decides. whete he wa:rtts to move. Truhip, and Luzinski said they have hact no s1.1ch discu.ssior:is with Gosman. • Gosm·an;75,had.thehouse,buiJt.after paying $12.1 million for the land in 1986. The former health-Ga.re _rnagnllte clec.lined intervfow requests before 1:tIJcl after the auction Monday. He was anhe courthouse but left before the auction took place. The $41,35 mi!Hon price: tag ec;lipses the $30.35 milhon sale of Lowell "Bu.ti" Paxson's !'aim Beach home arid guest house but falls short of the $45 million that Virginia h0111e builder .Dwight Sc.bar paid for Ron Perelman's 26,0QO'-square-foot,estate, Ca,sa:A:pavll, a designated landmark. Schar alsQ paid $18.(:i million for a lakefront lot ac:ross. thie street:fro1n the main house~ for a total of.$63.6 million. Insiders say Schar spent a tota:l of $70 million foi"his rtew property, making:it the pric:iest residential sale in -u:s. history; Gosman ona had a fortune that Fotbes'inagazine.estin1ated a:t $480,million. He voluntarily filed for Chapter 1 L bankruptcy protectiQn in 2001, listing assets of $250 million and liabilities of$23J.6 million. Whell ajudge ruled that Gosman had :to give up all of his ex.empt assets to cr,editors' ff he wanted to reorganize under Chapter 11, Gosman converted the case to Chapter? liquidation. Last year, l].S, Ba11kruptcy J udg~Lany Lessen Tule.d. that Abe and Lin Gosman's marri'age is invalid, because Floiida law does not recognize a Dominican Republic divorce that Lin Gosman tried to obtain from another man, Michael Castre. Thejudge's decisio11-was,a huge.victory for creditors because it preventsAbe Gosman from protecting assets by d~irning J'.oin.t,ownership'with his wife. Gosman's, assets, which include ah ex.tensive collection of attWork, .could total as,muchas :$70 million and will be sold h1ter, Without Less~n's ruli11g, L.uzinsh would have had a;mu~h harder time selling Gosman's estate, said David Cimo, special counsel :for the trustee. "We would haye been thwai1ed ... or at least substantially impaired," Cimo said, CA/Aronberg-0O1018 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The, trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife an ownership interest inhis home and other belongings only to avoid losing them in bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in 1999, well before he filed for bankruptcy. Lessen is expected to rule in the next two months whether Gosman made improper transfers, a decisionthat will affect how much money will be available to creditors . Cirno acknowledged that Monday wasn't the best of days for the Gosmaris but said they were willing to move Forward, in part because the upkeep of the estate now exceeds their means. "This is not a happy occasion for them, but at least we're moving to the next level," CimO said. "That's not a house you want to live in unless you’re making large amounts of money like Donald Trump." [email protected] CA/Aronberg-00.1019 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • .1 The, hustee alleged during .a week long trial in May that Gosman fraudulently gave his wife an ow11ershjp interest in;his nome and other belongings only to .avoid los~ng them in bankruptcy. Gosman has denied any wrongdoirtg, saying he made the property transfers in 19991 well before he filed for.bankruptcy. Lessen is exp:ected to rule in the next two. months whether· Gosman made·irriproper transfers, a decisi9n '.t}:iaj will ~ffect how lllu~h m9ney will be ~v~f}able to creditors, Cimo acknowledgedthat Monday wasn't the best of days for the Gosman:s·but said they were wHJin.g to move ,forward, ·i.n pa1t be93,l!S.e th,e \lpke~p of the estate IJ.OW ex~eeds their means. "This is not a happy,occasion for.them, but at least we're moving to the, next level," Cimo" said. 'That's not a house you w~nt to live. in unless you're rnaking large amounts of money like Donald Trump.'' paul'[email protected] CA/Aronberg-00.1019 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 11/11/2019 Indi^TOnt: Billionaire1 Solicited 3 Times - News - The;Palm Beach Host- West Palm Beach, FL ThePalm Beach fest REALNEWSSTftRTSHERE Indictment: Billionaire Solicited 3 Times Posted Jul 1,2008 at 12:01 AM Updated ,Oct 2,2019 at 2:30 PM [EDITOR'S NOTE: This story originally published in The Palm Beach Post onJuly 25, 2006) Billionaire money manager and Palm Beach part-time residentJeffrey Epstein, solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 of last year, according to an indictment charging him with.felony solicitation of prostitution. Epstein, 53, was booked; at the Palm Beach County jail at 1:45 a.m. Sunday. He was released On $3,000 bond. Epstein s case is unusual in that suspected prostitution johns are usually charged with a misdemeanor, and even a felony charge is typically made in a criminal information - an alternative to an indictment charging a person with the commission of a crime. His attorney, Jack to discuss the charge. State attorney’s office spokesman Mike Edmondson also had little to say. "Generally speaking, there is a case that has a number of different.aspects to it,” Edmondson said of a charge being submitted to a grand jury. "We first became aware ofthe case months ago by Palm Beach police." Prosecutors and police worked together to bring the case to the grand jury, he said. https://www.palmbeachpost.eom/news/20080701/indictment-billionaire-solicited-3-times 1/2 CA/Aronberg-00.1020 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11/11/2019 ]ndictment: Bi!IHonaire Solicite_d 3 Time:s Posted _Jul 11 2008,at 12:01 AM Updated.bet i,2019. at·2:3ci PM (EDITOR'S NOTE: This ~tory origi1Jally publisheq fn The Palm Beadt Post onjuly 25, 2006) Billionairemoneymanager and Palm Beach part-time tesident)effrey Epstein. solicite.d or procured prostitutes three· or more times bet:vVeen Aug, 1 and Oct, 31 of last year,, according tQ an.indictment-charging:him with.felony solicitation of prostitution. Epstein, 53,. was booked, at the Palm Be_ach County jail.it l :45 a:m, S"llnclay. He was.released on $3,U00 bond. Epstein's case is unu·sualin that suspected prostitution johns are u·1ff1ally charged with a misdemeanor, and even a felony charge is typically made in a criminal information - an alternative to anindiqment charging a person with the commission of a crime. His attorney,JackGoldperger,.declined to discuss the charge. . . State attorney's office spokesman Mike Edmondson.also had little to ;say,. "Generally speaking, there is a case t.h,at ha_s a 1111mber of qifferent aspt:!cts to it," Edmondson said of a prostitution-related ciharge being submitted to a grandjury. 'We first he·came aware ofthe case inonths ago by Palm Beatkpolite." Prosecutors and police worked together to bring the case to the grand jury, he said. https://www.palmbeachpost:com/news/20080701/indictment0billionaire-solicite_d-3"times CA/Aronberg-0O1020 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1/2 11/11/2019 Indictment: Billionaire Solicited.3 Times- News - The Palm Beach Post- West Palm Beach; FL. Palm Beach police-confirmed that and said the department will release a report today regarding its investigation. Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-squarc-foot'home with a pool and a boat dock on the Intracoastal Waterway since 1990, according to property records. A man answering the door there Monday said that Epstein wasn’t home. A Cadillac Escalade registered to him was parked in the driveway, which, is flanked by two massive gargoyles. Epstein sued Property Appraiser Gary Nikolits in 2001, contending that the assessment of his home exceeded its fair market value. He dismissed his lawsuit in December 2002. A profile of Epstein in Vanity Fair magazine, said he owns what are believed to be the.largest private homes in Manhattan - 5'1,000. square feet - and in New Mexico - a 7,500-acre ranch, Those, are.in addition to his 70-acre island in the U.S. Virgin Islands and fleet of aircraft. Epstein’s friends and admirers, according to the magazine, include prominent businessmen, academics and scientists and famed Harvard law professor Alan Dershowitz. [email protected] https://www.palmbeachpost.com7news/20080701/indictment-billionaire-solicited-3-times CA/Aronberg-00.1021 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11/11/2019 Palm Bea.ch police confir,med that and.said the department wilhelease a report today regarding its investigation. Epstein has owned a five"bedroom, 7 1/2~hath, 7,234-square~foot;home with a pool and a boat dock oh the lrttracoastal Waterway since 1990,. according to propertyrecords. A man answering the door there Monday said that Epstein wasn't home .. A, Cadill~~ Escal~de registE!red ro him was parked:in rhe driyeway1 whichis flanked by two massive gargoyles. Epstein suecf PrC>pef!Y Appraiser G'.ary NikoHts in 2001, con~ending thatthe assessmentof.his home exceedeqi(s fair market v:ilµe. He dismissec:l his lawsuit in December2002. A profile of Epstein in VanityFait magazine.said he owns what are believed to betheJargest private homes in Manhattan - s·I:,000 square feet - and in.New Mexico - .a 7,500-a.cre ranch. Those arnfo addition to his 70-acre island in the U.S. Virgin Islands and fleet:of aiTcraft. Epstein's frienc:ls ;1,n9 c1dmir<:!rs 1 according to tlle magazine; include prominent businessmen, academics and ~ckntists and famed Hi!rvard law·prof<:!ssor Alan Dershowitz. hltps://www. pa lrnbea ch post corri/news/20080701 find ictrne nt-bil Ii onaire-sol jcited-3-tirnes . .... l.-. CA/Aronberg-0O1021 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 2/2 11/11/2019 After long p^e, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL The Palm Beach Post REflLNEWSSTflRTSHERE j After long probe, billionaire faces solicitation charge Posted Jul 27,2006 at 12:01 AM Updated Oct 3, 2019 at 3:11 PM (EDITOR’S NOTE: This story originally published in The Palm Beach Post onJuly 26, 2006) Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young women brought to his home, where he received massages and sometimes sex, according to an investigation by the Palm Beach Police Department. Palm Beach police spent months sifting through Epstein’s trash and watching his waterfront home and Palm Beach International Airport to keep tabs on his private jet. An indictment charging Epstein, 53, was unsealed Monday, charging him with,one count of felony solicitation ofprostitution. Palm Beach police thought there was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious: molestation. Police Chief Michael Reiter was so angrywith State Attorney Barry Krischer’s handling ofthe Case that he wrote a memo suggesting the county’s top prosecutor disqualify himself. ‘‘1 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,” Reiter wrote in a May 1 memo, to Krischer. While not commenting specifically on the Epstein case, Mike Edmondson, spokesman for the state attorney, said his office presents cases Other than murders to a grand jury when there are questions about witnesses' credibility arid their ability to testify. https://www.paimbeachpost.com/news/20060727/after-long-prdbe-billionaire-faces-solicitation-charge | CA/Aronberg-001022 1/5 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11/11/2019 After Jong probe, bt,lil!ioiraire faces s.oltci:tatio:n Gharg:e Posted Jul 27, 2006 at 12:01 AM Updated Qcf3, 20J 9 at 3:J 1 PM (EDITOR'S NOTE: This story originally published in The Palm Beam Post on July 26, 2006) Palm Beach billionaire] effrey .Epstein paid to have underage-girls and young women .brought to his home1where he received massages and sometimes sex, according to an investigation by the Palm Beach Police Department. Palin Beach police spent months sifting through Epstein'.s trash and watching his waterfront home an:d Pa.Im Beach International Airport to keep tabs.on his privatejet. An indictment charging Epstein:, 53', was unsealed Monday, charging him with. one count offel9ny solii:;itationofpro~titution. Palm Bea.ch police thought there was probable cause t9 :c;harge ,Ep~teinwith un1awfu1 sex acts with a minor and lewd and lascivious, molestation. Police. Chief Michael Reiter w,as so angry with State Attorney Barry 1<:rischer' s handling of the ta.se that he wrote a memo suggesting the countis top prosecutor disqualify himself. ''l must urge you to examine the unusual coursethatyour office's handling of this , , .matter ha.s takel;l :and consider ifgood and sufficient reason exists. to .require your disquaiific:ation from the prosecution of these cases," Reiter wrote in a May 1 mem0,t0 Krischer; While not commenting specifically on the:Epst:ein case, Mike Edmondson, spokesman for the state attorney, said his pffice presents cases·other than murders to a grandjury when there are questions about witnesses'. credibility arid their ~bility to testify, hitps:/twww.paimbeachpostcom/news/20060727/af!er-long,probe-billionaire-faces-solicitation'charge CA/ Aronberg-001022 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1/5 11/11/2019 Afterlorig^We, billionaire faces solicitation charge - News - The Palm beach Post - West Palm Beach, FL I ' By the nature of their jobs, police officers look at evidence from a “one-sided perspective,” Edmondson said. “A prosecutor has to look at it in a much broader fashion,” weighing the veracity ofwitnesses and how they may fare under defense attorneys’ questioning, he said. Epstein s attorney, Jack Goldberger, said his client committed no crimes. "The reports and statements in question refer to false accusations that were not charged because the Palm Beach County state attorney questioned the credibility of the witnesses,” Goldberger said. A county grand jury "found the allegations wholly unsubstantiated and not credible/’ and that’s why his client was not charged with sexual activity with minors, he said. Goldberger said Epstein passeda lie detector test administered by a reputable polygraph examiner- in which he said he did not know the girls were minors. Also, a search warrant served on Epstein's home found no evidence to corroborate the girls’ allegations, Goldberger said. According to police documents: - A Palm Beach Community College student said she gave Epstein a massage in the nude, then brought him six: girls, ages 14 to 16, for massage and sex-tinged sessions at his home. - A 27-year-pld woman who worked as Epstein’s personal assistant also facilitated the liaisons, phoning the PBCC student to arrange for girls when Epstein was coming to town. And she escorted the girls upstairs when they arrived, putting fresh sheets on a massage table arid placing massage oils nearby. - Police took sworn statements from five alleged victims and 17 Witnesses. They contend that on three occasions, Epstein had sex with the girls. A money manager for the ultra-rich, Epstein was named one of New York’s most eligible bachelors in 200.3 by The New York Post. He reportedly hobnobs with the:likes of former PresidentClinton, former Harvard University President Lawrence Summers and Donald Trump, and has lavish homes in Manhattan, New Mexico and the Virgin Islands. https://vl'ww.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge I CA/Aronberg-00.1023 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 2/5 NOT A CERTIFIED COPY 11/11/2019 After-Ioli., billionaire faces solicitation charge - News -'The Palm. Post" West Palm Beach, FL . - I . Bythe;nat:u:re oftheir jobs; police officers look at evidence from a.'/one-'sided perspective," Edmondson said. "A prosecutor has to look at it in a kuch broader - I fashion," weighing the veracity of witnesses: and how they may fare under defense attorn,eys' question111g, he said. Epstein's attqrney, Jack Goldberger,_ said his client committed no crimes. "The reports, and -statements in q\test:ion refer t9 false acc::usations th,at were not charged because the Palm Beach Collnty state attorney questioned:the credibility ctfthe witnesses," Goldberger said. A county grand j_ury ''foun:d the allegatidns wholly unsubstantiated and not ct.edible," and that's why his dientwas not charged with sexual activitywith·minors, he said. Goldberger saic:l Epstein pass eel :a, lie detector test adm~nistered by a rep_µtable polygraph examinei0 in which he said he did not·know the girls were minors. Also, a search warrahtsetved on Epstein's hoinefound no evidence.to_ corroborate the girls' allegations, Go'ldberget said. According to police documents: - A Palm Beach-Community College studentsa:id she,gave-Epstein a massage in the nude; then brought him six girls, ages 14 to i 6, for massage ;,lnd sex-tinged sessiops at his home. -A 27-year-old woman who worked as Epstein's personal assistant also facihtated the_ liaisons, ·phop,ing the PBCC student to arrange for girls when Epstein was coming to tow11.And_she escorted the gids upstairs w_hen th:ey arriv.ed, putting fresh sheets_ on, a massage table aud pla:dng massage oils nearby. -Police took sworn statements from five alleged victims and 17 witnesses. They contend that qn three occasio:n.s, F:pstein had sex with the girls. A money manager for the ultra-rich, Epstein was named one of New York's most ehgi.ble bachdors_ in 2003 by, TJ1~ .NewYork Pqst. He reportedlyliobn9bs wfrh, the likes off or.mer President Clinton, former Harvard University President Lawrence-Summers and Donald Trump, and'.has lavish h0mes in ~anhattan, New Mexico and the Virgin Islands. hllpi;://wwwjialmbeachpb~tcom/ilews/20060727/a~erclorig-prbbe-bjHionaire-(;:ices-solicilalicirHh~rge CA/Aronberg-0O1023 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 2/5 11/11/2019 After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West PalmBeach, FL He has contributed tens of thousands of dollars to Democratic Party candidates and organizations, including Sen. John Kerry’s presidential bid, and the Senate campaigns ofJoe Lieberman, Hillary Clinton,. Christopher Dodd,and Charles Schumer. Goldberger is one of five attorneys Epstein has retained since he became the subject of an investigation, Edmondson said. Among the others: Alan. Dershowitz, the well-known Harvard law professor and author, who is a friend of Epstein- Dershowitz Could not be reached forcomment. Police said the woman who enlisted young girls for Epstein was Haley Robson, 20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in Wellington and said she was ajournalism major at Palm Beach Community College when she was questioned by police last October. She has an unlisted phone number and could.not be reached for comment. Robson said she met Epstein when, at age 17, a friend asked her if she would like to make: money giving him a massage. She said she was driven to his five- bedroom; 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs to a bedroom with a massage table and oils. Epstein, and Robson were both naked during the massage, she said, but when he grabbed her buttocks, she said she didn’t want to be touched. https://www.palmbeachpost.com/news/20d60727/after-long-probe-billionaireTfaces-soiicitation-charge 3/5 CA/Aronberg-001024 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11/11/2019 He ha:s contributed tens of thousands' of dollars to Democratic Party candidates and ·organizations, including Sen. John Kerry's presidential'bid, an~ the Senate campaigns ofJoe Lieberman•, Hillary Clinton,. Christopher Dodd.aAd Charles Schumer. Goldberger ·is one oHive attorneys Epstein has retained since he became the subject qfan-investiga,tion, Edmondson said. Among the others: Alan. Dershowitz( the well-known Ha.rvard law professor and author, who fa a friend of Epstein. Dershowitz could not he reached for, comme11t: Poli<:e,sa'fd the woman who enlisted young gids for Eps.tein was Haley Robson, 20, of Royal Paim Be~ch. Robson has vy:orkec:i .at an Olive Garden resta_ura,nt in Wellin:~toil and said she was a, journalism major a:t Palm Beach Community College ·when she was questioned by police last October. She has, ah,uhlisted phone number and could.not be reached for comment. Rob.son s_aid she met :Epstein wh~IJ., ,at, age 17, a fri.end as_ked he.r if she woµld lik~ to make money giving him a massage. She.said she was driven to his five- bedroom; 7 l/2~ba:th home .. ort the InttacoastalWaterway, then: escorted.upstairs to a bedroom with a massage table and oils. Epstein. ahd Robson were both naked during the massag~; she s~id,, but when he gral:>bed her buttocl~s, .sh~ said slie didn't_ W,!nt to be touched. https:/lwww.palmbeachpost.coni/news/20060727 iafler-long-probe~billionaireafaces-solicitation-charge CA/Aronberg-0O1024 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 3/5 11/11/2019 After long billionaire'faces solicitation charge - News - The Palm B^rch Post - West Palm Beach, FL Epstein said he’d pay her to bring him more girls - the younger the better, Robson told police. When she tried once to bring a 23-year-old woman to him, Epstein said she was too old, Robson said. , Robson,, who. has not been charged in the case, said she eventually brought six girls to Epstein who were paid $200 each time, Robson said. “I’m like a Heidi Fleiss," police quoted her as saying. The girls knew what to expect when they were taken to Epstein’s home, Robson said. Give a massage - maybe naked - and allow some touching, One 14-year-old girl Robson took to meet Epstein led police to start the investigation of him in March 2005. A relative of the girl called to say she thought the child had recently engaged in sex with a Palm Beach man. The girl then got into a fight with a classmate who accused her ofbeing a prostitute, and she couldn’t explain why she had $300 in her purse. The girl gave police this account ofher meeting with Epstein: She accompanied Robson and a second girl to Epstein’s house on a Sunday in February 2005. Once there, a woman she thought was Epstein's assistant told the girl,to follow her upstairs to a room featuring a mural of a naked woman, several photographs ofnaked women on a shelf, a hot pink and green sofa and a massage table. She stripped to her bra and parities: and gave him a massage. Epstein gave the 14-year-old $300 and she and the other girls left, she said, She said Robson told her that Epstein paid her $200 that day. Other girls told similar stories. In most accounts, Epstein’s personal assistant at the time, Sarah Kellen, now 27, escorted the girls to Epstein’s bedroom. Kellen, whose most recent known’ address is in North Carolina, has not been charged in the case. Palm Beach police often conducted surveillance ofEpstein’s home, and at Palm Beach International Airport to see if his private jet was there, so they would know when he was in town. Police also arranged repeatedly to receive his trash https://www.palinbeachpost.conn/news/200.60727/after-long-probe-billio_naife-faces-solicitation-charge CA/Aronberg-001025 4/5 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11/11/201~ I Afl,J loog. bUlloaal,e·f.!"'' so11,o,1;0.o ,,.,,, - Ney/S- Th• P•lm. PL JN.,t Palm a,,o;, fl Epstein sald he'd pay her to bring'.himmore girls - the younger-the better, Robso11 told police, When she tried once to bring a 23-year-,old wbman to nim, . I Epstei11 said she was too old, R,.cibson sajd, Rohson,.who.has not been chai:ged_in the case, said.she eventt1ally'brougbt six girls to Epstein Who were paid $200 eac:h time, Robson said. ''I'm 1ike .a Heidi Fleiss," police quoted her as saying. The girls knew what to exp.ecewhen they were take_:ri to Epstein's home, Robson said. Give,a massage - may&e naked - and aUow some tow:hing. Qne 14-year-9ld girLRobsontookto meetEpstein ledpciliceto start:the investigation ofhim in Marc:h 2005. A ,rela,tive of the girl c:.illeci to ,s,iy sbe thought the child had recently engaged,in sex with 'a Palm Beach·man. The girl then got into.a fight with a classmate who accused her ofbeing a pr'~ostitute, and she couldn't explain why she had $300 in her purse. The gir_l gave police this account of her meeting with Epstein: She accompanied.Robson and a second girLto Epstein's house on a Sunday in F ebr.uary 2005\ Once there, a woman .she thought was Epstein's assistant told the gi1:l, to follow her upstairs to a ,room featuring a, mural of a, naked woman, several photographs of naked women on a shelf, a hot pink and green sofa and a massage table. She stripped to her bra and part ties and gave him a massage. Epstein gave the 14-'year-old $300 and she. and the other' girls leftrshe said. She said Robson told her that Epstein paid her ,$200:that day. Qther·girls told si)]lilar stqries. lp. Illostaccounts, Epstein'.s personal assistant at the time, Sar.ah Kdlen, now27Jescorted th~ girls to;Ep_stein's bedroom. I((;'llen, wh9s~ most r_ewnt known adcJres~ is in North Ca_i:oliI1a, :h?cs not been charged in. the case. Palm Beach police often conducted surveillance of Epstein's home, and at.Palm Beach International Airport to see if his private jet Was there, ,so they would know when he was in town. Police also arranged repeatedly to receive his trash htlps://www,pahnbeachpost.comlnewsl20060727/after-lon11~probe-billionaire-faces-solicitation-char~e CA/Aronberg-00.1025 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 4/:, 11/11/2019 After long probe,.billionaire faces solicitation charge - News - The Palm Beach; Post - West Palm Beach, FL from Palm Beach sanitation workers, collecting papers with names and phone numbers, sex toys and female'hygiene products. One note stated that afemale could not come over at 7 p.m. because of soccer. Another said a girl had to WorkSunday - "Monday after school?” And still another note contained the work hours of a girl, saying she leaves school at 11:30 a,m. and would come over the next day at 10:30 a.m. Only three months before the police department probe began, Epstein donated $90,000 to the department for the purchase of a firearms.simulator, saidJane Struder, town finance director, The purchase: was nevermade.. The money was returned to Epstein on Monday, she said. https://www.palmbeachpostcom/news/20060727/after-long-probe-billionaire-faces-solicitation-charge 5/5 ------■--... j. -. - ■- -.... CA/Aronberg-00.1026 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11/.11/2019 After long.,.billionaire faces solicitation charge - News - The Palm I: Post - West Palm Beach, FL from Pal:lll Beac:h sanitatfon workers, cqllect_ing pc1pers with na111e~ c1nd phone numbers, :sex toys and female'hygiene prod_ucts. One:notestated thata·female could not come over at7 p.m. because ofsoccer. Another said a girl had to work Sunday., "Monday after school?'' And still another note contained the work hours of a girl; s·aying slie leaves scho.61 at 11:30 a .. m. and would come over the next day at 10:30 a.m. Only three months before the. police department probe began,. Epstein donated $9Q,000 to the.depc1rtment for the purchase ofa firec1rllls. simulatc;>r, sa:icl]ang Strude.r, town fjnance:dire~t_or, The purchase:wa,,s never made., The money was returned to Epstein on Monday, she said. hllps://www.palmbeachpost:com/news/20060727/after-long-probe.-billionaire-faces-solicitation-charge CA/Aronberg-001026 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 5/5 11/11/2019 Police^^awyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL Palm Beach 'DailyNews Police say lawyer tried to discredit teenage girls Posted Jul 29, 2006.at 12:01 AM Updated Oct 3, 2019 at 2:00 PM (EDITOR'S NOTE: This story originally was published in. The Palm Beadv Post on July 29,2006) Famed Harvard law professor Alan Dershowitz met with the Palm. Beach County State Attorney's Office and provided about teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually charged,massages, according to police reports. The reports also state that another Epstein attorney agreed to a plea bargain that would have allowed Epstein to have no criminal record. His current attorney denies this happened. And the documents also reveal that the father of at least one girl complained that private investigators aggressively followed his car, photographed his home and chased off visitors. Police also talked to somebody who said she was offered money if she refused to cooperate with-the Palm Beach Police Department probe of Epstein. The state attorney's office said it presented the Epstein case to a county,grand jury this month rather than directly charging Epstein because, of concerns about the girls' credibility. The grand jury indicted Epstein, 53, on a single count of felony solicitation of prostitution, which carries a maximum penalty of five years in prison. Police believed there was probable cause to charge Epstein with the more serious crimes of unlawful sex acts with a minor and lewd and lascivious molestation. Police Chief Michael Reiter was so angry that he wrote State Attorney Barry Krischer a memo in May suggesting he disqualify himself from the case. https://www.palmbeachdailyhewsxom/article/20060729/NEWS/190917573: CA/Aronberg-001027 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1/4, NOT A CERTIFIED COPY 11i11i2019 Police.wyer-tried to discredit teenage girls - News, Palm Bea. News, Palni,Beach, FL Police say lawyer trTed to discredit teenage girls Posted Ju 129, 2006 .at 12:01 :AM Updated Oct,3, 2019 at 2:0.0 PM (EDITOR'S NOTE:·This stor:y originally was published in The,Pa'lm Beach Post onfuly. 29,2006) Fa med Harvard law'professor Alan D.ershowiti met with the Palnt. B'each County State Attorney's Office and provided damaging;information about teenage girls who say they-gave hh client_, :Palµi. Be.-i,ch billion3,ireJeffrey Epstein, sexually ch,!rge_d massage~, according to police reports. The creports also ,state that ·another Epstein ~ttorney agreed-to a pl~c1 i:>;irgain that would hav~ aUC>wed Epste1n to have no criminal ree<Jrd. H1s current attorney denies this happened. And the documents also reveal that the father ofat reast .orte girl complained that private investigators aggres·sivelyfollowed his car, photographed.his home and chased off visitors. Police also talked to somebody who said she was offered money if she refused to cooperate with.the Palm Beach Police Departme11t probe of Epstein. The state ~ttor;ney's office sa.id it presented the Epstein caseto a co:uncy.grand jury this month rather- than directly charging Epstein because; of concerns about the girls; credibility. The grand jury indicted Epsteiri;.53, on a single count of felony solicitation of prostitution, which carries a maximum penalty offiv~ ye~rs in prison._ Police believed there was probable cause to charge Epstein with tb..e. m,or~ serious c.rime~ of1Jnlawful s~x a~ts whh ~ lllinor and l~vvd :an.d lascivi<>us mqlestation. Pplice Chi~f Michael Reiter was so angry that he wro.te:State. Attorney Barry Krischer a memo in May suggesting he disqualify hitnselffrom the case. https:ilwWw.palmbeachdailynews,comiarticle/20060729/NEWS/190917 573 CA/Aronberg-0O1027 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM ,1/4, 11/11/2019 • . • ! Police ray lawyer tried to discreditleenage,girls News 7 Palm BeacITDaily News - Palm Beach, FL. The case originally was going to be presented to the grand jury in February, but was postponed after Dershowitz produced information gleaned from the Web site myspace.com showing some ofthe alleged victims commenting on alcohol and marijuana use, according to the police report prepared by Detective Joseph Recarey. Haley Robson, a 20-year-old Royal Palm Beach woman who ,told police she recruited girls for Epstein, also is profiled on myspace.com. Her page includes photos of her and her friends, including one using the name "Pimpin’,Made EZ." Robson, who was not charged in the case, is a potential prosecution witness. According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with, Epstein, accepted the deal, in which Epstein would plead guilty to one count of aggravated assault with intent to commit a felony, be placed on five years’ probation and have no criminal record. The deal also called for Epstein to submit to a psychiatric and sexual evaluation and have no unsupervised visits with minors, according to Recarey’s report. The plea bargain was made in connection with only one of the five alleged victims, the report states. Fronstin - who declined to comment on the case - was subsequently fired and veteran defense attorneyJack Goldberger was hired. He deniesthere Was any agreement by any of Epstein’s attorneys to a plea deal. "We absolutely did not agree to a plea m this case,” he said. Neither Belohlavek nor a state attorney's spokesman could be reached for comment. The parent or parents of alleged victims who complained of being harassed by private investigators provided license tag numbers of two ofthe men. Police found the vehicles were registered to a private eye in West Palm Beach and another in Jupiter, according to Recarey’s report. "I have no knowledge of it,” defense attorney Goldberger said. The report, also says a woman connected to the Epstein case was contacted by somebody who was still in touch with Epstein. That person told her she, would be compensated if she didn’t cooperate with police, Recarey’s report says. Those https://www.palmbeachdailynews.eom/article/20060729/NEWS/190917573 CA/Aronberg-00.1028 2/4 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11/11/2019 Polic.awyer tried to discredit:teenage,girls "News ,Palm Bea.y 1ws -Palm Beach, FL. ' The c'ase originally was going to be presented to the grand j,ury in F ebniary, but was postponed afrerD.ershowitz produced information gleaned from the Web site myspace.com showing some ofthe alleged victims commenting on alcohol and madju,ana, use1 according to the police report prepared by Oetective Joseph Recarey; Haley Robson, a 20-year-old Royai P_afm Beach w_om:an who,.told police she recruited :girls for Epstein, also is 'profiled on myspace.com. Her pageihdudes photos of her and her friends, including one using the name "Pimpin',Made EZ." Robson, who was J-iOt:ch.i,rged in the case, is a potenti;i,l prosecution witnlc!ss_. According to Recarey, prosecutor Lanna,Bekihlavek offered Epstein attorneys Dfr:showitz a.nd Guyf rons_tfo a plea deal'in April. Fronstin, after ~peaki_ng with, Epstein, accepted the :deal, in which_Epstein would plead g:uilty to one count of aggravated assault with intent to commit a felony, be placed on five years' probation and have no .criminal record. The deal ,also .called for Epstein to submit to a psychiatric and -sexual evaluation and ha:ve rto unsupervised visits with rni,nor_s, c1ccordiIJJ; to:Rec:a_rey'sreport; The plea bargain was made in connection with qnly one _ofthe five allegeci victims, the report states. Fronstin -- who declined to :comment on the c:ase: - was subsequently fired and veteran defense attorney Jack Goldberger was hired. He denies there was any agreement by any of Epstein's attorneys to a plea :deal. "We absolutely did not agree to a )5lea in this ca:se /' he said. Neither Belohlavek nor a state attorney's spokes'nian could be reached for comment. The pare11t or parents of :illeged victirnswho coII1plain_ed ofbeing'hara._ssedby private investigators provided_ lice11se tag m1:rnber_s of two of the men. P,ofo:~ found the vehides were registered to a private eye: in West Palm. Beae:h and another in Jupiter, according to Recarey' s- report. Th ave no knowledge .of it/' defense attorney Goldberger said. The report also says a woman connected. to the Epsteiil case. was tpntacted by somebody·vefho was still in touch wfrh Epstein. That persontold ~er she would be compensc1ted if s,he-didn't cooperate wjth police, Recarey'~ reR~)ft says. Those https_:(/wwvl.palmtieach_dailynews,con:,lartii::!e/2_0060729/NEWSl.1909175 73 CA/Aronberg-0O1028 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 2/4 11/11/2019 • • Polices?lawyer tried to discredit teenage girls - News - Palm BeacTOaily News - Palm Beach, FL who did talk "will be dealt with/’ the woman said she was told. Phone records show the woman talked with the person who allegedly intimidated her around the time she said, Recarey reported. Phone records also show that the person said to have made the threat then placed a call to Epstein's personal assistant, who in turn called a New York corporation affiliated with Epstein, the report states. The issue in the Epstein case is not whether females came to his waterfront home, but whether he knew their ages. “He’s never denied girls came to the house,” Goldberger said. But when Epstein was given a polygraph test, “he passed on knowledge, of age,” the attorney said. After the-indictment against Epstein was unsealed this week, Police Chief Reiter referred the matter to the FBI. “We’ve received the referral,:and were reviewing it,” said FBI spokeswomanjudy Orihuela.in Miami. The chiefhimself has come under attack from Epstein’s lawyers and friends in New York, where he has a home. The New York Post quoted Epstein's prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted only "because of the craziness ofthe police chief.’' Reiter has declined to comment on the case. Prosecutors have not presented a sex-related case like Epstein’s to a grand jury before, said Mike Edmondson, spokesman for the state attorney’s office; "That’s what you do with a case that falls into a gray area,” he. said. The state: attorney’s office did not recommend a particular criminal charge on which to indict Epstein, Edmondson said. The grand’jury was presented with a list of charges from highest to lowest, then deliberated with the prosecutor out of the room, he said. “People are: surprised at the grand jury proceeding/’ West Palm Beach defense attorney Richard Tendler said. “It's a Way for the prosecutor’s office to: not take the full responsibility for not filing the (charge), and not doing what the Palm Beach Police Department wanted. I think something fell apart with those underage witnesses,” hUps://www.palmbeachdajlynews.com/article/20060729/NEWS/190917573 I 3/4 CA/Aronberg-00.1029 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11/11/2019 Police.awyer tried to discredit teenage girls - News - Palm Bea.y News - Palm Beach, FL who did talk "will be dealt with," the woman ·said she was told. Phone records show the woman talked with the person who allegedly intimidatt:!d her arqund the time she s::1icl1 Recarey reported. Phqne records also show that the person said to have made the threat then placed a call to.Epstein;s personal assistant, who. in turn called a NeviYork corporatib'n affiliated with Epstein, tliereport states .. The issue in.the Epstein case i's not whether .females c.awe to hi~ waterfroi:it home, but whether he knew their ages. "He's ne\:er clenit:!d girls came ~o the hoµse," Gqlclbt!r:gersa1cl. ~ut when Epstein was given ::1 polygraph test, "he passed on knowledge. q[ageJ" the: attorney said. Aftedhe· indictment ~gainst Epstein was unsea:led this week; Police Chief Reiter referred the· rnatter'to the FBL "We\ie received the referral,: and we're reviewing it," said FBI SpokeswomanJudy Orihuela-in Miami. The chief himself has come under attack from Epstein's lawyers and friends in New York, where,he has a home. The New York Post quoted Epstein's prominent New Yor~ lawyer, Gerald Lefcourtr as saying his client was indicted only "becaµse gf the craziness of the police chief." Reiter has declined.to comment on the,case. Prosecµtors· have not. presented a sex,-related case· like Epstein's to ·a grand ·jury before, said Mike Edmondson, spokesman for the. State attornels office: "That'.s what you do with a case that fallsirtto· a gray area," he. said. The state attorney's office did not.recommend a particular ~ri01in.il charge on which.to inructEpstdn, E.dmondsonsatd. Thegrand:j.urywaspresented with a list of charges from .highesno lowest, then deliberated with the pros.ecutor out of the room, he said. '!Peqple are:surprised at the grand jury pr0<:eeding;'' West Palm Beath defense attorney Richard Tendlet said. "It'.s a way for the prosecutor's -office to; not take the .full responsibility for not filing the (charge), and not do in$, what the. Palm Beach.Police Department wanted. I think somethingfelf c1part wit,h those underage witness~s." https://www.paln,be_;ichda_ilynews.com/article/2()060?29/NEWS/190.917573 CA/Aronberg-001029 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 3/4 11/11/2019 • • Police^^Hawyer tried to discredit teenage girls - News - Palm.Beact^aily News - Palm Beach, FL Defense attorney Robert Gershman was a prosecutor for six years. "Those girls must have been.incredible or untrustworthy, I don’t know,” he said. Other attorneys said Epstein's case raises the issue ofwhether wealthy, connected defendants like Epstein - whose friends include former President Clinton and Donald Trump - are treated differently from others. Once he knew he was the subject of:a criminal probe, Epstein hired a phalanx of powerful attorneys such as Dershowitz and Lefcourt, who is a past president ofthe National Association of Criminal Defense Lawyers. Miami lawyer Roy Black - who became nationally known when he successfully defended William Kennedy Smith on a rape charge in Palm Beach - also was involved atone point. Said defense attorney Michelle Suskauer: "I think it’s unfortunate the public may get the perception that with power, you may be treated differently than the average Joe." https:Wwww.palmbeachdailynews.corn/article/20060729/NEWS/i909i7573 4/4 CA/Aronberg-00.1030 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 11i1112019 Poiic.wyertried to discredit teenage girls - News - PainfBea.y News • Palm Beach, FL Defense attorney Rob.ert Gershman was a ;prosecmtor for six years. "Those girls must have been.incredible or untrustworthy, I don't know," he said. Other attorneys said Epstein's case. raises the .issue of whether wealthy, connected defendants like Epstein - whose friend~- include forrner Presidt!ntCli_ntpn ,_md Donald T ruinp - are treated differendy from qthers. On_ce he knew he· was the subjec_t ofa criminai probe, Epstein hired a phalanx ofpowedul attorneys such,as Dershowitz and Lefcourt, who is a past president ofthe National Association of Crirhina] Defense Lawyers. Miami lawyer Roy Black - vvho became nationally known when he successfully defended William Kennedy:Smith on. a r~pe -charge in Palm. Beach-- also was involved at one point. Said defense atto_r:ney Michelle Suskauer: 'T think it's·unfortunate the public may get the. per.ceptionthat with p·ower, you .may be treated· diffe"rentlythan the av.erage Joe." htips:itwww.palmbeachdailynews.com/articlei200607291NEWSl190917573 CA/Aronberg-001030 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 414 TheBata Beachfest REALNEWSSTARTSHERE Expert: Ignorance of age isn’t defense in sex cases Posted Aug 5. 2006 at 12:01 AM Updated Oct 3,2019 at 1:38 PM (EDITOR’S NOTE: This story originally published in The Palm Beach Post on Aug. 5,2006) Even if Palm Beach money managerJeffrey Epstein didn?t know that girls. who police say gave him sexual massages at his Intracoastal home were under the legal age, that alone wouldn’t have exempted him from criminal charges of sexual activity with minors. “Ignorance is not a valid defense," said Bob Dekle, a legal skills professor who was a Lake City prosecutor for nearly 30 years, half of that time specializing in sex crimes against children, “There is no knowledge element as far as the age is concerned," Dekle said. After an 11-month investigation, Palm Beach police .said there was probable cause to charge Epstein, 53, with unlawful sex acts with a minor and lewd and lascivious molestation. They contend that Epstein - friend of the rich and famous and,financial patron of Democratic Party organizations and candidates - committed those acts with five underage girls. In the past week, New York Attorney General and gubernatorial candidate Eliot Spitzer has returned about $50,000 in campaign contributions: he received,from Epstein,, arid Mark Green, a candidate to replace Spitzer in CA/Aronberg-00,1031 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1031 • • The: PalnI Bt1a:ch Post .• • : . ;, , ·."':k~~:N_EWSSTA~Hatf : ~: '~ •.. '. E.1<pert: lg.ngran«:J ;r,f :~gQ~ isal't ,:dJe:f:tu1se: In:: sex·:c·ase.s Posted i'.\ug 5; 2006 at-12:01 AM Updatgd Oc;t ~. 2019 at 1 :~8 'PM (EDITOR'S NOTE: This story originally published in The_ Palm Beach Post on Aut 5, 2006) Even if Palm Beach money manager Jeffrey Epstein didn't 'know that girls,who police s_;1.y gave hi:m sexu_;1.l massages at his Intra coastal home were under the legal age, that alone wouldn't nave exempted him from ctimihal charges of sexµal ac:tivity w:frh minors. ''Ignorance is not a valid defense;'' said'Bob. Dekle, a leg~ skiils professor who was a Lake City prosecµtor for nearly 30 years, halfofthat time specializing ih sex crimes against children, ·'There is no knowledge element as far as the. age is concerned/' Dekle said. After an U-'.'m0rith investigation, Palm Beach police:said there w:as pr:obable cause to chargeEpstei1T, 53, vyith unlawful sex acts with a minor and lewd and.lascivious' molestation. They contend tha:t Epstein "friend of the rich ar.ip famous-and.finaI1cial patron of Democratic Party organizations and candidates - committed those acts with five ·underage girls. In the past week, New. Y:ork Attorney General and gul:>ernatQrial ~andipaJe EH9t Spitier~has :r:eturried aboµt $50,000 in campai~n contributions: he received. from Epstein,, and Mark Green, a: candidate to replace Spitzer in FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM his current job, has returned S10,000 to'him because of the Palm Beach scandal, the New York Daily News has ’ reported. Rather than file charges, the state attorney’s office presented the case to a county grandjury. The panel indicted Epstein last-week oh a single, less serious charge of felony solicitation of prostitution. The case raised eyebrows because the state attorney’s office rarely, if ever, kicks such charges to a grand jury. And it increases the difficulty of prosecuting child sex abuse cases, especially when the defendant is enormously wealthy and can hire high-priced, top-tier lawyers. At least one of Epstein’s alleged,Victims told police he knew she was underage when the two of them got naked for massages and sexual activity. She was 16 years old at the time and said Epstein asked her questions about her high school, according to police reports. A girl who said she met Epstein when she was 15 said he told her if she told anybody what happened at his house, bad .things could happen, the police reports state. Epstein’s youngest alleged victim was 14 when she says she gave him a massage, that included,some sexual activity. She is now 16. The girl's father says he doesn’t know whether she told Epstein her age. “My daughter has kept a lot of what happened from me because of sheer embarrassment,” he said, "But she very much looked 14. Any prudent, man would have had second thoughts about that.” Defense attorneyJack Goldberger maintains that not only did Epstein pass a polygraph test showing he did not know the. girls, were minors, but their stories weren't credible. The state attorney’s office also implied that their credibility was an issue when it decided not to charge Epstein directly, but instead give the case to the grand jury. CA/Aronberg-00.1032 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1032 • • his rnrrent job,, has returned $10,000to:h:im because of,:he . I Palm ,Beach scandal, the New York Daily News has reported. Rather tha,n 6.kcharges, the st.ate attorney's office presented the case to a county grnnci.. jury. The panel indicted Epstein last'.week oh a single,. iess: serious chaq~e•of felony solicitation of prostitution. The case raised eyebrows beca.use the state attorney's qffice rarely, if ever, kicks such charges to a grand jury. And it increases the difficulty of prosecuting child sex abuse cases, e_speciaJly wheri:the defendant 'is enormously we;;lthy and can hire high-priced, top-tier lawyers. At least one ofEpstein'.s alleged:Vittims told polite he knew· she was underage when the two of them. got naked for m.as.s.ages a1.1_d sexu:1lactiyity. Shew~s. 16 years_ old at the time and said Epstein asked herquestions about her high school, accotdihg .to police reports. A girl who ·said she; met Epstein when she was 15 said he told. her if s.hetold ;wybody whatha,ppe11eci at his hottse, bad .things could happen, the ·police .reports_ state, Epstein's yo:ung·est alleged victim was 14 when she says ,she gave him a massage. that included some sexual activity. She is.now 16'. The girl's father says·he doe_sn'.t.knowwhgth:er she told Epstein her age. "My daughter ,has kept a lot ofwha:t happened from me be~at1se of sheer embar:rassqient," he said~ "~ut she very mudhJooked 14. Any pr.uden'tm·an wou_ld have had second thoughts about that." Defense attorneyJack Goldberger maintains that not only did Epstein p~ss a polygraph_ test showing he d_ia not know the. girls were minors, but their-stories weren't credibie. The state attorney's office also i1nplied that their credib;ility w~s. an issµe wlien it dedded not to charge Epstein dir:e,i::tJy, but instead give the case to the grand jury. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM "A prosecutor has to look at it in a much broader fashion,” a state attorney's spokesman said last'week. ! NTElMGENT QR© f Epstein hired Harvard law Professor Alan Dershowitz when he became aware he was under investigation, and, Dershowitz.gave prosecutors information that some ofthe alleged victims had spoke of using alcohol and marijuana on a popular Web site, according to a Palm Beach police report. Prosecutors typically consider two things in deciding whether to charge somebody with sex-related offenses against minors - whether there is sufficient evidence and whether there is a public interest in doing so, Dekle said. If two teens are in a sexual relationship and the boy turns 18 before the girl, he could be charged with a sex crime'if the sex continues. There would be no public interest in pursuing that, Dekle.said. But where there is a large gap in ages - and especially in. cases of teachers with students - there is a public interest in prosecuting, he said. Likewise if the accused has a track record,of sex with minors. CA/Aronberg-00.1033 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1033 • • "A prosecutor has to look at it in a much broader fashiori," a ~t.ite attorney's spokesman said last'\veek. Epstein hired Harvard law Professor Alan Dersho:witz whel} he._peaJ.m.e ;iware h~was under investigation, artd. Dershowitz,gave prosecutors information that some of tp.e alleged victims had spoke of using afcohol and marijuana o.n a pop',!lar Web site, according to a Palm Beach police report, Prosecutors typically consider two things in .deciding whether to charge somebody with sex:..relate<l offenses against m1110.rs -whether there is sufficient eVidertte ahd whether'there is a,public interest in doing so, Dekl~ s.;,tid. Iftwo teens are in a sexual rdationship. and the .boyt!-]rns 1'8. before the girl, he could be charged with a sex crime'if the sex c:.o.ntlnue~. Th.ere wquld.be no public interest in pursuing that,. Dekle.said. B.utwheretheteis a large gap in ages .,_a:nd espeda:lly in. case~ of teachers with students - there is a J;>ublk irtterestin prose_cuting, he Sitid. Lj.lq!wisedf the a~cµse9 has a. trac:k record.of sex with minors. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Still there is a "universal constant” in prosecuting these cases, Dekle said. Men who exploit underage children for sex often carefully choose their victims in ways: that Will' minimize the risk to them, he said. Victims usually are from a lower social status, and they may suffer from,psychological problems, Dekle said. "Lots of child sexual abuse victims have been victimized by multiple people over a period of time. Then the act of abuse produces behavior in the victims that further damages their credibility.” Examples include promiscuous behavior and, drug abuse. Some ofthe alleged victims in the Epstein case returned to his home multiple times for the massage sessions-and the $200 to $300 he typically paid them per visit. “That would be a definite problem for the prosecutor,” said Betty Resch, who prosecuted crimes against children in Palm Beach County for five years and now is in private,practice in Lake Worth. “The victim becomes less sympathetic” to a jury, Resch said; “But she’s a victim nevertheless. She’s a kid.” Most men charged,with sex crimes against minors look normal, Dekle said. A jury expecting to see a monster seldom will. And the victims’ ages work against them and in favor of the defendant in a trial, Dekle said. If a child and an adult tell different stories and both swear they’re telling the truth, adult jurors are more likely to believe the adult, Dekle said, “You have all. these things working against-you in a child sex abuse case. Prosecutors normally try to be very careful in filing those cases because they know what they're getting into. There is no such thing as an iron-clad child sexual abuse Case.” CA/Aronberg-00.1034 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-001034 ---• - - - -• Still th.ere is a "universal const_.1nt" in prosecuting these cases, Dekle said. Men wli.o exploit underagechilclrenfo:r sex often ,carefully choose their victims in ways that will 1 minimize the riskto them, he said. Vicfims usually ax:e from aJo:wer soc;i::iJ status, a11d they !pay surfer from psychological problems, Dekle said. "Lots of child sexual abuse victims hav.e been victimized by multiple people o'vet a period of time. Then the act ofabuse- produces behavior in the vi<;:tims that further damages their credibility.'' Examples include promiscuous behavior a.rtd. drug abuse., Some .of the alleged victims in the Epstein case returnedto his home muitipk times for the'massage s_essicms·and the $200 to $300 he typically paid. them per visit. "That would be a definite problem :for the prosecutor," said Betty Resch, who prosecuted crimes against childre11in J>aJ_ml~e:i.ch County. for five years and. now is in private, practice in Lake Worth. "The victim becomes less sympathetic" to a.jury, Resch said, ;'Buts_he's _a vktim n_eyertheless. She's· a kid." Most men chargecl:with sex crimes against minors look normal, Dekle said. A jury expecting to see a monster sel<:ioro wi_ll. And the victims' ages work ag,ainstthem and in favor: of the defendant in a trial, Dekle sai9., Ifa child and an adult telldifferent,storics and both swear 'they'.re telling the truth, adultjurors are more likely to beli_eve the adult! Pekle said._ "You have all. these things working again:st-: you in a chilcl_ sexabuse case. Prosecutors hOrmallyt-ryt◊ be very',carefol i11 filing th9~e cases because they know what they're gettin,g intp. There 1s no s_ucb thing as an iron-c;l_ad chilc:f s_exµal abuse case." FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM • • TheMm Beach Post REALNEfcSTARTSHERE EpsteincampcaHs female accusers liars Posted Aug 8,2006 at 12:01 AM Updated Oct 3,2019 at 3:35 PM (EDITOR’S NOTE: This story originally published in The Palm Beach Post on Aug. 8,2006) Attorneys and publicists for Palm Beach financierJeffrey Epstein went on the offensive Monday, contending that teenage:girls who have accused Epstein of sexual shenanigans at his waterfront home are liars and saying that the Palm Beach Police Department is “childish.” "There never was any sex between Jeffrey Epstein and any underage women,” his lead attorney, Jack Goldberger, said from Idaho where he was vacationing with his family. Epstein did have young women, come to his house to give him massages, Goldberger said; "Mr. Epstein absolutely insisted anybody who came to his house be over the: age of 18, How he verified that, I don't.know. Thequestionis, did anything illegal occur. The law was not violated here,” He had no explanation as to why Epstein would pay girls or women with no massage training - as the alleged victims, said was the case - $200 to $300 for their visits. “The credibility of these witnesses has been seriously questioned,” Goldberger said. Epstein, 53, was indicted by a county grand jury last month on a charge of felony solicitation of prostitution. After an 1 Umonth investigation thatincluded sifting- through Epstein’s trash and surveilling his home, Palm Beach police concluded there was enough evidence to charge him with sexual activity with minors. When the grand jury indicted CA/Aronberg-00.1035 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/ Aronberg-00.1035 ;Ep.ste.in c·~_mp~:e·ans.·no1lale: }~'C,«;Us·e_rs liaJts Po.sted Aug 8, 2006 at 12;01 AM Updci,eq Oct 3, 2019 aq~35 PM (EDttOR'S NOTE: This story originally published in The Palm Beach Poston Au$, s; 2006) Attorneys and publicists for Palm Beach financier Jeffrey Epstein went Qnthe offensive Monday, c:ontending that teenage girls who have accused Epstein of sexual shenanigans at his waterfront- home a.re liars and -saying thar the Palm Beach Police :Oepa,rtment.is ''.childish." "There neverwas anysex·betweenJeffreyEpstein and any underage women," his lead attorney,,] ack Goldberger,_ said from Idaho wherehewasvacationing with his family. Epsteiil d(d have_ young women, come to hfs. h_ouse t.o give .him massages, Goldberger said, "Mr. Epstein absolutely insisted anybody who came to his ho.use be over the age of 18. How he verified that, I don't.know. The question, 'is,; did anything ill!:!gal occur. The law was ·npt ·violated here." He had no explanation as to why Epstein would,pay giris or- 'w'omen with no massage tr.aining - as the a1leged_victirris, saiq. was t_he case- $200 to $300 for th<:;ir visi~s. "The credibility of.these witnesses has been seriously questioned/ Goldberger said. Epstein, 53, was indicted by a county grand jury last month Oil a charge of felcmy solicitatioI). of prostitution, After an n~month investigation that inciuded sifting-througµ Epstein's ·trash and surveilling his home, Palm Beach police concJuded tbere'was enough ev.:idence to ~h.:i.rge him w,j,th sexual activitywith minors. When the grand jury indic,ted FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 9 • Epstein on the less serious charge, Police Chief Michael Reiter referred the case to the FBI to determine whether there were federal law violations. After a spate of stories about the case last week?, New York publicist Dan Klores - whose client list has included Paris Hilton and Jennifer Lopez - said on Saturday that Epstein’s camp was ready “to get their story out.” They did that Monday via Goldberger and a Los Angeles publicist for Miami criminal defense attorney Roy Black, who also has represented Epstein in the case. "We just-think there has been a distorted view of this: case in. the media presented by the Palm Beach police)” Goldberger said. Reiter has consistently declined to comment on the case and did not respond to a request for Comment Monday. The implication that State Attorney Barry Krischer was easy on Epstein by presenting the case to a grand jury rather than filing charges1 directly against him is wrong, Goldberger said. CA/Aronberg-001036 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O103.6 • • • • • • • Epstein on the Jess serious charge, PQli\:=e Chief Mic_hg,eJ_ Reiter referred the case to the FBI to dt!termine whether there were federal law violations. After a spate of stoties ·about the case last week, New Y~rk pµblidstDan l\.lores - whose client list has included· Paris Hilton.andJennifer;LC>pez - said:on Saturday that :Epstein's camp was ready "to:get their story oue' They did that Monday via Goldberger and a: Los AngeJc·s publicistfor Miami ~rhninal defense attorney Roy 13lack, who.also has represented,Eps_teinintht! case. "We just-think there 'has been. a distorted view of this case in. the media presented by·the Palm .Beach police," Goldberger said. Reiter has -consistently dedine_d to ,c_omment on the c~s_e and did not tespond to a request for comment Monday: The implication: that State Attorn:ey·Barry Kristher was easy on Epstein by presenting the case to a grand jur:y rather than filing charges directly against him is wrong:, Goldberger said. I I ...... ,.:.. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM • • The Palm Beach Police Department was happy and ecstatic” that the panel was going to review the evidence. "I think what happened is they weren’t happy with the result. They decided to use the press to embarrass: Mr. Epstein.” But records show that-Reiter wrote Krischer on May 1 - well before the case went to the grand jury - suggesting that Krischer "consider if good and sufficient reason exists to require your disqualification from the prosecution ofthese cases.” Rather than flat-out decline to charge Epstein, Krischer referred the case to the grand jury to "appease” the chief, Goldberger said. A state attorney’s spokesman would say only that the office refers cases to the grand jury when,there are issues with the viability ofthe evidence or witnesses’ credibility. Bpththe state attorney and the grand jury concluded there was not sufficient evidence that Epstein had sex with minors, according to Goldberger. "It was just a childish performance by the Palm Beach Police Department,” Goldberger said. The defense attorney said one of the alleged victims who claimed she was ,a minor was in fact over the age of 18. Another alleged victim: who was subpoenaed to testify to the grand jury failed to do so. Epstein’s accusers, he added, have histories of drug abuse and thefts. "These women are liars. We’ve established that.” But why would they all invent their stories about meeting Epstein fbr sexual massages? "I don’t-have an answer aS to what was the motivation for these women to come forward and make these allegations," Goldberger said. CA/Aronberg-001037 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/ Aronberg-0O1037 . . - ' • The '.Palm l3each Pplic~· Department was "happy· ;md ecstatic;' thatthe·panelwasgoingto review the.evidenct!. "I think what happened is theywere·n't happy with the res tilt. They decid~d to use the press to embarrass Mr. Epstein." l3ut _records sliow that·Reitenvrote Krischer on M'ay 1 - welLhefore the case went to the :grand jµry - sµggesting that Kris ch er llconsider-if-good and sufficient reason exists. to requlre your disqu~lification from the·prosecution of these " cases. Rather than flat-out dedine to charge Epstein, K_rischer referred the case to. the grand jury to "appease" the chief, Goldberger said. A state attorney's spokesman would say only·that the office refers cases, to the &rand jury when. there ate issues with the viability of the evidence or witnesses'. credibility. Both ·the ~tate attorney and the grand jury concluded there was no.t sufficient evidence that Epstein had sex with minor~, according to. Goldberger. i'It wasjust a childish performance by the Palm Beach Police Department;" Goldberg~r said. The defense attorney said one of the alleged'victirns-who daimed she·was,a minor was in fict over the age of 18. Ano~her alleged victim who was subpoenaed to testify to th_e gr::i,ncLjuryJailed to do sp. Epstein'.s acq1sers, he added, .have histories, of drug: abuse and thefts. ''These women· are ha,rs, We've established that." Bµt why w94ld,th~y all inve_n_t their stories about meeting Epstein for sexual :massages? "I dort't- have an answer- a:s tc:fwhat was the motivation for tliese w9men to come forward and make these allegations," Goldberger said. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The Palm Beach Post (West Palrn’Beach, Florida) • 14 Aug 2006, Mon • Page7 Downloaded on Nov. 11.2019 Newspapers- lyRaneestry- m^hn^cix.sgiUriA^ «» k S' m*t Witt M»>» <<5^, , A < }wrrf&«t iowi. h<1fx'w«<*ftVWli* teKWiSi jiraww utoh mKhI t'* b*& < ^hht^itwr- v nriniAj v Cn^v^* Uh :j I ■...Ih&ti&d thrrtl^lwM'stftv fks *• f ® ntSCi^b 4U<vn£n«q 'il . -4 * -*”3 g f,ubi»rtkottri*2h~T "i * tart U hh Crw wjn il* >^4 r«*ir*« . 0^ 4s •■ IhW HarJ w? a m, lay ***««**»z brMr>ttr»;Aj^^f/r4(bw 0s*4«l Wh _ * «^rM9'» »•>%»•* tamcz? - t. . j\ $** . e^fOrBw; - j <'X y*ti*r,_ 4 *»i«urbih-»i|& j fc«l ri ME-wanJ ‘r»r^, »ke4wt 3 a* | WuX in ■.u«J »» itiifcinl ;f .. *<W.'Keta#wiafiw,<WfiMe>rfc^ l fw.---5<f» I ?’?~ih »i^.lu ^‘SAVirKr«Bi.^llcc4i*d.-lftj»345rrcfa»<;>itit!9fsJ ft/i»>1WcXjiU‘tJii*K9??.%VU?j?ai^ ^U®V«B£&rM &y.‘kmI : jOr »3 *4*hr«teH>V<Wf^iw-'« fomeshd ;^i*aJ&rw »pl: Cas aJ tep. «f. * y & <1*n‘Kcfu UM Sw er^sn* t^> Utw* , v l91?‘ A f Sa.VP 1^«?Md»3we< “< <*$W«ii.H«<| W»l«r«*vnh& l Reiter focus of fire in Epstein case Clipped By: ' .O' relter_m Sat, Apr 22, 2017 Copyright © 2019 Newspaperslcom. All Rights Reserved. Mew^ CA/Aronberg-00.1038 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • The Palm Beac_h Post·(West Palm·Beach, Florida)· 14 Aug 2006, Mon· Page 7, Downloaded on Nov.11.2019 Reit~r focus of fire in Epstein case , .relte_r_m .Sat, Apr 22; 20·17 Copyright© 2019 Newspapers:com. AU Ri[!hfs Reserved .. CA/Aronberg-00.1038 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM TheTata Beach Post REALHEWSSTARTSHERE Belays in Epstein ease unusual, lawyers say Posted Mar 13,2007 at 12:01 AM Updated Oct 3,2019 at 3:48 PM (EDITOR'S NOTE: This story originally published in The Palm Beach Post March 13, 2007) A federal probe or a plea deal could explain the wait in the Palm Bcacher’s solicitation case. Nearly eight months after Palm Beach tycoon Jeffrey Epstein was charged with felony solicitation of prostitution, there has been no discernible progress in his case. No witnesses deposed. No trial date set. Nothing, save for routine court hearings reset without explanation. "Usually that would be unusual," said criminal defense attorney Glenn Mitchell, who has no involvement in the case. "As a general rule, it would be unusual for nothing to have happened,” agreed Michael Dutko, a criminal defense attorney in Fort Lauderdale. He represents Haley Robson, 20, of Royal Palm Beach, potentially a key witness in the case. A routine hearing for Epstein was pulled from the court docket last week and reset for May 16. The delays arid inaction could be due to a potential federal probe of Epstein or because a plea deal is in the works, attorneys say. Unusual is the word that best describes everything about the case against Epstein, .54, an enigmatic money manager in New York.City who counts Bill Clinton and.Donald Trump among his friends. CA/Aronberg-001039 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-001039 D:~1a·ys ib:Epst~Jn :c:ase,, un11stoU, hiw;yets say; Posted Mar 13, 2007 at 12:01 AM Updated Oct 3, 2019 at.3:Mi PM (EDITOR'S NOTE: This story originally pub'lished in The Palm J?eqch Posl AfqrGh J3: 2007) A federal probe or a plea de.al ·could explain thewait:in the Palm Beac:her's solicitation case; Nearly eight months after Palm Beach tycoon Jeffrey Epstefo was charged with felony solicitation ofprQstitution, there has been no discernible. progress in his case. No witnesses deposed. No trial date set. Nothing, save for rout(n.e cQQrt hearings reset without explan:nion. "Osually that would. be unusual," s_aid criminal defense attorney Glenn Mitchell, who has no involvement in the case. "As a general rule, it would beunusualfor nothing to have h~pp!;!Ileci/1 agreecLtviichael Dutko, a criminal deferise attorney-in .Fort Lauderdal·e. He represents Haley Robson, 20, of Royal P~lm Beach, potentially a Jcey witne~s ip the case. A routine hearing for Epstein wa:s pulled fron:-nhe court docketlast week and reset for May 1.6. The delays and inac;tfon could.be due to a potential federal.probe of Epstein or because a plea deal is in the,:works1 attorneys say. Unusual' is the word that best describes everything about the case against Epstein,.54, an enigmatic money manager in New York, Cfry who counts Bili Clinton and. Donald Trump a:mong his friends. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM "Highly unusual” is how Palm Beach Police Chief Michael Reiter described State Attorney Barry Krischer’s handling of the case in a bluntly critical letter to Krischer last year before Epstein was indicted. , Reiter referred the matter to the FBI to determine whether any federal laws had been violated. Epstein’s allies countered by attacking the chief personally and professionally. Reiters department investigated Epstein for 11 months. Police sifted repeatedly through his trash and conducted surveillance on his five-bedroom, 7 1/2-bath, 7,234-square- foot home on the Intracoastal Waterway. Police said Epstein paid women and girls as young as 14 to give him erotic massages at his home. Police thought there was probable cause to charge him with unlawful sex acts with a minor and lewd and lascivious molestation. Epstein responded by hiring a phalanx of lawyers. One of them, Harvard law professor and author Alan Dershowitz, provided the state attorneys office with information about alcohol and marijuana use by some of the girls who said they were with Epstein. Prosecutors then referred the case to the grand jury rather than file charges directly, against Epstein. Epstein's attorneys deny he had sex with underage girls. The lawyers say the girls’ stories are not credible, But .if the court file is any indicator,, they’ve made no effort to depose the girls. Neither prosecutors nor defense attorneys have sought to question Robson, said Dutko, her attorney. She recruited teenage girls to visit Epstein for, massages and sexual activity, Palm Beach police said, and presumably would be a key witness. CA/Aronberg-00.1040 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1040 I • e! "Highly unusual" is how Palm Beach Police,ChiefMicl)a~I Reiter descr(bed State. Attorne.yBarry .K.rischer's handling of the .case jn a :bluntly critical letter to Kris ch er last year i before Epstein was indicted. Reiter referred the matter to the FBI to determine whether any federallaws,had been violateq. Epstein's allies countere4 by attacking the chief personally and. professionally. Reiter's department investigated Epstein :for 11 months,'. Police sifted repe_atedly thro1,1.gh his trash and ,conduc,;ted surveillance on his five-bedroom, 7 1/2-bath; 7 ;234-square,.,, foot home oh the hitra:coastal Waterway. Police said Epstein_pa:id,women and girls as young as 14 to give him erotic massages .a this home. Police ¢ought there was probable cause to charge him·with unlawful sex acts With a minor and lewd arid lascivious :molestation. Epstein responded by .hiring a phalanx of lawyers. One of then1, Hanrard law professor and author.Alan Dershowitz; provided the state attorney's office with information about alcohol and.marijuana use by some ofthe, girls who .said theywere with Epstein. :PrQsecutors then referred the case to the grand jury rather than file· charges dire·ttly. aga:insrEpstein. Epstein!s a:tt6rneys deny he had sex·with underage girls, Thelawye.rs say the girls' stories are not c:redible. )!ut .if the court 'file is any indicator,.they've made no effort'to depose the girls. Nei,tlu,~r prosecutors nor de(ense attorneys have sought :t.o question: Robson, said Dutko, her attorney. She recruited teenage g'irls to visit Epstein for, massages and ~exual activity, Palm ~eaclr poHce said, and. pres\lmably would b,e a key witness. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Epstein s attorneyJack Goldberger did not return phone messages. A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it,to federal prosecutors. “We still have a pending case,” FBI spokeswoman Judy Orihuela said Monday. State Attorney Krischer did not return a call for comment. His spokesman, Mike Edmondson, declined to say whether federal investigators, are delaying the Epstein case. But, he added, “if another agency is looking at something, we wouldn’t want to step on their toes." Attorneys say inertia in a criminal case often points to a pending plea deal. “It: would not surprise me if something has happened that’s riot reflected in the court file," said Dutko, such as an agreement that will be formalized later. Defense attorney Marc Shiner said defense attorneys sometimes put off overtly conducting discovery — deposing witnesses, requesting documents and the like -- because doing so creates more work for harried prosecutors, who may become angry and not offer a plea deal. “Sometimes defense lawyers, knowing that, will try and do discovery without taking depositions,” said Shiner, a former prosecutor for 13 years. Instead, they may conduct a below-the-radar probe such as having a private investigator check out leads, he said. Shiner and others say a plea dealfor Epstein probably would result in pretrial intervention, in which a defendant may be ordered to undergo a psychological evaluation, counseling or other conditions in return for dropping the charge, CA/Aronberg-00.1041 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.104 t • - . . . • i .Epstein s attorney JacikGoldberger did.n9t return phon¢ messages. A source. close to. the case suggested it:is languishing pertding,a decision hy the FBI on whether to refer itto federaL prosecutors. "We·still have apen_ding case," FBI spokeswomanJudy Orihuela said Monday. State Attorney· Ktischer did not tettitn a tall for comment. His spokesman, Mike Ecl.111011-dson, declined to s::iy·vv:heJher federal investigators. are delaying the Ep:stein cas:e .. But; he added,. ''ifanotheragency is looking at something, we wouldn't want to step on their toes." Attorneys say inertia in a cr.'iminal case often points to. a pe.nding plea deal. "It would not surprise me if something has happened that's Iiotreflected in the court fife;" said Dutko, such as an agreementthat will be formaHzed1ater. Defense attorney Marc Shiner said .defense attcirneys sometimes put off overtly conducting discovery-- deposfng witnesses, :requesting documents and the Hice -- because doing sq creates more work for haJTied prosecufors who may become angryand notoffeta: plea deal. ''S.ometimes defense Ia,vyers ,. knowing that, will try and do discovery wifuout taking depo~1.tiorts ," sajd Shiner, a fo1:mer :prosecut<,>r for 13 years, Jnstead,-theymay conduct abelow~the~tadar probe such.as having a private investigator check out lead~, he s_aid. Shiner and others say a plea deal for Epstein probably would result in pretrial intervention, in which a defendant may.be ordered .to. 'undergo a. psychological evaluation, counseling or other conditions :i11 rerurn fqr qropping the charge, FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Edmondson, spokesman for State Attorney Krischer, said there is no plea offer and no request for the prosecution to show its cards. "To my knowledge, it’s,never happened before on a filed case,” he said. CA/Aronberg-00.1042 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1042 •• • • • • • •• Edmondson, spokesman for State Attorney Krisc.,her, satd there -is no ·plea offer and no request for the prosecution to showits cards. "To.my knowledge, it's,neverhappenedbefore on a filed c:ase," he said. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 252 / 278 - Thursday, O.ctober 18, 2007 Edition: FINAL Section: LOCAL Page: 5B Source: The Associated Press Illustration?PHOTO (B&W) Memo: Ran all editions. Dateline: NEW YORK WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16 A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had sought his help becoming a model. The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financierJeffrey Epstein had the teen perform a sex act when she brought photographs of herself for him to review in his Upper East Side mansion sometime in 2000. Epstein,. 54, a money manager, told the teen he managed finances for Victoria's. Secret and "could get you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice" included massages and. other favors. When the girl told.Epstein, "I am 16 years old and just want to model," he replied, "Don't worry, I won't tell anybody," court papers say. Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been indicted in Palm.Beach on charges of soliciting underage prostitutes. That case is pending. The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural sex acts” while she was a minor, the lawsuit says. Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends, stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her 40s). 1 love girls your age.' " The young Woman,.now 23, kept returning to Epstein because she has "mental issues," said her lawyer. William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result of severe mental disease and defect." Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can read a newspaper and recognize the word 'rich.'" Lefcourt also said the statute of limitations has expired for the woman's case criminally and civilly, arid will almost certainly be disihissed. He refused to comment on Epstein's Florida charges. Meanwhile, Unroch, 57, also acknowledged that his client was living with him arid was at the center of a $10 million lawsuit he filed last year against a .neighbor who said he was having sex with underage girls. That case is pending. "What she was doing at .22 is irrelevant to what happened to her when she was 16," Unroch said Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve the case out of court. CA/Aronberg-00.1043 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • 252 / 278 ~ Thursday; 0.cfober 18; 2007 Edition: FINAL Sectiqn: LOCAL Page: SB Source: Th~ Associateci Press Illustration:- PHOTO (H&:WJ Memq: ·Ran all editfons. Dateline: NEW YORK • WOMAN SUESBILLIONAIREINVESTOR, SAYS,THEYHADSEX WHEN SHKWAS 16 A billionaire investor, already facingjail in Palm B.each County- on charges of soliciting underage prostitute~, is being sµed by a young wqman wfiq sc:1ys be: h1:1d se.x with her when she was 16 and had sought his ,help becoming a model. The,lawsuit, filed late Tue~day in M~nhatt~n's state Supreme Court, says fiIJ-1:mcier Jeffrey Epstein had the teen perform a sex act when she brought photographs of herself for him to review in his Upper East Side mans.ion sometime in 2000. Epstein, 54, a money manager, told the teen he managed finances for Victoria's.Secret and "could get yo\l into the catalqg" if ~he were "nic;e!' to him, court papers say. The papers say p~ing "riice'' included massages and. other favors. When the giri tolclEpstdn,. "I am i 6 yei:1r.s old a11d just want to model," he replied, ''Don't worry, I won't tell anybody," court papets say. Epstein, said by Loncl_qn's: MailQn ~Sµndc:1y ·to lJe 'l:1 c;lqse friend of Engl_ancl's Prjnge Am;lrew, has been indicted ih Palm.Beach on charges of soliciting underage prostitutes. That ca:se is pending. The girl visited Epste_in "severa.f times-over the ~everal months an,d e,ngaged in. bizarre and unnatural sex.acts" while she was a minor,·the lawsuit says. Epstein "repeatedly requested that(the girl) return with ller 14-, 1 ~-, and 16-year-old;girlfrier;id~, stating, 'Come by with your friends your age next time. Dmi't bring Sherrie. Ea mutual friend in her 40s} I love girls·your age.'" The yoiihg woman, ,now 23, kept returning to Epstein because. she has "mental issues," sa:id her lawyer, William J .. Unrqch. He.refused to ~!~borate, but court pape.rs ~ay she was "disabl~d as a result of.severe mental disease and defect." Epstdn's lawyer in NewYork, Gerald Lefcourt; •saiq, "The gi.rl has. a_dmitted she is ins;me, but she can read a newspaper and recognize the word 'rich."' Lefcourt also said the statute oflimitations has expired for the woman's cas~ criminally and civilly, artd will almost certainly be dismisI;ed. Be refused to comment on Epsteinis Florid.a chargl:!s. Meanwhile, Uhroch, 57, also acknowledged that his client Was living With him and wa:s atthe center ofa:. $10 million, lawsuit he filed. lasJ year against a neig_hbor who sajd he wa1> having sex with under.age girls. That:case is pending, "What she was doing at.22 is irrelevant to what happene.dto her when she was_l6," Unroch s_aid Wednesday. He went ort·the say he hoped Epsteihwouldagtee to "do:right't by his client and.resolve the case out of court; CA/Aronberg-001043 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:27:00 PM TheMmBeach Post REALNEWSSTARTSHERE Palm Beacher pleads in sex case Posted Jul 1,2008 at 12:01 AM Updated Oct 3,2019 at 1:47 PM (EDITOR’S NOTE: This story originally published in The Palm Beach Post onJuly 1,2008) Jeffrey Epstein will serve 1 1/2 years on teen solicitation charges, He lives in a Palm Beach waterfront mansion and has kept- company with the. likes of President Clinton, Prince. Andrew and Donald Trump, but investment bankerJeffrey Epstein will call the Palm Beach CountyJail home for the next 18 months. Epstein, 55, pleaded guilty Monday to felony solicitation of prostitution arid procuring a person under the age of 18 for prostitution, After seiying 18 months in jail, he will be; under house arrest for a year. And he will have a lifelong obligation to register as a sex:offender. He must submit to an HIV test within 48 hours, with the results being provided to his victims or their parents. As part of the plea deal, federal investigators agreed to drop their investigation of Epstein, which they had taken to a grand jury, two law enforcement sources said, Epstein was indicted two years ago after an 11-month investigation by Palm Beach police. They received a complaint from a relative of a 14-year-old girl who had given Epstein, a naked massage at his five-bedroom, 7,234- square-foot, $8.5 million Intracoastal home. Police concluded that there were several other girls brought in 2004 and 2005 to an upstairs room at the home for similar massages and sexual touching. CA/Aronberg-00.1044 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1044 .P-ann _Beacb,er :ple:~ds ln ,s,X: :e,iise 1 , Poste9_ Jul, 1, ZOOS at 1_2:0J AM Updated dct 3, 20i 9 at 1 :47,PM {EDITOR'S NOTE: This s,tory originally published in The Palm Beach Post on}uly 1, 2008) Jeffrey Epstein will serve ,1 1/2 years on teen solicitation charges. He li_ves in a Palm Beach waterfront mansion ang has _kept. company with the, likes ,of President Clinton:, Prince. Andrew and Donald Tr'ilnip, but investment bankerJeffrey Epste_in will ~aH the Palm Beach County Jail home for the next J 8 months. Epstein, '55, pleaded guilty Monday to felony soUcitationof prostittitiori and ptoturing a person under the age ,of 18 for prostitµtiw1. After ser,v:iµg '8 rpopths in j~il, he will be: under house arrest for a year. And he will have a lifelong obligation to register as a sex offender-. ,He. must- submit to a_n I-UV test-within 48 hours, with the results being proyided to his victims ortheir P-arents. As part of the plea deal, federal investigators agreed to drop their investigation of Epstein, which they had taken, to a grand jury:, 1:Wo law en.forc;em~nt s<;rnrces ~ajd. Epstein was indidedtwo years ago after an U-month irtvesti~atfon by Palm Beach police. Theyreceived a complaint from a relative .ofa 14-year-.old girl who had given Epstein a naked massage at his five..:bedroom, 1:2:34_ squart:Aoot, $8.5 million Intracoastal home. Police concluded that there were several other girls brought in 2004 :md 2005 to an upstairs room atthe home for similar-massages and sexµai touching. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The indictment charged Epstein only with felony solicitation of prostitution. The state attorney’s office later added the charge of procuring underage girls for that purpose. Prosecutor Lanna Belohlavek said ofthe plea: "I took into consideration the. length the trial would have been arid witnesses having to testify” about sometimes embarrassing incidents. Epstein may have made a serious mistake soon after he was charged. He rejected, an offer to plead guilty to one count of aggravated assault with intent to commit a felony, according to police, documents. He would have gotten five years’ probation, had rib criminal record and not been a registered sex offender, the documents indicate., Epstein arrived in court Monday with at least three attorneys. He wore a blue blazer, blue shirt, blue jeans and white and gray sneakers. After CircuitJudge Deborah Dale Pucillo accepted the plea, he was fingerprinted. Epstein then .removed his blazer and was handcuffed for the trip to jail while his attorneys tried to shield him from photographers’ lenses. When he eventually is released to house arrest, Epstein'will have to observe a 10 p.m. to 6 a.m. curfew, have no unsupervised contact with anyone younger than 18 and neither own nor possess pornographic or sexual materials “that are relevant to your deviant behavior,” the judge said, Epstein will be allowed to leave home for Work. The New York-based money manager told the judge he has formed the not-for-profit Florida Science Foundation to finance scientific research. “I’m there every day,” Epstein said. The foundation was incorporated in November. Epstein said he already has awarded money to Harvard and MIT: CA/Aronberg-00.1045 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1045 • • • • • The indictment charged 'Epstein only with felony solicitation ofprostitutiol'i. The state attorney's office later ,added the charge of procuring underage girls for that pt1rpose. Prosecutor Lanna Belohlavek said of'the"plea: '!I to:ok into consideration the. length the trial would have b.een and witnesses l;iaving to testify" about sometimes embarrassing incidents. Epstein may have:made a serious mistake soon after he was charged. He rejected an offer to plead guiltyto One count of aggravated assaultwith intent to commit a felony, according to police. documents. He would have gotten five years! probation, had ilb c1·iininaLrecord ,a:nd not beeri,a registered sex offender, the documents indicate .. Epstei11 .arriyedjn court Monday with,.at lea~t three attorneys, He wore a blue'bfazer, blue,shfrt; bluejeans and white.and gray sneakers. After Circuit)udge DeborahDale PucjU9 accept~d t_he plea, he was fingerprinted. Epstein then.removed his biazer and was handcuffed fonhe trip .to jail while his attorneys tried .to shield him from photographers' lenses. Wh~n he eventually is,released to house arrest, Epstein·will have to observe aJ O p.m. to 6 a.m., curfew, have;no unsupervised contact with anyone younger than 18 and .neither own no_r, pos.sess pornographic or sexual materials "that are relevant to yo.ur deviant behavior," the judge said. Epstein will be allowed to leave home for work. The New York-based money manager told the judge he has formed the not-f9r-profit Florida Scienc::e. f'oundati9Ilto finance scientific- research. 'Tm there ,every day/ Epstein said. The foundation wasintorpotated:in November. Epstein .said he already has awarded money to Harvard and MIT FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM When he is released fromjail, there is a chance that Epstein will be forced to move. Sex offenders are not allowed to live within 1,000 feet of a school, park or other areas where children may gather. No determination has been made as to whether Epstein’s home complies, but attorneys said it likelydoes. Sex offenders also typically must attend counseling sessions. Belohlavek said that was. waived for Epstein because his private psychiatrist is working with him. The judge was skeptical but agreed to it. Epstein’s legal woes don’t end with Monday’s plea. There are four pending federal civil lawsuits and one in state court related to his behavior. At least one woman has sued him in New York, where he owns a 51,000-square-foot Manhattan mansion. “It’s validation of what we’re saying in the civil cases,” said Miami attorneyJeffrey Herman, who represents the alleged victims in the federal lawsuits. West Palm Beach attorney Ted Leopold represents one alleged victim in a civil suit in state court He said lie anticipates amending that lawsuit to add "a few other clients” as well. In the criminal case, police went so far as to scour Epstein’s trash and conduct surveillance at Palm Beach.International Airport; where they watched for his private jet so they would know when he was in town. They concluded that Epstein paid girls 8200 to 8300 each after the massage: sessions. Tm like a Heidi Fleiss,” Haley Robson, now 22, told police about her efforts in recruiting girls for Epstein, There was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation, police concluded. CA/Aronberg-00.1046 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-001046 • When heJs released from:jail, there is-a chance that Epstein. will be forced to move. Sex offenders are not allowed to live within 1,QOO feet qf a school, pru:-lc or other: ;ire~s where chiidren may gather. No-determination has been JTiade as to. whether Epstein's home complies, but attorneys saidit likely does. Sex.: of(e_nders also typicallymu_st attend.cou_nselin,g sess}ons, , , Belohlavek said that was_ waived for Eps_tein b.eca.use his private ·psychiatrist is working with him. The judge was skeptkal bu~ agreed to it. Eps_tein's legal woes don't end with Monday's plea. There are four pending federal.civiUawsuits and one in sta.te court related to his behavior. Atleast one woman has sued him in New Ypfk, w.lJ.er:e he owns a 51,000:..squa_re-fqotJylanhattan mansion. "It's 'validation of what weire .sayin~ in the civil cases," said Miami attorney JeffreyHennart, who represents the alleged vic:tims 1n the fed_eral la,w~J,lits. We~t PalmJ~ea~h att9rn~y Ted Leopold represents one .alleged victim in a civil suit in state court He said he anticipates aniehdihg that lawsuit to add "a few other clients" a_s well. In the criminal case/ poHce·went so far as ~oscoµr Eps~ein'.s trash and con:duct:surveillance at Palm Beach.International Airport; where they watched for his private jet so they woµld know when he was in town. Th_ey cpI1ch1_dedJhat Epstein paid gids $200 to :$·300 each afterthe massage· sessions. 'Tm lj~e a Heidi Fkiss," Haley Robson, now 22, told police ab.out 'her efforts in recruiting :girls .for Epstein. There was prob.able cause to•charge Epstdn with un:lawfu:1 sex acts with-a minor and lewd and lascivio.us molesta:tion, polic;e conc:luded. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/2023 2:27:00 PM The state attorney’s office said questions about the girls’ credibility led it to take the unprecedented step of presenting the evidence against Epstein to a grand jury, rather than directly charging him. Palm Beach Police Chief Michael Reiter was furious with State Attorney Barry Krischer, saying in a May 2006 letter that the prosecutor should disqualify himself. "I continue to find your office’s treatment of these cases highly unusual/’ he wrote. He then asked for and.got a federal investigation. Epstein hired a phalanx of high-priced lawyers - including Harvard law professor and author Alan Dershowitz - and public relations people who questioned Reiter’s competence and the victims’ truthfulness. In addition to mansions in Palm Beach and Manhattan,. Epstein owns homes in New Mexico and the Virgin Islands., He’s a frequent contributor to Democratic Party candidates. He also donated $30 million to Harvard in .2003. Former New York Gov. Eliot Spitzer returned a $50,000 campaign contribution from Epstein after his indictment, then resigned this year during his own sex scandal. And the same Palm Beach Police Department that vigorously investigated Epstein returned his $90,000 donation for'the purchase of a firearms,simulator. Staffwriter Eliot Kleiriberg arid former staff researcher Michelle Quigley contributed to this story. i CA/Aronberg-00.1047 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/ Aronberg-00.104 7 • The state attorney's office said questions about the girls:· credibility led it to take the unprecedented step of pr!;:!senting the, evid~nce against Epstein to a grand jury,, rather than directly charging him. Palm Beach Police ChiefMichael Reiter was furious with State Attorney Barry Krischer, saying iri a May 2006 letter that th(;! pros_ecutor should di_squalify himself. "1 coptinue to find your office's tteat:trren:t of these cases highly unusµal/" .he wrote. He then asked fot and got aJederal favestig;ation. Ep_st_ein 'hired a,. phiila,1u: of high-priced lawyers - including Harvard law professor and author Alan Ders_howitz - and public relations people. who questioned Reiter's ·competence and the victiws't.I"uthfulness. In addition tq rpa,ns1ons i11 P~lm Beach and Manhattan,, Epstein owns homes in New Mexico,andthe Virgin Islands_ .. He'.s ·a frequent toiltributot to. Democratic. Party candidates. He als_o donated $30 .million to Harvard in .2003. Former New York Gqv. Eli9tSpitzerrehuned a'$~0,00b campaign contribution from Epstein ,after.his. indictrn~nt, then resig;ned this year during his own sex scandal. And the same Palm Bea,ch Police Department that vigorously investigated Epstein returned his $90,Q00 donaJionforth~ purchase ofa ffrearms.simulator.- Staffwriter Eliot.Kleinberg and former sta:ffaesearcher Michelle Quigley confribut_ed to this story. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The.Fata Beach Bost REALNEWSSTARTSHERE Jeffrey Epstein: Scientist, stuntmen; ‘sexsUa've’visitjaiBed tycoon By LARRY KELLER / Palm Beach Post Staff Writer Posted Aug 13, 2008 at 12:01 AM Updated Jul 16,2019 at 4:54 PM Tycoon Jeffrey Epstein mingled with an eclectic mix of people, including beautiful youngwomen, before,he got into trouble for paying teenage girls to give him sexual massages at his Palm Beach mansion. Not much has changed, even though he now resides in a dorm at the Palm Beach County Sheriffs Office's 17-acre, 967-bed stockade near the fairgrounds. During his first month of confinement, Epstein was visited by the female assistant who, girls told police, had escorted them to the room at his mansion where they gave him naked massages. Also trekking to the jail was a young woman whom Epstein purportedly described as his Yugoslavian sex slave. The wealthy financier and science wonk also has been visited by an expert on artificial intelligence, as well as a man who is a mixed martial arts aficionado and sometime movie stuntman. The only other people to visit him at the jail, according to records, are a Singer Island man and an individual who listed Epstein's Palm Beach address as his own. Epstein, 55, pleaded guilty onJune 30 to two prostitution- related charges and was sentenced to 18 months in jail,: followed by a year of house arrest. Epstein paid teenage CA/Aronberg-00.1048 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1048 letfr.~y.·_:f:rlsl~ill= ·Sci~n'Jist~. ·stu·ntman\ 'se~ ·shiv.et :vis~it'j'.alled; tY~iJQht' By LARRY KELLER lPalm Beach Post Staff Writer Posted Aug 13, 2008 at 12:01 AM Updated Jul 16.; 2019 at 4,54 ·PM Tycoon Jeffrey Epstein mingled with an eclectic mix of people, 1ncluding beautiful young·women, before:he got into trouble for paying teenage girls to ·give him s_exual massages at his Palm Beach mansion. Not much has changed, even though he. now resides in a do:rm at. th,_e P;ilm Beach. CqunJy Sl_ieriffs Office's F-acre, 967 ,,;h_e<i sto.ckade near the fairgrounds. During his first mortth of confinemen:t, Epstein was visited by.the female assistant'who, girls told police, had escorted tl:iem, to the room ,1t)1is Iil:J}1sion wh~re tl,ley gaye him •naked massages. Also trekking to the jail was a young woman whom Epstein purportedly described as his Yugoslavian .sex slave. The we~Jt_li.y finaIJ,~ier ;ind scjep,ce wonk also .h_a~ beep,: visited ·by:an ex:pert on a:rtificialirltelligen·ce, as well as a mah who. is a mixed martial arts aficionado and sometime movie stun_tman, The only other people to yisit him ~t the jail, ,according.to records, area Si'ngerlsland man and an individual who· listed Epstein's Palm Beach address as his ·own. Epstein:, 55 ! pleaded guilty on June 30 to two prostitution- related charges and was sentenced to 18 months. in jail, followed by :a year of house arrest: Epstein paid teenage FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM girls $200 to $300 in 2004 and .2005 for massages in his home that sometimes included.sexual touching, Palin Beach police said. His jail visitors in July included: - Sarah Kellen, 29, who some of the teen masseuses said phoned them when Epstein was in town and escorted them upon their arrival at his Palm Beach waterfront home to an upstairs room, where she prepared the massage table and provided the oils for their encounters;with him. Kellen visited Epstein three times in July, according to a jail visitor's log. Kellen lists a Manhattan home address. Reached by telephone, she declined to discuss Epstein. - Nadia Marcinkova, 23, whose familyin Yugoslavia Epstein paidmoney to so that he could bring her to the United States to. be his “sex. slave," two teenage girls told police. One girl, told police that Epstein instructed Marcinkova and her to kiss and have sex while he Watched and masturbated. Another said she engaged in sex with Marcinkova at Epstein’s urging. Marcinkova visited Epstein in jail four times in 13 days. She lists.her address as on the Upper East side of Manhattan, not far from Epstein's enormous apartment. - Roger Schank, 62, founder of the Institute for Learning Sciences at Northwestern University and an expert on artificial intelligence, paid one visit to Epstein. Schank has written numerous books on that subject and has a doctorate degree from Yale University in linguistics. He was one of 19 people who applied to be president of Florida Atlantic University in 2.003.. He became; “chieflearning officer” at.the online Trump University in 2005. Schank listed his address as being in Stuart, and records show he also owns a home in Lake Worth. CA/Aronberg-001049 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1049 • • girls ·$200 to $300 in 2004 and .2005 for massages in his home that sometimes included. sexual touching, P'alm Beach polic;e sald, His jail visitors inJuly included: - Sarah Rel1en, 29, who some of the. teen m_asseuses said phoned them when Epstein was-in town and escorted them upon their arr.ival at his Palm Beach waterfront home,to an upstairs mom! where, she prepared th~ massage table and provided the oils for:their encounters,with him. Kellen visited Epstein three times in July, according to a jail visitor's l9g. Kellen lis_ts a Manhattan hom.e address .. Reached· by telephone, she declined to discuss Epstein. - Nadia Marcinkova; 23; whose'familyin Yugoslavia Epstein paid:money·to so that he could bring her to the United States to be his ''sex slave," two teenage girls told police. One girL told police that Epstein instructed Marcirikova and her to kiss and have sex while .he watched and masturbat~<;l. Anoth~r said she engag~d in se"?C with Marcinkova at Epstein's urging. Marcinkova visited.Epstein inja:il four times in l3 days. She lists:her address as on the Upper Ea,~t side of Manhattan, not far from Epstein's• enor:moqs a,p:artment. - Roger Schank, 62, founder of the Institute for Learning Sciences at Northwestern University and a:1t expert on artificial inteUig~nce, paid one. vi~l_t tQ Epstein. Schank has written numero.us books on that subjec;t and has a .doctorate degree from Yale University in linguistics. He was one of 19 people who ~ppHed to be president ofFlor,ida Atlantic University in 2003 .. He became. "chief learning officer" at. the onlirie Trump University.in 2005. Schank.listed his addtes·s as being: in St\l:i.rt, and records .~how he al~o 9wns a, hqme :in, Lake Worth. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM CA/Aronberg-001050 Epsteinhas financed a number of scientists over the years, including Nobel Prize winners. He gave $30 million to Harvard University in 2003. In November, he formed the not-for-profit Florida Science Foundation, which he said finances scientific research. - Igor Zinoviev, a Russian mixed martial arts fighter, who coaches a Chicago team in the International Fight League. He also has worked as a personal trainer, celebrity bodyguard and movie stuntman, according to the league’s Web site. The New Jersey resident visited Epstein seven times in July. Zinoviev, Schank and Mar.cinkova could not be reached for comment. Staff researcher Niels Heimeriks contributed to this story,. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-001050 I I Epste~ financed a number of scientists over !~s, 1ndu9,ingNobel Prize winners, He gave $30 m..iJlio)J.to . Harvard University in.2003. In November,heformedtfe hoVJor'"ptofit Florida Science Foundation, which he sa+d finances scientific research. - Igor: Zinoviev, a Russ1an.mixed martial arts fighter, who coaches a Chicago team in the' Internati.onal Fight L.eagµe. He also haswotked as a.personal trainer, celebrity bodygµard ;3.n,dmoyie stuptqian, according to the league's Web sit!:!. The:NewJersey resident visited Epstein sE:!ven times in July. Zinoviev, Scharik and Marcinkova could not be reached for comm~nt. Staffresearch~r Niels Hdme:riks cQntr1butE:!d; to this story. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM felmtechMIf News ; i Bi1Iionaire sexoffensier leaves jail six days aweek forwork Posted Jul 1.2008 at 12:01 AM Updated Oct 4,2019 at 9:27 AM Palm Beach billionaireJeffrey Epstein, who’s serving 18 months in jail for soliciting an underage girl for prostitution, is allowed to leave the Palm Beach.County Stockade six days a week on a work-release program. Teri Barbera, spokeswoman for the Palm .Beach County Sheriffs Office, confirmed that Epstein, 55, has'been in the work-release program since Oct. 10. "He works six days a week: Friday through Wednesday 10 a.m. to 10 p.m.,” Barbera said via e-mail. ”(He) works at his local West Palm Beach office, monitored on an active GPS system (he wears an ankle bracelet), Mr. Epstein hires a permit deputy, at his expense, for his own security at his workplace, during the time he is out.” Miami attorneyJeffrey Herman represents six young women who ve sued Epstein, claiming he sexually abused them at his Palm Beach home when they were minors. Herman said he received a letter about the work-release program from the U.S. Attorney's Office within the.past few days. But Herman says Epstein had. been out on work¬ release for several weeks before the notification. “My clients expressed shock and disappointment,” Herman said. “I find it incredible that he’s on work-release in the community and my clients aren’t notified of this and we get this letter weeks after the fact.” Jack Goldberger, Epstein’s criminal attorney, said the CA/Aronberg-00.1051 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-001051 B,iUi'q1,1ajie s~x;·:siff~nde)~ :1~·":v . .,s=jail six; :da, s ~tw.a:fe]tlor: \WO'tk-· --·-- .... _Y,_ ... - ·: ... ·• ·- ___ ,., ....... . l?ost~d Jul 1, 20.08.at 12:01 AM Updated Oct 4, 2019 af 9:27 A.M Palrn Beach billjqnaire j effrey Epstein, who's serving 18. months in jail for soliciting an 'tmdera~e girlfor- prostittition, is allowed to leave the Palm Be<!-ch.County Stockade six days ::i. week on a work-release program. Teri Barher_a, spokeswoman for the Palm Beach Co.unty Sheriffs Office, confirmed that Epstein, 55; has' been in the worhrelease program since Oct, 10. "He w9r_\q; six: days a week: Frid_ay thr:ough W edn~sday 10 a.m. t_p 10 p.m.," Barb~ra sai<lvia e,-,mail. 1j(He) works at his lo:ca.L West Palm. Beach office, trion:itored on an active GPS system (he wears an ankle bracelet), IVlr. E'p~tein h,ires a permit dep\lty, at his expense, for his own security at his workplace, during the time he 'is out.;; Miami attorney Jeffrey·Herman represents sixyourig women who'.ve sued Epst_ein,d::i.imin,g'he se::wally _c1.bused themat:his Palm Beach home when they were minors. Herman said he. received a letter about the work~.release ·program from the lJ.S. Attorney's Office withi11 th~ pa~t few days. But Herman says Epstein had.been out on work- ·releas~ for several weeks before the notification. "Mydients expressed shocka!}.d disc1.ppoi11tment," Ben;nan said. "I find it incredible that he's on work-release in th:e community and m:y clients aren't notified .of this and we get this letter weeks .after the fact." Jack Goldberger, Epstein's criminal attorney, s~id the FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM arrangement is not unusual. "He goes to work every single day and,goes back to jail at night, just like everybody else (in the program),” Goldberger said. Epstein pleaded guiltyJune 30 to two felony counts: soliciting prostitution and procuring a person under 18 for prostitution. As part ofthe plea agreement, Epstein must serve one year of house arrest and register as a lifelong sex offender. CA/Aronberg-00.1052 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1052 • • arrangeme11t is no_tu11_usual. "He: goes to work every single day and, goes _back to jail a,t ni~ht,justlike everybody eise (in the program)," Goldberger said. Epstein pleaded.guiltyJune 30to two felony cou!).ts: solid ting prostitution and procuring a p<:1rson,under- l8' for prostitution.- As part of the plea agreement, Epstein must serve one year of house arrest and register as a lifelong sex offender. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The’Whn>e®ch Bast REALNEWSSTARTSHERE I Women want Epstein sex plea deal unsealed Posted Jul 1,2008 at 12:01 AM Updated Oct 2,2019 at 2:23 PM (EDITOR’S NOTE: This story originally published in The Palm Beach PostJune 10, 2009) Their attorneys will ask a judge to open Jeffrey Epstein’s records. When wealthy money managerJeffrey Epstein of Palm Beach pleaded guilty last year to procuring teens for prostitution, his case detoured around local and state rules regarding the sealing of court documents. At a plea conference on the state charges, a judge, a defense lawyer and a prosecutor huddled at the bench and decided that a deal Epstein had struck with federal prosecutors to avoid charges should be sealed, according to a transcript of the hearing. And so itwas. But Florida rules ofjudicial administration, as well as rules of the Palm Beach County court system, require public notification that a court document has been or will be sealed, meaning kept from public view- The rules also require a judge to find a significant reason to seal, such as protecting a trade secret or a compelling government interest. Yet.no notification or reason occurred in Epstein’s case, according to court records. CA/Aronberg-001053 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/ Aronberg-0O1053 - . I i\AJQ:ment '.Vif~Pl Epstebr.s~x ,p'le,; :d,al :urtstulled: .. - .,. .,.,. - -·,. ,- Posted Jul 1, 2008 at 12:0l AM' Updated 0d 2; 2019 af2:23 PM (EDITOR;S NOTE: This story originally published in The Palm Beach Post June 10, 2009) Their attorneys will ask a judge to openJeffr~yEp$tein's records. When wealthy money manager Jeffrey Epstein: of Pa:im Beach pleaded guilty last year to procuring teens for prostitu.tion,his case det9ured a,roundlqcal and state rnles_ regarding the ,sealing -of co_urt documen:ts. At a plea conference: on the .state charges, a jtidge, a defense lawyer and a prosecutor huddled at the bench and decided th.at a dea1::gpstdn ha,d$truck with federal prosecutors to avoid charges should ,be sealed, according to a transcript of the heating. Andsoitwas., But Florida, rµl~s c:>f judicial administr_atfon, as well as J.ttle_s of the Palm Beach County, court system, require public notification that a: court .document has been or will be sealed,,meaningkeptfrom public yiew-. The rules also require a j11dge Jo:find a significant reason to seaf, such as protecting •a trade secret or a compelling govermneht int~rest._ Yet,no notification or reason occurreci in:Epsteiri'.s case, accor<lingto to.urt.reccirds. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Epstein sown attorneys, in federal filings', have referred to his confidential deferred prosecution agreement with the U.S. attorney’s office, struck in September 2007, as "unprecedented” and "highly unusual.” And it was "a , significant inducement” for Epstein to accept the state’s ■ deal, observed the state judge who accepted his plea, CountyJudge Deborah Dale Pucillo. Epstein now faces at least a dozen civil lawsuits in federal and state courts filed by young women who said they had sex with him and now are seeking damages. Attorneys for some ofthose women want his agreement with federal prosecutors unsealed and will ask CircuitJudge Jeffrey Colbath to do so today. "It.is against public policy for these documents to be have been sealed and hidden from public scrutiny. As a member of the public, E.W. has a right to have these documents unsealed," wrote former CircuitJudge Bill Berger, now in private practice-and representing one ofthe women. The Palm Beach Post also will ask Colbath to unseal the agreement. Post attorney Deanna Shullman will argue that the public has a right to know the specifics of Epstein’s deal; According:to various media accounts, Epstein moved in circles that included President Clinton, Donald Trump and Prince Andrew. "International Moneyman of Mystery,” declared a 2002 New York magazine profile of Epstein, Epstein, 56, is in the Palm Beach County Stockade, serving an 18-month sentence after pleading guilty nearly a year ago to felony solicitation ofprostitution and procuring teenagers for prostitution. He is allowed out from 7 a.m. to 11 p.m., escorted by a deputy, said Palm Beach County Sheriffs Office spokeswoman Teri Barbera. CA/Aronberg-00.1054 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/ Aronberg-00.1054 .! Ep,tei!wn attorneys, in federal fiiings; h:ave referred to his confldential deferred prosecution ,agr.eemeht with the U.S. attorney's office, struck in September 2007, as "unprecedented" and "highly u11usµal." AI1d;it_ w:as "a significant inducement" for, Epstein to accept the state'.s i deal, observed the state judge who accepted his plea:, County Judge Deborah Dale Pucillo. Epstein now faces at least a dozen civil .lawsuits in, feder.tl arid state courts ;filed by young women who said they ha:d sex with him and ·now a:re seeking damages; Attorn~ys' for some of those women want his agreement withfederal prosecutQrs unsealed and will ask Circuit Judge Jeffrey Colbath to,do so today. "I tis ag;aihst ptibhc policyJot these documents to be have been sealed and hidden from public scruti11y. A,s a me_mber of the p11blic, E.W. has a right to haye these documents unseaied/' wrote former Circuit Judge Bill Berger, now in ptivateptactice-ahd representing one ofthe women. The Pilrn Beach Post also will ask Colbath to unseal the agreement. Post attorneyDeanha,Shullman:will atgue,that the,public has aright to know the specifics ofEpsteii;i'.s cleat: According' to ya,rious media accoµnts, Epstein moved in cirdes that indu.ded President Clinton, Donald Trump :and Prince, Andrew. "International Mof1eyman of Mystery," declared a 2002 NewY9rk magazine profil,e,of Epstein, Epstein, 56, is in the Palm Bea~h County'Stockad~, serving .an 18-month sentence after pleading ·guilty nearly a year ago to felony :solicitation of prostitution and procuring teenagers for prostitutfon. He. is allowed out from 7 a.m. to 1l p.m., escorted by a deputy, said 'Palm Beath County Sheriffs Office spokeswoman Teri Barbera. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM During a Palm Beach Police Department investigation, five victims and 17 witnesses gave statements. They told of young women brought by his assistants to Epstein’s mansion on El Brillo Way for massages and; sexual activity, and then being paid afterward. At Epstein's plea conference last year, his -attorney, Jack: Goldberger, and.then-Assistant State Attorney Lanna Belohlavek approached Pucillo in a sidebar conference. Pucillo, who had left the bench nine years earlier, was filling in temporarily as a senior judge. According to a transcript, Goldberger told Pucillo that Epstein had entered a confidential agreement with the U.S. attorney’s office in which federal prosecutors brokered not pursuing charges against him if he pleaded guilty in state court. Pucillo then said she wanted a sealed copy of the agreement filed in his case, and Goldberger concurred that he wanted it sealed, Belohlavek later signed off on it. The Florida Supreme Court has expressed "serious concern” arid launched an all-out:inquiry into sealing procedures across the state followingmedia reports in 2006 of entire cases being sealed and disappearing from court records. "The public’s constitutional right of access to court records must remain inviolate; and this court is fully committed to safeguarding this right,” justices wrote in-their final report. Epstein’s office on Tuesday referred any questions to Goldberger, who declined to comment. Pucillo also has declined.to comment. i CA/Aronberg-001055 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1055 • • During a Palm Beach Police Department investigation,Jive victims a,nd 17 witp.es~es gave sti:lten1ents. Tpey tqlcl of young women broughtbyhis,assistants to Epstein's mansion on El Briilo Way for massages and, sexual activ.ity, and then being paid afterward. At Ep~tein's plea coµference lastyear, :his ,attor11ey, Jack: Gqldb~rger, and;then-Assistant State Anorney Lanna Befohlavekapproached Pucillo ih a sidebar conferen:te. Pucillo, who had left the bench nine years earlier, was filling ,in temporarily as a :s.enior judge. According to a transcript, Goidberger told Pucillo that Epstein had entered a confide-ntial agree:tneht with the U;S. ;itt9rney's 9ffice in which frderal prosecutor:s b_rokeri:!d p.ot pµrs_uing chai;ges against him if he pl'eadeq guilty in state court. Pucillo then said she wante.d a sealed copy of the agreement filed-in his case, and Goldberger concurred that he wanted it se_aled, Belohlayek later signed, qff qn it. The Florida Supreme Co.urt has· expressed '"serious concern" and laun·ched an alh-outinquiry into sealing procedures across the state following media reports in2006 of entire cases being sealed and dis_appearing from court. records. "The 'p.ublic's constitutional right of ac::cess to court records mustremairt inviolate; and this court is folly committed to Si:lf~g\larding ¢_is _dgh_t/justkes vvi:ote in,their final repor:t. Epst_ein'snffice onTuesday referred any questions to Goldberger, who declined to :comment. Pucillo also has declined to comment. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:27:00 PM The PalmBeach Bast REALNEWSSTARTSHERE Epstein secret reveals “highly unusual” terms Posted Jun 10,2009 at 12:01 AM. Updated Oct 4,2019 at 9:23 AM (EDITORS NOTE: This story originally published in The Palm Beach Post on September 19, 2009) A secret non-prosecution agreement multimillionaire financierJeffrey Epstein struck with federal prosecutors is being called “highly unusual” by former federal prosecutors and downright outrageous by attorneys now representing young women who. serviced him. The deal reveals:"that the FBI and the. U.S. Attorney’s Office investigated him for-severalfederal crimes, including engaging minors in commercial sex. The crimes are punishable by anywhere from 10 years to life in prison. But federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein pleaded guilty to prostitution-related.felonies in state court, which he ultimately did; He received an 18-month jail sentence, of which he served 13 months. The U.S. Attorney's Office also agreed not to charge any of Epstein’s possible co-conspirators: Sarah Kellen, Adriana Ross,. Lesley Groff and Nadia Marcinkova. The deal was negotiated in part by heavyweight New York criminaldefense attorney Gerald Lefcourt. Unsealed on Friday after attorneys for some ofEpstein.'s victims and The Palm Beach Post sought its release, it offers the first public look at the deal Epstein’s high-powered legal counsel brokered on his behalf. CA/Aronberg-00.1056 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/ Aron berg-0O1056 f pste'i:n: se.c.re,t;p'a~t. with,: teds r.eveals "hl • hi ··• urui-su:af'·terms, ,'" . , . _g., .Y . , . .·. . . , , Posted Jun 10, 2009 at 12:01 AM. Updated Oct 4, 2019 at 9:23 AM (EDITQR;S NOTE: This story origina'lly published'ln The Palm Beach Post on September 19, 2009) A s~cret non ..:prosecution ~greement multimillionaire financier Jeffrey Epstein struck withfederal prosecutors is being called "highly unusual" by former federal prosecutors ;,ln_d dovmright 9utrageous by attorneys now representing youn,g women who. serviced him. The deal reveals: that the FBI and the.US. Attorney's Office investigated him for· sevetal. federal crimes, facludin~ eJ~g;,lgi,ng minors ~n commercial sex. The crimes are punishable 'by anywhere from 10 years to life 1.n. prison., But federal pr.os_ecutors backed down and agreed to recall grand jury subpoenas if Epstein pleaded guilty to prQ~tttutiqn_-ri:!latedJelonies· fn state, court, which he ultimately did, He re.ceived an 18-month jail :sentence, of which he served 13 months. The U.S. Attorney's Office also agreed notto charge any of Epstein); possible co-q>nspir~t,o:rs:,Sarah J(,'fd,ler11 Acµ:i@a Ross,. Lesley Groff and Nadia Marcinkova. The deal was negotiated in part by.heavyweight NeviYork crimin;µ defense attorn~y Gerald Lefcourt. Unsealed on Friday after attorneys for sqme of Epstei'n'.s victims and The· Palm B.ea.th Post sough tits release, it offers the first.public look at the deal Epstein's high-poweredJegal counsel brokered on, his behalf. .•, FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM MarkJohnson of Stuart, a former federal prosecutor, described the disparity in potential sentences as unusual, but even more so a provision on attorney payment. The first draft of the agreement in September 2007 required that Epstein pay an attorney — tapped by the U.S. Attorney’s Office and approved by Epstein -- to represent some of the victims. That attorney is prominent Miami lawyer Bob Josefsberg. But an addendum to the agreement signed the following month struck Epstein’s duty to payJosefsberg if he and the victims'did not accept settlements — capped.at SI 50,000 — and instead pursued lawsuits. Johnson.said it appears the government was trying to balance the lesser sentence for Epstein with recovering SI50,000 for each victim. “I’ve never, ever seen anything like that in my life,” he said. TVs highly unusual.” The deal does not say whether any victims were contacted of consulted before the deal was made. Attorney Brad Edwards of Fort Lauderdale, who represents three of the young women, believes that none of the 30 to 40 woman identified as victims in the-federal'investigation were told ahead oftime. Edwards said his clients received letters from the. U.S. Attorney’s Office months after the deal was signed, assuring them Epstein would be prosecuted. "Never consulting the victims is probably the most outrageous aspect of it/’ Edwards said. “It taught them that someone With money can buy his way out of anything. It’s outrageous and embarrassing for United States Attorney’s Office and the State Attorney’s Office.” Epstein now faces many civil lawsuits filed by the women, who are represented by a variety of attorneys. In many, the allegations are the. same: that Epstein had a predilection for teenage girls, identified poor, vulnerable ones and. used CA/Aronberg-001057 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1057 I .• . . .: Mark~son of Stuart, a former federal prosecutor, described. the disparity, in.potential sentences a:s unusual, but even more so- a provis'ion on attorney payment. The first draft of the agreement in September 2007 requirec:l that"Epsteil} pay an attorney -- t<).pped by the Q.S. AttCirnefs-0ffice and ~!?proved by Epstein ~-:to.tepreseilt some of-the victims. That attorney is prominent Miami lawyer Bob Josefsberg. But an addendum tothe·agreementsigned the following month .struck Epstein's duty to pay.Josefsbetg if he and.the victims· did not accept settlements -- capped.at $150,000 -- and 'instead pursued lawsuits. Johnson said it appears .the government was frying to. balance the lesser ·sentence for Epstein with recovering $150;000 for ~ach victi_m. 'Tve.11ever:, eve_r seen anything like that in my life," he said. "It's highly unusual.'' The_ deai does not say whether a:nyvictims Wl:!te contacted of consulted.before the deal was made. Attorney Brad Edwards of Fort Lauderdale, who represents thre_e of the young women, believes, that none of the 30 to 40 woman identified as victims in the federal investigation Were·toldahead of time. Edwards said his.clients received letters frorn the U.S . .A,ttome)(s Office months afte_r the de_al was ,signed,, assuringthE!mEpstein would be· prosecuted. "Never consulting the victims is probably·the most outrageous aspe.ct ·ofit;'.' Edwards s,,iid. "It taught them that some:one With money can buy his way out ofartythin~·- It's outrageous and embarrassing for United States Attorney's Office ancl the State Attorney's Office."' Epstein now faces many civillaws.uits filed by the women, . . . who are represented by a variety ofattorheys. ln many, the allegations are the, same: that Epstein had a predilection for teenage_ g1rls, ic:lentified poor, vulnerable ones and. use4 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM other young women to lure them to his Palm Beach mansion. They walked away with between. $200 and $1,000. : . i Former CircuitJudge Bill Berger, also representing victims,, called the agreement a "sweetheart deal,” "Why was it so important for the government to makethis deal?” Berger asked rhetorically. "We have not yet had an honest explanation by any public official as to why it was made ... and why the victims were sold down the: river,” Former federal prosecutor Ryon McCabe described the agreement as "very unorthodox.” Such agreements, he said, are usually reserved for corporations, not individuals. “It’s very, very rare. I’ve never seen or heard of the procedure that was set up here,” said McCabe, who has no involvement in any Epstein litigation. "He’s essentially avoiding federal prosecution.because he can afford to pay that many lawyers to help those victims review their cases.... If a person has no money, he couldn’t be able to strike: a deal like this arid avoid federal prosecution.” The backroom deal with federal prosecutors is all the more interesting in.light ofthe legal powerhouses who have worked for .Epstein, including Harvard professor Alan Dershowitz and Bill Clinton investigator Kenneth Starr. Lefcourt is a past president of the National Association of Criminal Defense Lawyers. Epstein’s local defense attorney, Jack Goldberger, issued a statement Friday saying he had fought the release ofthe sealed agreement to protect the third parties narried there; "Mr. Epstein has fully abided by all of its terms and conditions. He is looking forward to putting this difficult period in his life: behind him. He is continuing his long¬ standing history of science philanthropy.” CA/Aronberg-001058 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1058 • other yoqng women to lur.e them to his Palm Beach man:sion. They walked away with betwe.e1t$20Q and $1;000. I . . . I Former Circ:uitJudge Bill Betget,alsore_presen:ting vittirtis;. calle_c;l th.e agreemel)t a "sweetheart deaL" "Why was it so impo.rt_ant for the gqvemment to make this deal?" Berger asked rhet<Yrkally .• ;'We .ha:ve not yet had an honest explanation byany:public: official as to why''itwas made ... ancl:why the'victims ·were sqld <iqwn the: river.'.' Former federal prosecutor Ryon McCabe described the agreement a:s "very liriorthodox:" Such a:&teeinertts, he said; are usually reserved for corporations, not in&viduals. "It".svery, very rare. Fve never seen or heard'of the procedure that was setup here;" said McCabe, who· has no involvement in any Epstein: litigation. "He's essentially avoiding federal prosecution. because he can aff9rd to. P<!Y t;hat many fawyei:s to help those victims reyiew their cases .. ,. If a person.has no money, he couldn:'t be able to strike a deal like this·a:ndavoidfederal The b:i.ckroom deal with federal prosecutors is all the more ihter:estin:g in.iight of the legal powerhouses who.have worked for .Epstein, including Harvard professor Alan Dershqwitz and Bil_l Clinton fovestig~tor· Kenneth Starr. Lefoourt is a pa.st rresident of the National Association of Criminal Defense Lawyers. Epstein's local defe11se attorpey; J ac:k Goldl:>erger, ·issued a statement Friday saying he had fought the release of the . . sealed agreement to protect the third parties named there, "Mr. Epstein has fully abided by all of its-terms and cqnditic:ms. He is lookillg forward to_ putting this difficult yeriod in his life behind him. He is·contin:uinghis lon:g:- standing history of science philanthropy." FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The investigation triggered tensions between police and. prosecutors, with then-Palm Beach Chief Michael Reiter saying in a May 2006 letter to then-State. Attorney Barry Krischer that the chiefprosecutor should disqualify himself. “I continuelo find your office’s treatment of these cases highly unusual,” Reiter wrote> He then asked for and got the-federal investigation that ended in the sealed deal. "The Jeffrey Epstein matter was an experience ofwhat a many-million-dollar defense can accomplish,” Reiter told the. Palm Beach Daily News upon his retirement. I CA/Aronberg-001059 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1059 • . .i The investigation trigge:recl tensio-qs betwe~n_poljce and. prosecutors, with then:-PalmBeach.Chief Michael R~ite,r saying in a May 2006 letter to then-State Attorney Barry Kris ch er that the chief prosecutor should disqualify himself.,, . I "I conti_nue'to find your office's treatment of these-cases highly unusual/ Reiter wrote; He"the11 asked for anci got the· federalinvestigation that ended in the sealed de.al. "The Jeffrey Epstein matter was an experience of what a many-million-dollar defense can accornplish," Reiter told the; Pafm Beach Daily News upon his retirement. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 187/ 278 - Wednesday, January 27, 2010 Edition: FINAL Section: LOCAL & BUSINESS Page: 3B Source: By JANE MUSGRAVE Palm Beach Post Staff Writer Dateline: WEST PALM BEACH JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS In a decision that could spark a constitutional showdown over privacy rights,: ajudge Tuesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to subpoena abortion records from women who are, seeking millions in damages froth the part- time Palm Beach resident. Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut the women's claims that they suffered psychological, ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as young as 14. Hafele told Epstein's attorneys they c.ouldn't go on a fishing expedition. The medical records^ he said,, can't be sought until the women are asked whether they.have ever had ah abortion, how many and where. Further, he said, the records would not be made public and might not be admissible during trial. But, he said, since the vyomen claim Epstein, now 57, is responsible for their emotional distress, his attorneys can explore the impact of other events. Medical records, Hafele said, are a better source of information than a person's memory. Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm Beach clinic where abortions are performed, warned Hafele that.he was stepping on shaky constitutional grounds. "These records arc protected by our constitutional right of privacy," he said, referring to the Florida Constitution. After the hearing, Silver said an appeal won’t be necessary until,Epstein attorneys seek the records. In another ruling Wednesday, Hafele also said that videos from depositions in the state cases can't be released without a court order. The ruling came after Epstein attorney Robert Critton complained that a video of Epstein being asked whether he had an "egg-shaped" penis became a youtube.com sensation. It first appeared on The Palm Beach PostWeb site. Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was .public record. The civil suits began mounting after Epstein agreed to plead guilty to two state charges: procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18- month sentence. As part of the deal brokered with federal prosecutors, he agreed not to contest the accusations in the civil lawsuits., He 'can argue the women don't deserve the millions they arc seeking. [email protected] CA/Aronberg-00.1060 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • 187 / 278 - Wednesday, January 27, 2010 Edition: FINAL Section: LOCAL &BUSINESS Page: 3B Source: By JANE MUSGRAVE Palm Beach Post Staff Writer Dateline: WESTPALM BEACH • JUDGE RULES EPSTEIN ATTORNEYS-CAN SUBPOENAABORTION RECORDS In a decision. that could spark a c·o11stitutio11al showdowti over priyacy rights,. a judge Jµesday gaye laW)'ers representing multimillionaire sex offonderJef:frey Epstein the right to subpoena abortion .records from woineh who are. seeking millions in :damages frofu the part- time Palm Beach resident. • PaJrti Beach County Circuit Judge Donald Hafele };aid the retotds could help Epstein rebut the women's claims that they suffered psychological.ills after l?eing paid.to give him sexually-charged massages at his Palm Beach mahsionwheii they were as young as 14. Hafele t_old Epstein's attorneys they c.ouldn't go on a fish1ng expeditfon. The medical records, he said,. can!t be sought until the women are asked whether they.have ever .had an abortion, how many and. where. Further, he said, . .the r.ecords would.not be made pµblii:: aD<l might not be admissible duri'ng 'trial. But, he said, siiwe the women claim 'Epstein, now 57, is responsible for their emotionai distress, his attorneys can explore the impact of other events. Medical records, Hafele said, are a better so_urce ofinformation than a person's memory. Attorney Louis Silver, who represents the Presidential Women's Health Center, .a West Palm Beach clinic where abortions are performed, warned Hafele that.he was stepping on shaky constitutional grou1ids. "Thes.e. records :are: protected by our constitutional right of privacy," he said, refeningJo the Florida Constitution. After the hearing; Siiver said an appeal won't be necessary until .Epstein attorneys seek the records. In ·another ruling Wednesday, Hafele also said that vide.os fr.om depositions in the. state cases can't be, released :without a court order. The. tulirtg came after Epstein attorney Robert Critton complained that a video ofEpstein being asked whether he had an "egg.:shaped" penis 'became a y6Utt1be.torh sensatio1t It first appeared on The.Palm Beach Po_stWeb site. Critton blamed ,attorney Spencer I<.uvin for releasing it. Kuvin. said it was .public record. The civil ~uits began mounting. after-Epstein agreed to plead guilty to two .stc1t.e. charges: procµring a minor for prostitution and soliciting prostitution. He: served 13 months of an 18- mohth sentence. As part of the deal broh:red with feder~l prose~µtors, he agreed :Qot to contest the accusations in the civil .lawsuits .. He :can argue the wom·en don't deserve the millions they are seeking. --jane _ [email protected] CA/Aronberg-00.1060 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM TheMmBeach Bost REALNEWSSTARTSHERE . ,— . - —- - -- ■ , - ... . — ... „ - . . ; — • . Epstein Journal’s Findings Could Resurrect Case By Jane Musgrave Posted Sep17,2019 at 12:01 AM Updated Oct1,2019 at 10:51 AM: (EDITOR’S NOTE: This story originally published in The Palm Beach Post on March 20, 2010) A purloined journal that is said to contain the names of "hundreds” ofvictims of convicted sex offender Jeffrey Epstein could be used to'reopen the investigation into the multi-millionaire's appetite for teenage girls, an attorney representing seven of the victims said Friday. New details about the contents of the journal were released this week when.Alfredo Rodriguez, who worked as a property manager for the Palm Beach resident, pleaded guilty to obstruction ofjustice for lying to federal agents when asked if he had any information about his former boss' criminal activity. He later tried to sell the journal he Stole from Epstein for $50,000 to an unidentified person, who alerted authorities, according to court records. As part of the plea agreement, federal prosecutors saidthe journal “contains information material to the. Epstein investigation, including the names of material witnesses and additional, victims.” "Had the items been produced in response to the inquiries ofstate or federal authorities ... the materials would have been presented to the federal grand jury,” federal prosecutors wrote. CA/Aronberg-001061 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-0O1061 Ep~s:tein lournaI's• fio:~in,gs £OJiJdl ·Re.sutrect: 1C11se· , . ~ - . , . . ,,,, By Ja11e. Musgrave: Posted Sep 17, 2019 at "12:01 AM Upd.ated Oct 1, 2019 at 10:51 AM (EDil"OR'S NOTE: Thts story originally published in The Palm Beach Post on March 2012010) A purloined journal that is said to contain the names of "hundreds" ofvictims of c9nvicted s~x.offencier Jeffrey Epstein co.uld be used to'reop·en the investigation into the multi-millionaire's appetite for teenage :girls, an attorney representing sev~n of the victim~ said Friday. N'ew details ahoutthe contents of the jou_mal were reJe~sed this week when,Alfredo Rodriguez, who worked as a property manager fot the'.Palm Beach resident, pleaded gl!ilty to obstruction of j\J~tice for lying to Jederal agents when asked ifhe had.anyinformationabovt.hisformer boss' criminal activity. He later tried to .s.ell the journal he stole from Epstein for $50,000 to an unidentified person, who alerted authorities, a.c:cording to court records. As part of the plea agreement, federal prosecutors said the journal "contains information material to the. Epstein investigation, including the name~ of ma.teri.itl witnesses and additional victims." "Had the items been produced in response to the inquiries of state or federal authorities ... the materials would have be.en presented to the federal grand jury," federal prosecutors wrote. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Instead, prosecutors short-circuited the grand jury investigation and cut a deal with Epstein. They agreed riot to pursue federal charges if he didn’t contest prostitution- related felonies in state, court. The money manager pleaded guilty in July 2008.to procuring-a minor for prostitution and soliciting prostitution. He served 13 riioriths of an 18- month sentence. Attorney Adam Horowitz, who represent s seven of the roughly 18 women who have filed civil suits against; Epstein, said the new information could trump the so- called non-prosecution agreement. The multifaceted agreement, he said, deals only with a specific list,of victims that the U.S. Attorney's Office knew about when it penned the deal in 2007. If additional victims are listed in the journal Rodriguez stole) Horowitz said federal prosecutors could reopen the investigation., Tt:opens the door for further prosecution,” he said. In addition to turning over the journal to federal agents, Rodriguez told them he knew his former boss was having sex with.underage girls when he worked for him in 2004 and 2005. He had seen naked girls, who looked like,minors, in the pool of Epstein’s $8.6 million mansion. He had seen pornographic images of young girls on Epstein’s computer, according to court records. Neither Epstein's criminal defense attorney, Jack Goldberger, nOr attorney Robert Critton, who represents Epstein in the civil lawsuits, could be reached. Federal prosecutors have consistently declined comment. The Wording of the controversial agreement is unclear. It says federal prosecutors Would provide Epstein’s attorneys “with a list of individuals whom it has identified as victims,” Miami- attorney RobertJosefsbergwas appointed to I CA/Aronberg-00.1062 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/ Aronberg-00.1062 • • Instead, prosecutors short--:circuited. the grand fury investigation a:nd.c:uta deal With Epstein. They agreed not tq p1.1rsue fec:leral charges ifhe dldn?t.cqntest pros_dtutioµ,- related felonies in state coµrt. The money manager, pleape_d guilty in July 2008.to procuring' a rnin•or for p·rostitutiori and soliciting prostitution. He served 13 mcii1thsof an '1'8- month sentence. Attorney Adam Horowitz~ who represents seven.of the ro.ughly 18 women who have filed civil suits .against Ep,s~ein, said the new information could trump the so- called ;non~proserntion.agreemen t, The multifaceted agreement, he said, deals only with a specific list of victims thatthe U.S. Attorriey'.s Office knew abqut when i.t pe_nn~d the deal in 200?. If~dditional vi_ctims are listed •in the journal Rqdriguez stole, .HoroWitz said federal prosecutors co.uld reopen the investigation., "It opens the door for further prosecution," he said. In addition, tQ tµrnlllg 9ye1; the j<;rnrnaLto federal agent~, Rodrig:uez told them he knew his formerbosswas,having sex with .. undetage girls when he worked for him in 2004 and 2005. He had seen naked. girls; ·who looked like·,minors, in. the pool of Epstein's $8.6 mH}iqn mansion. H~ ha:c:f seen pornographic: images ofyoung girl~ on Epstein's computer, according to court records; Neither Epstein! s criminal detense atj:qrney, Jack Goldberger, nor attorney Robert Critton, who represents Epstein in the civil lawsuits, could be reached, Federal pr◊serntors have consistenfly declined c;omment. The wording ,oft.he contro:versiai agreement is unclear-. It says federal .prosecutors would prom de .Epstein's attorneys "with a U,st of:il)diyidualswh,orn i_t hc1,s_ i<;l<:!_ntihed·as v1_ctjms," Miami"attorney Robert Josefsberg was appointe'<l to FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM represent any of the victims on the list who wanted to pursue Epstein in civil court. As part of the agreement, Epstein is to pay for Josefsberg to represent the women. Some ofthe women,- most identified as Jane Doe in lawsuits, had already hired attorneys to represent them. Some have since settled their suits with Epstein, although terms were not disclosed. Horowitz said he has filed court papers to get the journal that Rodriguez stole. “It’s another piece of evidence that shows our clients were at Epstein's mansion," he said. Rodriguez told prosecutors he didn’t turn over the journal when both FBI and Palm Beach police asked for it because he wanted money for it. He: also saidhe was afraid Epstein would make him "disappear.” The information, he told investigators, was his “insurance policy,” He faces a maximum 20 years in prison when he is sentenced on June 18. [email protected] @pbpcourts CA/Aronberg-00.1063 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1063 • • rep_resent any of the victims on .the list who wanted t◊ pursue_ Epstein in civil court. As part of the; agreement; Epstein is to pay for Josefsberg to represent·the women. Some of the,womeh; rhost identified as Jane Doe in laws_uit~, ha_d already hired attqmeys tc>represent them. Some haye since settled their suits with Epstein, although termsWere,not disclosed. Horowitz said he has filed court papers to get the joµr_I)al that Rodriguez stole. "It's ,mother piece of evidence that shows our clients were at Epstein's manSion,"'.he said. Rodri&ueztold prosecutors he.didn't turn over the fournal when both FBI _and I,Jalm Beach police -~sked-for i_t because he wanted money for it. He· also said he was afraid Epstein would make him ''disappear." The,ihformation, he told investigators, was hi~ "insurance poli<:y." He.faces a maximum 20.years _in prison when he is sentenc.:ed onJune 18. [email protected] @pbpC(?UftS ,:'.~ ... ,• r. ~ •• >',;.:.. ... , FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The Palm Beach Post REALNEWSSTflRTSHERE . Epstein paid three women $5.5 million to end underage- sex lawsuits By Jane Musgrave Posted Oct 3; 2017 at 12:01,AM Updated Oct 4,2017 at 12:46 AM Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young women who claimed he used them as sex toys, court documents filed last week show he shelled out $5.5 million to settle lawsuits with,three of more than two dozen teens who sued him. Responding to requests from Epstein’s attorneys in a complex lawsuit that was spawned by the sex scandal, attorney Bradley Edwards said the politically-connected 64-year-old convicted sex offender paid more than $1 million to each of the three women Edwards represented. Identified in court papers only by their initials or pseudonyms because of the nature ofthe allegations and.their youthful ages, L.M. was paid SI million, E.W. $2 million,andJane, Doe $2.5 million, Edwards said ofthe settlements he negotiated with Epstein to end the lawsuits. Jack Goldberger, one of Epstein’s criminal defense attorneys, on Tuesday declined comment on the revelations, citing confidentiality agreements that were part of the settlements. For the same reason, he declined to say whether Epstein,paid,similar amounts to settle roughly two dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex when some were as young as 14 years old. AttorneyJack Scarola, who is representing Edwards, said his client was compelled to divulge the confidential settlements, to answer questions,posed by Epstein’s attorneys. “Brilliant move on their part,” he said. Even if Epstein’s attorneys hadn’t: opened the door, Scarola said the information would have likely come out. He says th&information will help him undermine Epstein’s claims that Edwards “ginned up” the allegations to help; his former law partner, imprisoned and disbarred Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1,2 billion Ponzi scheme. CA/Aronberg-00.1064 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • E'pst,dn ,p:ald 1h:r,-e ',W.CUTIQn: :$.5,.5; mUliQJl :tQ' ,p,nd, :und~·rage~ sel<Y:h1wsuils- By JaneJv'lusgr~ve Posted Oct 3; 2017 at 12:0lAM Updated OctA, 2017 at 12:46.AM Ending years-of speculation about how much Palm:Beach billionaire Jeffrey Epstein paid young - -- '.(-;--":;'-·.i:~+.· . • ... . ·i• wom(m who claillled.h_e,,used them.as sex toys, court documents filedJast week showhe shelled out $5.S-miUion to settle lawsuits with three of morethan·two dozen teens who sued him. Responding to requests from Erstein's attorneys in a complex lawsuinhat was spawned by the sex scandal, attorney Bradley Edwards. said;the politicalJy.:connected 64-year-old convicted sex offender pifd rnore tha]) $1 mHJfon tq each ofd1_ethree womenEdw~ds_repi:esented'. Identified in court pape.rs only 'by their inidals orpseuqonym,s ·bec~use of the nat\J,re qf the allegations and their youthful ages,-L.M. was paid $1-million, E.W. $2 million.andJane.Doe $2.S million, Edwards said of the settlements 'he negotiated with Epstein to end the lawsuits. - :.t.,.-. -- --¥'.· ~ .: •• Jack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday decljned comment on the revelations, citing .confidentialityagreementnhat·were part of the settlements. For the .same rea:sonj he declined to say whether Epstein.paid.similar amounts to.settle roughlytwo dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex • ·• .. : .. :.,_>_, ____ ; when some were as yotmg as 14years old. Attorney Jack Scarola, who is tepresenting Edwards, said his client was compelledto divulge the confidential settlements to answer questfons. posed by 'Epstein's attorneys. "Brilliant move on their part," he sa{d. Even if Epstein's attorneys hadn't opel)ed the door, Scarola said the information would have likely come out He says the,informatioh will help him undermine Epstein's daimsthat Edwards "ginned up"•the allegations to help his former law partner, imprisoned and disbarred FortLauderdaklawyer Sc:qtt RothstRin, perpetµate a $LQ, billion Ponzi s~heme. CA/Aronberg-0O1064 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The revelations of the settlements came as part of an ongoingdawsuit:that started as a dispute between Epstein and Rothstein, both billionaires. J A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a minor for prostitution, he sued Rothstein and. Edwards, claiming they trumped up the allegations of sexual molestation to perpetuate the Ponzi scheme. Rothstein was sentenced to 50 years in prison in 2010 after admitting; he had built his wildly successful law firm by forging the names of federal judges and others to persuade investors he had negotiated settlements in lawsuits against high-profile people. Investors were told they could get a cut of the cash. One of the high-profile people Rothstein used to lure investors was Epstein, according to a lawsuit West Palm Beach attorney Robert Critton filed on Epstein’s behalf. According to the lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the. lawsuits With the teens for $200 million — a claim Critton described as “a complete fabrication.” After Epstein dropped the.lawsuit in 2012, Edwards turned the tables on him. Edwards accused Epstein of filing the.lawsuit maliciously to punish him for representing the young women. Although Edwards was a partner in Rothstein's now defunct firm, Scarola claims Epstein had no evidence Edwards was involvedin the .Ponzi scheme. Federal prosecutors successfully charged other attorneys and members of the firm, butEdwards was .never implicated, Scarola said in the malicious prosecution lawsuit. The revelations about the money Epstein .paid to three .of the young woman came last week in documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit, Attorney Torija Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the: trial, in part, because she claimed she.has been unable to talk to her client since his estate on Jus private island in the U S. Virgin Islands was devastated last month by Hurricane Irma, “I’ve had no ability to communicate.With Mf. Epstein,” she said. CA/Aronberg-00.1065 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • The revelations ofthe settle"inents came as part of an ohgoing;lawsuinhai: started as a dispute between Epstein and Rothstein, both billionaires. ,A year afterEpstei11, i112008 pleaded gqjlty to solicitation qf prnstjJutio,ri ancl procµring a mino.r for prostitution, he sued Rothstein .an·d. Edwards, claiming they tn~mped µp ilie allegations of sexual molestation to perpetuate the Ponzi scheme. Roth~tein was sentenced to SO years in·prison in 2010 after admitting:he:had.buikhis wildly successful law firm by forging the nam:es of federal tudges and othe.rs to persuade investors, he had nego_tiated .settlements in lawsuits against high,.:.profife people. Investors were told they could get a cut of the cash. One of the high-profile people Rothstein used to lure inves,tors was. EpsJein, according to a lawsuit ·west Palm )3each attorney Robert Critton filed on Epstei1/s behalf. A<oco_rding to the lawsuit, Rothstein told investors Epstein, a. money manager, had agreed to ·settle the lawsuits with the teens for $200 million - a claim ·Critton described as "a complete fabrication." After Eps,tein. dropped th_el_awsµit in 20l2; Edwards t_urned the t.il;ilgs on i)i111, Edwarcis accused Epstein o(filing the laws_uit maliciously·to punish him for representing the y~rnng WQJUen. Although Edwards was a: partner in RothSteirt'.s how defunct firm, Scarola daims Epstein had no evidence Edwards was involved in the .Ponzi scheme. ,Federal prosecutors successfully charged other attor:neys and members of the firm, hut,Edwards was .never iinpliq1ted, Sqarola said in the malicious ,prosecution lawsuit. The. re:Velations about the money Epsteirtpaid to three of the yolirtg woman came lastweek in documents filed f9r a hearingTuesday:in preparation for a Dec:eI}lbertrial.on fu.e lawsuit, Attorney Tonja Haddad Coleman, who represents' Epstein,· on. Tuesday sought a delay of the tda], in part, because s.ne claimed sh~ ,has been unabl~ to talk to her: dient sinc;e his ~st.ate on ;his private island.in the U:S. ·virgin Islands was devastated las( month by Hurricane Irma. 'Tve had .r1o·abilicyto communicate,with Mt. E_1?stein/' she sai'd. CA/Aronberg-001065 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Pointing out Epstein's enormous wealth and his private jet, Palm Beach County CircuitJudge Donald Hafele rejected her request,, While saying he didn’t want to appear insensitive to those victimized by the storm that hammered the Caribbean and roared through South Florida, he said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims. Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide before the case goes to trial. Despite Searola's insistence that Edwards had nothing to do with Rothstein's Ponzi scheme, Coleman said the evidence indicates, otherwise. Why else would he try to depose Epstein's well-known friends, such as now President Donald Trump, former President Bill Clinton and illusionist David Copperfield, she, asked. He used the celebrities as a-draw, she said. “The Epstein cases were used to fleece money and defraud investors,” she said. Edward'smalicious prosecution case has/been difficultfbr both sides because both Epstein and Edwards have refused to answer questions. As he did in the civil lawsuits; Epstein has invoked his Fifth,Amendment right against self-incrimination when questioned by Scarola, Edwards has claimed that much of the information Epstein is seeking is protected by attorney-client privilege. The malicious prosecution lawsuitis one oftwo hotly-contested lawsuits that continue to pit Edwards against Epstein. Edwards also is suing the U.S. attorney's office, claiming it violated the federal Crime Victims Rights Act when it negotiated a:non-prosecution agreement with Epstein, Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein’s agreement to settle lawsuits filed against him by dozens of his underage victims. CA/Aronberg-00.1066 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • Pointi;ng o:ut Epst~i:n's erwrmouswealth and his private jet, PahnBeach County Circuit Judge Donald Hafele rejected her request., While saying he didri't want to appe_ai; insensitive to tho'se victimized by the Storm that hammered the Cadbl:,ean and roared through South Florida, he said 'Coleman offered,nq proof, :such _as· an :i.ffidavit from Epstein, to shore up het claims. •Still, Hafele ,gave_ Coleman extra time to respond to various motions that he will have to decide before the case goes to trial. Despite Scarolls insistence that Edwards h,a_d nothi:ng to do with Rothstein's Ponzi scheme, Coleman said th_e evjder,ice ip,<iicates: otherwise. Why .else would he try Jo depose Epstein's wen..:known friends,surih as now President Donald Trump, former P~esidentBUl Clinton and illusionist David Copperfield, she, asked. He used the cele_brities as a:draw, she said. "The Epstein cases were used to Jleece inoney and defraud investors/' she ·said. Edward's:malicious prosecuti_oµ case ·has,been difficult:for :both sides because both Epstein and Edwa,rds ,l:1ave refusedt,o answer questions. As he did in the civil lawsufrs; Epste\n has 1nyoked his Fifth,A:mendment right against -self-incriminatfon whe11 questioned by Scar:ola .. Edwards has claimed that much of the information Epstein is se_ekingis protected by attorney-client privilege, The rn.ali,cious pr:osecution lawsuit is one oftwo hotly-contested lawsuits :that c:o:n_tti,weto pit Edwards against Epstein. Edwards also 'is suing the U ,S. attpr_n!:!y's office, claimingjt vioiated . . . . . l . . the federal Crime Victims Righ_ts Act when it negotiated :a:non-prosecutiort agreemehtWith Epstein. Only after federal prosecutors agreed to drop their.investigation ofEpstei'n, did he agree to plead guilty,to two prostitution charges in P:11m Beach County Circuit Court. In federal. court records, prosecutors cJa'irn q,ne-ofthe key reasons they agree·d to drop their case'was Epstein's agreernentto settle lawsuits filed against him by dozens of his underage vj.~tirns. CA/Aronberg-00.1066 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Palm Beach Daily Judge rules feds’.agreement with Jeffrey Epstein pact violated/teeft victims’ rights By Jane Musgrave Posted Sep 17,2019 at 4:02 PM Updated Oct 8,2019 at 12:31 PM (EDITOR’S NOTE: Titis story originally published in The' Palm Beach Post on February 22, 2019) Federal prosecutors violated the rights ofJeffrey Epstein's teenage victims by failing to reveal they had dropped plans to prosecute the.billionaire bn dozens of federal charges in connection with the girls’ claims that he paid them for sex at his Palm Beach mansion, U.S. DistrictJudge Kenneth Marra ruled on Thursday. In a blistering 33-page ruling, Marra meticulously and methodically detailed the numerous steps federal prosecutors took to hide the agreement from more than 40 young women who claim Epstein paid them for sex when they were as young as 14, "While the government spent untold hours negotiating the terms and implications ofthe NPA with Epstein's attorneys, scant information was shared with the victims,” Marra wrote.. "Instead,:the victims were told to be 'patient' while the investigation proceeded.” By then, it was too late. A deal had already been cut with then-South Florida U.S. Attorney Alex Acosta and.Epstein's attorneys to shelve a 52-page federal indictment against Epstein, a former math teacher turned money manager who counts Presidents Donald Trump and Bill Clinton among his friends. CA/Aronberg-00.1067 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1067 Jud·e~tules ifeds' t~r··reem:entw,ith,· .. __ g: .. 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Jef:frey,.!~psteiatp.ac.t v1otated,J.;eu1: ivlcti~:s' ti:ghts By Ja11~Jv1usgr~ye Posted Sep i7, 2019 at4:02 PM Updated Oct 8; 20.19. at 12:31 PM (EDITOR'S NOTE: This story originally published in The' f'alm _Beach Post on February 22; 2019) Federal prosecutors violated the rights of Jeffrey Ep_stein's teenage, victims by failin&·to reveal they had dropp:ed plans to pr9sec~te the.billionaire on.dozens ,offedetal charges in connec.tion with the girls' claims tb<!t,he;paidtbem for St;!X at his' Palm B.eath mansion, U.S. District Judge Kenne.th Marra.ruled onThursday. 111 ~-bHstergig. 3J-page ruling; Marra meticulously arid methodically detaHe_d the n,umei:-ous steps federal prosecutors tookto hide the agreemerttfrom more than AO young women who cla:im::Epstein paid them for sex whert they wer<:! as yo\lng _as 14, "While the goyernment spent\lntoldho\lrsnegotiaJing the terms and implications ofthe NPA with Epstein's attorneys, scant infqrmat_io.n was shared with the victims," Marra wrote. "lns_tead,: the victims were. told: to be 'patient' while the investigation proceeded." By then, 1t was too late. A deal had already been cut with then-South.Florida U.S. Attorney Alex Acosta and.Epstein's attorneys to she lye a 52~page Jedera1 indict1:r1ent_ agains_t Epstein, a former rnatli teacher turned money man:a~et who counts Pr~sidents Donald Trump and Bill Clinton. among his .friends. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Prosecutors failure to alert the young women about the deal violated the Crime Victims’ Rights Act,.Marra ruled. "At a bare minimum the (act) required the government to inform (the young women) that it intended to enter into an agreement not to prosecute Epstein,” he wrote. Still, Marra said he wasn’t second-guessing prosecutors' decision not to pursue Epstein on federal charges if he pleaded guilty to minor state prostitution charges and agreed to compensate his victims for the trauma he caused. "The court is;not ruling that the decision not to prosecute was improper," Marra wrote. "The court is simply ruling that, under thefacts of this case, there was a violation Under the CVRA.” Further, he made no decision about what the remedy should be. He gave prosecutors and attorneys representing the young women 15 days to meet to decide how to unravel the complex legal web that has.been hanging over Epstein and his young victims ,for more than a decade. The chances an accord will be reached are slim, said attorneyJack Scarola, who is representing the two Jane Does who challenged the prosecutors' actions. Further, he said, there is no road map to follow. The lawsuit attorney Bradley Edwards filed on behalf of the' two unidentified young, women, claiming prosecutors violated the federal act, is unique, he said, “We are treading on virgin ground, to use what is probably an inappropriate phrase in this situation,'' he said. 5 Scarola said he and Edwards will ask that the nOn- prosecution agreement be thrown out, That would open the possibility that the long-shelved federal indictment could be dusted off and filed against the 66-year-old Epstein, who spends most of his time on a private island he owns in the U.S, Virgin Islands. i .. ... .. ... ,„i.. CA/Aronberg-00.1068 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1068 •• • Prosecutors' failure to alert the young women about the deal violated the Crime Victims' Rights Act"Marra ruled. "Ata Qc:J.re mip.imuw the (act) required the govern.me11t to inform (the young women) that it intend.ed to enter intp .an a_greement hot to prosecute Epstein/' he:wrote. Still, Marra said he wasn't second-guessing prosecutors' de~is_1on n_ot to purs.ue Ep$tein on.federals charges ifhe pieaded guilty to minor· state prostitution charges :and ·agreed to compensate his victims for the trauma he caused. "Th~ court is ,not ruli11g that the decision not to prosecute was improper,IJ Marra wrote. "The couttis simply ruling that; under the,facts of this case, there was a violation under theCVRA;" Fµr.t;her, b:e m.ade 11q decision about what the remedy .sho.uld be.- He gave prosecutors alld attorneys reprnsenting the youngwomert 15 days to meet to decide.how to unravel the complex legal web that has, been hanging over Epstein and his• young vie rims Jqr mwe tl;ian, c1 dgca.d<::!, The chances an: accord wilf be reached are Slim, .said attorney Jack ;Scarola, who is representing the two Jane Does who challen,ged the prosecutors' actions. Further, he s_aid, there is no n)ad,i:nap to fol.low; The lawsuit attorney Bradley Edwards filed.on behalfofthe't-wo unidentified young. Women, claiming ptosecutors violated the federal act, is unique, he said. "We are treading· _on virgin ground, to use-what is probably an 'inappropriate phrase in this situation," he said . .Scarola said he arid Edwards will ask that the non- prosecution agreement be thrown out., Tha,t would op7n the. possibility thanhe long-she'Ived federal indictment could be dusted off and filed against the 66'-'year~old Epst.eJn, who spendqnost of his time on a private ·islarid he owns, in the U.S. Virgin Islands, I '••··••'• J FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM "I don’t see the government conceding to that remedy,” Scarola admitted. Further, he said, it is likely Epstein will be allowed to weigh in. Miami attorney Roy Black years: ago filed papers asking to intervene on Epstein’s behalf. The U.S. Attorney’s Office said it wouldn’t comment on Marra's ruling. Neither Black nor New York City attorney Jay Lefkowitz, who led efforts to bury the federal indictment, responded to emails or phone calls for comment. West Palm Beach attorneyJack Goldberger, who represents Epstein, also didn’t respond. Scarola said it is likely Epstein’s star-studded legal team will argue that Epstein fully complied with the terms of the agreement he made in 2007 with federal prosecutors and therefore the agreement can’t be undone. As he promised, Epstein pleaded guilty in June 2008 to state charges of soliciting a minor for prostitution and soliciting prostitution. He served 13 months of an 18-month jail term in a vacant wing of the county stockade that he was allowed, to leave 12 hours a day, six days week. Further, as agreed, he paid settlements to the young women who sued him. While the settlements were confidential, court records show he.paid three women a total of $5.5 million. In return, federal prosecutors held up their end of the bargain.. Their investigation ceased. Having done all that prosecutors asked of him, Scarola said Epstein Will make a simple argument: “You can’t turn around and deprive me ofthe benefits 1 bargained for.” However, Scarola said, using’ Marra's ruling,, hewill counter that the contractEpstein signed was illegal and therefore unenforceable. CA/Aronberg-001069 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1069 -• • "ldort't see the government conceding to that remedy;'' Scarola admitted. Further, he safd, ids likely Epstein will l?e allowed to weigh in. Mfami attorney 'Ro¥, Black years ago fil'ed papers asking to intervene on Epstein'.shehalf. The U.S. Attorney's Office said itwotildn'.t comment oh Marra's ruling.Neither Black.nor.New York C,ity attorney Jay L_efkowil:_z, who led efforts to bu.ry thefe_cleral indictment, responded to·:emails ,or phon:e·calls for comment. WestP.almBeachattorneyJack Goldberger, who represents Epst~fo,_ also didn't respond. Scarola said it is likely Epstein's star'-studded legal team will argue that. Epstein fullt complied with the terms of the agreement he made in 2007 with federal prosecutors and therefore_ the agree_ment can't be undone. As he promised, EP,stein pleaded guilty in June 2008':to state cha:r~es of soliciting a minor for prostitution.and soliciting prostitution. He ·served 13 months .0L1n J8..:month jail t_erm in a vacant wing of the county stockacle that he was allowed. to, leave 12 hours a day; six days week. Further, as agreed, he paid settlements to the young ·women who sued him. While the settlemeptswer:e c9nfalenJial, cournecords show he:p:aiclthr.e_e wom·en:a toJal of $5.5 million . .In return, federal prosecutors held up their end of the bargain· .. Their Investigation ceased. Ha\Ting done all that prosecutors ,asked ofh'im, Scarola said Epstein will make a simple, argument: ·"you cari'.t tl.ltn ,around and. deprive me of the qenefits I bc!rgafoed for." However, Sc_arqh( s_aid, using Marra's. ruling, he:wiH counter thatthe cqntract.Epstein signed was iliegal and therefore unenforceable. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Even if Marra agrees to toss out the non-prosecution agreement; Scarola conceded that doesri’t mean Epstein will face federal charges. “The contract can be set aside and the federal government can attempt to enter into the same agreement/’ he said. “Except the spotlight of public attention will be oh them and the 40 victims will be able to explain to the court why this sweetheart deal should not be approved." Scarola said that prosecutors may'have had good reason not to pursue Epstein. "There may be.a reasonable explanation but we don’tknow'what,that reason may have been," he said. In court papers, federal prosecutors have said that many of the young women were, afraid to cross the powerful, politically connected .money manager and simply refused to testily against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prosecution agreement thrown out, initially described Epstein as “an awesome man” and told prosecutors she hoped “nothing happens” to him, While she later agreed to testify against Epstein, prosecutors said they feared Epstein’s attorneys would use her words to destroy her if she ever took the witness: stand. Marra, however, said the young woman’s comments didn’t mean shewasn’t entitled to know about the prosecutors’ plans to drop the charges. “There is ho dispute that Epstein sexually abusedJane Doe 2 while she was a minor,” he wrote. "Therefore, regardless of her comments to the prosecutor, she was a victim.” Before the case is finally resolved, Scarola predicted that “a lot ofpeople are going to have to. answer a lot of questions/’ CA/Aronberg-00.1070 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-001070 · • • Even if Marra agrees to toss out the non~prosecution agreement, Scarola conceded that doesn't mean Epstein will face federal. charge_s. I "The contract can be set .a5ide and the· federal .government cari;attempt to enterinto the same a~reemen:t/' he sa:id. "Except the spotlight of public attention Will be mi them a;nd the 40 vi~tims w.ill be able to eiplaJn to the court. why this sweetheart dea:l should not be approved.'' Scarola said that proseci1tors, may'have had good reason not tq pursue Epstein_. "1J1e_re may be .a reasonable explanation but we don'tknow·what:thatreason may have been," he said. In court papers, federal prosecutors have said that many of the y9u11g wqmep were. ~fraid to cross the powerful, politically connected.money.manager and.simply refused·to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who .is tryµigto have th~ non~prosec;ution agreement thrown out, initially described Epstein as "an awesome man" and told prosecutors she hoped ''.nothing l1appe11s'.' tQ hiIJ1. While sb,e later agreed to testify against Eps.tein,, prosecutors said they feared Epstein'.s attorneys would use her words to destroy her if she ever took the· witness, stand .. Marra, however, said the young woman's comments didri't mean she wasn't entitled .to know abo.ut the• pro_s~cutors' pla.ris to drop the charges. "Tliereis· ho dispute that.Epstein ~exually abu_sed Jane I)9e 2 while spg w.i,~ a, rn.in,or," be Wrote.: "Therefore, regar.dless of her tomrtrepts to: the prosecutor, she was a victim." Before the case is finally· resolved, Scarola predicted that" a lqt of peopli .ire going t9 h_~ve ro. ans;wer .a l.ot 9f questipps:" FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM • • In his ruling, Marra detailed what appeared to be a cozy relationship between.Acosta, his line prosecutors and Epstein’s team of lawyers. His phalanx oflawyers included noted Harvard law professor Alan Dershowitz and Kenneth Starr, the former U.S. solicitor general whose investigation led to the impeachment of President Clinton. Marra describes an October .2007 breakfast, meeting between Acosta, who is now U.S. labor secretary, and Lefkowitz shortly after the non-prosecution agreement was. inked, After the meeting, Lefkowitz sent Acosta a note thanking him for "the commitment you made to me during our October 12 meeting in which you assured me that your Office would not... contact any ofthe identified individuals, potential witnesses, or potential-civil claimants and their respective, counsel in this matter.” Marra quoted an equally pleasant note then-Palm Beach County State Attorney Barry Krischer sent to Assistant U.S, Attorney Marie Villafana, who was the lead prosecutor in Epstein’s case. "Glad we could get this worked out for reasons I won't put in writing,” Krischer wrote, shortly after the non-prosecution agreement was sighed. "After this is resolved I would love to buy you a cup at Starbucks and have a conversation." Many of the notes that were exchanged dealt with prosecutors’ and Epstein's lawyers’ shared desire to keep the deal secret from Epstein's accusers. In a September email, Villafana asked Lefkowitz for guidance about what she should reveal. “And can We have a conference call to discuss what I may disclose to ...,the girls regarding the: Agreement,” she asked. CA/Aronberg-00.1071 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1071 •• • In his rulin~, Marra detailed whar appeared to be a cozy relationship between.Acosta, his line prosecutor~and Ep~tein' s t~a111 of lawyers .. His phalan;x: of lawyers indud~.d note~ Hal'Vard.law professor Ala:nDershowitz and:Kenneth I Starr, the former U.S. solicitor ienetal whose investigation led to the impeachment of Presfdent Clinton. Marra descripes an OcJob~r 2007'.bre:ikfast meeting 'between Acosta, who is now U.S. 'labor secretary; and Lefkowitz shortly-after the·non-prosectition agreement was. 'inked, After the.meeting, 'Lefkowitz sent Acosta a note thanking him for ,;the commitment you made to me during out October 12 meeting in which you assured me that your Offic.e woulq not ... co11t~c:tc1.py ofthe identified individuals, poJential witnesses, or potential ,civil claimants an&their respective counsel in this matter.'.' Marra quoted an equally pleasant note then-Palrn Be.a.ch Cotmry St.it~ Attprn<c!Y, Barry Krisc:her sent to Assis tam D.S. Attorney Marie Viliafana; who was the lea:d prosecutor in Epstein!s ·case. '~Glad we could get this worked out for rea,sons I won't put fr:i wr:iti11g," Krischer wrote, shortJy .after thl':! non ~P.r9secution agreement was signed. "Aftenhis is resolved I would love. to buy you a cup at Starbucks and have a conversatiog." Many ofthe not(;!s that-were exchanged dea:lt with prpsecutors' and Epstein's.lawyers' shared desire to keep the deal secret from Epstein's accusers. In a S~ptember emaU, Villafana asked Lefkowitz for guidanc~ about what ·she should reveal, ,; An.d can we· have a conference call to discuss what I may di'sdose tck .. the girls regarding the Agreem~nt," she a.sked. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM • • Such cooperation between prosecutors and defense attorneys is unusual, Marra said. “It was a deviation from the government’s:standard practice to negotiate with defense counsel about the extent of crime Victim notifications,” he wrote. Further, he noted, that when Edwards and his two young clients asked for information, they were repeatedly misled. “The CRVA was designed to protect victims’ right and ensure their involvement'in the criminal justice process,” Marra wrote. "When the government gives information to victims it cannot be misleading.” Ultimately, the terms of the non-prosecution agreement were revealed only after Edwards and attorneys for the press successfully sued to make them public. @pbpcourts CA/Aronberg-00.1072 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY CA/Aronberg-00.1072 • •• Such cooperation betweenprosecutors and defen~e atton1eys is unusual, Marr.a said. "Jt w_as a deviationrrom the government's:standard practice to n·e·gotiate with defense counsel about the. extent of crirne victim notifications,'' he wrote. Further, he noted, that when E.dwards and his. twp yoµ11g clients asked for information, they were repeatedly misled. "The CRVA was designed toprotectvictirns' right and ensure their ,involvement :in the criminal justfre proc:ess ," Marra wrote. "When the government gives information to vittiJns it cannot be misleading." Ultimately, the terrns of the non~ptosec:ution agreement werer.evealed only after Edwards:am:l at:torneys for the press s~ccessfully sued to make them public. jm usgrave@pbposLcom :·. ••·:. ·,_,.,_._ :;.,, .. ;-••·-• . ..::..::..;.... __ ._.,_,. __ .'. ··.·,··~--... • ,;,-., . ._ .t . .:.co. ·--!'! _, -~ @pbpcourts FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM I • • 76 / 278 - Tuesday, July 9, 2019 Edition: Final Section: A Section Page: 1A Source: By Jane Musgrave, The Palm Beach Post Epstein/ indicted on sex charges Part-time Palm Beacher pleads not guilty to sex trafficking, conspiracy charges in federal court in Manhattan. Dressed in a blue prison jumpsuit^ billionaire Jeffrey Epstein on Monday pleaded not guilty to charges accusing him of creating a vast network of girls as young as 14 that he exploited for his sexual pleasure at' his homes in Palm Beach and Manhattan. The 66-year-old.money manager's appearance in U.S. District Court in New York City capped more than a decade of recriminations,by young;women and their.attorneys,who claimed Epstein used his money and political influence to avoid federal prosecution. Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach County Jail for 13 months more than a decade ago. However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state prostitution charges, prosecutors in New York.indicated they aren't willing to deal. Acosta is now U.S. labor secretary. "The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey Berman said at a morning news conference, "And while the charged conductis from a number of years ago, it is still profoundly important to many of the alleged victims, now young women. They deserve their day in court." At a detention hearing scheduled,for Monday, Berman said he will ask a federal judge to keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to commit sex trafficking, Epstein paid dozens of young women to give him nude massages that, for most, led to sex, he said. If convicted of exploiting: dozens ofyoung women, including many Palm.Beach County girls who were students at Royal Palm Beach High School, Epstein faces a maximum 45-year prison sentence. Citing Epstein's enormous wealth, his homes in New York, Palm Beach, the U.S. Virgin Islands, New Mexico and Paris and his ownership of two jets, Berman said there are few conditions that could keep Epstein from fleeing to a foreign countryto evadeprosecution. CA/Aronberg-00.1073 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • 761278:-Tuesday, July 9,201.9 Edition: Final Section: A Section Page, 1A Source: By Jane Musgrave, Th.e Palm Beach:Pos.t E-psteilt indicted oil' s·ex c)Jarges • f:'art-tio1e J_)altJJ Beac:Jter plea,Js :\lot gpilty to ·sex traffickii1g, con~piracy charges it1 f~deral co11rt in J'1:aidiattaI1. Dressed in a blue prison jumpsuit; billionaire.Jeffrey Epstein on Monday pleaded not.guilty tP clwrge§ a.ccu:,ing,him of freating a vast network o.f _girls 1:18.YO\Jflg a~ _14 that h_e exploited for his sexual pleasure at his homes in PalmBeach •and Manhattan. Th~ 66-year-old mQney man.ager':, a.ppea.rance in D.:S. District Court in New YorkCity capped more than a ,decade of re.criminations. by young;women and their.attorneys. who cl;1im_eq Epstein µsed his mo,ney and politic~} influence t.o ~void federal prpsecutipn. Epstein's attorney Reid Weingarten dismisse.d the two,-count indictment on sex trafficking c:harge~ as "ess.entially a dQ:-ovei" pf allegfl:tiQils that landec;l Ep~teir1 in the Pfl.lm Beach County Jail for 13 months .more than a decade ago, However, µnlike in.2007' when tll~n.-South:FJori~a O .S. At1:orney Al~x Acosta agreed to shelve a 53-page Jederal indictment affer Epstein agreed to 'plead guilty to two state prostitution charges, prosecutors in New York.indicated they aren't willing to deal Acosta. :is now U .S·. labor secretary; "The alleged behavior sho~ks the. c:onsciepc:e; ;,. New York City U :S. Attorney Geoffrey Herman said at a morni11g news conferel)ce,. ''And while the c;h;rrged conduc;_tjs from a nwnber ofyears c,1gq, it is still profoundly important to .many of the alleged victims, now young -women. They deserve th~ir d_ay in. c9,urt" At a detention hearing scheduled for Monday, Berman said he will ask a federal judge to keep Epstein behind bars until ·he js tried on charges of sex tr,afficking and 0c:onsp.iracy to commit sex trafficking: Epstein paid dozens of youngw.omen:to.give,himnude massages tb~t, for rnost, led to s~x, he sc:tid. • If convicted of exploiting dozens of young. women, inchiding many Palm. Beach County girls who were students at Royal 'Palm Beach High School; 'Epstein faces a maximumA5~year prison sentence. Citing Epste'in's enormous .wealth, his homes in New York, Palm Beach, the US. Virgin Islai1ds, New Mexico ai1d Paris and his>ownership of two jets, Berman said there are few conditions that could keep Epstein fi-om flee1hg to·aforeign c:ountry-to f.',Vadf.', prnsec:ution. CA/Aronberg-00.1073 I I I I .. .; FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM "We think he's a significant flight risk," Berman said of the man who: ferried Britain's Prince Andrew, actor Kevin Spacey, famed Harvardlaw professor Alan Dershowitz and former President Bill Clinton on his jet, dubbed the Lolita Express. Berman's hard-line stance was welcomed by young women who for years have been told that Epstein couldn't be touched because Acosta signed off oh the hdhprbsecutidn agreement, promising not to charge Epstein in federal court. Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning her into his sex slave and forcing her to have sex with others, including Dershowitz and Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she told the Associated Press. Dershowitz has vehemently denied Guiffre'sclaims. New York prosecutors were able to ignore the controversial nonprosecutibn agreement because it contained some: significant fine print, said former federal Judge Paul Cassell, who for years has fought to get the agreement thrown,out.. It says only that no charges could be filed against Epstein in South.Florida, he said. Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of Florida, " he said. "The. Southern District ofNew York is not bound by that, agreement and wasn't a signatory of it." That.means the sordid allegations that have been leveled at Epstein for years are now part of a federal indictment. Contrary to Epstein's claims, he knew the women who came to his homes. in New York and Palm Beach were minors because they told him their ages, according to the indictment. Epstein preyed.on young girls because he knew they were; "vulnerable to exploitation," prosecutors added. As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while he was in New York so they would be available for sex once he returned to Palm Beach, the indictment says. The employees weren't named. They were identified Only as "Employee-1," "Employee^" and "Employee-3." To ensure he had a steady stream of young girls, Epstein would turn some victims into recruiters, He would pay them to bring new girls to his home on El Brillo Way along the Intracoastal Waterway in Palm Beach or to his palatial townhouse on New York's Upper East Side. "This allowed Epstein to create an ever-expanding web of new victims," Berman-said. In both New York and Palm Beach, the lurid operation was similar. Unidentified employees of Epstein's would escort the teens into a room. They were told to take off all or most of their clothes before giving the naked billionaire massages, according to. the indictment. "Epstein would also typically masturbate during these encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys," the indictment says. As part of the criminal complaint, prosecutors are asking that Epstein be forced to turn over his multimillion-dollar townhouse on East 71 st Street. The' complaint does not seek forfeiture, of Epstein's: house in Palm Beach. While.heartened that Epstein now faces serious criminal charges in New York, Cassell said he would continue to push a West Palm Beach-based federal judge, to throwout the nonprosecution agreement.that Acosta forged with Epstein's star-studded legal team. CA/Aronberg-00.1074 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • i•We tliink h¢'~ & .s_i'gnificant flight risk," Berma11 said of the 1han who ferried Britain's Prince Andrew; actor Kevin Spacey, famed Harvard, law professor A'ian :Oershow,itz and former Presiqent Bill Clinton-on his jet, dubbed the Lolita Express. Bennan's hard-line stance was. welcomed by young ~omen who for years have been told that Epstein c:ouldn't be touched because Acosta signed off oh the n:onprosecuticin agreement; promising not to charge Epstein in 'fed~ral court. fonn€:lr l'alm Beach County resident Virginia Guiffre, whcj'has accused Epstein oftumirtg her into his sex slave and forcing her to hav.e sex with others, .induding Dershowitz and J>rince Ancirew, ·praised Berman. He·shbwed the case is "being taken in a serious Way," she fold the Associated Press. Dershow.itz 'has-vehemently dented Guiffre'.s claims. N.ewYork prqsecutors were able to :ignore the controversial nohprosecutioh agreement because it cortfained some, significant fine print; sa1d. i:ormer federal Jlldge Paul Cassell, \vho fQr years has fought tQ get the agreement thrown out.It says only that no charges could be filed against Epstein in South.Florida, he said. •• • Berman agreed. "Tl}_at agreement on\y binds, by its tetms, only binds the Southern District of Florida," he said, "The Southern District of New York is not bound by that agreementand wasn't a signatory o[:it." Thatmeans the sordid allegations that have been leveled at·Epstein for years are now part of a federal indi.ctment. Contrary to Epstein's claims, he knew the women who came. to his homes. in New York and Palm Beach we_r.e l)linors bec:m1se they told him their ages, according to the indictment. Epstein preyed.on young girls. because he knew they were: "vulnerable to exploitation," prose~uiors a.dded. As part of a carefully orchestrated sex ting; Epstein or his associates would call girls while he was in New York :so they would be av~U~ble for sex once he returned to Palin Beach, the indictment says. The ·employees weren't named; They wete:identified only as. l!Employee-1," 11'1~mployee~2•i 3)1d "E:mployeec3." To ensure'he had a steady stream of young girls, Epstein would tum some victims into recruiters, He would< Ray the111 to bringnew girls to.hi~ home on 131 Btillo Way along the IhtracoastaLWaterway in Palm Bea:ch or·to his palatial townhouse on New York's U,pperEast Side. "This allowed Epstein:to create art ever~expanding web ofnew·victin1s;'' Berman.said. In both New York and Palm Beach, the lurid operation was similar. Unidentified employees of Epstein's: Would escort the teens ,into a room:. They. were told to take off all or most of their clo.thes before giving"the naked biliio11alre IDJ}ssage.s, ~ccor<;lillg to.the i<nc!ictment, "Epstein would also typically .masturbate during these e11counters, ask victims to touch him: while. he· masturbated; and touch victims' genitals with his)1ands or with sex toys," the indictment says. As part of the criminal complaint, prosecutors are asking that Epstein be forced to turn over his multimillioh-dollat townhouse on East 71 st Street. The• complaint does i1ot seek forfeiture, of Epstein's:house in Palm Beach. •• While.heartened that Epsteih.hoWfaces serious criinina:1 charges in New: York, Cassell said he would conti'nue to push a West Palm Beach"-based federaljudge to throw·out the nonprosecution agreementthat Acosta forged with Epstein's star-studded legal team. CA/Aronberg-001074 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM U.S. District Judge Kencnth Marra has already ruled that Acosta violated! the federal Crime Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked. Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight Monday, explaining what action Marra should take to redress: that wrong. Gassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida victims deserve justice in Florida," said Cassell, who is:working on behalf of Epstein's victims'with attorneys'Bradley Edwards and Jack Scarola. Since it's likely Florida women will get to testify againstEpstein in New York, Scarola said he's not focused oh whether Epstein will face charges here.. Instead, ho said he wants to know how and why the agreement was reached. "There's been no explanation as to how a deal like this could have been cut and how the federal government could have been involved in a.conspiracy to violate federal law," Scarola said of his interest in continuing the legal battle over the. nonprosecution agreement. When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two prostitution charges and served 13 months of an 18-monthsentence in a vacant, wing of the Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He was also forced to register as a sex offender and settle civil lawsuits more than 30 young women filed, against him. U.S. Rep. Lois Frankel, D-Wcst Palm Beach, said she shares Scarola’s interest in finding out how the agreement came to be."I am especially more interested in why Epstein got the deal he got," Frankel said. "We need to know why he was given such an easy sentence. While she has asked the House Oversight Committee to investigate Acosta, Frankel said she is not sure that will happen. "It just seems to me it was a travesty that this guy got off the way he did and, without pre-judging it, let’sEave a proper court case," Frankel said. Former Palm Beach Police ChiefMichael Reiter was inflamed in 2006 when then-State Attorney Barry Krischcr refused to charge Epstein with serious crimes. Reiter took the information his-officers had gathered from dozens of Epstein's victims to Acosta, believing he would prosecute Epstein. He didn't. Reiter said he was heartened that 13 years later, Epstein will finally face justice. " Thankfully, U. S. Attorney Berman and the-other authorities, in New York.have the good judgment to investigate and prosecute Epstein in the way that should have occurred in Florida over a decade, ago," Reiter said in a.statement. And, Scarola said, there are signals that Berman's investigation is far from over. Berman declined to answer questions about whether others, such as Epstein's high-powered friends, would be charged. He brushed off questions about the significance that the investigation was being handled by the Public Corruption Unit. While agents on Saturday were -arresting Epstein aboard his private jet .at the Teterboro Airport in NewJersey after returning from Paris, Other officers were, searching .his New York. City townhouse. Agents seized nude photos of young girls who appeared to be minors, Berman said. He said his focus was on finding more women who were exploited and abused by Epstein. Turning to a poster, detailing the charges that had been filed against Epstein, he pointed a finger at a photo of the convicted sex offender who was once described as "a man of mystery." ______ ____. ,.....,.1. CA/Aronberg-00.1075 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • I U:S. District Judge Ken en th Marra has already ruled that Acosta violated/ the federal .Crime Victim.~• Rfahts Act by nottelling Epst~in's victims aboutthe agre<~ment before it was.inked. Coincidentally, Cassell an:d Epstein attorney Roy Black had to file paped by midnight Monday, exp faining what action Marra shouici .take to redress that wrong. Cassell insisted Epstein should.face chatges,in federal court in West Palm Beath. "Florida ·victims des.erve justice in Florida,'' said Cassell, who he working on behalf of Epstein's victims· wi'th attorneys· Bradley Edwards and Jack Scarola. S1rrce it's likely Floridawomenwffl get to testify against:Epstyin in New York, Scarola said he's not focused oh whether Epstein will face charges here .. Irtstead, he,saidhc wants to know how and why the a.gre_ementwas reached. "There's been ho explanation ·ag to how a deal .like this. could have been. cut and how the federal government couid have been involved in a conspiracy to vioiate fe:cteral law,"' Scar.ala said of his interest i11 continuing the legal battle over the. nonprosecution agreement. When Acosta agreed to .dropthefedernl investigation~ Epstein in2008pleaded guilty to two prostitution charges and served 13.moiiths of an 18-inorith sentence 'in a y~carit.wing of the Palm Beach County Jail - a cell he was allowed to leave 12 hours a day; six days .a week He was; also forced to register as a sex offender and settle civil lavvsµjts more than. 30 yqu.ng women filed against him. U,S. Rep. Lois .Frankel, D-West Palm Beach, :said s.he shares Sc_arola;s interest in ftnc;iing oll.t how the agre~ment.came to be.Ill am especially more interested in why Epstein got the deal he got, 11 Frankel said. "W c need to know why he wa~ given ,s4ch an easy sentence. While she has .asked the :House· Oversight Committee to investigate Acosta; Frankel said she is not sure that will happen. "It ju~t seems to,me it.was <1. trnve~ty th.at tbis guy gqt off the way he,did and, withoutpre~judging it, let's:have a propercomt case," Frankel said. Former Palm Beach Police Chief Michael Reiter Wa$ infla_n1ed in2006 w,he_n th.en-State Attorney BanyKrischer refused to charge Epstein with serious crimes. Reiter took the information his-officers had gathered from dozens of Epsteir1'.s victims to Acosta, believing he would. pros.ecute Epstein. He didn't. Reiter said he was .heartened that l3 years later, Epstein will finally face ju~tice. "Thankfully, U. S. Attorney Berman and .the, other authorities, in New York.have the good juqgrne1).t to, investiga,te and prosecute Epstein in the way tl:u1t shoµld h_ave qccµrred in Florida:. over a decade ago, 11 Reiter said in a. statement. Anc;i, Scarol~ said,_ there are signals that ~ennan's inve.stigatiori is fai: from over. Berman declined to answer questions about whether.others,· such as,Epstein's high-powered fri epds, woul_d be charged. He b.ru.shed offquesti ons aqqµt th.e signifi~ance thattµc investigation was being handled by the Public Corruption U11it. While agents Q11 Saturcl.fly were ,arresting Epste.m JJ,boarc:l hi~ pdvate jet .at the Teterboro Airport in New Jersey -after returning from Paris, other officers were. searching his New York. City tow]Jbou!'>e. Agents seized nud_e photo~ of young: girls who- a,ppeared to be minors, Berman said. He said his focus was on _finding more women who were exploited and abused ·by :Epstdn. Turning to a poster, detailing the charges-that had been filed.against Epsteiti.,.he pointed a: fing~r a,t a phot9 pfthe convicted sex offender w,howas once descrlbeci as ".a man of mystery." I ........ L .... CA/Aronberg-00.1075 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM "If you believe you are a victim ofthis man, JeffreyEpstein, we want to hear from you," Berman said. A special number, 1-800-CALLFBI, will, link victims of authorities. Bill Sweeney, assistant director ofthe FBI's New York office, said after years of being ignored by federal agents, the victims' voices will be heard. "The Jeffrey Epstein matter is No. 1 on the major case list in the country,'1 Sweeney said. Turning to address Epstein's victims directly, he said: "Your bravery may empower others to speak out against crimes against them." CA/Aronberg-00.1076 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • "If you believe you are a victim of this-man, J effrey:Epstein, we want to. hear from you/ . .. . . . . . . . . . . ... I Bennan said. A speciaJ 1_1umper, 1-800-CALLFBI, will)inkvic~i,01s of authorities. Bill Sweeney, assistant director of the FBI's New York office, said. after years of being ignored ·by federal agents, the vi~tims' voi~es will be he,ard. • • "The Jeffrey Epstein inatter is No. l on the major ca:se list. in the country," Sweeney said. Turning to address-Epstein's vi'ctims directly, he said: "Yo.ur bravery m1:ty empower others to speak out against crimes against. them." [email protected] CA/Aronberg-00.1076 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM Appendix 13 CA/Aronberg-001077 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • Appendix 13 CA/Aronberg-001077 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM IN THE CIRCUIT. COURT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. : 50 - 2019-CA-014681 Circuit civil division: "ag" CA FLORIDA HOLDINGS LLC PUBLISHER OF THE PALM BEACH POST., P1aintiff/Petitioner -vs- DAVE ARONBERG, SHARON :R. BOCK, De fendant/Respondent s HEARING BEFORE THE HONORABLE KRISTA MARX (ZOOM CONFERENCE) Wednesday., June 3, 2 02 0 10:08 a.m. - 10:28 a.m. REMOTE ZOOM CONFERENCE Tort Saint Lucie, Florida Stenographically Reported By: SONJA M. REED 'Court Reporter OEPOSITIONSOluflOHV CA/Aronberg-00.1078 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM NOT A CERTIFIED COPY • • IN THE CIRCUIT COURT IN AND FOR .PALM BEACH COUNTY, FLORIDA CASE NO.: S0.-20i9-CA-cH4fr81 CIRCUIT CIVIL DIVISION: "AG" Cl\ fLORJDA HC:fLDING$ I.LC PUBLI:SHE~ OF ~HE PALM BEACH POST I Piaintiff/Petition:er DAVE ARONBERG; SHARON R. B.OCK, Defendant/Respondents. ---------------------I CA/ Aronberg-0O1078 ;HEARING BEFORE TJ::IE HONO~BLE Is:RISTA MARX (ZOOM' CONFERENCE) Wedrres.day,, June 3, 2020 1 o : O 8 a . m . - .1 o : 2:s a . m . REMOTE ZOOM CONFERENCE :port Saint Lucie, Florida Stenqgr~phic:ally Reported By: $0NJA M, REE.D Court Repot'ter FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3,/28/2023 2:27:00 PM 1 2 3 4 5 6 7 a 9 10 11 1.2 13 14 15 1.6 17 18 19 2,0 21 22 2 3 2.4 25 APPEARANCES: On behalf of the Plaintiff/Petitioner: GREENBERG TRAURIG, P.A. 1840 Century 'Park East Suite 1900 Los Angeles, California 90067 310. 586 .7700 [email protected] BY: NINA D. BOYAJIAN, ESQUIRE On behalf of the Defendant/Respondent: JACOB, SCHOLZ & WYLER, LLC 961687 Gateway Boulevard Suite 2011 Fernandina Beach, Florida 32034, 904.261.3693 doug. wyler@comcast .-net BY: DOUGLAS A. WYLER, ESQUIRE On behalf of the Defendant/Respondent; CLERK '& COMPTROLLER., PALM BEACH COUNTY P.O- BOX 229 West Palm Beach, Florida 33401 561.355.2983 [email protected] BY: NICOLE R. FINGERHUT, ESQUIRE ESQUOtE : ’'.rV deposition: souhwhs CA/Aronberg-00.1079 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY l 2 3 4 5 6 7 8 9 10 12 13' 14 16 17 19 2.0 2-1 22 23. 24 25 • • APPEl,\R..ANCES: On behalf ·of the Plaint:·iff/Petitioner: GREENBERG TRAURIG, P.A. 1840 Century Park East Suit::e 1900 Los Angeles, c'aliforriia 9:0067 310.586.7700 [email protected] BY': NINA D. BOYkJIAN, ESQUIRE on behalf of the Def_endant/Respo:ndeht: J:ACO:e, SCHQLZ & WYLER, LLC ~61687 Gateway Botilevard Suite 20ii Fernandina Beach, Florida 32034, 904.261.3693 doug. wyler@comc:a:sb.net B:Y: DOUGLAS A. WYLE_R, ESQUIE,E On_ behalf qf, the pefendant:./Respo!}qent: CLERK '& COMPTROLLER., PALM BEACH COUNTY P -. Q .· B.ox 2 2 9 West Palm Beach~ ?lorida 334Dl 5 61 . 3· 5 5 . 2 9 8 3 [email protected] BY: NJ:CO.LE R. E'INC:ERHCJT, E$QUIB:E CA/Aronberg-001079 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6: 7 8 9 10 11 12 13 14 15 1.6 17 18 19 20 21 2 2 23: 24 25 PROCEEDINGS ***** i THE COURT: We are here today for a very limited purpose. I'm sure the attorneys are aware of that, but I just don't want there to be any confusion. We are here On Defendant Dave Aronberg and Defendant Sharon Bock for the: Comptroller and the State Attorney's motion to dismiss Count II. You're all acutely aware as the lawyers that this is a question of law. So. we're not going to be diving into facts and the Court will not be deciding the merits: of this motion, this morning. We are simply here for the sole purpose of that motion to dismiss. So I just wanted to make sure that we all stay on track and we're all on that same page. So, Ms. Boyagian, I'll send it to you first, Ma'am. I -- of course, we all know that the Law 101, I must look at the four corners of the motion, which alleges that the State Attorney, David Aronberg, and the clerk and comptroller, Sharon Bock, actually have custody and control of these, grand jury proceeding. Whether that is true or not is not for this court to determine because I'm looking simply at the four corners of the complaint. But, not for nothing, I think we all know that they don't have control and OfPOSITiON SOLUVIOtH I CA/Aronberg-00.1080 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 1.1 12 13 14 15 1.6 17 18, 19 20 21 22 23 24 25 • • 'PROCEEDINGS THE COURT: We are here today for a very limited purpose. I'm sure the att9rneys ,;lre aware of t:hat:, ou:t I j11st don•' t want the.re to ·be. al).y confusion. We are here on Defendant Dave,Aronber:9 and De.f:endant Sharon Bock for the CoTI).ptroller and the :State Attorney's ITI.Otion to dism;i.ss Cov.nt ;II. You're a11 acute1y aware as the lawyers that this is a question of law. So we•' :te not going to be di virtg into facts a.nd thE? Court wi:1-1 n:ot pe deciqirtg the mer.its -of this motion. this morning. We are ,simply here for the ·sole purpose of that motion to di$Miss. So I j~st w~nted to make $11re that we all stay .on track and we•' re all on that same pag.e. s:o-; Ms. Boyagian, I' 11 send it to you first, M?i'am. I .,.- of c9urse, w:e a."11 know' that the La:w 101, I must look at t:he four corners of the motion, which al lege,s that the State Attorney, David Aronberg, and the clerk and comptroller,. $harort Bock, actually hc;tve cust:ody and control of t:hesE? grarnJ j t1ry procee<:li:ng. Whether that is true or not is not for this court to determine because I'm lookihg simply at the f911r corner}3 of the comp},a,int. B11t, pat .for n9t}Jirig, I think we al.I know that they don't: have, :control and CA/Aronberg-0O1080 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 .5 6 7 8 9 10. 11 12 13 14 15 1.6 17 18 19 20 21 22 2 3: 24 25 custody of the records. But I'm going to assume that it's correct because that's what has been alleged. So what I first want to hear from is; the attorney for Florida Holdings with regard to, assuming arguendo, that Florida Statute 905.27 does create a cause of action, what relief is it that you're seeking from -- in Gount II, specifically. Not the dec action. We're not- here on that today -- what is it you hope to get, a judgment? MS. BOYAGIAN: Thank you, your Honor. Good morning, and thank you for the privilege of appearing before this court. The relief we are seeking is disclosure of the grand jury records, pursuant to the Furtherance of Justice Exception to 905.27. And under the First Amendment. The press, as your Honor is aware, has a right of access under the First Amendment as a surrogate of the public -- THE COURT: Let me just stop you .for a minute. I'd like you to answer my specific question. So I am not particularly convinced — and I'd like for you to address that. So we're not going to dive into facts or the press's standing because that's not something we're here to discuss today. CA/Aronberg-00.1081 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 4 ,5 6 7 8 9 io ii 12 13 14 15 1.6 17 18, 19 20 21 22 23' 24 25 • • cU$tody of the Ye.c:ord.s. But I im goirtg to' as$lit'ne that it '·S co.rrect because that's what has been alleged. So what I f1rst want to hear from 1.s the attorney for Florida Holciings :wit'h regard to, c1ssuming arguendo, thc1t Flor_idc:1 Statute :9'0$. 27 does create a cause of action, what relief is it that you're seeking from -~ in Count Il, spec'ifically. Not J:he de.a action. We 're not h,ere on t.haJ: today what i.s it you hope to g,et, a judgment? MS. BOYAGIAN: Thank •you, your. Honor. Good morn.:lD-9, axid thc:tnk you, for tJ::ie priyileg~ of a,ppeFl,;i;iqg beef.ore this court . The relief we are seeking is disclosure of the grand jury records, p1.1rsuant to the Pµrthe:tc:1nce of Jus,tice 'Exception to 905. 27. And under the First Amendment. The pres:s, as your Honor is aware, 'has a right of access under the First Amendment as a surrogate of the public -- THE COURT: Let me· just Ei-top you ,fa,r a minute .. I!cl lil<.:e YOll to c:1nswer my specific q1Je.stio.n. So I am not particularly convinced -·- and I'd like for you to address that. So we're hot going to dive j.nto .f~cts or the :press' s standing becau,se that's not something we' re here to discus's t.oday. CA/Aronberg-001081 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2 3; 4 5 6 7 8 9 10 11 12 13 14 15 1.6 17 18 19 20 21 2 2 2 3 24 2 5 And. I have read the voluminous paperwork -- I've received paperwork as -- and -- five-minute ago from some: of the other parties. But I deeply appreciate the fact that you sent this to me so much in advance and j have been able to spend some time with, as I said, the voluminous paperwork that was provided. •But as you know, Ma'am, we are here: for such an extremely limited issue today, and that their motion to dismiss where they state "you're suing the wrong people"; that the court has these’ records. And so, more importantly, I want, you to address whether -Section 905.27 gives you a private Cause of action against the state attorney arid the clerk. Again, I'm going to assume the facts are true that are asserted in the motion. Whether they are or riot -- because I think we can all agree we're not for sure if they ever -- that the state attorney doesn't have these records. So what is it you're seeking in COtint IT -- riot the dec action. I know you want the records, I've got that. But in; Count II, specifically,- what do you -- what's the relief you're seeking and, more importantly, how under .this: statute do you get to assert a private action -- a private cause of action against the state attorney and the CA/Aronberg-00.1082 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 4 5 6 7 8 9 10 ii 12 13 14 15 1.6 17 18. 19 20 21 22 23: 24 25 • • Arid. I h~v.e read th€;! voluminous paper&ork I I've rece:i'.ved paperwork as -- and -- five~minute ago .from some of the other parties. But I deeply appteciate t'he fact tha.t you SE;!nt this to me so much ,in advanqe a:n,<;1 l l:1c;J.ye 'be:en ahle to :-:;pend some time with, as I .sa:Ld, the voluminous paperwork that was provided. -But as you kl1pw, Ma' a.m, we a.re llere, :f'or such an extreme1y limited issue today/ ancf that their motion 'to dismiss where they: state 11 you 1 :te suing -the wrong people"; that the court ha,s these reco;rds:. And s:o, mo.re importantly, I want. you to address whether Beet ion 9,05 .'27 gives you a private cause of action a:gairtst the state attorney arid the clerk. Again, I 1 m going t.o ass.ume the facts- ar.e tr:ue that are a·sserted in the motion. Whether they are or not -- bec::ause I think we cart all agree we're not for sure if they ever -- that the state attorney doesn't have these re.cords. 'So what is it you'' re seeking in cbunt T'.I - - not t:;.he dee action. I know you want the record$. I've got that. :Bµt i11, Coul1t II;, .specifically,. what do you - - what's the r:elief you' re ,seeking and, tno're importantly, how under .this statute do: yoµ g~t to assert a. :private action -- 'a. private cause o.f action against the state. attorney and the CA/Aronberg-00.1082 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2: 3 4 5 & 7 8 9 10 11 12 13 14 15 1.6 17 18 19 20 21 22 23: 24 25 clerk? MS. BOYAGIAN: Your Honor, we are aware, of course,: that there is no expressed private right of action, 905.27. But that does not end the inquiry. As the Florida Supreme Court stated: "Where a statute like 905.27 forbids an act Which, is to Plaintiff's injury, the Party injured should have an action." And that's the Smith. Piezo case in the volume of materials that we sent you. There's no. question here that the denial of the FIRST AMENDMENT right to the press is an injury which gives rise to a right of action. Stated another way, looking at the analysis that the Fischer Metcalf Court, looked at, there, are three factors in determining whether, there is; a private right of action where a statute does not expressly provide for one. One is whether the Plaintiff is part, of the class for which the statute is intended to protect; second is a legislative history-; and the third is the underlying purposes of the statutory scheme. The first factor I already addressed, that the; press is part of the class that the statute is OPPOSITION SOlUIIOHS CA/Aronberg-001083 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 lb 1J 12 13 14 15. 1.6 17 18 19 20 21 22 23 24 25 • • clerk? MS. B'OYAGIAN: Your Honor, we are aware, of course, that there is no expressed private right of a<;::1.ion, 905.27. But that doei:, not end the. inquiry. As the Floricia. Supre.:me. CoUcrt state.cl.:. "Whe-re :a statute like 905. 27 forbids an act which is to Plaintiff•.s ir1j u_ry, the pc:t-rty ,inj µreel s.hould hcJ.ve an action. 11 And that '·s the Smith. Piez'o case in the volume ot tnateria1};; that we sent you. 'Ther.e:' s no quest.ion here that the deniai of the FIRST AMENDMENT right to the J?ress is an injury which gives :t.i:se to a right ol action. St:ated another way, looking at the analysis that the Fischer Metcalf Court. looked at,; there are three factors in determining whet'hE;:r there ii:;: a: private right of act.ion where a statute does not express.ly provide for one. One is whether the Plaintiff is part of the :clas_s Jqr whic:h the stc;tut:e i$ interide.d t:o protect; second .is a legislative history-; and the- third is the i.ihderlyins, purposes of the s-tatutory scheme. The f:ir$t factor J: already ,c:1.ddressed, that the press .is part of the· class that the statute is CA/Aronberg-0O1083 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:27:00 PM 1 2 3: 4 5 6. 7 8 9 10 11 12 13 1.4 15 1.6 17 18 19 2 0 2.1 22 2 3 24 25 intended to benefit, being the surrogate of the public and exercising its first, amendment right. The second issue of legislative history and the purpose -- statutory purpose are somewhat related. We were unable to find much legislative history on this issue of a private right of action under the statute. There is nothing that says we intend to create a private action, but there's certainly nothing that says we do not want to Create a private right of action. What we do have .is that in 1994., the same time that 905.27 was reenacted., a statute that pertains to the secrecy of State Grand Jury -- Statewide grand juries was also enacted. That, provision,, which is 905.395, has no exceptions for -- for revealing these records, By Contrast, the legislature intentionally enacted 905.27 with the Furtherance of Justice Exception. If the public through the press can't bring a private right of action to enforce that exception or to seek relief under that exception, that intentionally placed exiception of furthering justice is essentially rendered hollow -- (Speaking simultaneously.,) ^ESQUIRE CA/Aronberg-001084 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 4 5 6 7 8 9 10 li 12 13 14 15 16 17 18 19 20 21 22 23' 24. 25 • • intended to penefit, be·ing the surrogate of the public and ~xercising its first amendment right. The second issue of legislative history and the purpo?e -- .statutory purpose are somewhat related, We were u11ab1e to f ir1d. nmc'.h legislative hd,story on thfs issue of a. private right of action under the 'Statute. Tl:Ier~ is rioth.ing that says we intenc:1 to c,reate a. private action, but there's ce·rtainly nothing that says we do not want to create a private risht of ·a Gt: i CH) . What we do have .is that in 1994J the· same time that 905.27 was reenacted; a statute that pertains to the secrecy of State Grahd Jury - - stat·ewide grahd juries was also enacted. That, provision,, which is 905-.395, has no exceptions for -.- for revealing these records, By contrast, the legislature intentionally enacted 905. 27 with the Furthe.rance of Justi_ce Exception. If the public through :the press can't .Qring a private right of action to enforce that exception or to seek relief under that exception, that intentionally placed exce·ption of' fa.1rthering justice i~ esseriti~lly rend.erect. ~ollow (Speaking simultaneously.) CA/Aronberg-001084 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6: 7 8 9 10 11 12 13 14 15 16 17 18 19 2 0 21 22 23 24 25 THE COURT: Okay. Pause for a minute. I don't think anybody is saying that there isn't a cause of action or that the press doesn't have standing. That's not what I'm asking you. I'm asking you., how are the clerk and the state attorney the proper defendants? So, you know, nowhere have I said there isn't a cause of action. Clearly there is. I'nv puzzled by the procedural posturing of this case naming the state attorney. And, you know, I'm further stymied by the fact that you allege in your complaint that they have particularly David Aronberg the State Attorney -- that he has these records. But I'm going to assume that's true. So I'm not telling you, you don't have a cause of action. I'm just saying, okay, let's run this all the way out. Let's say you win and you get a judgment against the; State Attorney Dave Aronberg. What's he supposed to do with it? He can't release, the grand jury testimony. He has no authority whatsoever to do that. MS. BOYAGIAN: well, your Honor, as you stated, this is a motion to dismiss stage, and we are entitled to discovery on the issue of possession, OEPOSinON SOI UI lows CA/Aronberg-00.1085 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 lo 11 12 13 14 15 1.6 i7 18 19 20 21 22 23 24 • THE CdlJRT: Okay'. Paµs'e I don't think anybody is • for a minute. . I s.aying that. there • . isn't a cause of action or that the press doesn't have standing. That's, not what I 'm asking you, I'm asking you, how a.re, the clerk an.ct t:he stat:e, a.ttorney the proper defendants? So, you know, nowhere .have I said there isn't a ca:1.1se of actiori. Clearly there is. I 1m· puzzled. by the procedural posturing of this case naming the state attorney. And, you know, I' nt .further 13ty1TI:igd by tl\e :fact that you allege in your complaint that they have -- particularly David Aronberg the State Attorney -- that he has thes~ records. But r 'm going t.o assume that's true. So I'· m not tel 1 ing you, you don't ):rave a cause of action. I:, tn just saying, okay, let'$ run t::his all the way out. Let's say you win Bnd you get a judgment against the: State Attorney Dave Aronberg. What'$ h~ supposed to do with it? He c;:ahit release. t:.he grand. ju_ry test:.irnony. :HE~ hcts no authority whatsoever to do that. MS. BOYAGIAN: WeTl, your Honor, as you stated,. tpis is a motion.. to ciismiss stage, apcl w;e a,re entitled to discovery on the issue of po:ssession, CA/ Aronberg-001085 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2 3‘ 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2 2 2 3 24 25 custody, and control. My understanding is that the state attorney has asserted that he does not have possession. It's not my understanding that the. clerk has taken that position. So the clerk may indeed be the -- someone who does have possession, custody, and control. In any event, we would submit, that the state attorney, even it does not have actual possession at this time,, it might be. able to have the power to control or direct the entity or persons who do have control and possession to release those -- to effect the judgment; THE COURT: So let me ask you this: So the clerk is the keeper of the record. But even if you got a judgment against her -- let's say you asserted this cause of action and let's say you win and you get a judgment against the clerk. The clerk cannot release grand jury testimony to you. Only the court can. So really -- all I'm saying to you is I do not understand the way this case was filed or why these are the defendants because it's impossible for them to perform. I mean., I'm going to assume, based bn your motion, again,: that they do have the records. But we ^ESQUIRE * s ~ 1 -TV OPPOSITION SOUH IONS CA/Aronberg-00.1086 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 4 5 6 7 8 9 10 1J 12 13 14 15. 16 17 18 19 20 21 22 23 24 25 • • i:::U$tody, arid control. Ny understanding i$ that the state attorney has asserted that ·he does not have possession. It's not my understanding that the. clerk has taken that position. So the clerk may incleed be t.he. -- $Omeo11e who does have. possession, c:::ustody, and control. In ,any event, we would submit that the state attorney, even it cloe1:;1 not have act:ual posses•sio11 at this time, it might be.able to have the power to cont-r-e:H or direct the entity or persons who do have t:ontr6.l and. posses.sion to release th6s$ -·- to .ef feet the judgment, THE COURT: So let me ask you this: So the clerk 'i$ the keeper of the rec:::otd. But even if YO\l got a judgment against her -- let's say you asserted this cause of action a:nd let's say you win and you get a judgment agc3.inst the clerk. The clerk cannot reieas.e grand jury :testimony to you. Only the court can. so really -- all I'm saying to you is I 90 not;: unc:le.rst·anq t:be way tbi$ caf:)e was filed or why ·tJ1ese ar·e the defenda:nt·s b:ecause it's :Lmposs.ible for them to perform. ;r mea.n.-, I' .m going to as~um,.e, baseq on ym1r motion,: again, that they do have the rec.ords. But we CA/ Aronberg-00.1086 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2j 3! 4 5 6; 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2 3 24 25 all know -- everyone in the room knows they do not -- that only the court -- they're -- they're with a court interpreting. And only the court can release the records. So if you get a judgment against either the state attorney or the clerk, they cannot - - I mean, I guess what you're saying to me is, well, we want to do discovery and we want them to say unequivocally "I have these records" or "I don't have them." And -- I. mean, the law is abundantly clear. You cannot do it without a court determining whether, in the furtherance of justice, the release is appropriate. MS. BOYAGIAN: And that is a determination we're asking your Honor to make, and we're asking for an order from your court. THE COURT: When we get to the merits of the case, sure it. is., But, again, you’re' asking me to make that determination and for me to make a determination of whether the grand jury records should be released. And the. only thing we're here today about is why should the clerk and the state attorney have to, defend a civil action when it's a possibility of performance? They -- even if you were to win and get a judgment against them, they cannot ^ESQUIRE CA/Aronberg-00.1087 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 4 5 6 '] 8 9 10 li 12 13 14 15. 16 17 18 19 20 21. 22 23' 24 25 • • all kn9w· - - eveYyone in the rootn krtows they do not that .only the court - - they I re - - they' re with a court interpreting, And only the court c~n release the records. So if you get a judgment against either the 'State attorney or the clerk, they cannot ,guess what you're say;ing to me is, wel1, we want to cio disc:overy an:d we w:ant thern to sci.y lln1::::guivocally "I have these re·cords 11 ox "I don't have them. 11 And - - I. mean, the law is. abundantly clea'r. Y:9u cannot do ,it without a, court det,errninirtg whether, in the :further;ance of justice, the release is· appropriate. M$. BOYAGIAN: And that is a determinatiq·n we, 1 re asking your Honor to make, and we' re asking for an order from your court. 'THE COURT: When we get· to the merits of the case, sure it is. But., aga±n, you're· asking me to make that determination and for me to make .a de.t:ertnirtai;'ioh of whether the grand jury recon:ls shou.ld be release.ct. J\nd the only tbing we' re here today about is why should. the .clerk and the state attorney have to. def ertd a civil .action when it's a possil:>i1ity of performartc:e? They -- evert it you were to win and get a judgment against them, they cannot CA/Aronberg-00.1087 FILED: PA~M BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:27:00 PM 1 2 2 4 5 6: 7 8 9 10: 11 12 13 14 15 1.6 17 18 19 20 21 2 2 2 3 24 25 give you what they doh't have. So — I mean, it's as simply as this:: Are, you -- you just want to engage in some discovery for them to absolutely assert, particularly, the state attorney, "I don't have' these records"; look to the rules that say the moment the grand jury's over, they're sealed and they're turned over and they cannot be released without court order? So I'm not addressing the merits or whether you have an exception or you're able to argue that there's ah exception in the furtherance of justice. We're not getting there today. I'm. simply saying why should these two entities have to defend this lawsuit when even down the toad if they win they can't give you what they don't have? MS. BOYAGIAN: As your Honor stated, I'm not sure that'S the case with the clerk. That was not in their -- that issue was not stated in their papers. THE COURT: Let me ask you this, then: Do you think, if you got a judgment and. I or the court doesn't make the determination that the grand jury records should be released, that the clerk would be able to perform? Would they be able' to say "here you go"? I mean, could the clerk just make that unilateral CA/Aronberg-00.1088 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 4 5 6 7 f3 9 iO li 12 13 14 15 1.6 17 18 1.9 20 21 22 23' 24 25 • • give y9u·what they don't have, So -- I mean,. it's as simply as this·: Are. you -- you just want to engage in some discovery for them to absolute·ly a{:lsert, particularly, :the stat-e attorney, 11 I d.on ,. t have· these records 11 •; lc:>ok to t_he· rules that .say the moment the grand jury's over,. they're sealed and they're turned over and they c::annot be releaseq without court 9rger? So I'm not address:i'.ng the merits Qr whether you have ah exception or you're able to argue tha·t there'$ c;J-IT e_xteptio_n ,in the furth_erance of justj,ce. We' re rrot getting there today.. I'm. s{mp1y saying why ·should these two entities have to def'end this lawsuit when even down the road if they Wih they can't give you what they don't have? MS. BOYAGIAN: As your Honor stated_; I'm not -sure that is the ca$e with the clerk. That was not in their - - that issue was not stated. in the.ir papers. THE COURT: Let me ask you th1s, then: Do you think, .if you .got; a j:i,J.dgment .and. I or the court cioe_sn' t mc3,ke the qete_rrn:i:nation that the grc1,nd, j·ury records should be releas.ed, that the c.le-rk would be able to p.erf orm? Wou,ld they be ab.le to say 11 ]:lere you go''? r. mean,: could the clerk just make that ·unilateral CA/Aronberg-00.1088 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM decision "I'mgoing to release the records, Sealed confidential records"? Does she have any authority to do that? MS. BOYAGIAN: My understanding, your 'Honor, is that 905.27 requires a court order before the records are unsealed ,s THE COURT: Exactly. Exactly. All right. Let me hear from Mr. Aronberg's attorney, Mr. Wyler. MR. 'WYLER: Thank you, your Honor. May it please the Court -- THE COURT: Good morning', Sir. MR. WYLER: Good morning. Your Honor, I just wanted to let you' know that I spoke with counsel for the clerk, Ms. Fingerhut, a couple of days before this hearing, and we decided that I would just make the presentation for both of of us, being that our arguments overlap except for the fact of who this claim -- whether they have the records or not, which, of course, we've said we don't have custody of the records - But, nonetheless, our arguments overlap. The Plaintiff is attempting to assert a cause of action under Section 905.27. That statute settled testimony not to be disclosed exceptions. So it's just 1 2 3 4 5 6; 7 8 9 10 11 12 13 14 15 1.6 17 18 19 20 21 22 2 3: 24 2 5 t - - 1 jTV oeresiTfOw solutions 1 i i CA/Aronberg-00.1089 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 4 5 6 7 8 9 10 11,. 12 13 14 1.6 17 19 20 .21. 22 23 24 25 • • deci1:3i9n. "I'm .going to :t$leas(= the records, $ea.led confidential records"~ Does she have any authority to do that? MS, BOYAG:IAN: My understanding, your ~Honor, is t:hat 90.5. 27 requires ·cl c:::ourt order bef:ore th:e r.ecord;i are unsealed .. THE COURT: Exactly. Exactly. A11 r-igh.t:, Let me 11:ear from Mr, l:\,rqnberg' s attorney, Mr. Wyler. MR. 'WYLER: Thank you, your .Honor. May it please th.e Court 'THE COURT: Good morning·, Sir. MR. WYLER : Good morning . Y9u:t Honor, I just wanted to. let you: knqw that I spoke with counsel for the clerk, Ms .. Fing,erhut,. a couple of days before this hearinsr., and we decided that I would jµst make the presentation for both of of us., bein_g that our arguments overlap ex,cept for the fact of who· this claim-~ whether they have the '.rec::ordi:; or ·not, which, of cqµr~e, we've i::raid we don it have custody of the reoo:r:d$ . But, nonetheless, our arguments overlap. The Pla•irttif f 'is atternpt.irtg to ass.ert a cause of act-iort uncler: S$ct:ion, .9()5 ,27. Tpat ~tatute settled testirnoIJ.y not to be. disclosed exc.eptions. So it's just CA/Aronberg-00.1089 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2 3' 4 5 6: 7 8 9 10. 11 12' 13 1.4 15 1.6 17 18 19 20 21 22 2 3: 24 2 5 explaining exceptions to the disclosure of the grand jury testimony. Our position is. that it doesn't set forth a Cause of action and that it's impossible for us to perform what they're asking. I know you said you didn't really want to get into the Furthering Justice Exception, but I know that's what they're using as their basis to get to these. But it's our position that the clear unambiguous statutory language:, it shows that this disclosure only applies to a civil or criminal case, and that within that civil or criminal -- (Speaking simultaneously.) THE COURT: Again, sir -- I'm sorry. As I told Plaintiff's counsel -- MR. WYLER: -- Can only be used in the defense for - - THE COURT; Okay. We're not there. We're not discussing the merits of the case, and -- I'm not ready to cross that bridge. I'm here for a very, very limited hearing today. So just as I stopped Plaintiff's counsel from arguing the merits of the Case: and whether or not the Furtherance of Justice Exception will apply in this instance, we're not even there yet. ' CA/Aronberg-00.1090 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 3' 4 5 6 7 e 9 iO li 12 13 14 15. 1.6 17 18 19 20 21 22 24 25 • • explaining exceptiohS to the dis9·1osure of the ,grand jury testimony. Our ~p:osition is. that it do:esn' t set forth a cause of action. and t:hat it's impossible f:or us to perform what they'' ;re ·ctsking. I know you s:aid you didn't really want to get into the Furthering Justice Exception, but I know tl:iat' s whc:lt 1:hey' re m~ing as their pas-is to get to these. But it's our position that the c:lear unambiguous statutory· language, it shows :that th-i-s dis-closure on,ly appli~El to ct c~i vil qr crimii:i~l ca_se, and that wit'hin that civil or criminal (Speaking simultaneously.) -THE COURT: Again, sir - - I 1·m sorry. As I tQld Plaintiffrs counsel MR. WYLER: can only be used in the def~nse for THE COURT: Okay. We're not there. We 1re not discuss.ing the merits of the case,, and ~ - I'm not ready t:o cro~·s that bridge. I im h~re ,for a ve'.ry, v~ry limited hearing today. So just as I stopped Plaintiff's counsel from 'arguing ·the merits of the case and whether or hot the Furtherance of ,Justice Exceptioi:i. y,1i-ll. ctpply in this .inst:ance, we 're not even there yet .. CA/Aronberg-00.1090 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3:;28/2023 2:27:00 PM 1 2 3 4 5 6, 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2 3 24 25 I'm only here for the purpose of determining whether or not the clerk and state attorney should be dismissed. And I am bound by the four corners of the document, which assert that you do have control and custody over it• So if you'll fashion your argument with regard to that limited purpose, I would, appreciate it. MR. WYLER: No problem, your Honor. I apologize. Within the four Corners of their complaint,, Our position is that they failed to state a cause of action under 905.27. It does not provide for -- it doesn't list that there's no element that they have adequately pled to assert a cause of action under that. There's -- and the only thing they're asking for is records that we don't have. There's really not much more to it, your Honor And we would ask that you. would grant our motion to dismiss for failure to state a cause of action. THE COURT: Okay. Ms. Fingerhut, are you still on the phone? MS. FINGERHUT: Yes, your Honor. THE COURT: Is there anything you wish to add? MS. FINGERHUT: We agree with the state CA/Aronberg-00.1091 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3. 28 2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 4 5 6 7 8 9 10 11 12 13 14 15. 16 17 18 19 20 21. 22 23' 24 25 • • I"m only here f9r the pµrpose of get~rminirtg whether or not the clerk and state atc.torney should be dismissed. And I am bound by the four corners of the document, which assert that you do have contr9l and custody over it. So if you'' 11 fashion your argument with regard to that limited purpose, I would. appreciate it. MR, WYLER: No problem, your Hon.or. I apologize. Within the four corners of their compla:i.n:t, our pos·it;i.on is tl:lat: they fa,ileq to state ~ c~use of act.ion under 905 .,27. It does not provide for it doesn't list that there's .no element that they 'have ,adequ.;3.tely pled to assert a cc:i.use of action under that. There's -- and the only thing they're asking for is records that we don't have. :There I s really not much more to it, your Honor,. And we would ask that you. would grant our motion to dismiss for failure to state a cause of action. THE COURT.: Okay\ M_:;,. Fingerhut' i:l.TE;'! yqu $'.till on t:h~ phone? MS, FINGERHUT: Yes, your Honor. THE COURT: Is there artythihg you wish to add? MS. FINGERHUT: We agree with the ~t'i:lte CA/Aronberg-00.1091 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3(28/2023 2:27:00 PM 1 2 3! 4 5 6 7 8 9 10 11 12 13 14 15 1.6 17 18 19 20 21 2 2 2 3 24 25 attorney's position, and we also agree with what the Court has said, that the plain language of the •statute, a cause of action doesn't exist. And we really cannot -- we'll be defending something without the four corners. We're simply involved in this action because the clerk is the custodian of the records. THE COURT: Okay,. Thank you,- Ma'am.- Ms. Boyagian, back to you. MS. BOYAGIAN: Your Honor, I'd like to note that in the Butterworth case in which the Supreme Court limited the application 905.27 by saying that a, witness can reveal her Own testimony and prohibiting that they violate the First Amendment -- THE COURT: Say that again, please. MS. BOYAGIAN; In the Supreme Court Case, the Butterworth case', in which the Supreme Court ruled that 905.27 can't restrict a Grand Jury witness from revealing her own testimony, that would be a violation of First Amendment, in- that case, the state attorney was, in fact, a party. THE COURT; Well, I assume the state attorney that was present -- I mean, I don't find that that's close to what we're talking about here, and that's whether or not -- I mean, as we know,, this was in ESQUIRE o.f?6sinoN soiuuoHv CA/Aronberg-00.1092 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 4 5 6 '] 8 9 10 ii 12 13 14 15. 16 17 18 19 20 21 22 23: 24 25 • • attornE:!y·• s po1?ition, and w~ -also agree:! wi.t-h what the Court has said, that the plain language of the ·statute, a cause of action doesn't ex1st. And we really cannot -- we 1 11 'bE:! defending something without t:he f,qur c::orners. We' re_ simply involve.ct in this action becaus.e the clerk is the custodian of the records. THE COlJRT: Oka,y. 'X'han}< you,. Ma, I clffi .. Ms.. Boyagian, back to you. MS. HOY.AGIAN: Your Honor, I'd like 't'o note tha,t in the Butte:r:worth ca,se in whic:h the _$µp:r'~me: Court limited the app,lication 905. 27 '.by saying that a. witness can reveal her own testimony and :prohibiting that they viol~te the First: Amendment -- THE COURT.: Say that again, please. MS. BOYAGIAN: In the Supreme Court :case; the Blitterwort:h c::ase·, in which the Supreme Ccnrrt rulE:!d that 905.27 can't restrict a Grand Jury witness from revealing her own testimony, that would be a vi9lation of First Amendment:, in. that Cc:l/3e, the stat.e at to~ney was, :in fact,, a party. THE COURT: Well, I assume the state attorney that was 'present I mean, r don't f'ind that that's close to wha.t we I re t'.::i.l:king about llere, and that '.s whether .or not -- I mean,. as we know,, this was in CA/Aronberg-00.1092 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2: 3: 4 5 6; 7 8 9 10 11 12 13 1.4 15 1.6 17 18 19 20 21 22 2 3 24 25 2006. Certainly Dave ArOnberg wasn't even the state attorney then. But this is about the release of records\ I want to give you ample opportunity -- and again,, ;i sincerely appreciate that all of the case law and the way that it was presented to the Court in such a timely fashion. I really do. And I did spend some time with it. But I want to give, you whatever opportunity you want to take to convince me that it is in -- as to Count 2, again. Not the dec action -- whether these would be the appropriate defendants. And, you know, really, I want you to boil it down, for me as to this -- let's take it all the way down the road. You win, You get a judgment, against the clerk and the state attorney. I know there's other reasons why you might have filed it this way. But I'm just simply puzzled because I do hear what the clerk and the state attorney are saying, and that is, performance is impossible- They don't have the records and cannot -- absolutely. There's not even an inch of wiggle room -- that they could release the records even if you got a judgment. It is solely a determination for the court. I, frankly, think, you know, there's ways to OFPOSinON SOLUTIONS CA/Aronberg-00.1093 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 3 4 5 6 7 13 9 10 11, 12 13 14 1.6 17 18 19 20 21 22 24 25 • • 2006. <;:ertaittly Dave Arortbe-rg -wafJh' t even th~ ·state attorney then. B.ut this is ,about the, release of records. I want to give you ample qpportunity -- and again,, I s,i_ncere1y appre.cii::ite that all of the cas·e law and the way that it was pre·sented to the Court in 'Such a timely .fashion. I really do.. And I did spend sorne :time with it. But I want to give you whatever opportunity you want to take to convirrce: me that it is in-~ as to Count 2, again. Not the dee action whether the_se wou1d be the 9ppropriate clef eI).da11ts. Ano, you know, really, I want you to boii it down. for me as to this-~ letjs take it all the way down the road, You win, You get cl. Judgment. against the clerk and the state attorney. I know there's other reasons why you might have •filecl it this, way. But;: I'm just s-irriply puzzled bec_ause I do hear what the cle_rk and the state attorney are saying, and that is, performance is impo~s,ible. Th~y don I t have the recorq,s 'and c::cJ.nnot - - abso1utely. The.re 1- s- :riot ev~n an iilch of wiggle room - - that they could release th'e records even i.f you got a judgment. It is: solely a dE=1:e_rmin_at:ion .fo;r- th,e cou_rt. I,, frankly,. think_, you know, there I s ways to CA/Aronberg-00.1093 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3'./28/2023 2:27:00 PM 1 2 3: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2 3 24 25 get to your records. There's ways to get confidential records. But it isn't by suing the state attorney and the clerk. So I just want to hear your last final argument on how Count IT, the appropriate defendants are the clerk and the state attorney. Even assuming arguendo they have the records -- we know they don't -- you were to get a judgment against them, how would you expect them to perform? MS. BOYAGIAN: Two points, your Honor: One is that-, again-, the clerk did not assert, in her papers that she does not have control,. That is a position that the State Attorney's Office has asserted. It is Our allegation, and as your Honor noted, allegations must be accepted as true -- as true at this stage of the proceedings. Second, it is also our understanding that the state attorney and the clerk intend to block access to these records. So our allegation is that they do have possession, custody, or control, which the clerk has not denied; and second, that they are trying to block access to the records -- THE COURT: What do you mean.? What do you mean? They're not trying to block it.. They're saying that despite the fact -- let's just talk about CA/Aronberg-00.1094 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 4 5 6 7 8 9 iO li 12 lJ 14 15 1.6 17 21 22 23 24 25 • • get to yo,,.fr records. Th~r~' s way~f t-6 9et confidential records. But it isn't by suing the state attorney and the clerk. So I jui:it want 1;:.o hear your la~t finc;':ll argument on how Count II, the ·cl.ppropriate d_ef endant$ are the clerk and the .state attorney. Even assuming arguendo· they have the records ""' - we know they don't -~ -- you w~-r~ to get a judgmE=nt agc:1,inst:. thE::TTJ, h,ow would you expect them to perform? MS. BOYAGIAN: Two points_, your Honor: One is thqt,, a,gaiD--, t;:he clerk did not ~ssert in her pap~rs that she does not have control. That ·is a position that the State Attorney's Office has asserted. It is our alle<:3ation, anci a::; your Honor noted, allegation$ mus:t be acce,pted as true - - .as true at this stag.e of the proceedings. Second, it is also our unde-rstanding that the -state attorney and the clerk intend to block access to the-se records. So our allegation is that they do hc:1.v~ p9ss~ssion, .cu:3fody, or control, which the c.lerk ha$ not d~niecl; ,:1-1::id_ seoond, that they arE= trying to block access to the records THE COURT: What do S,bu tnea'n? What do you Tlley' re riot trying to block it .. saying that despite the fact - - let's j us,t taik about CA/Aronberg-00.1094 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6: 7 8 9 10 11 12 13 1.4 15 16 17 18 19 20 21 22 23 24 25 the clerk, because we all know the state attorney doesn't have it. So the clerk is the custodian of records. That's her main job. There's no doubt about it. We all know that. But we also know, unequivocally -- unequivocally, only the court can make the determination of whether the moving party has satisfied that there is an exception that these should be released. So, again, I ask you -- she is, in fact, the custodian of the records -- is it your opinion that if you got. a judgment saying clerk and comptroller gets a judgment against them, that she can release the records without the court -- without the court weighing in, without the court making that determination as required by law? MS. BOYAGIAN: No, your Honor. We are asking your Honor to order the clerk to do that under your discretion. THE COURT: All right. Mr. — Ms. Fingerhut,, you wish to be heard on that? MS. FINGERHUT: Your Honor, our position is that we're hot trying to block access to the records -- CA/Aronberg-00.1095 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 4 5 6 7 8 9 to 11 12 13 14 15 16 i7 18 19 20 21 22 23 24 25 • • the, .cleYk, becq,use we all know ·the state attc:irney does.n' t have it. So the clerk is the custodian of records. That's her tnain job. There's no doubt about it. We ~11 know tllc3.t. But:. we als:o know, unequivocal;J_y ·unequivoca:lly, only the court can make the ·determination of whether the moving party has sc3.t:isfie4 that there is an e:x:ception thc3.t t).1,ese should be released. So, aga'in, I ask you -- she is, in fact, the cust9dia:n o.f the records - - is it your opinion that if you got a j:udgment s:aying c.lerk and comptroller gets a judgment against themi that she can release the records without the co1,1:tt - - without the ,court weighing in, without. the court making that determination as required by law? M$.. '.BOYAGIAN: No, your Honor, we ;:ire asking your Honor to order the cierk to do that under your d1.scretion. Mr. - - M:;;. Fingerhut,. you wis_h to l;)e hearcl o:ri that? MS. FINGERHUT: Your Hoho:t' o·ur position. is tJ:ic:;1:t we' re not trying to block acces$ t:.o tl1$ records -·- CA/ Aronberg-00.1095 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 1 2 3' 4 .5 6: 7 8 9 10 li 12' 13 14 15 16 17 18 19 20 21 2 2 2 3 24 25 (Speaking simultaneously.) THE COURT: Can you hear? Can the attorneys hear? MS, FINGERHUT: - - custodian the records and that he cannot release the records without court -- THE COURT: Exactly. Okay. All right. Anything further., Mr. Wyler? MR. WYLER: No, your Honor. I concur with the attorneys for the clerk's office that it's impossible for us to. release these records. There's no intent to hide them or block anything from the Plaintiff. THE COURT: Okay. Anything further,. Ms. Fingerhut? MS. FINGERHUT: No, your Honor. THE COURT.: And, Ms. Boyagian, anything further, Ma'am? MS. BQYAGIAN: Nothing further, your Honor. THE COURT- Okay. I will, get an order out quickly. Thank you, folks so much. And I'll see you On the next round. Thanks a lot. MS . BOYAGIAN: Thank you., your Honor. MR. WYLER: Thank you, your Honor. (The: proceedings concluded at 10:28 a.m.) Of PO $ JT10 N: 5 61U 0 N 5 CA/Aronberg-00.1096 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY 1 2 4 .5 6 7 8 9 10 li 12 13 14 15. 16 17 18 19 20 21 22 23' 24 25 • • (Speaking $imulta.nec5usly·,) THE COURT.: Can you hear? Can the attorneys hear? MS' FINGERHUT: - - custodian the• records .ahd that 'he cannot release t:he records without <:ourt -- THE COURT: Exactly. Okay. All ri9.ht. Anything further, Mr. Wyler? MR. 'WYLER: No, your Honor. I 9QilCUr with the attorneys for the clerk's office that it"s impossible for us to release these records. There's no intent to hJpe them or block anytb.ing, fror:n the PlaJnt;if f. THE COURT,: Okay. Anything further,. Ms. Fingerhut'? MS. FINGERHUT: No, your Honor. THE COURT.: And, Ms. 'Boyagian, anything further, Ma'am? M$, BQYAGIAN.: Nothing further, your Honor. THE COURT: Okay. I wfll. get an ortjer out qu1ckly. Thank you, folks so much. And I'll see you on the next round. Th~nk§ a lot. MS. BOYAGIA:t-J: Thank yoµ, your I:Ionor. MR. WYLER: Thank you, your Honor. (The proceedings c:ortcluded .at 10 :28 a .. trt. )' CA/Aronberg-0O1096 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:27:00 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 2 5. CERTIFICATE OF REPORTER I, Sonja M. Reed, Court Reporter, certify that I was authorized to and did stenographically report the foregoing proceedings and that the transcript, pages 1 through 19, is a true and complete record of my stenographic notes. Dated this 3rd day of June, 2020. Sonja M. Reed Court Reporter CA/Aronberg-00.1097 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIED COPY • • l CERTIFICATE OF RKPORTER 2 3 4 5 7 8 10 11 i2 13 14 15 16 17 18 19 20 21 22 23 24 25, r, Sonja M. Reed, Court ReportE=r, certify that t was auth0rize·d to and d"id sbenog:ua:phically report the foregoi'ng pro.eeedings and that t:he transcript, pages 1 thr011gh 19, is -~ true and c;:om~lete recc:;:>rd of my stenographi,~ pqtes. Da_ted this 3rd d<:ly oJ .,Tune, 2020, ~ Sonja M. Reed Court Reporter CA/ Aronberg-001097 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM

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