Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 65 Program: CMS301L Case No • 1-0 - (Continued) cellular phone occurred at 1:02 pm. The call durations were one minute or ess. The ti e was within thirteen minutes apart. It should be noted that s residence was in close proximity to the v. ' 's. The next call occurred at 5:50 pm when the victim telephoned s residence. Several calls were made after the above mentioned calls both incoming and outgoing Further analysis showed no telephone calls to either cellular telephone or residence were registered prior to February 6, 2005. I also conducted an analysis on the telephone calls from The subscriber information confirmed that the number is registers to Paul A Lavery from Hialeah, Florida. The address was crossed referenced to the Office of Kiraly and Riley Private Investigators. I researched the web page www.rileykiraly.com which also showed various cases in which they assisted. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy Black is among his clientele. air eves and ad telephone contact with either just after I attempted to interview them, or just prior. A background was conducted on Lavery which revealed he holds a current Private Investigator License. A criminal arrest record revealed he had been previously arrested for possession of cocaine and solicitation of prostitution. i also researched the girls using www.myspace.com. This web site is a new social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. The site allows one to establish your own myspace.com page and decorate the page any way one wishes. I received a Cingular Wireless packet which contained a CD which ' e results of the subpoena request for verbatim calls on . An analysis will be conducted in the near future on the phone numbers called. Investigation Continues. ******t********** ,t********** N A R RA **************t*********** NA Reported By: 12/27/05 Entered By.: 12/29/05 Upon doing research on the message b ocated the identity was registered to seventeen years old and is atten•lng t vered in the search " The telephone number 's EFTA00230986

Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 66 Incident Report Program: CMS301L Case No (Continued) responded to , also known as thrills locate t e Simon Yout Foundation. I located inside the foundation and informed her that I was investigatin e against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life e in her. I explained that although she is seventeen years old I needed to inform her parents that she would be interviewed. She provided her home telephone number. I attempted contact and left voice mail messages at the house to speak with her parents. Det at about Jef rey Epstein. She advised she is • in love with Epstein and would do anything for him. She further explained that she would not speak with us about him either negative or positive. She asked us to leave her property. I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to rrival residence I had telephone contact with he , who was told she would be interviewed. is currently seventeen years old and as a juvenile, parental notification would be required. We then left the area and returned to the police station. d I then located at her residence located in West Palm Beac . I attempted to intervi er the police station, I left another parents. I began an an one. The telephone number and the financially response• e party is Jeffrey Epstein of 457 Madison Ave. in New York City, New York. The time frame which was subpoenaed was September 2005, through October 2005. There were eighty seven pages of calls made either to the cell phone or from the cell phone. The local (561) numbers were analyzed. A spread sheet was prepared and placed into the attachment file of who was called. The unknown numbers were researched using FoneFinder.com and subpoenas were requested to determine subscriber information. This was done to Wil y additional victims or witnesses. The analysis revealed that had called the victim/witnesses frequently when Epstein was in the Town of Palm Beach to "work." Thiii firms what the girls ry inte iewed had previously stated. would notify them when Epstein was in town and their willingness to "work." The CD was placed into evidence. Investigation Continues. ***************** ****** ***** NA N A R R A • ************************** Reported By: 1/03/06 Entered By.: 1/03/06 On December 29, 2005, I received a facsimile from National Compliance EFTA00230987

Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 67 Program: CMS301L Case No • 1-05-000368 Center from Cingular Wireless was the teleR4one number for during the time frame when the victim, II, was brought to the Epstein house to "work." An analysis of the phone records, of all incoming and ou oing calls, showed that on ary 6, 2005, t to first called at t 12:50 pm (EST). The next call was made to Epstein's house in Palm Biirh, at 12:52 pm (EST). The following call was made to the victim, , at 1:01 pm (EST) and at 1:02 pm (EST). This confirms the information provided by the victim and victim's father. I photo copiedi iiecords and enlarged the page 8 of 10 to show the calls made by on February 6, 2005. tinued) e number . This ictim, •, was brought , Epstein's assistant, To this date, I have not heard from parents. I will attempt to establish contact with them during the evening hours. I received a package from Atty. Guy Fronstin, which was hand delivered at the police station. Within the package, was a letter from Alan Der were that of wo profiles. The profiles and . MySpace.com is a social networking service that allows me ers to create unique personal profiles online in order to find and communicate with old and new friends. This package was in response to a previous meeting in which Mr. Dershowitz called to assist in the investigation in providing any additional witnesses such as house employees who have been reluctant to speak with law enforcement. " I reviewed the p Mr. Deriiiiifz enclosed. , who designed Fucking ," still attends Royal Palm Beach her blog to be High School, sends and receives messages from friends which contain some profanity. Upon reviewing her friends' comments section from Myspace, most of her good friends sent messages to establish contact and invite her to go out. I then reviewed web blog which ded by Mr. Dershowitz. Ms. designed her blog to be " ' " Her blog states that her interests inclu usic, theater and weed (Marijuana). I reviewed her packet in which iill declares her love for her live- end. She also describes using marijuana with her boyfriend The letter Mr. Dershowitz sent advised he was looking into the allegation that one of the private investigators used by the private attorneys of Epstein, attempted to impersonate or state that they were police officers from Palm Beach. 'tz advised that the investigators used to interview had "quite a distinct speech impediment", did not claim to be nor did they impersonate themselves as a police officer. This package was sent to both ASA Lana Belohlavic and ASA Daliah Weiss at the State Attorney's Office. I made telephone contact with ASA Weis package and request an interview with and Janusz Banasiak. She advised she would assist in attempting to EFTA00230988

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 68 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 contact Mr Dershowitz. (Continued) On January 3, 2006, I received a telephone call from ASA Weiss who informed me that she made telephone contact with Mr. Dershowitz. She had requested the employees be available the week of January 3, 2006. Mr. Dershowitz informed her that the assistants are out of the country and would require additional time to locate them and make them available. Investigation Continues. ****************************NAREA E ************************** NA Reported By: Entered By.: ■ 1/03/06 1/03/06 On Thursday, 03/31/05, I started conducting surveillance at 358 El Brillo. his point I observed at 1155 hours, tima bearing FL tag in Roadway, B bearing FL tag in drive, Tan Honda Civic bearing FL tag in Roadway, Black Chevy Suburban in driveway and a Black Cad lade in driveway. At 1325 Hours I observed Tan Honda Civic in roadway, Black Chevy Suburban in driv eack Caddy Escalade in drive and a White Kia ciiiiiiring FL tag . At 1615 hours I observed a Tan Honda Civic, in roadway, Black Chevy Suburban ive, Black Caddy Escalade in driveway and a White Kia car in roadway. On Friday, 04/01/05, I continued surveillance at 358 E1 o. At 1130 hours I observed a Tan Honda Civic bearing FL tag IIIIII in roadway, Black Escalade in driveway and a Tan unknown make/model bearing FL t in roadway. At 1227 hours, I observed a Tan Honda Civic in roadway, Black Caddy Escalade in driveway and a Black Chevy SUV located be • e Escalade. At 1345 hours, I observed a Tan Honda Civic in roadway and a Blac SW in driveway. At 1558 hours, I observed a Tan Honda Civic in roadway, Black Chevy SW in driveway, Black Caddy Escalade in driveway and a dark unknown model/make car parked in garage. On Saturday, 04/02/05, I continued surveillance at 35 rillo. At 0713 hours, I observed a Red Explorer bearing FL tag in roadway and a Black Caddy scalade in driveway. At 0814 hours, I observed a roadway, Black Caddy Escalade in driveway and a nda Civic At 0952 hours, I observed a Red Explorer in roadway, Black Caddy Escalade in driveway, Tan Honda Civic in roadway and also a Grey unknown make/model with a B.M in trunk retrieving landscaping tools. At 1155 hours, I observed a Grey Camaro bearing FL tag , parking in the roadway in front of 358 El Brillo. A W/F, blond hair, teens to early 20's, thin and tall wearing a white tank top and short blue jean shorts, exited the vehicle annulled to the rear of the house. I also observed a Red Explorer IIII in roadway, Tan Honda Civic in roadway and a Black Caddy Escalade in driveway. At 1310 hours, I Red Explorer EFTA00230989

Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 69 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) observed a Red Explorer W/F driver lea e area, Tan subcompact on roadway and a Red Neon bearing FL tag Then observed 3 W/Fs, approximately 16 to 18 years of age jogging. All 3 females ran into the driveway. There were 2 with blond hair and one brown hair. On Sunday, 04/03/05, I continued surveil at 358 El Brillo. At 0719 hours I observed a Tan Honda Civic in roadway and ck Caddy Escalade. At 0934 hours, I observed a Tan Honda Civic in roadway and a Black Caddy Escalade reway. At 1057 hours I observed only the Tan Honda Civic On Tuesday, 04/05/05, I continued sure ce at 358 El Brillo. At 1052 hours, I observed a lorer in roadway, a Green Baring FL tag in roadw Expl Grey Altima bearing FL tag in roadway, White Ford Truck in roadway, Black Mercedes in driveway being washed by a B M and an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and p in the driveway. At 1119 hours, I observed the White Fort Truck leave the area and the drive was the pool man. At 1126 hours, I observed a Grey unknown make/model car park in roadway. W/M got out of the car and walked to a house on the south side of El Brillo. At 1406 hours, I observed a Red Explorer parked on roadway and a large white box truck parked behind the surveillance suburban. ***** ***** **** ***** *********NARRATIVE # 32 ************************** NA Reported By: C . 1/03/06 Entered By.: A. 1/03/06 On 03/31/05, at approximately 1500 hours while conducting surveillance at 358 El Brillo, I observed a Black Cadillac Escalade, unknown tag, a Chevrolet Suburban, unknown tag, a Black Mercedes $600 FL tag parked in the east dri ext to the 3-car garage. There was a Tan Honda Civic FL tag parked on the street in front of the residence. At approximately 1700 hours, I observed the Black Suburban, Black Escalade, Black Mercedes and Tan Honda Civic parked in the same place. At 1750 hours, there was no change in vehicles. At 1840 hours, I observed the Black Escalade, Black S an d Black Mercedes along with a Silver Hyundai Accent FL tag parked_in_the east driveway and a Red Ford Explorer FL parked on the street in front of the residence. At 2000 hours, I observed the Black Escalade, Black Suburban parked in the ease driveway and the Red Explorer and Tan Civic parked on the street. On Friday, 04/01/05 at approximately 1700 hours, I observed the Black EFTA00230990

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 70 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Escalade and Black Suburban parked in the east driveway and the Tan Honda Civic parked on the street in front of the residence. At 1820 hours, I observed the S and Civic in the same place and a Gold Chevrolet Camaro FL tag parked on the street in front of the residence. At 2250 there was no change. At 2330, I observed the Black Escalade parked in the driveway and the Red Explorer parked on the street in front of the residence. On Saturday, 04/02/05 at approximately 1700 hours, I observed a Black Escalade, unknown tag, parked in the driveway and a Tan Honda Civic FL tag X98AMP parked in the street in front of the residence. At 1805 hours the Escala Civic were in the same position and the Black Mercedes FL tag was also parked in the east driveway. At 1920 hours the Escalade and Civic were the only vehicles and both were in the same position. At 2030 hours and 2145 hours there were no vehicles observed. At 2115 hours, I ed a Black Mercedes, 4-door parked in the east driveway FL tag At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes was the only vehicle observed. **************************** NARRA ************************** NA Reported By: 1/05/06 Entered By.: 1/05/06 I made contact with Mr. , father of , who was told that I wished to interview his daughter. Mr. stated he was aware and had spoken with his daughter about the incident. He stated that his daughter had previously told him she was hired to model lingerie at a Palm Beach mansion. Mr. stated he kn ing else about what she did when she went to "work." Mr. advised he would cooperate with the investigation and make his daughter availa interviews. I asked if she was available for an interview, stated she was not at home at the mome informed him I wou make contact with her at a later time. Mr. expressed his interest in the resolution in this matter as he stated this information has affected his daughter emotionally. On January 4, 2005, I acquired the subpoenas from the State Attorney's Office for Cingular Wireless, Metro PCS, Verizon, Bell South ' ions and Sprint for the unknown telephone numbers from cellular telephone. The subpoenas were sent to the respective telephone carriers for subscriber information. I received a -teIeplibne call from State Attorney's Office, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on-goings at Epstein's house during his employ. I responded to the State Attorney's Office and encountered Mr. Rodriguez waiting in the lobby. I brought Mr. Rodriguez to the interview room. EFTA00230991

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 71 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months. He was referred by associates and his employment lasted the months of November 2004 through May 2005. His responsibilities as house manager included being the butler, chauffer, chef, houseman, run errands for Mr. Epstein and provide for Epstein's guests. Rodriguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. Epstein, he would have to notify Epstein's secretary "Leslie" in York City, who would then notify Epstein's personal assistant, who would relay the message to Epstein. Rodriguez stated Epstein id not want to see or hear the staff when he was in residence. I asked Rodriguez if Epstein received many guests during his stay in Palm Beach. Rodriguez advised he had many guests. I asked specifically about masseuses coming to the house. Rodriguez stated he would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he wouldkginformed to expect someone and make them comfortable until either IIIII or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer the ething to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. He advised he didn't ask their ages but felt they were very young. Rodriguez stated they ate like his own daughter who is in high school. Rodriguez stated they would eat tons of cereal and drink milk all the time. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would clean Mr. Epstein's bedroom after the alleged massages and would discover massager/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's bed. Epstein ordered Rodriguez to go to the Dollar r t a car and rent a car for the same girl he brought the roses to, that she could drive her self to Epstein's house without incident. RoPariguez said _the girl__ always needed rides to and from the house. Rodriguez referred himself as a "human ATM machine" and was ordered by Epstein to maintain a minimum balance of $2,000 dollars on him at all times. When a girl would come by the house and Mr. Epstein was either not in residence or was not at home at the time, Rodriguez was to provide the girl (masseuse) several hundred dollars for their time and to notify Epstein the amount they were given. Epstein also ordered Rodriguez to EFTA00230992

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 72 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) purchase several gifts and provide them as tips to the girls. I asked what kind of gifts. Rodriguez stated he purchased IPODS, jewelry, anything the girls would want. Rodriguez stated the amount of girls that came to the house was approximately fifteen. Each of the girls knew each other and all seemed to know at Royal Palm Beach High School who Mr. Epstein was. When asked to identify these girls, Rodriguez stated he could not at the moment but knew he wrote their names down on a journal he kept during his employ with Mr. Epstein. He kept a journal in the event he needed to explain either to Mr. Epstein or his assistants what was done at the house or who visited the house as he stated he was in-charge of Mr. Epstein's personal security while in Palm Beach. I informed him I would need to view this journal to which he stated he would research the book and contact me to provide the book. The interview was concluded and left the area. i returned back to the police station where the micro cassette was placed into evidence. At approximately 7:20 pm, I was notified Rodriguez located the journal and would call me on January 5, 2005 to provide the journal. Investigation Continuesa& lalt **************************** N A R R A ************************** NA Reported By: 1/09/06 Entered By.: A. 1/10/06 On January 5, 2006, I attempted to meet with Alfredo Rodriguez to recover the folder or journal in which he kept the notes that were given to him during his employ with Mr. Jeffrey Epstein. He kept this folder to justify what he did during his employ should the need arise to justify what occurred with the monies he had to keep or any questions as to the petty cash he withdrew from the household account from the bank. At approximately 10:00 pm, I attempted contact with Mr. Rodriguez and discovered he was assisting his wife at her place of employment and would not be able to meet with me. Mr. Rodriguez stated he would meet with me on January 6, 2006, in Broward County, in the morning hours. On January 6, 2006, at approximately 9:00 am, I received a telephone call from Mr. Rodriguez who advised he had the file in hand and would be traveling northbound to meet with me in Broward County. At 10:50 am, I met with Alfredo Rodriguez at the parking lot of Bank of America in Boca Raton on Yamato Road and Military Trail (known as the Polo Center). Rodriguez produced a green folder which contained documents, a note with Mr. Epstein's stationary with direction toagliger bucket of roses to Royal Palm Beach High -Salool after (iill) high school drama ( or e. Also in that same note was direction to rent a car for ) and direction to extend the rental contract. I returned to the Palm Beach Police Station and placed the folder into evidence. I received a fax from Verizon from the subpoena request sent on EFTA00230993

Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 73 Program: CMS301L Case No • 1-05-000368 01-04-06, for telephone number registered to Dr Perry Bard, from West chiropractor and has an office located Palm Beach. The cellular number is Dr number. (Continued) The phone number is Palm Beach. Dr. Bard is a 4275 Okeechobee Blvd in West Bard's personal cellular On January 9, 2006, Det. and I tray Palm Beach Gardens in an attempt to locate , who been previously seen on the property and identified through her Florida Drivers License and Florida license Plate. A business card was left for her to return my Youth Foundation and located speak with us and in a private taped statement. in had travelled o the Simon agreed to room within the school provided us a During the statement, advised that when she was fifteen or sixteen yea a en to Jeffrey Epstein's house by her associate, stated this occurred late May 2004 or early June 2004. She was told she could model lingerie for money for a wealthy Palm Beacher. She remembered they traveled by yellow cab from their residence in West Palm Beach to Epstein's house. She remembered encountering Epstein at the front door during the evening hours. He introduced himself and brought them into the kitchen II that the ould prepare somethin em to eat. After having a meal, and Epstein brought upstairs to a master bedroom which had a large bathroom. She observed a large style shower, sauna and there was a large massage bed also in the bathroom. Epstein iiiiiid a room within the bathroom and came out wearing oniiiiiiiwel. said they would p a massage on his feet. her this was part of asked why they are doing this. told tine and told her to rub his comfortable. Epstein's direction, by herself. Epstein told to get comfort her blouse and pants and stayed in her panties. stated she was not wearing a bra. She believed she was g panties. onto his back and heaan and began stein Epstein•• to get calvea and feet. At left the room leaving there removed ; he but stayed on anties. During the first massage, she stated Epstein was and began masturbating himself at the same time. He put his hands_ under the dowel and______ as to ' if however she never saw his penis. She continued until he grabbed her and pulled her closer to him. He appeared to have climaxed because after he pulled her closer to him the massage was over. Epstein had told her that there was two hundred dollars for her on the dresser. He told her that she could not teliiiiiiie what happened at the house or bad things could happen. stated she went to Epstein's house three EFTA00230994

Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 74 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) or four times total. was very scared and felt very nervous. She knew because of Epstein's money he was powerful. After the massage, Epstein ordered his houseman at the time to drive the girls home. The employee was to drop off the girls at their house and watch them go inside their house. IIIIIII could not er who the houseman was. She stated Epstein and his assistant would call her at her father's house to arrange for her to come and "work." She advised 'me she returned to the house, Epstein would do the same thing. stated it was a routine with Epstein. She es. He would then turn over and begin to . The only differ one wit out panties. Epstein's fingers would as he would masturbate and finally climax and the massage woul be over. She was paid $200.00 each time she went. Each time she went she was reminded not to speak of what happened at the house and that she would be co ed again. She began to purposely miss the calls when ' or Epstein would call her. She once brought a friend, " " un no work for Epstein. She was paid $200.00 or MO ringing nailliii stated she no longer retuned to work for Epstein. She a so stated . wanted to notify the police of what happened at the house. stated she was scared of what could have happened to her or her family if she notified authorities. On January 10, 2006, I received the results BellSouth Telecommunicatio number is assigned to Mr. Beach Gardens. I also received t confirmed the money order sent to from Jeffrey Epstein in New York City. The "wire" was sent by Jeffrey Epstein of 457 Madison Ave in New York City on December 23, 2004 at 12125 pm. t of $222.00 was charged to Epstein's credit card II that ncould receive $200.00 in Royal Palm Beach. The twenty-two dollars was for processing and local fees to send ey via Western Union. A copy of the check presented to attached to the receipt of the wire. This confirmed w at advised she received as a Christmas bonus from Epstein. from t from . The 's father in Palm estern Union which Investigation continues. **************************** NA l NARRA ************************** Reported By: 1/10/06 Entered By.: A. 1/10/06 I received and reviewed the Cingular Wireless results from the cribe and , is assigned to Janusz Banasiak Epstein of 457 Madison Ave in New York City. houseman/house mans El Brillo Way The second number, , is assigned for telephone numbers The first number, in care of Jeffrey Banasiak is the current in 3480. to of EFTA00230995

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 75 Program: CMS301L Case iiIIIIIIIIiiiiI5-000368 nued) in West Palm Beach. Research conducted on revealed she is a licensed Massage 'stile Florida conditional/active license number . had been previously arrested for battery / unwanted touching and DUI. Requests for copies of the reports involving the arrests were reques Palm Beach County Sheriff's Office. The last number is assigned to Thomas Rofrano of 9850 Alt AlA in Palm Beach Gardens. Research on Mr. Rofrano, revealed that he is a Florida Chiropractic Physician. Vehicles that were previously documented on the property while surveillance was being conducted were rese I determined a tan Chevrolet Camaro, bearing Florida license , was seen on the property in which a young white female was seen entering the Epstein property. Res onducted which reveal at the vehicle is ' to and La_Mr. has two daughters, is currently residing in Connecticut and residing with her father in Lake Worth. Research on revealed she was recently involved in a traffic stop in Lake Clarke Shores in May 19, 2005. A request to discover any information from the stop was requested. I spoke with ASA Daliah Weiss who informed me that Janusz Banasiak will be available for an interview tomorrow at the State Attorney's Office in West Palm Beach at 1:30 pm. I informed her that I would be at her office for the interview. **************************** N A R R A 35_************************** MI NA Reported By: 1/23/06 Entered By.: A. 1/23/06 2006, Det. and I at in Palm Beach Gardens. h was identified as a licensed massage therapist who had previously b n on Epstein's property when physical surveillance was done. was told of the on going investigation and I felt she may hav information pertaining to the case. During a sworn taped statement, stated she met Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed irls to work at the house to answer phones and run errands. accepted the job Si an working at Epstein's house on El Brillo in Palm Beach. stated it was a part time job during the time she went to Palm Beach Atlantic College. She continued going to Epstein's ho would be notified when Epstein would travel to Palm advised she would be notified by Maxwell, Epstei , his assistant, when he would travel to Palm Beach. stated she began providing massages to Epstein before she became a massage limpli o licontin iving massages noti liow2sti.cnd o to and his what occurred during the massages. Ili, stated as she was twenty EFTA00230996

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 76 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) three years old when she met Epstein, anything that happened was between two consenting adults. I explained to her that she was not in any trouble however as t of this investigation, I needed to ask certain questions. stated that there were times that Epstein would ask her to per orm uring the massage.Iiiiiiiuld instruct her to rub his nipples as he masturbated himself. stated she felt "grossed" ab i behavior but as she was getting paid, she just continued. also advised she would on occasion perform the massages naked. Epstein would on occasion, utilize the r/massager on her vagina area when she performed the massages. explained that Epstein never exposed himself to her as he maintained himself covered under the towel he would be wearing. When Epstein would masturbate he would be covered. I asked if Epstein. Epstein took She received ever received any gifts, or any gratuities from advised aside from being paid well, she advised care of her tuition from Palm Beach Atlantic College. a rental car for a week when her scooter broke down. Additionally she received other gifts from Epstein. Epstein also recommended her to another client who resides at Breakers Row in Palm Beach. The client she was referred to was "Glenn" unknown last name, and his wife, who she provided a massages to. The statement was concluded and placed into evidence upon our return to the Palm Beach Police Department. While at the police station, I researched Florida tag which was also previously seen on the property when there was physical e being done at the property. The vehicleiiiiiegistered to r. and the „ of Lake Worth, Florida. vehicle revealed that his daughter, had been driving ' the vehicle and was cited for unlawful speed in Lake Clark Sho, eh is a tan, Camaro, 2-doo date o •' th, , resides at space page called . In her web page, shows various photos of photographed at a beach. An interview is forthcoming. A review of the video disks which was extracted at the Palm Beach County Sheriff's Office Computer Crime Unit revealed that only one hidden camera was functional at the time. Several image ' work' ii" iit e were seen. Additional footage of and was seen. There was other footage of females seen. The identity of the females is unknown at this time, until such time as I meet with certain—females to show the video footage to confiiilifiliiiirct, • ' n the video. At this time it appears that and are seen sitting with Epstein beside his desk in the evening hours. Due to poor lighting, a direct confirmation cannot be made at this time. Inv. Continues. EFTA00230997

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 77 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 **************************** N A R R A NA Reported By: Entered By.: (Continued) MI ************************** 1/30/06 II 1/30/06 anuary 25, 2006, Det nde in Lake Worth and met with ilii, stated last year, when she was seventeen e, met Jeffrey Epstein through her former roo a was allegedly dating Epstein at the time. and once cohabitated together when they modeled. explain called her on her telephone dvised her that s e was in Palm Beach and requested to slit made arrangements to m ith . at Ep 's house. arrived and met Epstein and went to Palm Beach Mall togetherand went shopping. advised that and she had received money from Epstein to go to the mall. They visited Victoria's Secret and purchased undergarments from the store utilizing s given by Epstein. advised she purchased one item and purchase various items. The money used to purchase the items was the money given by Epstein. a continued shopping and having a day together. stated explained how she and Epstein been dat ach other and he has een paying all of her bills. claimed advised they met in New York and had been dating ever since. They later returned to Epstei ome and encountered Epstein. He had a brief conversation with out her modeling career. He knew of her modeling career from . He requested to see her modeling olio and explaine that he coulgjaglp her with modeling jobs. had her book with her to show IIIII and showed the book to E n. He commented negatively about her photographs and portfolio. felt uncomfortable with the comments made as she had been working with other professional modeling companies who had offered her work from her photograph stein requested to see what was purchased at the mall. took out the undergarments which were purchased. She immediately showed E ' different s urchased. Epstein then requested to view what purchased. was reluctant to show the outfit however since it was Epstein's money that purchased the i she pulled ' t of the bag. Epstein asked her to try it on. looked at who told her "yeah, try it on." Feeling compelled to try the un ergarment outfit on; she went to another room and put on the bra and panty set. She walked out to the living room where they were sitting, and modeled the suit. She then ack into the other room and chan ack into her clothes. returned into the room andliiii she would be going home. scheduled another day for to return for massages with her. stated within t ame week, she returned to meet with and have a massage. had told her that she would be unable to with her as she would be going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. EFTA00230998

Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 78 Incident Report Program: CMS301L Case 1-05-000368 (Continued) stated she met with an unknown ma therapist and had the table already set up in a guest room. removed her clothing, leaving he ties on, and wrapped herself with a towel for the massage. remembered that the door to the guest room was closed but not loc ed. As the therapist was working ack, the door was opened by Epstein and entered into the room. was trying to conceal herself as Epstein was talking to her a out his opractic session. Epstein told turn over onto her back. eas Epstein as he stated Epstein " removed her self the table, got dressed and left occasions to to her back to Epstein's house to which had attempted to call her further stated " 'm busy." advised she has not had contact with either Jeffrey Epstein. It should be noted that her mother, was present during the interview. The interview was and we thanked them her for their time. the house. several concluded **************************** N A R R A NA Reported By: Entered By.: A. On 0 ade telephone contact with at is a licensed massag apist who frequented the home of Jeffrey Epstein. Ms. has been meet with me in Palm Beach County, and because she lives and Port cie, a telephone interview was conducted. I explained to Ms. that there was an on going investigation involving Jeffrey Epstein. stated she knows Epstein and has been approximately three years. Epstein has paid Massages (Deep Tissue) on him and other guests. approximately three year ago she met Ghislaine Maxwe Epstein through a mutuiiiiiiend. Epstein and Maxwell were looking for a massage therapist. stated si t time, she is notified when Epstein is coming to Palm Beach. d she comes to his house and provides the massage or massages explained she has also massaged his guests and assistants. continued that she is paid $100.00 and hour for the massage. I asked if anything occ during the massage that would have made her feel uncomfortable. stated she only provided massages lind that was it. -She never was approached for anything else. I iced if Epstein ever asked her to rub his chest she sta., would not rub his chest as that is not part of her massage. explained that she was not Epstein's type. The girls she would mil Epstein's house were very thin, beautiful and without tattoos. explained she has several tattoos that are visible. Maxwell and Epstein have commented negatively about her tattoos previously when she has provided massages. 1/31/06 1/31/06 had unable to works in ed by him for perform Swedish explained that and Jeffrey EFTA00230999

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 79 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) stated she only provided massages for Epstein andliiii, associates and nothing happened during those massages. stated as she does Swedish style massages, the patient is usually sore after the massages. I thanked her for her assistance and the interview was concluded at this time. I recei ile from T-Mobile Cellular service on telephone number , which is assigned to David Rodgers, pilot for Mr. Epstein, who resides in Lake Wo s' telephone number was dialed on several occasions by . A background on Rodgers indicated he has a valid FAA pi of icense First Class for the Southern FAA Region. Rodgers has another historical FAA license for Airline Transport Pilot. Investigation Continues. NA all ****************************NARRA ************************** Reported By: 2/14/06 Entered By.: A. 2/16/06 uary 3, 2006, I had made arrangements to meet with at the Palm Beac 'on. At approximately 1:00pm, and her friend, arrived at the police station. During an interview with , she stated she met Epstein when she turned eighteen years old and was brought to Epstein's house to provide She advised this occurred on May of 2005. She advised informed her if she wanted to provide a massage for $200.00. eed and was brought to Epstein's house to provide a massage. stated she to the house on many occasions during the massage sessions. also state uld remove her clothing to provide the massage on Epstein. advised Epstein would pay her $300.00 to rub his back, legs and chest. During the massages, Epstein would mast ' she rubbed his chest. her if Epstein ever during the massages. replie n " I askegIImher • ' or massaged her vagina. stated . I asked her i r penetrated her with either his stated that during a massage he she massaged him. She stated this occurred one time only. stated the massage over when Epstein would climax onto a towel. I asked if she ha al massage training to which she replied that she did not. then asked if she ever brought anyone to the house to "work." stated she brought two people to the house. She advis eceived money-for-bringing e house to "w her friend stated she brought a gir Pectin-eat and was still wa r in the lobby of the police station. I thanked o her time and her cooperation and escorted her to the lobby. I asked Ms if I could speak with her about this investigation. I EFTA00231000

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 80 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) brought her to the interview room and explained to her that I was conducting an investigation on Jeffrey Epstein and felt she may have information " o the investigation. Ms identified and resides in Wellington, Florida. She herself as advised approximately a year lire was brought to Epstein's house to provide a massage for money. stated she ded to make money and felt it was a quick way some money. stated she was brought to the house by and was intro uced to Epstein and his assistant. She was broug t to his main bathroom and provi a massage. I as v aked. ted she did. She I asked if Epstein touched er uring t e massage. id not, however he did masturbate himself as she . Once he climaxe e massage was over. She was pal her money and left the area. advised it occurred one time and she n returned to Epstein's ouse. The interview was concluded and was escorted to the lobby. I located a telephone number for pted to contact ligL2n several occasions. I called and spoke with Ms. who advised she would speak with me in Deerfield Beach where she resides. Due to a scheduling conflict, we were unable to meet. I informed her I would contact her to schedule another appointment to speak with her about this investigation. I have attempted to meet with her and make telephone contact with negative results. On February 13, 2006, I met with David Rodgers at 7318 Heathley Drive in Lake Worth. Rodgers was identified as Epstein's pilot. I spoke with Rodgers who advised he has been employed with Epstein since 1991. He flies both planes for Epstein depending where he wants to fly to. Rodgers was asked about passengers in the plane heLliaa. Rodgers stated unless Epstein flew to his island off of St there would be no way of knowing who the passengers were. I menti ent flight to Ohio, where Rodgers flew to Ohio to pick up Rodgers s he recalled flying on several occasions and did remember . Rodgers stated once he is in the cockpit, he does not know who the passengers are. When he prepares the passenger mani e lists Epstein and his assistants he knows by name, and . Rodgers stated he would list either female or male passengers on the manifests only to keep a count on the passengers. Mrs. Rodgers came into the living room and recommended that her husband consult with an attorney. Mr. Rodgers agreed he would speak with the family attorney to inform him of this questioning. I explained to Mr. Odgers that he was not the suspect ih this investigation and ceased all questions. Based on the fact Rodgers could not advise who passengers were in the plane, I then left the area. I attempted to locate at in Wellington. I left my business card for her to return my call. February 14, 2006, at 12:06 pm, I received a call back from Ms. EFTA00231001

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 81 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-00036Ammm. (Continued) on my ' • Ms IIIII left her telephone number for a return call . I left her a message to return call. Investigation Continues.. Mt ***************** ******* ****NARRA ************************** NA Reported By: 2/21/06 Entered By.: A. 2/22/06 On February 15, 2006, I made telephone contact with who provided dire • could locate her. Det I in La rk to meet with ded to i Upon my arrival, I met with in the parking lot directly behind MAACO Auto Painting. She was advised I was there to speak with her about an 2againg investigation that concerned Jeffrey Epstein in Palm Beach. IIIII stated she knows Epstein very well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want to speak with me about anything concerning Jeffrey Epstein. I explained to her that she was seen at the house and I would like to speak with her. She stated she knew there was an investigation and that I had spoken with other iiiiie and therefore I should know what happened at Epstein's house. ended the conversation and ack into her boyfriends business, Blanton Automotive. Det and I left the area and returned to the police station. Investigation continues. ****************************NARRA ************************** NA Reported By: 4/10/06 Entered By.: 4/10/06 A Grand Jury Session was requested during the month of February 2006, in which all the girls that had been interviewed would have been called to testify before the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some marijuana use. The State Attorney's Office wanted time to review the material. I requested additional subpoenas from the State Attorney's Office in which I requested information from Dollar Rent a Car and Jet Aviation. The lfiformation requested from Dolma Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's planes were in Palm Beach County. I continued to research other names that were acquired either from interviews or intelligence gathered during the investigation. I EFTA00231002

Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 82 Program: CMS301L lila Case No. . ed) in Royal Palm Beach. I responded (Co in Royal Palm Beach. During the interview stated she knew I would be speaking with her. stated she ' introduced to Epstein when she turned eighteen years old. stated she was sure of her age as it was her senior year in Royal Palm Beach High School. She advised she was brought there to make money and was told she would have to provide a massage to this each guy. She remembered she met Epstein and his assistant in itchen area. She stated she was taklajay one of her friends, She stated she went upstairs with while got ready for the massage. He exited his bathroom naked and . IIIII • ound. Epstein asked her if being naked offended her. stated it made her omf able. Epstein then put on a towel and lay on the table. stated she rubbed his back and e stated she had no massage training or experience. buttocks. s during the massage, • ouch her pulled away as . She told him again she was uncomfortable with him touching her. Epstein then cut the massage short and became upset with her. Epstein ' $200.00 for the massage and told her to leave the house. ed to the house. She did advise of time she went with , however she waited in the car for she did not want to go into the house. clusion of visit with Epstein they left the area. stated she had heard from other girls that have gone to the house t at Epstein now required them to do the massage naked and allow him to touch the ' 'r private areas for monies. The interview was concluded as did not have any other information to provide. I then learned from the original victim, II, the defense attorney had learned of her identity. I spoke with the father of the victim, who stated there has been a private investigator on his house photographing his family and chas itors who come to the house. He provided a Florida License of . This vehicle is registered to Ivan Robles of West Palm Beach. Robles is a private investigator intern who is licensed by the state. I informed the State Attorney's Office of the above information. I received the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on April 18, through April 20, 2006. Investigation continues. Ili tt*********** ****** rtrt*1-**It N -A--R -R- A *4************* ***** ****** NA Reported By: 4/14/06 Entered By.: A. 4/18/06 The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 006, at approximately 7:30 p.m., I personally served the parents of II, who had informed me that the private investigators were still photographing the family. On April EFTA00231003

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 83 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served II at her Issidence in Royal Palm Beach. The subpoena was given to her mother, III. I learned through one of the victims (*) that she was personally contacted through a.gource that has maintained contact with Epstein. The source assured II she would receive monetary comp sation for her assistance in not cooperating with law enforcement. II also stated she was told, "Those who help him wile compensated and those who hurt him will be dealt with." I told III that tampering with a witness/victim is an arrestable offense an ery serious. I asked her who approached her during this encounter. II originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends. On April 11, 2006, Det I traveled e, Florida with the victim, identified , W/F, as the person w o approached her in Rayal Palm Beach while want to pursue the intimidation charges on was III o slated she did not II she was home during Spring Break in March 2006. concerned that the defense attorney was given a copy of the report as certain things she had told me in confidence were repeated to her by . Prior to our departure, the victim was given a copy of her subpoena for the Grand Jury which was scheduled to commence April 18, 2006. Upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Grand Jury. I spoke with ASA Weiss and informed her of the possible intimidation by the defense. On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, I again left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury. At approximately 12:30 pm, I went to the State Attorney's Office and located ASA Weiss and ASA Belohlavic in their offices. I entered ASA Belohlavic's office who informed me that she was going to return my call. She explained that an offer was made to the defense, Atty Guy Fronstin and Atty Alan Dershowitz. The offer is 1 count of Agg_ Assault with intent to commit a felony,-TiVe years pra5rfiOn, with adjudication withheld. Epstein would have to submit to psychiatric/sexual evaluation and no unsupervised visits with minors. When asked about the all the other victims, ASAmSelohlavic stated that was the only offer made as to one victim, II. ASA Belohlavic cell phone rang and went to voice mail. She checked her voice mail and played the message on speaker. The caller identified himself as EFTA00231004

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 84 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Atty Guy Fronstin and acknowledged the deal made between them. Fronstin stated in the message, he spoke with his client, Jeffrey Epstein, and agreed to the deal. Fronstin asked to call off the grand jury as they would accept this deal. Belohlavic stated a probable cause would be needed to book Epstein in the county jail and would let me know as to when it would be needed. I explained my disapproval of the deal and not being consulted prior to the deal being offered. However I expressed that was only my opinion and the final approval come from the Chief of Police. She explained to have Chief call Barry Krisher about the deal. I left the area and returned to the police station where I briefed the Chief about the deal offered. I checked my voice mail me ges and discovered a message from II, stepmother for the victim II. She was calling because the State Attorney's Office still had not returned any of her calls as to when they are needed for this case. I then called ASA Belohlavic's office and left messages for her to call the victims on this case and explained to them what the State Attorney's Office had done. On April 17, oximately 4:30 pm, State Attorney Investigator called to officially notify me of the cancellation of t e Grand Jury. He requested I contact the victims that ha ved to appear, to notify them of the cancellation. advised that as this Grand Jury session was called based on the State Attorney's Office decision to have the victims heard by the Grand Jury that I felt it was the States Attorney's Office responsibility to contact the victims and advise them of the reason they were no longer needed. NA Mk ****************************NARRA ********** ****** ********** Reported By: 5/04/06 Entered By.: 5/04/06 As I had not received any contact from anyone at the State Attorney's Office, on May 1, 2006, I prepared three arrest warrant requests and submitted them to the State Attorney's Office. The packages were delivered to the Crimes against Children Unit in care of ASA Lana Belohlavek. Jeffrey Epstein's arrest warrant was requested for 4 counts of Unlawful Sexual activity wi minors and one count of Lewd and Lascivious Molestation. , Epstein's assistant's, arrest warrant request was for 4 counts of Principal in the 1st degree Unlawful Sexual activity with certain minors and one • ipal in the 1st degree Lewd and Larivious Molestai-inn arrest warrant request was for Lewd and Lascivious Acts on a victim under 16 years of age. The receipt of delivery was signed and brought back to the records division at the police department. On May 3, 2006, at approximately 2:54 pm, I received a telephone call from ASA Daliah Weiss on my cellular telephone. ASA Weiss advised she EFTA00231005

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 85 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has been assigned the case. ASA Weiss stated she can no longer speak about the Epstein case with me. I thanked her for her telephone call. ASA Weiss further stated that ASA Belohlavek would be calling me. ****************************NAREATI■ E # 4 ************************** NA Reported By: 5/15/06 Entered By.: 5/15/06 On May 10, 2006, information was received that Epstein's associate, Leslie Wexner, The Limited Inc, CEO's, plane had arrived in West Palm Beach, PBIA. The plane, a Gulfstream 4 bearing a N900LS registration, was on the tarmac at Galaxy Aviation. As Epstein had recently acquired the services of a new attorney, and the fact that Epstein's house is currently under remodeling, it was believed that Epstein may be in Palm Beach. I conducted physical surveillance at the residence, 358 El Brillo Way. I observed a large construction crew conducting remodeling at the house. The contractor, David Norr, was observed driving a Ford E , white in color. The vehicle has a Florida registration of r left Epstein's house and traveled north on County Road. Det and I conducted surveillance on Norr. Norr traveled to several construction sites and check ertain jobs. Surveillance was discontinued on Norr and Det and I traveled to Galaxy Aviation. I observed the white plane with a blue stripe along the body and tail of the plane; the tail number was visible on the bottom of the tail, closer to the body of the plane. We maintained visual surveillance on the plane until 4:57 p.m., when a caravan of Cadillac Escalades drove onto the tarmac. We observed several people exit the vehicles and discovered that they were part of the executive team for Limited Inc. The executives were in Palm Beach County for an executive meeting for the day. They arrived in Palm Beach County on May 9, 2006 at 9:30 pm and were scheduled to leave on the 10th at 5:00 pm. On May 12, 2006, I met with ASA Lana Belohlavek at the State Attorney's Office. She explained that her boss, Barry Krischer, was requesting this case be taken to the Grand Jury again. I o her ted arrest warrants for Jeffrey Epstein, and sm I asked that she either issue the warrants or direct file, as II much time has elapsed since the original request to the Grand Jury _l__explained that the Palm Beach Police Department--had--- concluded the case in December of 2005 and has been waiting for the case to go forward. Belohlavek stated the original offer was again offered to the new defense attorney. She was waiting for their answer by Friday May 19, 2006. She stated she would advise me of the answer. **************************** N A R R A # 45 ************************** NA Reported By: 6/05/06 EFTA00231006

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 86 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Entered By.: 6/06/06 On Mali 2006, I received several phone calls throughout the day from , who ed he had been followed aggressively by a private investigator. stated that as he drove to and from work and running errands t roughout the county, the same vehicle was behind him • other vehicles off the road in an attempt not to lose sight of vehicle. I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also explained to him that there was a meeting scheduled with ASA Lana Belohlavek and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA Lana.galohlavek to inform her of the private investigators following IIIII however; she was on her vacation during the week of May 22 through May 30 2006. On May 23, 2006, I received other phone calls from Mr. and who advised they were able to acquire the private investigators license plate information. The t following them was again driving very aggressively and caused to run off the road. the vehicle is a green Chevy Monte Carlo bearing Florida tag The vehicle is registered to Zachary Bechard of Jupiter Florida. Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the State of Florida. Since the diacovery of the threat made against one of the victims in this case ( ) subpoenas for all calls made to and received from during the month of M her and home phone. I had confirmed with the exact dates of Spring Break for 2006. The Spring Break was from March 4, 2006 through March 12, 2006. I received a subpoena from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the 989 calls made and received during the month of March 2006. I observed on March 7, 2006, made and received thirty five calls during that day. Date Time Seconds 7-Mar-06 11:03 AM 492 In/Out Outbound 7-Mar-06 11:16 AM 6 Inbound 7-Mar-06 11:22 AM 887.2 Inbound 7-Mar-06 11:37 KFU--- 48 —Outbound- 7-Mar-06 11:39 AM 28.2 Inbound 7-Mar-06 12:02 PM 727.2 Inbound To/From 561XXXX 561XXXX 561XXXX The table reflects the date of the calls, time of day (EST), duration EFTA00231007

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 87 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) of cal n econds, inbound or outbound calls and ca ade to or from ne. On March 7, 2006, at 11:03 am, made a call to the victim which lasted 492 seconds (8 minutes and 2 seconds). The victim then returned the call a •16 am which lasted 6 seconds. The victim then made contact with at 11:22 am for 877.2 seconds (14 minutes and 6 seconds). These sequences of calls were consistent with what the victim had described to me on the date of the intimidati I ' tely after speaking with the victim, makes a call to , Epstein's assistant, which lasts for forty-eight seconds. A call is then immediately received, a telephone number registered to a Corporation affiliated with Jeffrey Epstein located at 457 Madison Ave in New York. An extensive computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corporate number which lasts 12 minutes and 1 second. It should be noted that there is no further contact with either the victim during the month of March or April of 2006. I also noted that there was no NA further contact with or Jeffrey Epstein during the remainder of the mont o Marc or April 2006. On June 1, 2006, ASA Lana Belohlavek telephoned me to inform me of the meeting that occurred with Atty. Jack Goldberger and her reference this case. She advised she would make her determination on whether to file on this case or not by Monday June 5, 2006. Inv Continues. MI ****************************NARRA ************************** Reported By: 7/12/06 Entered By.: A. 7/12/06 On June 29, 2006, I had spoken to ASA Lana Belohlavic who informed me that the case would be sent to the Grand Jury for charges. She informed me that the grand jury would convene on July 19, 2006 to hear the Epstein case. Belohlavic stated State Attorney Barry Krisher made the determination to go the Grand Jury to hear the case. On July 12, 2006, I spoke with mother of the victim, II, who inquired about the_atatus_o_f_the _case. I explained rn her that--I-was--- told we would be going to the Grand Jury during the week of July 19, 2006. She stated she had not been contacted as of yet by the State Attorney's Office for any information. I provided her with the telephone numbers to the State Attorney's Office. Investigation continues... * * * * * * * * * * * * * * * * END OF REPORT * * * * * * * * * * * * * * * * * EFTA00231008

EFTA00231009

07/27/2006 THU 18:22 FAX 07/26/2006 15:44 5610354700 reiru Irunrnre fool A TRUE BILL IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit The Grand Jurors of the State of Florida, inquiring in end for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31, 2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31. 2005, contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1) against the form of the statute, to the evil example of all others, and against the peace and dignity of the State of Florida. I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law. State Assistant State Attorney of the Fifteenth Judicial Circuit of the of Florldep-rosecuting 1W-the said -- Slate EFTA00231010

07/27/2008 THU 18:23 FAS 07/26/2005 15:44 5610354700 PBPD 114-11NINd rm•a• 0414,022 GRAND JURY FOREPERSON DATE Jeffrey E. Epstein, Rasa* White, Sex: Male, DOB: January 20, 1953, Issue Warrant EFTA00231011

t4 1, k-0 ) gOckin EFTA00231012

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 peangl (O1)60 D.C. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, aik/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN and Defendants. July 18, 2008 STEVEN N. LARUAORE CLERK O.S. MST. CT. S.O. or FLA. • MIAMI NOTICE OF REMOVAL In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(e), the defendants, Jeffrey Epstein, , and hereby remove this action' from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. Sec Jane Doc III v. Epstein, Case No. 08 cv 80069 KAM (S.D. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. filed Mar. 6, 2008). Lewis "rein 30S9GKAKAAviAut,Suin 340,EocoorutSkOvr,FFOROA33133 1.1511 EFTA00231013

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 2 of 100 Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as the instant Amended Complaint, and demanded damages of $50 million. (The amount of the demand against Epstein is evidently the product of recent reports in the press that Epstein is wealthy.) The First Federal Action was quickly followed by a series of substantially identical "Jane Doe" lawsuits, all filed by the same attorney in a three-month span. Compare Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Jan. 24, 2008), with Jane Doe #2 v. Epstein, No. 08-CV-80119-KAM (S.D. Fla. filed Feb. 6, 2008) (asserting identical causes of action based on the same operative allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed Mar. 5, 2008) (same), Jane Doe #4 v. Epstein, No. 08-CV-80380-KAM (S.D. Fla. filed Apr. 14, 2008) (same), and Jane Doe #5 v. Epstein, No. 08-80381-CV-KAM (S.D. Fla. filed Apr. 14. 2008) (same). On February 20, amid these filings, Jane Doe 41 was deposed in State of Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she made numerous admissions that completely undermined the allegations against Epstein that she had pled in her complaint. A copy of her deposition, with names 2 Lewis -rein re. 3059 Gump Avoduc Sum 140,CocoNa Gaon. Rota 33133 2.0111 EFTA00231014

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 3 of 100 redacted, is attached hereto (Exhibit A). Two days later, counsel for Jane Doe # I filed a notice of voluntary dismissal without prejudice in the First Federal Action. See Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 refiled her complaint in Florida Circuit Court as the instant case, adding two nominal defendants: Mr. Epstein's personal secretary, and , one of Jane Doe #1's contemporaries. These defendants have nothing to do with the plaintiff's case against Mr. Epstein, except that the presence of as a defendant in this new case, because she is a citizen of Florida (Am. Compl. 114), would ostensibly prevent complete diversity.2 As discussed below, however, was named in the refiled lawsuit only to destroy diversity jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court . 3 2 Defendant is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section 3509(k) of Title 18, United States Code, provides as follows: It, at any time that a cause of action for recovery of compensation for damage or injury to the person of a child exists, a criminal action is pending which arises out of the same occurrence and in which the child is the victim, the civil action shall be stayed until the end of all phases of the criminal action and any mention of the civil action during the criminal proceeding is prohibited. As used in this subsection, a criminal action is pending until its final adjudication in the trial court. 3 3059 Gino Awing. Sun 340, [adu•Gtovt, km0,433)33 344311 EFTA00231015

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 4 of 100 besides having nothing to do with the substantive allegations of the plaintiff's $50,000,000 case, is a community-college student with no assets whatever. Even if this case purports to identify a new (and strategically nondiverse) tortfeasor, the reified lawsuit is still directed against only one defendant—Jeffrey Epstein. Then and now, the operative allegations are the same: Jane Doe alleges that Jeffrey Epstein assaulted her "in violation of Chapter 800 of the Florida Statutes."4 (Am. Compl. ¶ 18.) To sharpen her lawsuit, the plaintiff says she is seeking damages in connection with a "conspiracy" (Am. Compl. ¶ 22), a "plan" (Am. Compl. ¶ 32), a "scheme" (Am. Compl. ¶ 32), and an "enterprise" (Am. Compl. ¶ 32). These theories of liability, however, cannot be supported by the allegations in the Amended Complaint. Even if everything in the Amended Complaint were true, recovery against , under any formulation, is impossible under Florida law. Focusing on the real parties to this controversy, the instant case could have (once again) been brought here in federal court- just like the four other "Jane 18 U.S.C. § 3509(k) (emphasis added). 4 Chapter 800, Florida Statutes, is entitled, "Lewdness; Indecent Exposure." 4 Lewis Tein n ..., • 3059 GRAM) AVINIR. Sum 340. Coccxyr Groa.Ftwo• 33133 40311 EFTA00231016

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 5 of 100 Doe" lawsuits presently pending against Epstein, filed by this plaintiffs former lawyer. This case is properly removed to federal court, first, because there is complete diversity among the real parties-in-interest, second, because the amount in controversy exceeds $75,000, and third, because this Notice complies with the requirements of 28 U.S.C. § 1446. Discussion A. This case is properly removable because it falls within the original jurisdiction of the United States District Court for the Southern District of Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co.'. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case today. Even though it was reconfigured to look like a state-court lawsuit, this action falls squarely within the bounds of the diversity-jurisdiction statute. See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original jurisdiction over cases where the amount in controversy [is more than $75,000] . . . and [when the controversy] is between citizens of different states"). 5 Lewis 'rein ri 3059GuADAvimist,Sunt 340,Caccour Gtove.ftota 13113 5 d 316 EFTA00231017

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 6 of 100 1. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-KAM (S.D. Fla. filed Jan. 24, 2008) (Compl. ¶ 6). That allegation is now deleted and the Amended Complaint substitutes a generic prayer for reliefs It is clear, however, that Jane Doe still seeks more than $75,000 in damages. This case, precisely like the First Federal Action, seeks damages in connection with an alleged assault. (Am. Compl. ¶¶ 16-19.) The Amended Complaint alleges that Jane Doe "has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological, and emotional damages." (Am. Compl. ¶ 19.) These are the identical injuries Jane Doe asserted in the First Federal Action, and are no less serious simply because pled under a state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, and "clearly [surpassed]," based on "the nature of the injuries alleged" in the complaint). 5 The Complaint seeks damages for "[more than] . $15,0007 (Am. Compl. ¶ 6.) This boilerplate is routinely used in Florida pleading practice to trigger application of section 26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for filing in Florida's Circuit Court (as opposed to County Court). 6 1...e364A1:Fi II rt. 3059 Game Avow. Suns 340, Cocomo Gam, rims33133 9 a/ 31$ EFTA00231018

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[wjhen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from the complaint that the amount in controversy exceeds the jurisdictional requirement." Williams v. Best Buy Co., Inc., 269 F.3d 1316, 1319 (11th Cir. 2001). This case meets that standard, and satisfies the first prong of diversity jurisdiction. 2. There is complete diversity among the real parties to this controversy. Diversity jurisdiction requires complete diversity. Carden v. Arkoma Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the diversity statute to require `complete diversity' of citizenship." (citing Strawbridge v. Curtiss, 7 U.S. (3 Cranch) 267, 267-68 (1806))). See also MacGinnitie v. Hobbs Group, LLC, 420 F.3d 1234, 1239 (1 1 th Cir. 2005) (stating that "[c]omplete diversity requires that no defendant in a diversity action be a citizen of the same state as any plaintiff"). As demonstrated below, this case satisfies the statutory requirement of complete diversity. (a) PlaintiffJane Doe is a citizen of Florida. (Am. Compl. 1.) 6 6 Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint,—See-tiew-Kor-lc-Rostriloh-1,4008-(reperting-thaterrhirwarinhr his state-court state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by Doe. who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that 7 Lewis 'rein a 30596244444044,Sunt 340, COCOMO Goa.% home. 33233 70316 EFTA00231019

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 8 of 100 (13) Defendant Jeffrey Epstein is a citizen of the U.S. Virgin Islands.' (c) Defendant 3. Defendant is a citizen of New York. (Am. Compl. ¶ 5.) was fraudulently joined to defeat diversity. "A non-diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her twin sister lives with her mother in Georgia); Affidavit of at ¶ I (stating, "I am the mother and natural guardian for Jane Doe #1" with jurat executed in Georgia before a Georgia notary), DE 4-2, Jane Doe No. 1 v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), I)E 5-2, Jane Doe No. I v. Epstein, Case No. 08-80069-Civ-Marra (1/29/08); Petition for Removal of Disability of Non-Age, at ¶¶ 1, 2, 7 (filed "on behalf of S.D.G.," alleging that "The mother is , and her address is .... Ga.," and stating that "S.D.G. is also the unnamed party in a lawsuit filed by her father on her behalf in the U.S. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re (Palm Beach Co. Family Ct.) . If this turns out to be the case, there is complete diversity, regardless of citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has since allowed it. Compare Lowery v. Ala. Power Co., 483 F.3d 1184, 1215-16, 1221 (11th Cir. 2007) (holding that jurisdictional discovery to determine citizenship upon removal is inappropriate), with Calixto v. BASF Constr. Chemicals, LLC, slip op., Case No. 07-60077-CIV-ZLOCH, 2008 WL 1840717, *I (S.D. Fla. Apr. 22, 2008) (ordering that parties "shall engage in jurisdictional discovery for the Court to determine the citizenship of BASF and whether it has subject-matter jurisdiction over this action"). 7 The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New York. 8 Lewis "rein n. 3059 GWID AVINUI. Sum 340, Comm QomItasca 33133 101319 EFTA00231020

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 9 of 100 Oct. 15, 2007) (Moreno, J.) (citing Riley v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 292 F.3d 1334, 1337 (11th Cir. 2002)); accord, e.g., Tedder v. F.M.C. Corp., 590 F.2d 115, 117 (5th Cir. 1979) (denying motion to remand where two resident defendants were joined for the fraudulent purpose of defeating federal jurisdiction). In this case, the plaintiff relies on her original allegations to support three causes of action against : civil conspiracy (Am. Comp!. II 20-23); Intentional Infliction of Emotional Distress (Am. Comp!. 23-28); and civil RICO (Am. Compl. 11: 29-34). These allegations, however, do not support these claims, or any other theory of liability that would allow recovery against . Cf. Parks v. The New York Times Co., 308 F.2d 474, 477 (5th Cir. 1962) (observing that "determination of fraudulent joinder is to be based on whether there was a real intention on colorable grounds to procure a joint judgment") (emphasis added).8 (a)Nonresident defendants have a right of removal. The removal statute was enacted specifically "to protect defendants." Legg v. Wyeth, 428 F.3d 1317, 1325 (11th Cir. 2005). Cf., e.g., Picquet v. Amoco Prod. Co., 513 F. Supp. 938, 941 (M.D. La. 1981) (explaining that courts developed the fraudulent-joinder doctrine to protect "the right [of removal] granted to In Bonner v. City of Prichard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc), the ----E4eventh-Gireuit-Geurt-ef-Appeels-adepted-as-binding-preeedent-aIl dwisiuns of 3ho former Fifth Circuit rendered prior to October 1, 1981. 9 L.exylCrsin FL 3039 Gomm Mout. Sum 340. Coccoon Goon, Fos 33133 1@1311 EFTA00231021

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 10 of 100 [defendants] by . . . Congress"). In this case, by reconstituting her original federal lawsuit and refiling it in state Court, the plaintiff has clearly sought to avoid the strictures of the mandatory stay of this case that federal law requires under 18 U.S.C. § 3509(k).9 In federal court, pursuant to 18 U.S.C. § 3509(k), this action must be automatically stayed pending final disposition of an ongoing parallel criminal action against Mr. Epstein. See 18 U.S.C. § 3509(k) (providing that a parallel civil 9 By filing in state court, the plaintiff's attorney has also evidently sought to avoid the clear command of our local rules forbidding public comment about the merits of a pending lawsuit. Compare S.D. Fla. Local Rule 77.2(7) ("A lawyer or law firm associated with a civil action shall not during its investigation or litigation make or participate in making an extrajudicial statement, other than a quotation from or reference to public records, which a reasonable person would expect to be disseminated by means of public communication if there is a reasonable likelihood that such dissemination will interfere with a fair trial and which relates to (a) Evidence regarding the occurrence or transaction involved. (b) The character . . . of a party . . . . (d) The lawyer's opinion as to the merits of the claims ") with Ricci—Leopold Home Page, http:// www.riccilaw.com (click on "Breaking News," then access the hyperlink entitled, 03/13/08 - Consumer Justice Attorney Ted Leopold Files Case to aid Jane Doe in seeking justice against sexual predator Jeffrey Epstein and his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida criminal statutes) and quoting the plaintiff's attorney "Ted Leopold, managing partner" as characterizing Epstein as "an extremely powerful and wealthy man," with "vast resources," who acted "in the vilest way" at his "lavish mansion" with "lurid fantasies" and inflicting "untold damage," and opining that he should "be held accountable;" also quoting the plaintiff's attorney as opining that "[t]his case is both about justice and making sure that a wealthy and powerful man knows that he is not above the law;" also quoting the plaintiff's attorney's view of the evidence that plaintiff "continues to endure emotional trauma daily") (Web site last visited July 17, 2008). 10 1-1e3YARTeinn. 3059GasidoAvulut,Surri 340,CooNve Gaon. FLOMA 33133 100311 EFTA00231022

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 11 of 100 action arising from an alleged sexual assault of a minor "shall be stayed until the end of all phases of [any] criminal action") (emphasis added). In this case, there is a parallel federal criminal grand jury action pending in the Southern District of Florida, In re Grand Jury, No. FGJ 07-103(WPB) (S.D. Fla.), which arises out of the same allegations pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. cf Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WI_ 517847, at *1-2 (ND. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds that "the language of 18 U.S.C. § 3509(k) is clear that a stay is required in a case . . . where a parallel criminal action is pending which arises from the same occurrence involving minor victims") (emphasis added). Even outside the context of a mandatory federal statute, "the Supreme Court [has] admonished [that] `the Federal courts should not sanction devices intended to prevent a removal to a Federal court where one has that right, and should be equally vigilant to protect the right to proceed in the Federal court.'" Legg, 428 F.3d at 1325 (citing Wecker v. Nat'l Enameling & Stamping Co., 204 U.S. 176, 186 (1907)). See also id. (observing that "Congress 'did not extend [to defendants a right of removal] with one hand, and with the other give plaintiffs a bag of tricks 11 Lewis 'Minn. 3059 Glow Am or. Sum 340. Cocis0 I Gwa.I Io6M 3)133 11 01 716 EFTA00231023

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 12 of 100 to overcome it" (quoting McKinney v. Bd. of Trustees of Maryland Ono) Coll, 955 F.2d 924, 928 (4th Cir. 1992))). To protect a nonresident defendant's right of removal, a federal court will "determine the matter of jurisdiction" by examining "the true situation both as to panics and causes of action." Bernblum v. Travelers' Inc. Co., 9 F. Supp. 34, 35 ( W.D. Mo. 1934) (emphasis added). See also id. (observing that "[t]he federal courts will . . . strike out the fiction injected into a case by a party to prevent removal"). In accordance with these principles, a plaintiff cannot destroy diversity jurisdiction simply by conjuring up a nondiverse defendant; there must be at least some "possibility that the state law might impose liability on [the nondiverse] defendant under the circumstances alleged in the complaint." Florence v. Crescent Res., LLC, 484 F.3d 1293, 1299 (11th Cir. 2007) (citations omitted). See also, Holloway v. Morrow, No. 07-0839-WS-M, 2008 WL 401305, at *5 (S.D. Ala. Feb. 11, 2008) (emphasizing that "'Nile potential for legal liability must be reasonable, not merely theoretical" (quoting Legg v. Wyeth, 428 F.3d 1317, 1325 n.5 (11th Cir. 2005))) (emphasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 1...evfitACCFin N. 3059 Gumo Ave nue n 340, Cocewin Gaon, host" 33133 t2 0311 EFTA00231024

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 13 of 100 complaint contains four claims for relief, the first and second claims state only one cause of action") (emphasis added). Using her original allegations and adding nothing, Jane Doe has tried to add claims against for civil conspiracy (Am. Compl. ¶1 20-23), Intentional Infliction of Emotional Distress (Am. Compl. ¶¶ 24-28), and civil RICO (Compl. ¶¶ 29-34) in order to append a nondiverse defendant to her Complaint. These claims, however, are untenable under Jane Doe's own allegations, and therefore cannot be used to destroy diversity jurisdiction. (b) There is nopossibility that the plaintiff can establish a cause of action against under Florida law. (i) The conspiracy claim against must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).10 10 This case is governed by the general rule. Cf. Churruca v. Miami Jai-Alai, Inc., 353 So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily ... no independent ton for conspiracy," there is a narrow exception to this rule when "the plaintiff can show some peculiar power of coercion possessed by the conspirators by virtue of their combination") (emphasis added). See generally Liappas v. Augoustis, 47 So. 2d 582, 583 (Fla. 1950) (observing that -'instances of conspiracy which is in itself an independent tort are rare and should be added to with caution' (quoting Fleming v. Dane, 22 N.E.2d 609, 611, (Mails. 1939))) (emphasis added). Plainly, th;s Cat ;nvulvcs dic genera-rule, not the narrow exception, because only one person could have caused Jane Doe's injuries. CI Martin v. Marlin, 529 So. 2d 1174, 1179 (Fla. 3d DCA 1988) (upholding 13 LeNviA:Ein n. 309 Gram Avow'. Sun( 340,Cocoito Gnm. ha/a:433133 13 1315 EFTA00231025

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 14 of 100 Here, Jane Doe cannot assert a cause of action for "violation of Chapter 800, Florida Statutes" (Am. Compl. ¶ 18) because there is no private right of action under that Chapter. See generally Am. Home Assurance Co. v. Plaza Materials Corp., 908 So. 2d 360, 374 (Fla. 2005) (observing that "not every statutory violation carries a civil remedy" (citing Villazon v. Prudential Health Care Plan, Inc. 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ'g Co. v. Ferre, 636 F. Stipp. 970 (S.D. Fla. 1985) (King, C.J.) (holding that violation of Florida's criminal extortion statute does not give rise to a civil cause of action for damages); Mantooth v. Richards, 557 So. 2d 646, 646 (Ha. 4th DCA 1990) (per curiam) (affirming dismissal of plaintiffs claim for parental kidnapping where "the mentioned statutes concern only criminal violations and do not afford a civil remedy") (citation omitted) (emphasis added); Wright v. Yurko, 446 So. 2d 1162, 1 165 (Ha. 5th DCA 1984) (holding that "[a]n act which does not constitute a basis for a cause of action against one person cannot be made the basis for a civil action for conspiracy"). In this case, Jane Doe's claim under Count H (civil conspiracy) fails because it derives exclusively from Count I (violation of Chapter 800, Florida Statutes). Cf grant of summary judgment against claim for independent conspiracy, noting that "lwihen the concerted acts of the defendants do not create a greater harm than if the acts v‘ ere committed by one person alone. then there can be no recovery"). 14 Lewis "rein it 3059 GuNoAvmvt,Suirt 340.,Cccaivr Grow. FLORIDA 33133 14 of 31$ EFTA00231026

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 15 of 100 Buchanan v. Miami Herald Publ'g Co., 230 E. 2d 9, 12 (Fla. 1969) (holding that where Count I of the complaint had failed to state a cause of action for malicious prosecution, there could be no civil-conspiracy claim in Count II "based on the allegations of Count I"). Because the statute she expressly pleads as the basis for Count I, Chapter 800, Florida Statutes, provides no civil remedy, Jane Doe cannot prevail on Count I. Therefore, she cannot prevail on her claim for conspiracy (Count II) to violate Chapter 800, Florida Statutes (Count I). (II) The laintiff cannot prevail against nondivcrsc defendant on her claim for Intentional Infliction of Emotional Distress (IIED). Even if the plaintiff, for the sake of argument, can assert an IIED claim against Jeffrey Epstein, the plaintiff still does not have a cause of action for IIED against First, the plaintiff cannot recover damages in connection with her own illegal conduct; and second, the plaintiffs purported IIED claim fails as a matter of law. 15 Le.Vp:rein n. 3059Gams Avtrout, Sun 340, COCON.J1 Gaol. 1100 D.33133 IS of 316 EFTA00231027

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "brought Jane Doe to Epstein's mansion in Palm Beach" to help the plaintiff execute her own plan. (Am. Compl. ¶ 13.) Yet, the plaintiff's plan was illegal: under Florida law, it is a cringe "to practice massage" without a license. § 480.047, Ha. Stat. (1997). To say it another way, the plaintiff admits that she went to Mr. Epstein's house to commit a crime. Based on these allegations, it is clear that the plaintiff seeks damages in connection with her own illegal conduct; this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a finding of fraudulent joinder). This conclusion is supported by well-established principles. Under Florida law, a plaintiff cannot recover damages flowing from her own illegal conduct. See Hall v. Hall, 93 Fla. 709, 112 So. 622, 628 (1927) (referring to "the universal rule of our law that one in a court of justice cannot complain . . . of another's wrong whereof he was a partaker") (internal quotation marks and citation 16 Lewis Tein,,. 3059 Gunn Iwthui.Stalit 340. Como' i Gioia, I LOAMA 33133 16 o1316 EFTA00231028

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 17 of 100 omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Ha. 4th DCA 1998) ("[N]o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such as occurred in this case."). Cf Ewe!! v. Daggs, 108 U.S. 143, 149 (1883) (stating that "'[n]o court will lend its aid to a [plaintiff' who founds [a] cause of action upon an immoral or an illegal ace") (quoting Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that this policy is "not for the sake of the defendant, but because [the courts] will not lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) (emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) (Harris, J., concurring) (remarking in the context of an action brought against an alleged prostitution house that "the court should continue its tradition of not interceding in civil conflicts involving transactions that are either illegal or are against public policy"). Based on the foregoing, the plaintiff cannot blame someone else ( ) for the consequences of her own criminal conduct. Cf. Feld & Sons, Inc. v. Pechner, Dorfman, Wolffe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super. Ct. 1983) (holding that law-firm clients could not recover damages flowing from their own criminal acts, even though clients' lawyers had suggested the unlawful conduct to begin with). See also Turner v. Anderson, 704 So. 2d 748, 751 (Fla. 4th 17 Lewis 'rein re • 3059 GoApAytmit,$urt 340, GXOPan Gam. ROMA 33133 11 of 316 EFTA00231029

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 18 of 100 DCA 1998) (approving reasoning in Feld & Sons, holding that "no public policy should allow [a plaintiff] to recover damages as a result of engaging in criminal conduct" where the plaintiff had provided false testimony at an arbitration proceeding). 2. The plaintiff's IIED claim fails as a matter of law. To state a cause of action for TIED, a complaint must allege four elements: II) deliberate or reckless infliction of mental suffering; (2) outrageous conduct; (3) the conduct caused the emotional distress; and (4) the distress was severe. Metro. Life Ins. Co. v. McCarson, 467 So. 2d 277, 278 (Fla. 1985). Whether conduct is outrageous enough to support a claim of intentional infliction of emotional distress is a question of law, not a question of fact. Liberty Mut. Ins. Co. v. Steadman, 968 So. 2d 592, 595 (Fla. 2d DCA 2007) (citations omitted). In this case, without reaching the question of "outrage," the plaintiff has failed to show that conduct - - allegedly arranging an illegal sexual massage that the plaintiff herself agreed to perform - - itself caused the plaintiff to suffer any emotional distress. Even if the alleged agreement was fraudulently induced, the plaintiff's IIED claim flows from Epstein's alleged conduct, not the joint conduct of and Doe in planning the massage. 18 LewfrA,Tvinn. 3059 GaAs° Rvav E. Sun 340, (memo Glow. f 10110A 33133 1110316 EFTA00231030

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 19 of 100 (iii) The plaintiff cannot prevail on her claim for civil remedies for criminal practices or racketeering ("civil RICO") pled in Count IV. A cause of action under section 772.104, Florida Statutes ("Civil Remedies for Criminal Practices") requires a showing of direct injury. Even assuming for the sake of argument that Jane Doe can establish that the defendants engaged in a "pattern of criminal activity," she cannot establish that she was directly injured by those activities. Section 772.104 allows someone to bring a civil RICO claim only if "he or she has been injured by reason of any RICO violation. § 772.104, Fla. Stat. (2007). Here, the allegations in Count IV, even if they are true, do not add up to a civil RICO claim because there is no proximate cause between the purported "pattern of criminal activity" and Jane Doe's alleged injuries. In a doomed attempt to satisfy the extremely high burden of pleading civil RICO under Florida law, the Amended Complaint lists a series of violations rooted in Florida's prostitution statutes. (Am. Compl. 1 31.) According to the Amended Complaint, the defendants participated in a criminal enterprise . . . or conspir[acyj" (Am. Compl. 1 30) over an unspecified length of time "to repeatedly find and bring [Jeffrey Epstein) underage girls . . . in order for Epstein to solicit, coerce, entice, compel, or force such girls in acts of prostitution and/or lewdness" (Am. 19 LeNtigt,Ttin n 3059GusoAviltut,Stml 340,Cocosur Gmm, Folio. 33133 19 of 3111 EFTA00231031

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 20 of 100 Compl. ¶ 32). The alleged "pattern of criminal activity" comprises violations of Chapter 796, Florida Statutes—the chapter that proscribes various crimes of prostitution.13 These allegations do not tie directly into Jane Doe's alleged psychic injuries. In contrast to a cognizable RICO claim, this action concerns only an isolated occurrence. More important, the alleged injuries in this case are pled to have resulted from an alleged sexual assault, an assault "in violation of Chapter 800 of the Florida Statutes" (Am. Compl. ¶ 18)—not anything having to do with the facilitation of prostitution, or more succinctly, the violation of Florida's prostitution law. Civil RICO claims are extraordinarily difficult to plead successfully. There are examples in the case law of RICO claims stemming from a prostitution enterprise, but they are vastly different from what plaintiff pleads here. They involve, for example, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Bala: v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution," 13 The Amended Complaint alleges a "pattern of criminal activity" comprising the following criminal violations: §§ 796.03, 796.07(2)0), 796.07(2)(h), 796.045, and 796.04, Fla. Stat. (Am. Comp1.1 31.) 20 LewAct:Csirt n. IDS9GUND nn SUL SUITE 340, COCONUT WOK RONDA 33133 maw EFTA00231032

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 21 of 100 where petitioners alleged that they had "suffered emotional pain, anguish, humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and emotional distress" as a result of being forced repeatedly, over time, to "perform sexual acts to retain their employment"). Here, even if the Amended Complaint can be read to plead that the defendants schemed to solicit other massages from other people (see, e.g., Am. Compl. ¶¶ 9, 11, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 E. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 M. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-injury requirement under Florida's RICO law, Jane Doe has failed to allege a cause of action against for violation of section 772.103, Florida Statutes. B. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446. 1. This notice of removal is timely. In accordance with 28 U.S.C. § 1446, this notice of removal is timely. Only defendant Epstein has been served with process. Defendants and 21 Lewis Teinn 3059 G.no AVIMA.SVIII 140, Comma Gwn, kola 33133 21 M311 EFTA00231033

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 22 of 100 have not yet been served. In a multi-defendant lawsuit, removal is timely when effected within 30 days after the last defendant is served. See Hill Dermaceuticals, Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Or1-31KRS, 2008 WL 1744794, at *3 (M.D. Ha. Apr. 11, 2008) (concluding that removal petition was timely where it was filed within 30 days after the last defendant was served). 2. Notice has been given, and state-court papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties, and the amount in controversy exceeds $75,000, exclusive of interests and costs, this Court has original jurisdiction over this action pursuant to 28 U.S.C. § 1332(aX1). 22 Lewis Tein 3059 GRANO Amos, Sum 340. COCONUT 69059, itos.04 33133 22 o1318 EFTA00231034

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 23 of 100 WHEREFORE, the Defendants, Jeffrey Epstein, , and , remove this case from Palm Beach Circuit Court to the United States District Court for the Southern District of Florida. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: Fax: • By: 1;4 • fdt- GUY A. LEWIS Fla. Bar No. 623740 [email protected] MICHAEL R. TEIN Fla. Bar No. 993522 ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 Tel. Fax. By: Jack A. Goldberger Fla. Bar No. 262013 Attorneys for Defendant Jeffrey Epstein 23 Leal:Finn 3059 G9550 Avow. ant 340, [atom! Gam. hors 33233 23 01310 EFTA00231035

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 24 of 100 Michael R. Tein CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document is being served this day, July 18, 2008, on counsel of record identified on the service list by U.S. Mail. 24 Lewis. Min II. „•••••••• ••••A 30S9GowoAwuw,Swlt 340,Cocomo Wow, kola 33333 24 01315 EFTA00231036

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 25 of 100 Service List Theodore J. Leopold, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: Counsel for Plaintiff Jane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P.A. Centurion Tower 1601 Forum Place, Suite 1110 West Palm Beach Florida 33401 Fax. Counsel for Defendant Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach Florida 33401 Fax. Counsel for Defendant Robert D. Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach Florida 33401 Fax. Co-Counsel for Jeffrey Epstein 25 LeVykt:11:, in VI 3059 Gam Avi NJ,. 54411 340, COCONu I 61.0vT, :LOMA 33133 25 of 316 EFTA00231037

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 26 of 100 EXHIBIT A 24 ol 318 EFTA00231038

Case 9:08-cv-80804-KAM 4ti ent 1 Entered on FLSD Docket 07/21/2008 Page 27 of 100 nsor & Associates Reparaap and Transcriptice, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CF09454AXX STATE OF FLORIDA, -vs- JEFFREY EPSTEIN, Defendant. DEPOSITION OF Wednesday, February 20, 2008 2:00 p.m. - 4:30 p.m. Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401 Reported By: Judith F. Consor, FPR C PY Notary Public, State of Florida Consor ry Asociates Reporting and Transcription Phone - Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 270316 EFTA00231039

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 28 of 100 nsor & Associates Repo,.ling mid Traascii pnon. Inc Page 2 1 APPEARANCES: 2 on behalf of the State: 3 LANNA BELOHLAVEK, ESQ. ASSISTANT STATE ATTORNEY 4 401 North Dixie Highway West Palm Beach, Florida 33401 5 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 12 WEST PALM BEACH, FLORIDA 33401 13 14 ALSO PRESENT: ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 15 KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL-EZE 16 17 18 19 20 21 22 23 24 25 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 2$ al MI EFTA00231040

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 29 of 100 nsor & Associates Repnrnnp and Transcri pan Inc 1 2 WITNESS: INDEX Page 3 PAGE: 3 DIRECT EXAMINATION 4 4 BY MR. TEIN: 5 6 7 NOEXHIBITS MARKED 8 - - - 9 CERTIFIED QUESTIONS 10 Page Line 53 22 11 55 1 59 2 12 111 14 112 2 13 14 15 16 17 18 19 20 21 22 23 24 25 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 atoms EFTA00231041

Case 9:08-cv-80804-KAM 1 ent 1 Entered on FLSD Docket 07/21/2008 Page 30 of 100 nsor & Associates Roponing and Transcription. lac. Page 4 1 Deposition taken before Judith F. Consor, 2 Court Reporter and Notary Public in and for the State of 3 Florida at Large, in the above cause. 4 - - - 5 Thereupon, 6 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 THE WITNESS: I do. 10 DIRECT EXAMINATION 11 BY MR. TEIN: 12 Q. Good afternoon. Please tell me your full 13 name. 14 A. 15 Q. And can you please spell it. 16 A. 17 18 Q. Thank you. 19 May I call you a 20 A. Uh-huh. 21 Q. going to ask you a few 22 questions, several questions today. If at any time you 23 wan: to take a break, you just let me know. Okay? 24 A. Okay. 25 Q. If you at any time don't understand one of Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 30.1311 EFTA00231042

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 31 of 100 nsor & Associates ReportinE and Traoscripion. Inc Page 5 1 my questions, will you just please let me know? 2 A. Yes. 3 Q. And if at any time you're not feeling well 4 or something like that, you'll tell us, right? 5 A. Yes. 6 Q. Do you feel okay today? 7 A. Yes. 8 Q. Not taking any alcohol or drugs or anything 9 like that, right? 10 A. No. 11 O. II you feel ready to have your deposition 12 taken? 13 A. Yes. 14 Q. what is your address? 15 A. I'm currently living at my aunt's house and 16 I don't know it off the top of my head. 17 Q. Where is it? 18 A. In Jupiter. 19 Q. Who is your aunt? 20 A. 21 Q. Who else is living there? 22 A. my uncle. 23 Q. Anyone else living there? 24 A. No. 25 Q. The contempt motion that your mother filed Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 31 of 316 EFTA00231043

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2006 Page 32 of 100 nsor & Associates Reparnag and Transcii Nit°. Inc Page 6 1 against your father regarding your fifty million-dollar 2 lawsuit against Jeffrey Epstein says that you live with 3 your aunt and uncle and have been living there; is that 4 correct? 5 A. Yes. 6 Q. How long have you been living with your 7 aunt and uncle? 8 A. Since my father kicked me out. 9 Q. That was Thanksgiving of this past year? 10 11 12 A. Q. Yes, sir. Okay. Didn't your firefighter boyfriend get an apartment for the two of you? 13 A. No, sir. He has an apartment, but by 14 himself. 15 Q. Did he get an apartment for the two of you 16 to live in? 17 A. No, sir. 18 0. Are you planning to move in with him? 19 A. Maybe one day in the future. 20 Q. Do you have a plan to move in with him 21 presently? 22 A. No. 23 Q. Have you been to the apartment that you and have discussed moving in together? 25 A. I have been to the apartment. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 32 al MS EFTA00231044

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 33 of 100 nsor & Associates Her:multp mid lranscripom Inc 1 Q. Where is that? 2 A. Palm Beach Lakes. 3 Q. Have you spent the night over there? 4 A. No, sir. 5 Q. Do you know the address there? 6 A. I do not. 7 Page 7 Q. Isn't your sister planning on living 8 with you and it 9 A. No. 10 Q. you know that this court case is a 11 criminal prosecution, correct? 12 A. Correct. 13 Q. And you know that it's a criminal 14 prosecution against a man who has no criminal background. 15 Do you know that? 16 A. I do now. 17 Q. You agree that court is a very serious 18 matter? 19 A. Yes. 20 Q. And you're here with your lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently 24 filed a lawsuit in federal court against Jeffrey Epstein, 25 seeking fifty million dollars. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1101316 EFTA00231045

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page34of100 nsor & Associates Repartinf end Transcripiina, inc. 1 MR. LEOPOLD: Let me just object. 2 3 Page 8 IIIIIIIIplet me instruct you. Anything that you have learned through conversations between you 4 and me are protected. II if you know any of that 5 information outside of those discussions, you may 6 answer. But if the only way you know it is 7 through our discussions, do not answer that 8 question. 9 BY MR. TEIN: 10 Q. you know that Mr. Leopold recently 11 filed a lawsuit in federal court on your behalf against 12 Jeffrey Epstein seeking fifty million dollars? 13 MR. LEOPOLD: Same objection. 14 If you know the answer to that outside of 15 our discussions, you may answer. If it is the 16 only way that you know the answer is through our 17 discussions, do not answer that question. 18 THE WITNESS: Okay. 19 MR. LEOPOLD: Attorney/client privilege. 20 BY MR. TEIN: 21 Q. You can answer the question unless 22 MR. LEOPOLD: Same objection. 23 MR. TEIN: Let me finish. 24 MR. LEOPOLD: Excuse me. We're -- 25 MR. TEIN: No. Let me finish. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 34 ol 116 EFTA00231046

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 35 of 100 sor & Associates Roponin and Transcri rum. Inc. Page 9 1 MR. LEOPOLD: Lewis, we're not going to do 2 3 MR. TEIN: My name is not Lewis. 4 I'm going to finish my question. Okay? 5 MR. LEOPOLD: Do not answer until you hear 6 from me. 7 BY MR. TEIN: 8 Q. Other than conversations that you have had 9 with Mr. Leopold -- I'm not asking about that -- are 10 aware that Mr. Leopold has filed a lawsuit in federal 11 court seeking fifty million dollars from Jeffrey Epstein 12 on your behalf? 13 MR. LEOPOLD: Same objection. 14 Anything that you learn through 15 conversations between you and me, do not answer. 16 Those are protected. If you know through any 17 other realm of knowledge, you may answer. 18 THE WITNESS: No. 19 BY MR. TEIN: 2 0 Q. 21 fifty million-dollar lawsuit on your behalf against 22 Jeffrey Epstein? that. you You have no idea that Mr. Leopold filed a 23 MR. LEOPOLD: Same objection. 2,1 Do not answer that question if it's through 25 discussions that you and I had. Outside of that, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 66 o1316 EFTA00231047

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 36 of 100 nsor & Associates Reporting ad Tranxtip:inei. lac 1 2 3 4 5 6 7 8 9 10 13. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 10 you may answer. II do not answer that question if that is the only basis by which you understand that answer. THE WITNESS: No. BY MR. TEIN: Q. You didn't know that? MR. LEOPOLD: Don't answer that question. Again, it's attorney/client privilege. Any Information you've learned through conversations between you and I are protected. If you know it through any other realm, you may answer. MR. TEIN: Are you going to say that for every question in the deposition, Mr. Leopold? MR. LEOPOLD: When you ask improper questions like that without the proper -- MR. TEIN: You're going to stop your speaking objections right now. Okay? MR. LEOPOLD: Without the proper -- MR. TEIN: You need to stop your speaking objections. Let's continue. MR. LEOPOLD: Counsel, you just asked me a question and I'm going to state it on the record -- MR. TEIN: You need to stop your speaking Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Motile EFTA00231048

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 37 of 100 nsor & Associates ReponmsrowllanwfiNum.bc 1 2 Page 11 objections. Check your rules. MR. LEOPOLD: Excuse me. For the record, 3 Counsel asked me a question. I'll state the 4 answer on the record. Be asked me the question am 5 I going to be answering that way throughout the 6 deposition. II long as there's improper 7 foundation and predicate asked by the attorney, I 8 will protect my client and I make the record where 9 appropriate. If counsel wishes to ask an 10 appropriate worded question with the proper 11 foundation and predicate, I will certainly allow 12 the client to answer the question. 13 MR. GOLDBERGER: Why don't you just state 14 attorney/client privilege and just be done with 15 it? 16 MR. LEOPOLD: I want the record to be 17 clear. 18 MR. TEIN: You want to waste time is what 19 you want to do. 20 You were supposed to be here this morning 21 and you totally broke the deal, the agreement that 22 you had with us if your hearing got cancelled. 23 But let's move on and maybe you'll stop 24 obstructing this deposition. 25 MR. LEOPOLD: I think the record is very Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 IT of 316 EFTA00231049

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 38 of 100 nsor & Associates Ripening and Transaiption. loc. 1 2 3 4 clear where we stand thus far. Is there a recording taken of this deposition? THE COURT REPORTER: Yes. Page 12 5 MR. LEOPOLD: Just make sure that's 6 preserved. 7 BY.MR. TEIN: 8 Q. Go to Exhibit 20-01 -- well, before you do 9 thate are you aware that a lawyer named Jeffrey 10 Herman filed a lawsuit on your behalf, yes or no? 11 MR. LEOPOLD: Objection. 12 13 regarding that, if that is the only way by which 14 you understand how to answer that question, do not 15 answer. It's attorney/client privilege, as well 16 as any conversations you may have had with the 17 attorney from Miami. That is also attorney/client 18 privilege. And I'm assuming -- 19 MR. TEIN: You're actually wrong about the 20 attorney/client privilege. 21 22 asking you to divulge attorney/client -- 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Any conversations that you and I have had MR. LEOPOLD: I'm assuming Counsel is not Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 31 of 3i6 EFTA00231050

Case 9:08-cv-80804-KAM ent 1 EnteredonFLSIDDocket07/21/2008 Page 39 of 100 nsor & Associates Rein-min? and lransc option. Inc Page 13 1 an attorney, filed a fifty-million-dollar lawsuit on your 2 behalf against Jeffrey Epstein, yes or no? 3 MR. LEOPOLD: Same objection. 4 MR. TEIN: We've heard the objection 10 5 times already. 6 MR. LEOPOLD: Counsel, excuse me. 7 MR. TEIN: Just say attorney/client 8 privilege. Stop interrupting my questions. 9 MR. LEOPOLD: I'm entitled to make an 10 objection for the record, which I'm doing, and 11 I'll make the same objection. And if it calls for 12 attorney/client privilege, any conversations you 13 and I have had, do not answer the question. 14 And I think that it might be appropriate, 15 for the record, to ask questions via 16 as opposed to 11.1, I think that 17 would be more appropriate for this deposition. 18 BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. 20 A. Yes. 21 O. Thank you. 22 In fact, you know that Mr. Berman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 A. After it happened. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 39 of 316 EFTA00231051

Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 40 of 100 nsor & Associates Roportenp and Tanscriptinn, 2 4 5 6 7 8 9 10 11 stepmother and Mr. Herman at the press conference 12 regarding your lawsuit? 13 A. Yes. 14 Q. Now you know that this is a very serious 15 matter, don't you? 16 MR. LEOPOLD: Asked and answered. 17 objection. 18 MR. GOLDBERGER: All right. You can 19 20 21 You cannot make legal objections. You have no Page 14 Q. You know that he had a press conference, don't you, yes or no? A. Yes. Q. In fact, let's go to Exhibit 20-01. MR. GOLDBERGER: Look behind you. You'll see it. BY MR. TEIN: Q. Have you ever seen that picture before? A. Yes. 22 23 24 25 Q. Is that a picture of your father, your object. You're representing a witness here, Mr. Leopold. You can object on privilege grounds. standing to do so. MR. LEOPOLD: I'm going to make them and then -- MR. GOLDBERGER: We're -- Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 40 or 314 EFTA00231052

Case 9:08-cv-80804-KAM D. ent 1 Entered on FLSD Docket 07/21/2008 Page 41 of 100 nsor & Associates Rc ponies and Transcription, Inc 1 2 3 appropriate. There's no reason to have this kind 4 of demeanor. If you want to have this kind of 5 demeanor with me -- 6 MR. TEIN: You are obstructing this 7 deposition. 8 MR. GOLDBERGER: Why don't you guys go 9 outside and just talk about -- 10 11 difficult and she's not going to be able to take 12 us both talking at the same time. 13 MR. GOLDBERGER: Off the record. 14 MR. LEOPOLD: We're not going off the 15 record, Jack. We're not, Jack. Her job is very 16 difficult. I'm going td make the record. 17 I don't think it is appropriate, especially 18 in the small confines of this room, to be very 19 aggressive with this young lady. 20 MR. TEIN: That's not happening. Stop, 21 stop actually -- 22 MR. LEOPOLD: If you're going to interrupt Page 15 MR. LEOPOLD: We're going to leave or we're going to take a break, because his demeanor is not MR. LEOPOLD: She -- her job is very 3 me, we're going to cancel this deposition 24 MR. TEIN: Stop misrepresenting. 25 THE COURT REPORTER: I need one at a time, Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 41 of 314 EFTA00231053

Case 9:08-cv-80804-KAM D jent 1 Entered on FLSD Docket 07/21/2008 Page 42 of 100 nsor & Associates Reporting and 'I ranscririon. Inc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 Page 16 no matter who it is MR. LEOPOLD: I think we're going to take a break. Perhaps you might want to talk to your co-counsel -- MR. TEIN: I don't need to talk to him. MR. LEOPOLD: But we're going to take a break. MR. 'FEIN: We're not taking a break unless the witness needs a break. You're obstructing this deposition, Ted. MR. LEOPOLD: Come on, You all want to continue in this demeanor -- MR. TEIN: You're obstructing the deposition. Stop making speeches. We're not discussing this with you. The questions are to your client. Go take your five-minute break. MR. LEOPOLD: Fine. We need to make sure the record's clear and clean. And I want. to make sure, as I've already asked you -- I know that you're one of the best in town -- that this audio -- this needs to be preserved. Okay? MR. TEIN: Go take your five-minute break, Mr. Leopold, now. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 42 at 616 EFTA00231054

Case 9:O8-cv-8O8O4-KAM nt 1 Entered on FLSP Docket 07/21/2008 Page 43 of 100 nsor & Associates ReportivE aad Trauctipdm, lac. 1 2 3 back. 4 Page 17 You were supposed to be here at nine a.m.; it's now after two. Take your break and come MR. LEOPOLD: Okay. If the demeanor keeps 5 up, we will not be here beyond those five minutes. 6 7 8 relax. 9 10 break. 11 MR. GOLDBERGER: Let them take that 12 five-minute break. 13 MR. LEOPOLD: But I would suggest that you 14 take deep breaths. 15 MR. TEIN: Suggest whatever you want. Go 16 take a break. 17 (Thereupon, a recess was taken.) 18 BY MR. TEIN: 19 Q. 20 today at your deposition is something very serious, don't 21 you? 22 A. Yes. 23 Q. And you respect the court, don't you? MR. TEIN: Take your break and come back. MR. LEOPOLD: Okay. So I suggest that you MR. TEIN: I suggest that you take your rialf you agree that giving testimony 24 A. Yes. 25 0. Let me show you Exhibit 31-001. Can you Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 430316 EFTA00231055

Case 9:08-cv-80804-KAM nt 1 Eotterod on FLSD Docket 07/21/2008 Page 44 of 100 sor H,55OClate5 Ropartrnp and 1 ranacri pnon. Inc. Page 18 1 read that out loud, please. 2 A. Okay. What do you want? 3 Q. Will you read that out loud, please. 4 A. Oh. 5 Q. Thank you. 6 A. Lol hah my baddd...lol yah i got some 7 stupid court shit on the 20th...bullshit...and damn you 8 still have court shit with him? Like after so long wow 9 im sorry... well yah well we will definitely havta make 10 plans for sure..because i miss u tons times a million and 11 no no no i love you...o and p.s. i love ur default pic 12 niggaa. Muah xo. 13 Q. Did you send that message last week to a 14 friend of yours on MySpace? 15 A. I wouldn't know. There's no dates and I've 16 deleted that MySpace, so -- 17 O. We're going to talk about that in a second. 18 A. Okay. 19 Q. Did you send that message last week -- 20 A. Right. 21 Let me finish my question. 22 Did you send that message last week to a 23 friend of yours on MySpace? 24 A. I wouldn't know the date, but obviously, 25 it's to a friend. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 44031f EFTA00231056

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 45 of 100 sor & Associates Reponinp and Transcripaw, 1 2 3 4 5 6 7 8 Page 19 Q. Did you send that message to a friend of yo.frs on MySpace? A. Sure, yes. Q. Were you referring to this deposition? A. Yes. Q. Do you find the term n-i-g-g-e-r offensive? A. That's not anywhere in there. Q. What word did you use in there? 9 MR. LEOPOLD: Where are you referring to, 10 Counsel? There's 20 plus words in there. 11 MR. TEIN: Don't make a speaking objection. 12 THE WITNESS: Are you referring to 13 anything -- 14 MR. LEOPOLD: No, Don't -- don't 15 let him ask you the question. 16 BY MR. TEIN: 17 Q. What question were you asking, Ill? 18 MR. LEOPOLD: She doesn't ask questions. 19 You ask the questions. What is the question 20 pending? 21 BY MR. TEIN: 22 Q. what is the last word on there in 23 the text of your message—before the closing?- 24 A. Niggaa. 25 Q. Don't you find that term offensive? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4501316 EFTA00231057

Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 46 of 100 nsor & Associates Reportins. and Transcription, /nt Page 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 A. No. MR. LEOPOLD: Can you spell it for the record, please. THE WITNESS: N-i-g-g -- MR. TEIN: No, no, no. You are not going to be asking questions. MR. LEOPOLD: I'm not asking questions. I'm asking for the record the word to be spelled, because we don't have a video here today. MR. TEIN: These exhibits are part of the record. You -- MR. LEOPOLD: Well, it's not marked as an exhibit. MR. TEIN: Stop interrupting me, Mr. Leopold. I have marked and identified as an exhibit and you will get it. MR. LEOPOLD: There has been no identification of this document in the record. MR. TEIN: Mr. Leopold, stop interrupting this deposition. MR. LEOPOLD: What is the exhibit number marked for identification? MR. TEIN: 31-001. MR. LEOPOLD: Do we have copies? Is it on the record anywhere? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 44.1311 EFTA00231058

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 47 of 100 nsor & Associates Reporting and Transcription, Inc. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Q. And you think this deposition is bull 19 s-h-i-t, don't you? 20 21 22 Page 21 BY MR. TEIN: Q. Let me ask you, did you in fact write your friend this message about this deposition? A. Yes. Q. So you wrote your friend that this deposition is stupid court s-h-i-t, correct? A. Yes. Q. Because you think this deposition is stupid court s-h-i-t, don't you? A. No. Q. You wrote that to your friend, didn't you? A. Yes. Q. You think that court is stupid, don't you? A. In some cases. Q. And you think that court is bull s-h-i-t, don't you? A. No. A. No. Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and 23 answered. 24 25 BY MR. TEIN: MR. TEIN: That's not an objection. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 47 e131$ EFTA00231059

Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page48of100 sor & Associates Ropontng end Transcririon, 1. 2 .3 4 Page 22 Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered, for the fourth time. MR. TEIN: You are improperly objecting, 5 Mr. Leopold. You have no grounds to object. And 6 that's not an objection. 7 MR. LEOPOLD: It is an objection. 8 MR. TEIN: Then terminate the deposition if 9 you think it's been asked and answered. 10 N.R. LEOPOLD: Counsel, I am not precluded 11 from just making an objection to the form of the 12 question. As the courts well know, and if you 13 practice here in West Palm Beach, many of the 14 judges require you to set the objection with 15 specificity. And I will do that. And if you 16 don't want me to, you can make the record. But I 17 will do that. 18 MR. TEIN: Here's what we'll do, Ted. You 19 can -- I will allow you to reserve an objection to 20 form for every single one of my questions. 21 Otherwise, all you're doing is obstructing. 22 23 MR. TEIN: Of course; because you want to 24 obstruct. 25 MR. LEOPOLD: All right. MR. LEOPOLD: I won't do that. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Hot316 EFTA00231060

Case 9:08-cv-80804-KAM P ent 1 Entered on FLSD Docket 07/21/2008 Page 49 of 100 nsor & Associates Roporung end ITansoription. /he 8 9 10 11 12 Page 23 1 BY MR. TEIN: 2 Q. _you think that giving testimony 3 today, under oath, is bull s-h-i-t, don't you? 4 A. No. 5 Q. And you wrote that to your friend on 6 Myspace last week, didn't you? 7 MR. LEOPOLD: Objection. Asked and answered. THE WITNESS: No, I did not. BY MR. TEIN: Q. You didn't write this exhibit? A. I wrote that, but I didn't write what you 13 said. 14 4. 15 16 you write that? 17 18 19 20 21 22 about what happened when you went to Jeff Epstein's house You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't A. Yes. Q. Referring to this deposition, didn't you? A. Referring to the court. I was later informed that it was a deposition. Q. I'm going to ask you some questions now —2-3- three years 09e.—Okey-? 24 25 A. Oh-huh. Q. When the police interviewed you one month Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4S of 316 EFTA00231061

Case 9:08-cv-80804-KAM ment 1 Entered on FLSD Docket 07/21/2008 Page 50 of 100 D sor & Associates tenoning and Transcription. Page 24 1 after you went to Epstein's house, you swore on your 2 mother's grave that you and Epstein did not engage in sex 3 of any kind? 4 A. Yes. 5 Q. Didn't you tell that to the police? 6 A. Yes. And I will continue. I have never 7 had sex with him. 8 Q. Did what happened upstairs at Jeff 9 Epstein's house take you completely by surprise,. 10 A. Yes. 11 Q. Now the civil complaint that you filed 12 against Mr. Epstein for fifty million dollars alleged 13 that you were totally shocked by what happened when you 14 got there. 15 A. Yes. 16 Q. Were you totally shocked by what happened 17 when you got to Epstein's house? 18 A. Yes. 19 Q. You didn't expect it at all, did you? 20 A. No. 21 Q. You had absolutely no idea why your friend 22 ias taking you to Epstein's house, right? 23 A. I was informed it was a massage. 24 Q. All you thought that it was going to be was 25 a massage, correct? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 SO of 318 EFTA00231062

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 51 of 100 nsor & Associates Repnninp and T:anictipcion, lnc. 1 A. Yes. . Page 25 Q. Before you got to Epstein's house 3 never said anything to you on the telephone about sexual 4 activity with Epstein, did she? 5 A. No. 6 Q. And before you got to Epstein's house 7 lillillinever sent you a message over the Internet about 8 sexual activity with Epstein, did she? 9 A. No. - 10 Q. Did ever try to convince you to 11 engage in any sexual activity with Epstein? 12 A. No. 13 Q. Did every try to convince 14 you to engage in any sexual activity with Epstein? 15 A. I don't know who is. 16 Q. Do you have a friend IIIII? 17 A. No. 18 Q. Okay. Before you went so Epstein's house 19 did anyone call or e-mail you to induce you to engage in 20 sexual activity with Epstein? 21 A. No. 22 Q. So you're sure that before you got to 23 Epstein's house no one tried to persuade you to engage in 24 sexual activity with Jeffrey Epstein? 25 A. No. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 el EFTA00231063

Case 9:08-cv-80804-KAM ent 1 EnteredonFLS,DDocket07/21/2008 Page 52 of 100 nsor & Associates Rept-mins and Iran:dm:dice, lmc Page 26 1 O. You're sure that -- let me ask the question 2 again. 3 You're sure that before you got to 4 Epstein's house no one tried to persuade you to engage in 5 sexual activity with Epstein for money. Are you? 6 MR. LEOPOLD: Objection. Asked and 7 answered. 8 THE WITNESS: No. And I've already 9 answered that a bazillion times. 10 BY MR. TEIN: 11 Q. He's coaching you now. So I'm going to ask 12 the question -- 13 MR. LEOPOLD: Counsel, I've made an 14 objection for the record. 15 MR. TEIN: Stop speaking. 16 MR. LEOPOLD: I'm not going to stop 17 speaking. You can't interrupt me when I'm making 18 the record. 19 MR. TEIN: You're coaching the witness. 20 MR. LEOPOLD: Counsel -- 21 MR. TEIN: Stop coaching the witness. 22 BY MR. TEIN: 23 0. UM let me ask you -- 24 MR. LEOPOLD: If you continue to -- 25 MR. TEIN: Stop interrupting my questions. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 112of 314 EFTA00231064

Case 9:08-cv-80804-KAM gg ~r ent 1 Entered on FLSD Docket 07/21/2008 Page53of100 nsor & Associates RepartenE and Trannyipuon. Inc 1 2 3 BY MR. TEIN: Page 27 MR. LEOPOLD: If you do it one more time, we're leaving. 4 O. MP 5 MR. LEOPOLD: I'm going to make the record. 6 You cannot interrupt me when I'm making the 7 record. Out of professional conduct, you cannot 8 do that. I'm entitled to make the record. I made 9 an objection, asked and answered. Your demeanor 10 is inappropriate. You're willing and you are able 11 and you're responsible to ask a question in a 12 professional manner, and ask the question and once 13 you get the answer, to either follow up on it or 14 move on, but not continuously browbeat and ask the 15 same question over and over because you don't like 16 the answer. 17 MR. TEIN: Calm down, sir. 18 MR. LEOPOLD: Trust me, I'm very calm here. 19 When I'm not calm, you'll know it. I'm very calm. 20 So please continue on. But I will not 21 allow you to continue to harass her in the 22 demeanor that you're doing. Ask her a question 23 and move on. 24 MR. TEIN: Are you done? 25 MR. LEOPOLD: Thank you. I am. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 53 o1316 EFTA00231065

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 54 of 100 nsor & Associates Repcontnp. and Tratictirmo, Inc. 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 Page 28 MR. TEIN: Stop misrepresenting the record and calm down. I'm going to ask my question. Stop it. BY MR. TEIN: Q clear. MR. LEOPOLD: I think the record is very MR. GOLDBERGER: Let me just clarify something. When you object to the form of a question, you're not instructing the witness not to answer the question, are you? MR. LEOPOLD: No. And I'm not making that objection; only on attorney/client privilege. MR. TEIN: Will you stop speaking now so I can ask my question? Are you done? Okay. I'm going to ask my question. BY MR. TEIN: Q. Listen, IIIIII-- MR. LEOPOLD: Hold on. Stop. I've been doing this for 20 plus years and have met a lot of attorneys, but I've never had an experience like this where I've -- MR. TEIN: Stop your speeches. MR. LEOPOLD: If you continue to do this, whether it's with me or with my client, I will not Ph. Fax. 1655 Palm Beach Lakes Blvd.; Suite 500 - West Palm Beach, FL 33401 5401316 EFTA00231066

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 55 of 100 nsor & Associates Raped:lop and Tranicrildion, Page 29 1 2 3 Mr. Goldberger knows all this, because I know that 4 he wouldn't do this. So I will not put up with 5 it. And I think it's highly inappropriate to do 6 this with this child sitting here, the way you're 7 acting, primarily towards me, and I will not put 8 up with it. 9 MR. TEIN: Will you please stop your speech 10 so I can ask questions? 11 MR. LEOPOLD: So long as you act 12 professionally, I will do so. But if you continue 13 to do it this way, I will leave. 14 15 BY MR. TEIN: 16 Q. are you sure that before you got to 17 Epstein's house no one tried to persuade you to engage in 18 sexual activity with Epstein for money? 19 MR. LEOPOLD: Asked and answered. 20 Objection. L1 MR. TEIN: Did you get her answer? 22 THE COURT REPORTER: No, I did not. put up with it and I don't need to put up with it and it's not appropriate. And I'm sure MR. TEIN: Suit yourself. 23 THE WITNESS: I'm sure. 24 BY MR. TEIN: 25 Q. Let me ask you a few questions about your Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 6501316 EFTA00231067

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 56 of 100 sor & Associates Reporunp mid Transcripucct Inc Page 30 1 contact with Jeffrey Epstein. Okay? 2 A. (Witness nods head up and down.) 3 Q. Jeff never e-mailed you, did he? 4 A. No. 5 Q. Jeff never text messaged you, did he? 6 A. No. 7 Q. Jeff never chatted in a chat room with you, 8 did he? 9 A. No. 10 Q. Before you got to Epstein's house you had 11 never spoken to Jeff, had you? 12 A. No. 13 Q. And before you got to Epstein's house you 14 had never met Jeff? 15 A. Correct. 16 Q. Before you got to Epstein's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein's house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein's house 23 that one time three years ago, correct? 24 A. Yes. 25 Q. You never went there again, correct? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 540311 EFTA00231068

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 57 of 100 nsor & Associates Reporting and Transcrtpt.nn, loc. Page 31 1 A. No. 2 Q. All right. Let me ask you two final areas 3 of questioning about this and we'll move onto something 4 else. Okay? 5 A. Uh-huh. Yes. I'm sorry. 6 Q. Before you got to Epstein's did anyone 7 associated with Epstein ever call you on the phone and 8 try to persuade, induce, entice or coerce you to engage 9 in any sexual activity? 10 A. No. 11 Q. Before you got to Epstein's did anybody 12 associated with Epstein ever contact you on the Internet 13 and try to persuade, induce, entice or coerce you to 14 engage in any sexual activity? 15 A. No. 16 O. IIIII who told you that when you got to 17 Jeff Epstein's house you should lie to Jeff about your 18 age? 19 A. 20 Q. Was it or was it the other girl in 21 the car who you rode over with to Epstein's house? 22 A. 23 Q. Who was the other girl in the car with you 24 that day? 25 A. I honestly don't know. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 570316 EFTA00231069

Case 9:08-cv-80804-KAM ment 1 Entered on FLSD Docket 07/21/2008 Page 58 of 100 nsor & Associates Rona/in, and Traniciiption. Inc Page 32 1 Q. Had you ever seen her before? 2 A. No, sir. 3 Q. You told the police that when you rode over 4 to Epstein's you had no idea who she was, right? 5 A. Correct. 6 O. You told the police that you didn't know 7 her name, but she was like really dark, kind of like a 8 Spanish girl? 9 A. Yes. 10 Q. Those were your words, right? 11 A. Yes. 12 Q. Do you now know who she is? 13 A. No, sir. 14 Q. So it was who told you to lie about 15 your age to Jeff Epstein? 16 A. Yes, sir. 17 Q. And "Ill' told you that if you weren't 18, 18 Epstein wouldn't let you into his house, right? 19 A. That's -- yes, yes. 20 Q. All right. Let's talk for a minute about 21 when you first met Jeff. Okay? 22 A. Sure. 23 Q. When you first met Jeff he tried to find 24 out how old you were, right? 25 A. Excuse me? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 58.4316 EFTA00231070

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 59 of 100 nsor & Associates Ropnrtinp aiul Trartscripnon. lnc. 1 2 out how old you were, right? Page 33 Q. When you first met Jeff he tried to find 3 A. Not when we first introduced each other; 4 when we get upstairs, then, yes. 5 Q. During the massage Jeff asked you how old 6 you were, correct? 7 A. Yes, yes. 8 Q. Now hadn't you already told Jeff's 9 ass:.stant, the one who walked you upstairs, that you went 10 to college and had just moved down here from Ohio? 11 A. I never spoke to the lady. 12 Q. Do you want to rethink that answer? 13 MR. LEOPOLD: Is that a question? 14 BY MR. TEIN: 15 Q. Do you want to rethink that answer? 16 A. No. I didn't really speak with her that 17 much. 18 Q. Do you want to try to refresh your memory 19 on that? 20 MR. LEOPOLD: Do you have something to 23. refresh her memory with? 22 MR. TEIN: Do you want to stop making 23 speaking objections? 24 MR. LEOPOLD: No. But to refresh someone's 25 memory, you show them a document. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 59013111 EFTA00231071

Case 9:08-cv-80804-KAM Do ent 1 Entered on FLSD Docket 07/21/2008 Page 60 of 100 4 nsor & Associates Rowans and lraitscripacm. Inc Page 34 1 MR. TEIN: I know how to do this. 2 MR. LEOPOLD: Then show her a document. 3 MR. TEIN: Stop speaking. 4 MR. LEOPOLD: I'm not going to stop 5 speaking. I'm going to continue to make the 6 record. 7 MR. TEIN: You're obstructing. Please 8 stop. 9 MR. LEOPOLD: I'm not obstructing. But if 10 you want to refresh her recollection, you need to 11 show her something. 12 That's not a proper question. I object to 13 the foundation and the predicate of that question. 14 MR. TEIN: Are you done? 15 MR. LEOPOLD: I am now. Thank you. 16 BY MR. TEIN: 17 Q. Do you want to try to refresh your memory 18 as to whether you had any conversation with the woman who 19 walked you upstairs in Epstein's house in which you told 20 her that you went to college and had just moved down from 21 Ohio? 22 MR. LEOPOLD: Objection. Object to the 23 form of the question. Lack of foundation and 24 predicate. 25 BY MR. TEIN: Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4001316 EFTA00231072

Case 9:08-cv-80804-KAM ent 1 teredonFLS,DDocket07/21/2008 Page 61 of 100 nsor Associates Roportiap anti Transcript'''. Inc 1 2 3 4 5 6 7 Page 35 Q. You can answer the question. A. Sure. Q. Is there anything that would refresh your memory that in fact you told Mr. Epstein's assistant, the one who walked you upstairs, that you went to college and you had just moved down here from Ohio? A. I don't remember saying that, but if you -- 8 I don't remember saying that myself, so -- 9 Q. That would be a lie, right? 10 A. No. I really don't remember. 11 Q. So you told Jeff that you were 18 years 12 old, correct? 13 A. Yes. 14 Q. Do you remember Detective of 15 the Police Department, Palm Beach Police Department? 16 A. Yes. 17 Q. Do you remember you spoke to her? 18 A. Yes. 19 Q. Do you remember that you told Detective 20 that when you lied about your age to Jeff you said 21 it really fast because you didn't want to make it sound 22 like you were lying? 23 ---Ar-I-denit remember-the-words exactly, but-I-- 24 do remember telling her I told him I was 18. 25 Q. And do you remember telling Detective Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 61 a 316 EFTA00231073

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 62 of 100 nsor & Associates Repot:ins and Transcription, Inc Page 36 1 that when you lied to Epstein about your age that you 2 said it really fast so Epstein wouldn't realize you were 3 4 A. No, I don't remember saying those words 5 exactly to her. 1 remember telling her that I told 6 Epstein I was 18. 7 0. Does it sound right to you that you told 8 Detective that you said your age really fast to 9 Epstein -- 10 MS. BELOHLAVEK: Objection. Asked and 11 answered. 12 BY .MR. TEIN: 13 Q. -- so he wouldn't think that you were 14 lying? MR. LEOPOLD: Objection. Asked and 16 answered, lack of foundation, mischaracterization 17 of her earlier testimony. She's already answered 18 that question. 19 BY MR. TEIN: 20 Q. You can answer it. 21 MR. LEOPOLD: Same objection. It's been 22 asked and answered. 23 You can answer. I'ye made the objection. 24 THE WITNESS: I forget the question, now. 25 Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 62 o1316 EFTA00231074

Case 9:08-cv-80804-KAM 4Agrnent 1 Entered on FLSD Docket 07/21/2008 Page 63 of 100 sor & Associates Rep:smut lranscririon, Inc Page 37 1 BY MR. TEIN: 2 Q. Let me put it again. 3 Does it sound right to you that you told 4 Detective that when you lied about your age to 5 Jeffrey Epstein, you said it really fast because you 6 didn't want to make it sound like you were lying? 7 MR. LEOPOLD: Objection. Lack of 8 foundation, asked and answered. 9 THE WITNESS: I could have possibly said 10 that, yes. 11 BY MR. TEIN: 12 Q. You didn't want Mr. Epstein to know that 13 you were lying about your age, right? 14 A. Correct. 15 Q. You didn't want Mr. Epstein to know that 16 you were not 18 yet, right? 17 A. Correct. 18 Q. You wanted Mr. Epstein to believe that you 19 really were 18, right? 20 A. Correct. 21 Q. Do you remember when Mr. Epstein asked 22 where you went to school? 23 A. Yes. 24 Q. And you told Mr. Epstein you went to 25 Wellington, right? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 I33 0I111 EFTA00231075

Case 9:08-cv-80804-KAM 4 D ent 1 Entered on FLSD Docket 07/21/2008 Page 64 of 100 ior nsor & Associates kg:Toning add Tansciirinn, Inc Page 38 1 A. Yes. 2 Q. Was that the truth? 3 A. No. 4 Q. In fact, you went to Royal Palm, right? 5 A. Yes. 6 Q. So you lied to Mr. Epstein again, correct? 7 A. Yes. 8 Q. Is Wellington the college that you told 9 Jeff's assistant that you were attending? 10 A. I don't remember having that conversation 11 with her, so I wouldn't know if that's what I said. 12 Q. That was a lie, though, wasn't it? 13 MR. LEOPOLD: Objection to the form of the 14 question, lack of foundation. You're making an 15 assumption. She just answered you she can't tell 16 you that. 17 MR. TEIN: Speaking objection. And you 18 well know that, Mr. Leopold. 19 MR. LEOPOLD: She can't answer that 20 question. The way you phrased that question, 21 you're purposely making her not be honest in her 22 testimony. She can't answer a question like that. 23 She doesn't remember. So then you say, "So you 24 were lying." That's improper and you know that. 25 That's not a proper question. And any attorney Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 14.1311 EFTA00231076

Case 9:08-cv-80804-KAM D c went 1 Entered on FLSD Docket 07/21/2008 Page 65 of 100 sor & Associates Reporting and Triune:in:ion. Inc Page 39 1 that would do that to a witnesses or to a person 2 that's sitting in this chair is not acting 3 professionally. You can't ask a question like 4 that. You can do it, but it's not proper. And 5 I'm sure you weren't trained that way, certainly 6 not ethically. 7 MR. TEIN: Will you stop? 8 MR. LEOPOLD: I'm not going to stop, 9 because the way you're asking that question is 10 improper and you know it. 11 MR. TEIN: You're losing your cool. 12 BY MR. TEIN: 13 Q. ms. NM -- 14 MR. LEOPOLD: Trust me. I'm very calm. 15 When I lose my cool, you'll know it. 16 MR. TEIN: I do know it. 17 BY MR. TEIN: 18 Q. Ms. IIIIIIIII Mr. Epstein never asked you 19 to do anything other than massage him, correct? 20 A. incorrect; because he asked me to take off 21 my bra, so that would be two things he's asked me to do. 22 Q. Other than asking you to take your bra off, 23 Mr. Epstein never asked you to do anything with him other 24 than massage, correct? 25 MR. LEOPOLD: Objection. Foundation, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 66 or 616 EFTA00231077

Case 9:08-cv-80804-KAM ent 1 gpteredonFL$DDocket07/21/2008 Page 66 of 100 nsor & Associates Repotting ad Tunic/intim, Inc. Page 40 1 predicate. 2 THE WITNESS: Correct. 3 BY MR. TEIN: 4 Q. You told the police, in your words, that 5 you did not whack him off, right? 6 A. Correct. 7 Q. What does that mean? 8 A. Whack, like whacking off? 9 O. Your term, what does that mean? 10 A. Masturbating. 11. Q. Mr. Epstein never tried at any time to grab 12 your hand, did he? 13 A. No. 14 Q. Mr. Epstein never tried to put your hand 15 anywhere, did he? 16 A. No. 17 Q. At no time did you touch Mr. Epstein's 18 penis, did you? 19 A. No. 20 Q. And he did not touch you, correct? 21 A. Incorrect. 22 Q. Well, you told the police, "At no time did 23 he touch me." Were you lying to the police then? 24 A. No. Well, I wasn't being fully truthful, 25 but I wasn't lying. Ph. Fax. 1655 Pam Beach Lakes Blvd., Suite 500 - West Palm Beath FL 33401 Illet316 EFTA00231078

Case 9:08-cv-80804-KAM Qgyfnent 1 Entered on FLSD Docket 07/21/2008 Page 67 of 100 nsor & Associates Repomig and Tranicription, Inc. 1 Page 41 Q. You told the police twice when you spoke to 2 that "at no time did he touch me." Didn't 3 you say that to the police? 4 A. Yeah. 5 Q. And you're saying that that was not fully 6 truthful. Is that what you're saying now? 7 8 A. Correct. Q. And you're saying if you're not fully 9 truthful, that's not a lie. Correct? 10 A. You took that out of context like really 11 bac. I didn't mean like that. Touching my legs and 12 he never kept his hands to himself the entire time. 13 That's what I'm trying to say. 14 Q. You told the police, "At no times did he 15 touch me." You agree with that, correct? 16 A. No, I don't agree with that, because he did 17 touch me. 18 Q. Did you tell the police that he did not 19 touch you, yes or no? 20 A. It's a possibility, but I do not remember. 21 Q. Okay. And you did not have any type of sex 22 with Jeff, correct? 23 A. No. 24 Q. And you did not have any type of oral sex 25 with Jeff, correct? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 67 ol 311 EFTA00231079

Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 68 of 100 sor & Associates Ronan Ins and Trariscripunn.loc Page 42 A. No. 2 Q. No type of intercourse with Jeff, correct? 3 A. Correct. 4 Q. All right. Let's talk about what happened 5 after the massage was over. 6 A. Okay. 7 Q. After the massage, you told Epstein that 8 you wanted to bring your twin sister back so she could 9 make some money, correct? 10 A. Incorrect. 11 Q. Your twin sister is IIIIII right? 12 A. Correct. 13 Q. And you love -very much, don't you? 14 A. Yes. 15 Q. And when you left the house you were joking 16 with the other girls, weren't you? 17 A. Incorrect. 18 Q. Well, when Mend the other girl in the 19 car that day made their statements to the police they 20 told the police that you were joking afterwards. Are you 21 saying that they were lying to the police about that? 22 A. No. But a question or -- questions from 23 like she asked me questions, but it wasn't 24 joking. She was kind of like in a happy way, like, "Oh, 25 what did you do? What did you do?" Like those kind of Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 OS of 311 EFTA00231080

Case 9:08-cv-80804-KAM Docummnt 1 Entered on FLSD Docket 07/21/2008 Page 69 of 100 nsor & Associates Roporting And Tranactiptim, ≥nr. Page 43 1 2 3 4 5 6 7 8 things, but it wasn't joking about it at all. Q. You joked about it, didn't you? A. No. Q. You said to IIIIIII that if you did this every weekend you'd be rich, didn't you? A. No. That's what told me. Q. You didn't tell that to MR. LEOPOLD: Objection. Asked and 9 answered. 10 11 BY MR. TEIN: 12 Q. After you left Epstein's house you took the 13 money and you went shopping with and the other 14 girl in the car, correct? 15 16 money. 17 Q. 16 19 Q. 20 didn't you? 21 MR. LEOPOLD: Objection. 22 THE WITNESS: No. A. Incorrect. I didn't spend any of the You went to Marshall's, didn't you? A. I went along, yes, but I didn't -- You went shopping with them at Marshall's, THE WITNESS: I guess you could say that. 23 MR. LEOPOLD: Objection. Lack of predicate 24 and foundation. Mischaracterization of earlier 25 testimony. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 66 of 516 EFTA00231081

Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 70 of 100 nsor & Associates Reporting, And Tranacriptton, Inc. Page 44 1 BY MR. TEIN: 2 Q. And IIIIIIrbought a purse, right? 3 A. Yes. 4 Q. And you were with her the whole time at 5 Marshall's, correct? 6 A. Yes. 7 Q. Now tell me about when the federal 8 prosecutors told you about getting reimbursed. 9 A. I have no idea what you're talking about. 10 Q. Tell me about when the federal prosecutors 11 spcke to you about getting money you feel you're entitled 12 to from Mr. Epstein. 13 A. I don't know what you're talking about. 14 Q. Do you know who is? 15 A. No, sir. 16 Q. Did you ever meet with any federal 17 prosecutors? 18 A. I think -- yeah. I think they were I 19 think they were like FBI. 20 Q. Uh-huh. Did you meet with federal 21 prosecutors? 22 A. They came to my house one time, yes. ?3 Q. When did they come to your house? 24 A. Very long ago. 25 Q. Was it this year, 2008? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 70 of 315 EFTA00231082

Case 9:08-cv-80804-KAM ent 1 iltered on FLSD Docket 07/21/2008 Page 71 of 100 sor & Associates Repaning one Transcriptive, Inc. Page 45 1 A. It was not this year, no. 2 Q. Was it 2007? 3 A. I'd have to say at least two years ago or a 4 year ago, yeah. So it would be 2007, 2006; but it was a 5 while ago. 6 Q. How many federal prosecutors or FBI agents 7 came to your house? 8 A. I'm trying to remember. I want to say four 9 people came. 10 Q. Did they give you their business cards? 11 A. If they did, I don't remember, and they 12 weren't toward me. Maybe my parents have them. I don't 13 know. 14 Q. Did they give you their cell phone numbers? 15 A. No. 16 Q. Did you ever speak to them on their cell 17 phones? 18 A. No, sir. 19 0. Did they speak to your parents? 20 A. That's something you'd have to ask my 21 parents. 22 O. Do you know whether they spoke to your parent' 24 A. No, sir. 25 Q. You have no idea? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11 01 31! EFTA00231083

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 72 of 100 sor & Associates Ktriormis an4 Transcriponn, inc. Page 46 1 A. No, sir. 2 MR. LEOPOLD: Objection. Asked and 3 answered. 4 BY MR. TEIN: 5 Q. So if I say the name to you 6 , you don't know who that is? 7 A. No, sir. 8 Q. How many women and how many men came to 9 your house? 10 A. : want to say two ladies and two guys. 11 Q. Did someone named come to 12 your house? 13 A. I don't know names, sir. 14 Q. Do you know who is? 15 A. No, sir. 16 Q. Do you know who Jeffrey Herman is? 17 A. Yes. 18 Q. That's the lawyer who first sued Epstein on 19 your behalf, right? 20 A. Yes. 21 Q. Has Mr. Herman advanced your family any 22 money? 23 MR. LEOPOLD: Any conversations that you've 24 had with Mr. Herman regarding that issue, you are 25 not to disclose. If you've learned in some other Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 72 of 316 EFTA00231084

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 73 of 100 sor & Associates Repartrns and Tann )nc. a 2 3 fashion, you may answer. THE WITNESS: Okay. I wouldn't know. Page 47 4 BY MR. TEIN: 5 Q. You don't know? 6 A. No. 7 MR. LEOPOLD: Objection. Foundation. 8 Attorney/client privilege. 9 BY MR. TEIN: 10 Q. And you say you don't know who 11 is? 12 A. No, sir. 13 Q. Does it refresh your recollection that he's 14 the number two prosecutor at the U.S. Attorney's Office? 15 A. No. 16 Q. That he's boss? 17 A. No. 18 Q. Does it refresh your memory that he's the 19 ex-partner of Jeff Herman, the first lawyer who sued 20 you -- sued Mr. Epstein on your behalf for fifty million • 21 dollars? 22 A. No, sir. I don't know who he is. 23 Q. Without telling me any conversations that 24 you've had with your lawyers, how is it that you selected 25 Mr. Herman as your lawyer from the 81,000 members of the Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 73 M310 EFTA00231085