39 1 evaluations. 2 Number one, does the document, in 3 fact, have a relationship to the criminal 4 case in the state matter. And, number two, 5 evaluate the right of public access versus 6 the victim's right to confidentiality. If 7 this Court does decide to unseal those 8 records, then the State would ask that this 9 Court before making the document public 10 access, then make certain that in place is 11 that the victim's identities are amended to 12 initials if their names are used. 13 The State does have a concern 14 regarding the argument of the Federal Rule 15 Six in that is this Court bound by a 16 federal rule which perhaps has been made 17 unenforcible by virtue of making it a part 18 of the state file, so I think the Court 19 also would need to address that issue 20 before making its ruling. 21 THE COURT: All right, great. Thank 22 you so much. 23 MS. BURNS: Thank you, Judge. 24 THE COURT: One last chance for the 25 federal government, they're not here and SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231386
40 1 I'll let rebuttal of any other 2 presentation, Mr. Goldberger, or, 3 Mr. Critton, you'd like to make. 4 MR. GOLDBERGER: Thank you, your 5 Honor. As to the last argument made by 6 Ms. Burns as to the applicability of 7 Federal Rule 6 of the Rules of Federal 8 Criminal Procedure it's something that we 9 learned in the law school that the 10 supremacy clause controls and to the extent 11 there's a conflict between the federal 12 doctrine and the state doctrine, the 13 supremacy clause requires the federal rule 14 of law to apply and to control. And 15 certainly in this case you cannot use a 16 state procedure to circumvent a federal 17 rule of criminal procedure that confers 18 secrecy to a grand jury proceeding. 19 And the Palm Beach Post response to 20 the argument never made note of the grand 21 jury rule, they simply avoided that issue 22 and that in our mind is equally important 23 as the fact in the interest of comity this 24 Court should defer to the rulings of 25 Judge Marra already. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231387
41 1 As to Mr. Kuvin's argument that he 2 has a client that is in state court and is 3 not in federal court and therefore he 4 doesn't have a remedy in federal court. 5 With all due respect to Mr. Kuvin, that's 6 similarly wrong. Judge Marra's order 7 spebifically dealt with a class of 8 individuals who were identified as victims 9 of Mr. Epstein's conduct, and Judge Marra's 10 order says that anyone who's been 11 identified by the United States attorney's 12 office as a victim has right to the 13 nonprosecution agreement under the same 14 rules. 15 Just so the Court understands, I know 16 we are talking like the Court understands 17 everything about this case. There was a 18 list of victims that was created at the 19 time that the nonprosecution agreement was 20 entered into and Mr. Kuvin's client is on 21 that list. That list was created by the 22 U.S. attorney's office. He has the same 23 rights to the nonprosecution agreement as 24 if he filed this case in federal court and 25 he knows that we've told him that he has SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231388
42 1 that access. 2 As to the fact that the 3 nonprosecution agreement is presumably not 4 filed in the federal case in our last 5 hearing in front of Judge Marra on June 5th 6 -- I'm sorry, June 12th, Mr. Edwards 7 advised Judge Marra that he had, in fact, 8 filed a nonprosecution agreement to no 9 one's surprise under seal in the federal 10 file, so the nonprosecution agreement 11 according to Mr. Edwards' declaration at 12 that hearing is contained in the federal 13 court system. 14 For all of those reasons, your Honor, 15 and the reasons that I previously indicated 16 to the Court, we would ask the Court to 17 defer to the federal court in this matter. 18 THE COURT: Okay. Thank you very 19 much. Here is what I'm planning on doing, 20 so you know where I'm going on this. I'll 21 make an oral announcement and I'll follow 22 it up with a written order so that you all 23 can have something to take to wherever you 24 want to take it. 25 I find that the appropriate procedure SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231389
43 1 to seal or close these documents has not 2 been met, so I'll deny the motion to seal 3 the documents. I'll grant the motion to 4 unseal them. I will take a look at the 5 documents. I will redact out of them 6 the -- what I'll do is, I'll leave the 7 originals intact sealed in the court file 8 to protect the names of any underage 9 victims. 10 I will make copies of those. I'll 11 redact out the names leaving -- expose the 12 initials of any of the individuals. I'll 13 get that done -- I'll get my written order 14 out granting and denying the respective 15 motions hopefully by the end of today. If 16 not today, tomorrow. I plan on releasing 17 the redacted versions probably Monday, so 18 that those will be available for public 19 consumption on Monday. 20 MR. GOLDBERGER: Your Honor, thank 21 you. Thank you for the oral pronouncement. 22 Your Honor, based on the Court's ruling, we 23 do have a motion to stay disclosure of the 24 nonprosecution agreement. The rules of 25 appellate procedure require us to file that SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231390
44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 before, your Honor. Your Honor, we do intend to take certiorari on this to the Fourth District Court. THE COURT: That's why I figure between the written rule and the disclosure give you a chance to catch your breath and do that. I guess you might want that. Is Monday 5 p.m. enough time for you to get over to the DCA? MR. GOLDBERGER: Actually, your Honor, the Rule of Appellate Procedure maintains matter to THE jurisdiction with you on this entertain the motion to stay. COURT: So I need to handle the motion to stay? MR. GOLDBERGER: Correct, your Honor. THE COURT: Do you want to argue that now? Do you want to take a look at that, catch your breath, come back and see me Monday sometime; what's your pleasure? MR. GOLDBERGER: We're ready to do it now, your Honor. We're ready to do it now. THE COURT: All right. Interveners, your thoughts. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231391
45 1 MR. KUVIN: Matter of procedure 2 point, I just want to make sure that the 3 motion to intervene is, in fact, granted. 4 THE COURT: You're motion to 5 intervene is granted. Do you have a 6 written order for me to sign off on there? 7 MR. KUVIN: I can submit that. 8 THE COURT: Why don't you catch your 9 breath and come back tomorrow and I'll hear 10 argument. It will give me a chance to read 11 the motion, check out the rules, take a 12 look, got to get myself gassed up. Anybody 13 want to drop anything off for me to read 14 before the hearing, please do that. Why 15 don't we do that tomorrow morning, and why 16 don't we reconvene here tomorrow at 1:30 on 17 the motion to stay. 18 MR. GOLDBERGER: That's fine. 19 THE COURT: How does your schedule 20 look? 21 MR. GERBER: Your Honor, is it 22 possible to have it a little later, perhaps 23 an hour later tomorrow? 24 THE COURT: 2:30. 25 MR. GERBER: If possible. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231392
46 1 THE COURT: How about a little later 2 than that still, let me take a look at our 3 official calendaring system here. 4 MR. CRITTON: Judge Colbath, I'm gone 5 tomorrow, I'm going to Gainesville at one 6 or 12:30-ish. I told my wife I would be 7 home at one. My daughter's birthday, 21, 8 she's having a party, I plan to be there. 9 Can we do it tomorrow morning any time, it 10 would be great. 11 THE COURT: Tomorrow morning is ugly. 12 This isn't going to take long. 13 MS. BURNS: This is a five-minute 14 motion. 15 THE COURT: Why don't we do this, 16 meet at 8:15? 17 MS. SHULLMAN: Your Honor, I'm not 18 going to be able to get my kids to school 19 if I have to be here at 8:15. My husband 20 is in California right now. 21 MR. GOLDBERGER: I don't mean to jump 22 in. I wonder if we can do some of this -23 telephonically. 24 MS. SHULLMAN: Yes, I can appear by 25 phone or I can have one of my partners. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231393
47 1 THE COURT: In the morning what would 2 be a good start time for you? 3 MS. SHULLMAN: Nine would be getter. 4 I can't drop them off before eight. 5 THE COURT: It's going to be brief 6 argument, let's do it 9:00 tomorrow 7 morning; 9:00 work for you? 8 MR. CRITTON: Yes, sir. Thank you. 9 MR. GOLDBERGER: Just very briefly, 10 the Court is going to look at the 11 nonprosecution agreement and do some 12 redacting, I believe. I just need to 13 advise the court in addition to Mr. Epstein 14 and perhaps victims mention the 15 nonprosecution agreement, there are third 16 parties who the Court needs to look about 17 redacting their names also, and that's 18 contained in the nonprosecution agreement. 19 In other words, there are other 20 people beside Mr. Epstein and Mr. Victims 21 whose names are mentioned in the 22 nonprosecution agreement, and I would ask 23 the Court to look at those names also for 24 the purpose of redacting. 25 THE COURT: I'll like a look. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231394
48 1 MR. EDWARDS: Your Honor, those are 2 not names of victims, those are 3 co-conspirators as listed in the agreement 4 and we would object to any redaction of those names. I don't think there's any 6 standing to ask for that. 7 THE COURT: I'll take a look. All 8 right. See you all tomorrow morning at 9 nine. If you want to send anything to me 10 later this afternoon or tomorrow morning 11 before we take the bench, I'm happy to 12 receive it. Have a good afternoon. 13 (Proceedings concluded.) 14 15 16 17 18 19 20 21 22 - 24 25 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231395
49 1 2 CERTIFICATE 3 4 THE STATE OF FLORIDA, 5 COUNTY OF PALM BEACH. 6 I, SUSAN S. WIGGINS, R.P.R. Official 7 Court Reporter for the Fifteenth Judicial Circuit, 8 Criminal Division, in and for Palm Beach County, 9 Florida; do hereby certify that I was authorized 10 to and did report the foregoing proceedings before 11 the Court at the time and place aforesaid; and 12 that the preceding pages numbered from 1 to 48, 13 inclusive, represent a true and accurate 14 transcription of my steno notes taken at said 15 proceedings. 16 IN WITNESS WHEREOF, I have hereunto 17 affixed my official signature this 29th day of 18 June, 2009. 19 20 21 (7).#/4" (13 tt) CAA 22 SUSAN S. WIGGINS, .P.R. 23 24 25 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231396
LEGAL RECYCLED PAPER .................. •111 I° REORDER ( 9.544;46,3,n. EFTA00231397
1 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 2 IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION 3 STATE OF FLORIDA ) 4 ) vs. ► CASE No. 2008CF009381AXX 5 ) JEFFREY EPSTEIN, ► 6 ) Defendant. ) CERTIFIED COPY 7 8 PROCEEDINGS BEFORE THE COURT 9 PRESIDING: HONORABLE JEFFREY COLBATH 10 APPEARANCES: 11 ON BEHALF OF THE STATE: 12 BARRY E. KRISCHER, ESQUIRE State Attorney 13 401 North Dixie Highway West Palm Beach, Florida 33401 14 By: BARBARA BURNS, ESQUIRE Assistant State Attorney 15 ON BEHALF OF THE DEFENDANT: 16 JACK GOLDBERGER, ESQUIRE 250 S Australian Ave Ste 1400 17 West Palm Beach, Florida 33401 And 18 ROBERT CRITTON, ESQUIRE 515 N Flagler Dr Ste 400 19 West Palm Beach, Florida 33401 20 ON BEHALF OF THE PALM BEACH POST: DEANNA SHULLMAN, ESQUIRE 21 Thomas, LoCicero & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231398
2 1 ON BEHALF OF EB, MOTION INTERVENER'S PLEADING: 2 SPENCER KUVIN, ESQUIRE 2925 PGA Blvd Ste 200 3 Palm Beach Gardens, Florida 33410 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 June 26, 2009 24 Palm Beach County Courthouse West Palm Beach, Florida 33401 25 Beginning at 9:59 o'clock, a.m. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231399
3 1 BE IT REMEMBERED that the following 2 proceedings were had in the above-entitled cause 3 before the HONORABLE JEFFREY COLBATH, one of the 4 judges of the aforesaid court, at the Palm Beach 5 County Courthouse, located in the City of West 6 Palm Beach, State of Florida, on June 26, 2009, 7 beginning at 9:59 o'clock, a.m., with appearances 8 as hereinbefore noted, to wit: 9 THEREUPON: 10 THE COURT: Epstein. 11 MR. GOLDBERGER: Yes, your Honor. 12 THE COURT: Let me call up the State 13 of Florida versus Epstein. Let's have 14 everyone announce their appearance, please, 15 name on the record. 16 MR. CRITTON: Robert Critton and Jack 17 Goldberger on behalf of Mr. Epstein as well 18 as Barbara Compiani from the office of Jane 19 Walsh. 20 MS. SHULLMAN: Deanna Shullman of 21 Thomas, LoCicero and Bralow on behalf of 22 the Palm Beach Post. 23 MR. KUVIN: Spencer Kuvin on behalf 24 of the intervener ■. 25 MS. BURNS: Barbara Burns on behalf SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231400
4 1 of the State of Florida. 2 THE COURT: That's it. 3 MR. CRITTON: That's it, it's a wrap. 4 THE COURT: Okay. Orders. Who's not 5 here that I have to mail it to? 6 MR. GOLDBERGER: Mr. Edwards is not 7 here, your Honor. 8 THE COURT: Okay. Mr. Berger, 9 Mr. Edwards. Did I give you enough copies 10 of the order? 11 MR. GOLDBERGER: I ran out. I have 12 just enough. Do you want me to get a copy 13 to Mr. Edwards? 14 THE COURT: Yes, if you'd mail a copy 15 to Mr. Edwards. I got spares if anybody's 16 interested. Anybody need a spare? 17 MR. GOLDBERGER: We're good, your 18 Honor. 19 THE COURT: All right. Motion to 20 Stay, Mr. Goldberger. 21 MR. GOLDBERGER: Thank you, your 22 Honor. 23 THE COURT: Mr. Critton. 24 MR. CRITTON: Good morning, Judge 25 Colbath, do you have a copy of our Motion SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231401
5 1 to Stay? 2 THE COURT: I do, the one that was 3 handed up to me yesterday? 4 MR. CRITTON: Yes, sir, and I have a 5 proposed order in the event the Court 6 chooses to grant; may I provide that to the 7 Court as well? 8 Your Honor, as you know, 9 Mr. Goldberger and I represent Mr. Epstein. 10 We have hired Ms. Walsh and Ms. Compiani as 11 appellate counsel to assist in the filing 12 of a writ of certiorari. I know that comes 13 as no surprise to the Court in that whoever 14 prevailed and lost yesterday, I think the 15 Court recognized we probably filed a writ 16 of certiorari. 17 THE COURT: Let me ask real quick. 18 Anybody objecting to the defendant having 19 the ability to have my decision reviewed by 20 the appellate court before I release these 21 things? I mean, it seems pretty straight 22 forward. 23 MS. SHULLMAN: We have an objection, 24 your Honor, to some extent. The -- you 25 know, the procedure in place here is very SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231402
6 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 similar to that for which they would have to obtain a preliminary injunction. THE COURT: Right. MS. SHULLMAN: So to demonstrate likelihood of success and irreparable harm, I don't think they can do that. I think the plan that you put in -- proposed yesterday is a good one, that is you redact and you release on Monday and that gives them today and Monday to get to the Fourth, otherwise, we're stuck in a position where we have a 30-day window to appeal, and we are all delay, delay, delay. THE COURT: What if I do that? I don't know if it's a difference with that or distinction, but, procedurally, I was thinking I was leaning yesterday towards issuing the order that I just issued. I think that that's a fairly accurate rendition of the written version of my oral pronouncement yesterday, but I order that nothing -- that the redacted orders not be released until -- I'll make it, you know, five of five Monday. That will give you Monday to get down to the Fourth to get SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231403
7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 them to stop this from being released; what do you think? MR. CRITTON: Here's what the problem is, Judge, is Ms. Compiani and Ms. Walsh spoke to them yesterday and today, we need a transcript from the hearing yesterday which has not yet been obtained. They need the underlying motions, they need some time to research. It's not a matter of simply filing a writ of petition and that stays the release of the order. There would have to be a separate motion that would be filed with the Appellate Court. The Motion to Stay that we file under 9.310, subsection A, it party that seeks review Appellate Rule provides that the shall come to the lower tribal, which is the trial court, which is you, in this instance, and then it's within your discretion either to stay or not to stay under the circumstances, and we simply don't have the time within which to file the appeal under those 23 circumstances. 24 There are two criteria that have 25 to be met here, one is the likelihood of SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231404
8 1 2 3 harm where no stay is granted, and the second criteria, not necessary mutually exclusive; that is, you don't have to have 4 both of them, but you certainly have to 5 give an indicia of both of them. The 6 second one is the likelihood of success on 7 the merits. 8 we believe that based upon the 9 Court decision, respectfully, that the 10 Court, that the Appellate Court, will quash 11 your order, for the reasons Judge Puccillo 12 was the one who requested that the document 13 in this -- this was argued yesterday, so 14 I'm going to be very brief. She is the one 15 who requested post sentencing, that the 16 document be filed under seal. It was her 17 request that the defense seceded to that 18 under the circumstances. That certainly 19 was inadvertent, could have just as easily 20 remained under seal with Mr. Goldberger or 21 with the State Attorney under those 22 circumstances. 23 Secondly, that it relates to the 24 portions of it, specifically, within the 25 MPA to deal with the grand jury proceeding, SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231405
9 1 that would be a violation of Federal Rule 2 Six. I note you just handed us your order 3 about two minutes ago, Judge, so no one's 4 had an opportunity to review it, certainly 5 appellate counsel has not had an 6 opportunity to review it. I don't know if 7 you dealt with the appellate rule, but I do 8 note that within your written order, that 9 you, basically, said that in the second to 10 last page, you said this order is no way to 11 be interpreted as permission not to comply 12 with U.S. District Court Judge Marra's 13 previous orders. 14 We respectfully submit that it would 15 not comply with Judge Marra's previously 16 issued orders. We also believe that the 17 supremacy clause, as Mr. Goldberger argued 18 yesterday in conjunction with comity 19 principle, that we think that there's a 20 substantial likelihood on success of the 21 merits on this. 22 with regard to the likelihood of 23 harm, this is a paramount issue here. It's 24 undisputed that this was a confidential 25 agreement. It's a confidential contract SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231406
10 1 between Mr. Epstein and the United States. 2 United States vigorously defended 3 Mr. Edwards when he came into federal court 4 and filed an action to have the MPA 5 released, Judge Marra subsequently entered 6 an order. Another attempt that was made to 7 make the MPA public again. 8 All plaintiffs' counsel has it. 9 The only ones that don't have it is the 10 Post, under the circumstances, and public 11 under the circumstances, but all the 12 plaintiffs' lawyers of the alleged victims, 13 they either have the MPA and the addendum, 14 which I will refer to as the MPA, or they 15 have the ability to get that. That is very 16 clear from Judge Marra's order. 17 So there's certainly no harm to 18 the plaintiffs from under these 19 circumstances. And the harm in this 20 instance is only to Mr. Epstein under the 21 circumstances because as Judge Letz 22 (phonetic) once said, it's very much like 23 an attorney/client privilege or a privilege 24 document where once the proverbial horse is 25 out of the barn, you can't get him back in. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231407
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 11 We cited a case called mariner versus Baker 3 -- So. 39, So.2d 608 First District 1989. In the Mariner case, this was not a usual incident report and the Court, I know your Honor previously did a great deal of personal injury work and related work, you're very familiar. In fact, you commented yesterday and said, I don't see how the MPA is going to be admissible in a civil proceeding anyway. Again, you're not ruling on that ultimately, the judges in both the State and federal court cases will do that. In the Mariner case, the judge ordered that the defendants object at the direction of incident reports. The judge said, sorry, you've got to produce those incident reports. And the Court said, give them to me under seal because, again, we are talking about incident reports as distinct from an agreement between two parties which was deemed to be confidential 23 between the United States government and 24 Mr. Epstein. Only irreparable harm here as 25 to Mr. Epstein because if it's released, SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231408
12 1 you cannot remedy that harm on appeal. 2 And in the Mariner case, if the judge 3 said, if you put the documents under seal, 4 which is exactly the situation we have now 5 is, I will grant the stay and let the 6 appellate court determine whether or not 7 incident reports, which have a much lower 8 threshold for production or for discovery 9 reasons, and, again, there's no harm in an 10 instance like that, even in an incident 11 report came out in the Mariner cases, so 12 what. It won't be used, you can't use any 13 of the information you obtained. In this 14 particular instance, because it is 15 confidential, there is no way the Court can 16 remedy the harm. 17 With regard to the defendants in this 18 case, again, I think we've demonstrated 19 both irreparable harm, and we believe a 20 substantial likelihood on the success. 21 Again, how do you demonstrate a substantial 22 likelihood on the success? The fact that 23 we would -- if this Court thought that we 24 should prevail, my guess, you would not 25 have ruled as you did, but as the Court is SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231409
13 1 aware, oh, surprise to all of the lawyers 2 here. Sometimes judges get reversed. I 3 know that's a shock to most of the lawyers 4 in this room and most of the courts, but 5 that happens on occasion, and, therefore, 6 we believe we can show through the 7 supremacy clause, the grand jury reference 8 that we will prevail and that your order 9 will be quashed. 10 With regard to alleged harm by any 11 other party, the Post in this instance 12 reported at the sentencing of Mr. Epstein 13 on or about June 30th of 2008. They waited 14 until June 1st of '09. This was such a 15 pressing issue, the Post wanted to get this 16 desperately out to the public, they were so 17 anxious to do it, that they waited 11 18 months before they did anything. 19 Mr. Edwards, who is not here 20 today, filed a federal court action and 21 those issues were talked about and 22 discussed at some length with regard to 23 Judge Marra's two orders. 24 Judge Marra's rule, you can't get 25 them, if you want to get them, go to that SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231410
14 1 case, that would be Judge Hafele or two of 2 Mr. Edwards' cases are where is Mr. Kuvin's 3 case is or Judge Marra, where Mr. Edwards' 4 case is. Judge Marra can certainly control 5 whether or not they should be released, and 6 I've covered Mr. -- oh, and Mr. Edwards 7 because he could have gone back to Judge 8 Marra because he's got one federal court 9 case -- did he try for that form and get 10 it no, they came in here. He tried to 11 do it in a run around Judge Marra. 12 He didn't file his motion until 13 late May of '09. My guess is it was 14 Mr. Edwards who probably said to the Post, 15 gee, why don't you join in this, you 16 haven't been here for 11 months, why don't 17 you come in now, maybe intervene. And then 18 Mr. Kuvin, on behalf of his client, II 19 estate court case, came in on June 11th, 20 again, almost a year to the date after 21 Mr. Epstein's sentence. 22 It's no burning issue, there's no 23 fire here to put out, giving us 30 days, or 24 at least a reasonable period of time to 25 file petition for writ, and then if the SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231411
15 1 Court denies our stay at least asking the 2 appellate court for stay under the 3 circumstances. There's no harm to them. 4 The harm is only to Mr. Epstein, and we 5 think as a substantial likelihood, that we 6 would succeed. 7 Therefore, we would request the 8 Court grant a stay as I've suggested in my 9 proposed order for 30 days of giving 10 Ms. Walsh and Ms. Compiani an opportunity 11 to actually do their job under the 12 circumstances, so the court reporter 13 doesn't have to work over the weekend to 14 expedite transcripts for us, and secondly, 15 if we file within the 30 days, then let the 16 appellate court determine whether or not 17 the stay remains or not. 18 THE COURT: Thank you much. 19 Ms. Shullman, don't worry about 20 responding to the issue of motive or 21 seeking this relief or the timing of your 22 request or party's request. I don't think 23 that bears upon the merits of either 24 parties. 25 MS. SHULLMAN: The constitutional SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231412
16 1 2 3 4 5 right of access doesn't have a waiver provision, your Honor. THE COURT: Well, go ahead. Let me hear -- I'm on board so far with Mr. Critton's version of, Judge, if you let 6 it out, you let it out, so irreparable harm 7 8 9 10 11 is kind of easy. I think that it is a two-prong test. I think he's got to jump over both hurdles. I think he's got to show some likelihood of success. If you want to spend some energy arguing that 12 there's no irreparable harm, you may do so, 13 but if I hand it out today and everybody 14 gets to see it, you can't fix that 15 tomorrow. 16 MS. SHULLMAN: Sure. 17 THE COURT: So I think they've 18 established that. 19 MS. SHULLMAN: Let me address that 20 very briefly first, your Honor, to remind 21 you in meeting this burden that they failed 22 to meet yesterday, they identified four 23 interests which they liken now to the 24 motion to stay to the four harms. 25 One, of -- for the first three of SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231413
17 1 them, they mentioned they have no standing 2 to assert the compelling government 3 interest, the government didn't show up, 4 the imminent threat to the administration 5 of justice, again, that's the government's 6 issue. The innocent third party privacy 7 rights, they have no standing. The only 8 one is, he's not really articulated today 9 it's some sort of invasion of Mr. Epstein's 10 privacy rights. 11 Florida law is clear that those 12 who are participants in crimes do not have 13 privacy rights with respect to the facts 14 and circumstances surrounding those crimes. 15 So unless I'm going hear something outside 16 of the context of Mr. Epstein's criminal 17 prosecution, he has no privacy right in 18 this agreement. 19 THE COURT: Let me share with you 20 what I'm thinking about doing, even at the 21 conclusion of Mr. Critton's presentation, 22 and that is deny the motion to stay, but 23 delay the release of the records in 24 question until noon Friday. That will give 25 them a little bit of time to see if the SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231414
18 1 Fourth sees this case from a different 2 vantage point, a different light, and maybe 3 they'll look down and say, oh, Judge 4 Colbath, you missed it and, you know, stay 5 the matter. That will give them a 6 reasonable amount of time to get the 7 transcripts to go to the Fourth because I'm 8 a big fan of appellate review and making 9 case law. 10 MS. SHULLMAN: And I understand, your 11 Honor, if you are suggesting a week from 12 today, that's a little bit long. Remember 13 the status quo here, we are in sort of a 14 strange procedural posture because your 15 Honor decided that the initial closure was 16 improper, but the recent request for 17 closure was denied, so instead of a status 18 quo where we have a document that should be 19 released, it's under seal where it 20 shouldn't be, so any moment that it is kept 21 under seal is a serious deprivation of the 22 public and the press's right to access, 23 which you have already determined they 24 have, we think you are correct, of course, 25 so I would ask that any stay -- SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231415
19 1 MR. CRITTON: She's pandering, your 2 Honor. 3 MS. SHULLMAN: I will say he 4 respectfully disagreed with you, so I think 5 a week is too long. I do this day in and 6 day out, I have spent many a weekend on 7 these matters in my career. If you want to 8 give them till Tuesday, I'll be kind, but 9 the Fourth will act quickly on this. I 10 don't think that a week's delay is 11 necessary. I think, in fact, it under 12 minds the public purpose here. 13 THE COURT: All right. Any other 14 respondents want to go anything further? 15 MS. SHULLMAN: The State Attorney's 16 office also advises me that Friday is a 17 holiday and the courts are closed. 18 THE COURT: Thank you for telling me 19 that. Friday is a holiday. 20 MR. KUVIN: July 4th. 21 THE COURT: The day of the birth of 22 our constitution. 23 MR. KUVIN: Good morning, your Honor. 24 On behalf of intervenor II, obviously, the 25 Court is inclined to delay the disclosure SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231416
20 1 of this, but under Rule 9.310, if your 2 Honor were to issue such a stay, we would 3 point out the provision C of the rule, 4 which requires a posting of the bond. 5 We not only agree with your Honor's 6 ruling, but we believe such appeal they are 7 filing is absolutely frivolous and we are 8 going to be requesting fees and cost for 9 the filing of that appeal, so as a result, 10 we are requesting a bond be posted if a 11 stay of any type is issued in this case 12 because of the fact that we want to make 13 sure that our attorneys' fee and costs are 14 covered for the frivolous nature of the 15 appeal. And it's dictated strictly in 16 subsection A. It gives the Court the 17 authority. It says: 18 A stay pending review may be 19 conditioned upon a good and sufficient 20 bond, other conditions or both. Therefore, 21 we believe your Honor does have the 22 authority to issue such a requirement that 23 the posting of a bond be issued. 24 THE COURT: All right. Thank you 25 very much. I will deny the motion to stay. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231417
21 1 I will delay the release of the documents 2 until noon Thursday. I will deny the 3 request to compel the movant, the 4 defendant, Mr. Epstein, to post a bond, and 5 I'll let the appellate court tell us and 6 teach us what the law on this case will be. 7 It's always interesting how these 8 cases unfold and come to us a little 9 different than everyone else. Now, let me 10 have the attorneys come up here and 11 approach. 12 (The following proceedings were held 13 sidebar, out of the hearing of the jury.) 14 THE COURT: I reviewed the two 15 documents, I didn't see any kids' names in 16 there. Everybody was hinting the 17 children's names or the initials' names. I 18 had my big black highlighter out, I don't 19 see anything worth redacting, so. 20 MR. GOLDBERGER: it's the plaintiff's 21 document that identifies the children's 22 names. It's a letter to me actually. 23 THE COURT: I was wondering if 24 everybody thought there was something in 25 there that wasn't in there. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231418
22 1 MR. CRITTON: It's a test of your 2 skills, your Honor. 3 THE COURT: You're right, exactly. 4 One is page one through seven, and the 5 second one is just two pages that's not 6 even signed by everybody. 7 MR. GOLDBERGER: While we're all up 8 here chatting, there are references to 9 other names up here. 10 THE COURT: Yes, Mr. Goldberger, and 11 no one has identified in the document says 12 these are people that are not going to be 13 prosecuted. Mr. Kuvin made the argument 14 that these are co-conspirators. These are 15 innocent people that have nothing to do 16 with these proceedings. They have nothing 17 to do with -- 18 MS. SHULLMAN: They have a standing. 19 THE COURT: I will renew my ruling 20 that I gave you yesterday, and deny your 21 request to redact those names out of there. 22 All right, so I'll hang on to these till 23 Thursday at noon, and anybody that comes 24 wants to come and get them, I don't know if 25 there's a mechanism for -- I stand on the SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231419
23 1 courthouse steps and pass them out. 2 MS. SHULLMAN: If there are no 3 redactions to be made. 4 THE COURT: No redaction. 5 MS. SHULLMAN: I would do an order 6 directing the Court to release them and 7 they may become unsealed. You don't 8 need -- 9 MS. COMPIANI: Your Honor, are you 10 going to write up a written order 11 denying -- 12 MR. GOLDBERGER: Are you going to do 13 that? 14 THE COURT: Put together a written 15 order? 16 MS. SHULLMAN: Denying the stay? 17 THE COURT: Yes, A, denying the stay; 18 B, delaying the disclosure or unsealing of 19 these documents until noon Thursday; C, 20 denying the motion for bond. 21 MR. GOLDBERGER: And you'll need that 22 order quickly. 23 THE COURT: Yeah, fax that and we'll 24 get it signed quick today. 25 MR. GOLDBERGER: Are you forcing the SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231420
24 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 court reporter to work over the weekend so we can get a transcript? MR. CRITTON: Thank you, your Honor, for moving us this morning. (Side bar conference held outside the hearing of the jury concluded.) SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231421
25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 June 2009. 19 20 21 22 23 24 25 CERTIFICATE THE STATE OF FLORIDA, COUNTY OF PALM BEACH. I, SUSAN S. WIGGINS, R.P.R., Official Court Reporter for the Fifteenth Judicial Circuit, Criminal Division, in and for Palm Beach County, Florida; do hereby certify that I was authorized to and did report the foregoing proceedings before the Court at the time and place aforesaid; and that the preceding pages numbered from 1 to 24, inclusive, represent a true and accurate transcription of my stenonotes taken at said proceedings. IN WITNESS WHEREOF, I have hereunto affixed my official signature this 29th day of (C-aecktfi (23 60 SUSAN S. WIGGINS R.P.R. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231422
CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and Federal Express this Sox. day of June, 2009, to: U.S. Attorney's Office-Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale FL 33394 Counsel for SPENCER T. KUVIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Counsel for M. JUDITH STEVENSON ARCO State Attorney's Office-West Palm Beach 401 North Dixie Highway West Palm Beach, FL 33401 DEANNA K. SHULLMAN 400 North Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post HONORABLE JEFFREY COLBATH Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach, FL 33401 ROBERT D. CRITTON BURMAN, CRITTON, LUTTIER & COLEMAN 515 North Flagler Drive, West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and EFTA00231423
JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 Counsel for Petitioner By: - 751SL‘-• ICUI-S. W4 ALSH lorida Bar No. 272371 EFTA00231424
EFTA00231425
MARTIN a WEINBERG, P.C. ATTORNEY AT TAW 10 PARK PLAZA, SUITE IMO BOSTON, MASSACHUSETTS 02116 FAX NIGHT EMERGENCY: Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 S. Australian Ave. West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. July 22, 2011 EMAIL ADDRESSES: MIN Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the NPA. Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order. Very truly yours, Martin G. Weinberg cc: Roy Black EFTA00231426
07/22/2011 15:55 3053562006 BSKS PAGE 02 MARTIN G. WEINBERG. P.C. ATTORNEY AT LAW nitorEnAz4surreimo EMAIL ADDRESSES: sortm. mAsuaniszny nsrn tAx MOW EVERGEACY: AssistarRl.:iiit States Attorney United States Attorney's Office Southern District of Flo • 500 S. Australian Ave. West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. July 22, 2011 Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/ victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public wiMessivietim list which was referenced in paragraph 7 of the NPA. Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order. Very truly yours, / m dc k 2 Martin G. Weinberg cc: Roy Black EFTA00231427
07/22/2011 15:55 3053582006 BSKS PAGE 01 BLACK SPEBNICK KOPNSPAN STUMPF TRIAL ATT0RNEYS Email: Roy Black Howard M. Srebn'ck Scott A. Kornspan Larry A. Stumpf Maria Neyra Jackie Perczek Mark A.J. Shapiro Jared Lopez Marcos Reaton, Jr. Jessica Fonseca-Nader Kathleen P. Philips Jenifer J. Souliklas Noah Fox Joshua Shore FACSIMILE TRANSMITTAL SHEET FAX: (305) 358-2006 TELEPHONE: (305) 371-6421 TO: AUSA ~., Esq. RE: )epaeti , N.v. -DAZ DATE: July 22, 2011 SENDER: Jackie Perczek NO. OF PAGES (INCLUDING TRANSMITTAL SHEET): 17/JO . MESSAGE: SIF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL (305) 371.6421e PACETIMS CORTADIS PRIMA:~ Ani C0111.21tanu, INTORRIATION 3Olt ORLY.POIL nopostor tki rzerviounot ABOVE. DT TRE RITADER OP THISPAOSIRHE inbOT T8E reut= Iterntlft OR PM ~LOM% OR »Mrt R6BPOR8BLS TOR DILIVICRINO IT TO TIM INTATORWRIORIPIMT, YOU Ans tamari Neem= THAT ARY MISIISTIRATTOR OR OOM«) 01 TIMPACEITIMS IS ITTRICTLY PITOICOMRD. &POR Adat MCLIVIW tuis PAOSIIMS ERROR. PLEAMISTERIAISLIMOTHTUSZY TICLEPHON; ARO RiprIMIT taz °MIMI MOSHILLR TOUR AT TM AZOVITADDRISS VIA 111Z 17.S. PORTAL ~Ot. TRAM TOR. Y 201 S. Eliscayne Boulevard. Suite 1300, Miami. Florida 33131 (F) iwww.royblack tom EFTA00231428
U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 Facsimile: July 27, 2011 DELIVERY BY FACSIMILE Martin G. Weinberg, Esq. 20 Park Plaza, Suite 1000 Boston, MA 02116 Re: IttfiraMin Dear Mr. Weinberg: Thank you for your letter of July 22, 2011. In order to review and address the objections that you raised in that letter, the Office deferred making its planned disclosure to the District Attorney of the County of New York of the Non-Prosecution Agreement ("Agreement") and the list of identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after completing a full review of your objections, the Office still intends to proceed with the planned disclosures. The Agreement requires the Office only to provide Mr. Epstein with notice prior to a disclosure of the Agreement "[i]f the United States receives a Freedom of Information Act request or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to your suggestion, that such disclosures of the Agreement may be made other than in response to "compulsory process." Here, moreover, the District Attorney of the County of New York, as a local law enforcement agency, has provided a legitimate request for disclosure of the requested information, as well as a promise to maintain the confidentiality of the information, particularly the names of the minor victims. / our objection pursuant to Federal Rule of CninmaiProcedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agreement) for your claims that the Office cannot disclose the Agreement and EFTA00231429
MARTIN WEINBERG, ESQ. JULY 27, 2011 PAGE 2 OF 2 the victim list to the District Attorney of the County of New York, we would be willing to consider those authorities before making any disclosure, provided that any such authorities are furnished to us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously-planned disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New York at 5:00 p.m. on July 29, 2011. Sincerely, Wifredo A. Ferrer By: IIII. cc: Deborah L. Morse, Assistant District Attorney, County of New York Roy Black, Esq. EFTA00231430
United States Attorney's Office Southern District of Florida 500 S. Australian Ave., West Palm Beach, FL 33401-6235 DATE: 7/Z7/2 01/ TO: ititiVrim lAkiiva:XO ORGANIZATION: FAX #: SUBJECT: jerr" EeSTE/P4 FROM: (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: 3 COMMENTS: Original document: To follow via Federal Express To follow via hand delivery Nothirino follow, FAX = original EFTA00231431
Fax Send Report Date/Time Fax Number Fax Name Model Name No. Name/Number 246 : JUL-27-2011 03:01PM WED : phaser 3300PFP StartTime Tine Mode Page Result 07-27 03:00PM 00'31 ECM (lotted Stale> AIN: ney's Office Southern Ulsiriet of Florida 500 S. Australiau Ave., West Palm Beach, Pl. 33401-0235 DATE. -7/£272Ciel— _. • — 70. Ates7a illeavApeit ORGANIZATION: FAX,: SIAUFCT: tirefflt feSX09_ .11— ( f"Afeje (Fax) FROM: NUMBER OF PAGES. INCLUDING t11IS PAGE: 3 - COMMENTS: Origentallocunmot 7u Sew via fagot.). snarl To foam via Federal ExweAS 7o Meow via hand Mine X Meiji° toast FAX r ()Arai 003/003 CO( EFTA00231432
United States Attorney's Office Southern District of Florida 500 S. Australian Ave., West Palm Beach, FL 33401-6235 DATE: —7/2-7/Zip TO: belockain 11- ORGANIZATION: ive (A) 0,4( 6(5/rid orAtt FAX It: SUBJECT: sreri FROM: A . Marie Vi &AA-ex MI (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: 3 COMMENTS: Original document: Tn follow via rcgul To follow via Federal Express To follow via hand delivery X Nothinrto follow, FAX = original EFTA00231433
Fax Send Report Date/Time : JUL-27-2011 03:03PM WED Fax Number Fax Name Model Name : Phaser 3300MFP NO. Name/Number startTime Time Mode Page Result 247 07-27 03:01PM 00'57 ECM lifiered Slam Alloracy's Office Somber,' NisINN of Ala 500 S. Austrahau Ave., West Palm Beach, 8.334014235 cals . 77/1 .7 4-00 — 1O: bakomin_ ORGANIZATION- tJQW etbisterlettlitenstiPEitii FAX a: SUBJECT- tT6..6r FROM- rax) NUMBER OF PAGES. INCLUDING THIS PAGE:.. _ _ COMMENTS: OrigitutIclownieni: x To letlow Ina 'oval mac lo follow wa Feder?' express To follow era hand delivery Nottunrio fNbw. FAX 's origwed 003/003 O.K EFTA00231434
U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 Facsimile: July 21, 2011 DELIVERY BY ELECTRONIC MAIL Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: ,Jeffrey Epstein Dear Mr. Black: On July 17, 2011, the Office received a written request from the District Attorney of the County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to Deborah L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure. By: Sincerely, Wifredo A. Ferrer United States Attorn ss►stant m tates ttorney cc: Deborah L. Morse, Assistant District Attorney, County of New York EFTA00231435
United States Attorney's Office Southern District of Florida 500 S. Australian Ave., West Palm Beach, FL 33401-6235 DATE: 7/21/2..0 r I TO: )1OLindri moyse ORGANIZATION: bi.hr/Ci - A FAX #: SUBJECT: FROM: (Fax) NUMBER OF PAGES. INCLUDING THIS PAGE: 2 - COMMENTS: Original document: To follow via Federal Express To follow via hand delivery X Nothirrto follow, FAX = original EFTA00231436
Fax Send Report Date/Time : JUL-21-2011 02:08PM THU Fax Number Fax Name Model Name : Phaser 33001, SP NO. Name/Number StartTime Time Mode Page Result 211 07-21 02:07PM 00'25 ECM 002/002 O.K - • - United Stales Attorney's Office Southern District Of Florida 500 S. Australian Ave., West Palm Reach, VIL 33401-6235 DATE. 7 /21/loll TO: Dineati / /kwve n ORGANIZAI ION: FAX 0: SUBJECT: FROM. NUMBBROFPAGESJNCLUDINGTHSP COMMENTS: . avinardmmmat To w nr rirqu r via Fel J-r Express To via h. n d Avery Offikraw, AN'HorIgMal EFTA00231437
2123359288 Fax: Jul 17 2011 10:15ps P001/002 DISTRICT ATTORNEY CYRUS R. VANCE, JR. otrucT Arrow/v. Date: To: Fax: From: OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York, N. Y. 10013 APPEALS BUREAU FAX DOCUMENT COVERSHEET FAX # Vi-dy /7_Zoft 4-45,4 Tel #: .335- 921.3 # of Pages 2- (includes cover sheet) IlAre 444 K URGENT K ROUTINE Deliver Immediately 0 Discuss with Appropriate Person(s) o As Requested Review and Comment K For Your Approval Take Necessary Action o For Your Information 0 Reply Via FAX K File Reply Via Messenger K Reply Directly K Progress Report o Investigate K Let's Discuss K Prepare Reply for Signature o Other Action To Be Taken/Additional Comments: art/7i - 6.4 AiA.. Atio eAkoj e A 414 he ?PAS. -rs IA/c /sorer, 2 • lg. t un, ei rkedele. rem_ Of ratio.; --4 )ciporA4 dictre—, EFTA00231438
2123359288 Fax: DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE Now York. N. Y. 10013 CYRUS R. VANCE, JR. 0MMUCT Arroromr , Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida liaktralian Avenue West Palm Beach, Florida 334O1 Dear Ms. Jul 17 2011 10:15Pa P002/002 July 15, 2011 As we have discussed, I am currently working on the appeal brought by defendant Jeffrey Epstein In which he challenges his risk-offender designation under New York State's Sexual Offender Registration Act. The non-prosecution agreement between defendant and your Office would be of assistance to us in fashioning our response on appeal. I would appreciate it if you would send us a copy of that agreement, including the list of victims. Please let me know If you need any further information in order to make this material available. I appreciate your assistance, and courtesy, in this matter. Yours truly, e Deborah L. Morse Assi nt District Attorney EFTA00231439
U.S. Department of Justice United Stales Attorney Southern District of Florida 500 S Australian Ave, Ste 400 West Palm Beach, FL 33401 (56!) 820-8711 Facsimile: July 21, 2011 DELIVERY BY ELECTRONIC MAIL Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: On July 17, 2011, the Office received a written request from the District Attorney of the County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to the District Attorney's request; the U.S. Attorney's Office intends to disclose these items to Deborah L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure. Sincerely, Wifredo A. Ferrer United States Attorne By: istant nit tates ttorney cc: Deborah L. Morse, Assistant District Attorney, County of New York EFTA00231440
DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York, N. Y. 10013 CYRUS R. VANCE, JR. OTRCT ATTORNEY May 6, 2011 , Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida 500 S. Australian Avenue West Palm Beach, Florida 33401 Dear Ms. As I explained during our telephone conversation last week, I am currently working on an appeal brought by defendant Jeffrey Epstein. Defendant Epstein challenges the designation that he was given under New York State's Sexual Offender Registration Act. The underlying sexual misconduct at issue was the subject of an investigation and/or prosecution by your Office, as well as the Florida State's Attorney Office in Palm Beach County. I know that you handled the matter on behalf of your office when the case was presented to the federal grand jury. Those grand jury proceedings would be of assistance to us in fashioning our response on appeal, and I would appreciate it if you would send us a transcript of those roceedings. If we furnish the minutes to the appellate court, we would do under seal for the purpose of an in camera review. Please let me know if you need any further information in order to make the materials available. I appreciate your assistance, and courtesy, in this matter. Yours truly, Deborah L. Morse Assistant District Attorney EFTA00231441
DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE Now York, N. Y. 10013 CYRUS R. VANCE, JR. DISTRICT AITCRMEY August 15, 2011 , Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida 500 S. Australian Avenue West Palm Beach, Florida 33401 Dear Ms. Pursuant to our conversation, I have enclosed copies of the brief and appendix filed by defendant Jeffrey Epstein on appeal, as well as a copy of our brief in response. I look forward to hearing your opinion. Yours truly, ti 6t 1 of Lc.) Deborah L. Morse Assistant District Attorney EFTA00231442
New York County Clerk's Index No. 30129/2010 'sin 'Dark $ig:matte &curt APPELLATE DIVISION-FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, Respondent, —against— JEFFREY E. EPsTEIN, Defendant-Appellant. APPENDIX CYRUS R. VANCE, JR. NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE One Hogan Place New Yor New York 10013 Attorneys for Respondent JAY P. LEFKOWITZ SANDRA LYNN MUSUMECI KIR1CLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Attorneys for Defendant-Appellant REPRODUCED ON RECYCLED PAPER EFTA00231443
TABLE OF CONTENTS PAGE Appellant's Pre-Argument Statement, dated February 9, 2011 Al Appellant's Notice of Appeal, dated February 9, 2011 A3 Order Appealed From, dated January 18, 2011 with Notice of Entry A4 Palm Beach Police Department - Probable Cause Affidavit of Det. - Defendant dated May 1, 2006 A6 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated July 23, 2006 A28 2006 Grand Jury Indictment of Felony Solicitation of Prostitution - Jeffrey E. Epstein A29 Information for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 26, 2008 A31 Guilty Plea for Felony Solicitation of Prostitution and Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A32 Judgment for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A33 Sentence for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A34 Community Control Standard Conditions, dated June 30, 2008 A35 Palm Beach Sheriffs Offiee-Beeking-Gard-for-Jeffrey--Epstein dated June 30, 2008 A47 EFTA00231444
ii PAGE Order Granting Jeffrey E. Epstein's Motion for Travel, dated December 18, 2009 A48 Letter from Florida Department of Corrections Regarding Termination of Supervision, dated July 21, 2010 A49 Letter from Palm Beach Sheriff's Office Regarding Jeffrey Epstein's Participation in the Work Release Program, dated August 12, 2010 A50 Letter from Jack A. Goldberger to NYS Sex Offender Registry Regarding Florida Registration Level applicable to Jeffrey E. Epstein, dated August 12, 2010 A51 Letter from Martin G. Weinberg to NYS Board of Examiners of Sex Offenders Regarding Level and Designation Determination for Jeffrey Epstein, dated August 16, 2010 A53 Letter from Stephen R. Alexander, Psy.D. to Jack Goldberger Regarding Opinion of Jeffrey E. Epstein, dated August 16, 2010 A58 Recommendation of Board of Examiners of Sex Offenders, Including Risk Assessment Instrument, dated August 19, 2010 and Case Summary, dated August 23, 2010 A62 Letter from Supreme Court attaching Notification, Recommendation and Notice of Right to Appeal, dated August 26, 2010 A67 Letter from Supreme Court to Jeffrey E. Epstein informing of SORA Level Determination Hearing, dated August 26, 2010 A68 Order Sheet for Jeffrey Epstein, dated August 26, 2010 A69 Letter from Supreme Court to Counsel Informing of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00231445
in PAGE Letter from Jay P. Leflcowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Determinations, dated January 19, 2011 A78 Court Action Sheet - Jeffrey Epstein, No. 30129-2010 A80 Handwritten Notations on Court Jacket - Jeffrey Epstein, No. 30129-2010 M1 Transcript of SORA Hearing, dated January 18, 2011 A82 EFTA00231446
Al Appellant's Pre-Argument Statement, dated February 9, 2011 [pp. Al-A21 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK PEOPLE OF THE STATE OF NEW YORK, Plaintiff-Respondent, -against- JEFFREY E. EPSTEIN, Defendant-Appellant. Index No.: 30129-2010 PRE-ARGUMENT STATEMENT 1. TITLE OF ACTION: As set forth in caption. 2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES: As set forth in caption. There has been no change in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETTTIONER: Jay P. Leflcowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne 4611 Telephone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYiiii m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJEGF-OF-ThE-C-AUSE-OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the Correction Law. 7. RESULT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW: Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual offender, without additional designation. 8. GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of EFTA00231447
A2 discretion and constituted reversible legal error based, in part, on the following: (1) the Court improperly relied on untrustworthy double and triple hearsay contained in the recommendation of the Board of Examiners of Sex Offenders, even though the District Attorney, as the party appearing on behalf of the State, rejected much of the Board's recommendation as not constituting clear and convincing evidence to support a Level 3 designation where such hearsay allegations were rejected as a basis for state prosecution; (2) the Court failed to provide the parties with an opportunity to present evidence on contested issues, as required by statute, and instead relied wholesale upon the recommendation of the Board, over the objection of the District Attorney, without any inquiry; (3) the Court did not apply the guidelines established by the Board, as required by statute; and (4) the Court failed to set forth the findings of fact and conclusions of law on which its determinations in support of a Level 3 designation were based, as required by statute. 9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PENDING IN ANY COURT OF THIS OR ANY OTHER JURISDICTION. 10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION. Dated: February 9, 2011 Ja . Leficowitz, P.C. S Lynn Musumeci KIRKLAND t ELLIS LLP 601 Lexington Avenue New York, Neal -4611 Telephone: Facsimile: Attorneys for Defendant-Appellant Jeffrey E. Esptein. -2- EFTA00231448
A3 Appellant's Notice of Appeal, dated February 9, 2011 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK, Plaintiff, - against - JEFFREY E. EPSTEIN, Defendant. NOTICE OF APPEAL Index No. 30129-2010 CRIMINAL TERM PART 66 JUSTICE RUTH PICKHOLZ PLEASE TAKE NOTICE that the above named defendant, Jeffrey E. Epstein, hereby appeals to the Appellate Division of the New York Supreme Court in and for the First Department, from an order entered in the above entitled action in the office of the Clerk of New York County on the 18th day of January 2011, which order adjudged defendant Jeffrey E. Epstein to be a Level 3 sexual offender pursuant to Article 6-C of the Correction Law, and this appeal is taken from each and every part of that order as well as from the whole thereof. Dated: February 9, 2011 To: Clerk, New York County Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NY Telephone: Lefkowitz, P.C. a Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne Telephone: Faccim; Attorneys for Defendant Jeffrey E. E P'ILED FEB OP SISUPREME COURT NOW YORK COUNTY APPA'ALV: ro.thant.m) EFTA00231449
A4 Order Appealed From, dated January 18, 2011 with Notice of Entry Ipp. ASUPERVIGINGp.ff.F10ER: -km.. rh•• . '‘ C.; ''g;C: •!. ' §UPERVISING AGE Y, Le NONE ; OFFENDEipp UNS • ,:. ' ttitl'i it0 :" ' 4. ' )ft'i '4'. i - cA: 114aboliii:rekerOnoed,I id . ;o54ntitteistan oflatala amulet midi_ keitaliliihetiesT eh 4Stite:at Ulkaddnisilicsflpikekft tia:lstridethmgned.3_ ' ..r. ,113fit Vender!kri quirad tc1,1". ister'and b.e..W Tak r in„, ... ixeria. a lilt Cave) :lac eacti(Madiga:/ et • ottendeld Hew Y iiii . PtOttigKe e„....a.gurritnary'ind daili410fiximnit aifirfaciellieVeify di 0:.NYS and 0 E*.rlieke.k ion Si attietladVskalsettn" 1 -.. Htnitia i ,-..... -7- war:kW" silence Offen:1476:C 'DJ sexually 68:1420fifi dealt' iitS C°In In' a ' 9' 7' — en nieelit theldelailtiqq. sivUttlYiroA, ifitifinkadosiocesiThipdaatt. .. e. fe alp ',aartheit the offender:,. ,,.. .1.kiiagalabOOffend or ' like fort la Cofrectba LOW Seaton iise-a OM ieViiif t yvitt' gi ld ate '145tal7Puhk - .0' Las;ii.612bOtnied '46 erlid: 2005:. d gild •andJus.4!fil4liiserrameiiiiedi j p.pvtgelhet.the'•Aoari:lhaniiiiidtici the: riskfijoicand,dosignatiOR:pf4a4 oftkier; Savkig.isienlikien Padeelkitdifliittle. Oak:: elti:c and place of the 0 0444),, U!ItiBi_ toflriseit,iiittimit , ' liototattl foltrit4rnninsitts'afemler's risk Iiiimit no Widthtinny nollt.itatIOW6 Li0r . .,b fv.itf . ., :::,,....tvIstretiet4'Aysit.trerit,Itira*.;SS. py or, titit'otaat:il t.. ':' ,.. ;level and designation determinations an thdiar.idliveahaton . WhitilialkatclettirminaliOns:aratlatiseditafral Ws. sUbmitted to' the' Divisioff: of "CHmilialrJtiatia6ZSgvial'AV 0tit WI py'llhic.00titC, inf.' ditItin,' please: compete and; attach this ttorni•IndVilitict:Ife7offeh&I'Mrt • natlo P ii.to,thaiark.buler Please distribideNiernainktutcOisiis indicatiiitiajkA2, *014iff•:4 4::I'Tssia44-:, !.t.r)Fri'?- 4.:';4:It t ."Ft:"":\i?'‘‘::wi3;:-.?* 'f.. .",,; W401/sA; OiSit.k1:Inz FINAkRISIC LEVED,DETE iNAllati Miele Calie • ile;Ve4Wr'• bESIGNATIO :4.1leAse,check• h that applir pUrstiantto A • 4.,..tas ' t" t Otipation. ow ts.to.bopomple K", tf-wtet EFTA00231450
A5 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK, Plaintiff, - against - JEFFREY E. EPSTEIN, Defendant. NOTICE OF ENTRY Index No. 30129-2010 CRIMINAL TERM PART 66 JUSTICE RUTH PICKHOLZ PLEASE TAKE NOTICE that the within is a copy of an order entered in this action on the 18th day of January 2011, in the office of the Clerk of the County of New York. Dated: February 9, 2011 To: Clerk, New York County Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYaili m Telephone: Jar. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Neill -4611 Telephone: Facsimile: Attorneys for Defendant Jeffrey E. Epstein FI LED FEB op 2811 New „ abme cou, ANP `Jr* a cou ev r aAte sr Wiry Dvra,u EFTA00231451
A6 Palm Beach Police Department - Probable Cause Affidavit of Det. dated May 1, 2006 [pp. A6-A271 Probable Cause Affidavit Palm Beach Police Department Agency OM FLO 500600 - Defendant Police Case#: 05-368 (2) Defendant: Sarah Race/Sex: White Female DOB: Charges: Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts Principal in the 1e1 Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006 the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, a and Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawfbl sexual activity that took place at the residence of Jeffrey stein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein for which at received monetary compensation. During the visit they would be introduced to a, Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstcin's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their ciothin to •rovide the massage. As the victims complied and provided the massages, stein would On occasion, Epstein would introduce a massa et/vibrator and vided the .m o. On three separate occasions, Epstein . At the conclusion of the massages the victims were paid sums of money ranging front $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to est." dob 05/13/1990, and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff" had t while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, ■ stated that-, dab a cousin of SCI's boyfriend and classmate at Ro al Palm Beach High School, worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make money. During the beginning of the month of February 2005 explained that she was first approached by to go with her to Epstein's house, stated that alo with a Hi anic female, later identified at .. her up at her father's house on a Sunday. was not sure of the exact dates but knew it was a Sunday. told her sp fathet that they were going shopping but in reality drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed info a thi " day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida al Beach Signature Date: 05/To 006 Officer Pagc I of 22 EFTA00231452
Signature of Poli e Officer (F.S.S. 1.1.7.10) A7 Probable Cause Affidavit Palm Beach Police Department Agency ORIM FLO $00400 conversation occurred between and II whereas reportedly toldlihat if tasked her age, she should say she was eighteen. It was later confirmed by the that picked his daughter up on February 6, 2005. According to M father, drove a pick up truck. . described Epstein's house as a two-story pink house with a Cadillac Escalade parke in the driveway. She recalled that . house was on a dead end street. Upon arriving at the house . stated that they walked up a driveway, ast what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to sec Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Short( thereafter, Epstein and his assistant, described as white fe ale vS,I) blond hair and later identified as entered the kitchen. Epstein introduced himself to M.. described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving. alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. . was instructed to follow upstairs: . recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a larlbathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. recalled there al a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told. to take off her clothes.. stated Epstein was stern when he told her to take off her clothes. M said she did not know what to do as she was the onlune there in the room, she took off her shirt leaving her bra on. Epstein had removed his towel and told the. to take off everything. stated Epstein was nude when he took his towel off, placing it on the floor as he laid il down on the table. stated she then removed her pants leaving her thonsjanties on. Epstein then instructed her to give him a massage poirW to a specific lotion for her to use. As IN began to giv ' e, he told her to t on his back. . stated she straddled herself on Epstein's back whereby Epstein's bare buttocks. M said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed. to massage his chest m was now standing on the ground and resumed massaging Epstein's chest area. M stated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then brined to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before rue this in day of May, 2006 by Det Joe Recarcy, wholipersonalfy known to mc. Page 2of 22 Date: 05 006 Slate of Florida Court of Palm B ach Officer EFTA00231453
A8 Probable Cause Affidavit Palm Beach Police Department Agoney ORIN FLO 500600 stated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with was paid old El said she number. :::1 an were leaving the house, told shc received two hundred from Epstein. Before s surked to leave her phone dollars that y or aging er. During the course of the investigation, parental consent was granted for to assist with the ?stn. At our direction conducted controlled taped phone calls to cellular telephone . dig • II spoke with in an attemaiange another meeting with Epstein.. asked Robson, she need to do to make more ney. stated, "the more you do, the more you get paid." had subs uently called back U and left a voice mail message for her indicating that she had set up an ointment for . to go to Epstcht's house at 11:00 am on April 5, 2005. This message was recorded from voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a message pstcin W which stated -and. name at 11:00 am. This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt and I knocked on the door and met with was told that we were investigatinga claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach was asked if she would accompany us back to the police station for further questioning. She was also told at at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective. Bureau where I obtained a taped, statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turned 17 years of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked iiim anted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to inc. Signature of Police (ricer i.S.S. 117.10) State of Florida County of Palm Beach Officer Signature Date: 05/0 006 Page3of 22 EFTA00231454
A9 Probable Cause Affidavit Palm Beach Police Department Agency O1U0 FLO 500600 (Unknown last name) and Tony (Unknown last name) picked up and she was taken to Epstcin's house. Upon her arrival to the house she ' uced to Epstein in the kitchen of the house. She wait was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her as Jeff Epstcin's bedroom. arranged the massage table and covered the table with a sheet. She brow t out the massage oils and laid them next to the massage bed. MI, then left the room and informed Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Durnmassage, tried to touch her. stated that Epstein stated "He tried to touch me and I stopped him." I asked how he and she felt uncomfortable. told Epstein, NI massage you but I don't want to he touched, stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brought to see Epstein, each time site was paid $200. stated she had brought the following girls: - ' • - ' , • , M. ( al6 year old female), (a 16 year old female) and :.._.* - . said that at the time she brought these girls to Epstein's house they werea1114 through 16 years of age. ! asked which one was the youngest. =I advised. was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they a ted. They were told they would provide a massage, possibly naked, and allow some touching. I asked her If . was aware. She stated every girl she brought knew what to expect. She ex lamed she knew that. wanted to make money. She approached. and explained about going to work for .. agreed and arrangements were made to bring her to Epstein's house on a weekend. stated that she and .__ (Later identified as -,..:... 71„,. .. . ) picked up. at her house. stated that at that time she was driving a red pickup truck. They traveled 6: Stein's house and entered through the kitchen door. They met with the li eheld Epstein's assistant =.. was introduced to Epstein while they were in the kitchen area. upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing. to Epstein's house. stated. told her she was paid $300.00 for the massage. stated that. was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by =. She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this l w day of May, 2006 by bet Joe Recarey, who is personally known to me. Signature of Police filet (F.S.S. 117.10) State of Florida Coun of Palm Beach Signatur Date: 05/01/2006 g Officer PageSof 22 EFTA00231455
A10 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 when he was going to travel to Palm Beach. =said when Epstein announces to his assistant, he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein'. stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. further stated that still tries to call Robson.'s house and leaves messages. Sgt . entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstem's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was laced within the vehicle to record NI any conversations within the vehicle. During the drive back to her home, made the co " I'm like a Heidi Plass." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with a sixteen year-old female who was brought to Epstein's residence by . We met with mother at their front door. We explained the ongoing investigation and asked to speak with, as we had information that she had "worked" for Jeff. introduced us to her husband and allowed us entry into the home. tfalgt in the dining room and met with Date of Birth . As she was under the age of eighteen, = was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed,, who denied havi any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with approximately eight months ago and sat in the .was with the house chef, but nothing happened. As the parents were present during the interview, we felt that withholding information from us. She made several comments as to putting the entire incident behind her. I left myarne number and advised should she wish to speak with me again to telephone me. Sgt NI and I thanked for her time and left the area. She stated she would ask, again after we left as to what happened at Epstein's house. I informed her that I had my telephone number and hopefully she would call. On OctoberS2005, Da. and I drove to the — dob . During a sworn taped statement stated approximately a year ago. _ when she was seventeen years old, she was taken to a house by . stated she knows because they both attend Royal Palm Beach High School. She was told she could make money working '• home and met with ' and The foregoing instrument was sworn to or affirmed before me this I" day of May, 2006 by Del who is personally known to me. Signature of Police t7Mcer .5.5. 117.10) State of Florida Date: 05/01/2006 PageSof 22 EFTA00231456
All Probable Cause Affidavit Palm Beach Police Department Agency OM PLO 500‘00 for Jeff She was told she would have to rovide a massage to Jeff. 7_, stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was alreadyApshe kitchen area. stated would wait for her in the kitchen. I . was introduced to =, Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a , massage. Epstein entered the room wearing only a towel and she provided a massage. - t her clothes on during the massage. She advised sometime during the massage Epstein and pulled her close to him. r said she was uncomfortable by the incident involving Jeff At the conclusion of the massage, she was paid $200.00 for the massage. I asked : ... : . if she has any formal training in massages to which s! hed no. I asked her if received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. ic stated she returned to Epstein's house on another occasion with and another 'z stated she waited in the kitchen with , while was taken upstairs by . stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach *.: via cell phows 4 voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested : to call her back reference the police questioning. T...'t provided the Incoming telephone number as . • . stated she inadvertently told'. ...._ about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Epstein. : asked her what wasgoing on at the house that the police would be asking questions. . • stated . then called Jeff and and asked what was going on reference the ongoing police investigation. According to has since then been trying to contact her to ask about the police questions. I instructed ' ' not to contact and do not provide any more information to as she would notify Jeff Epstein and what was transpiring. On October4, 2005, I made telephone contact with who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She .further advised she did not want to speak of this incident in front of heir )(Aber. At approximately 3:48 pm I made telephone contact with,. During a taped recorded statement ■ stated the following: approximately a year ago, when she was sixteen years of age, stook her time she went• drove to the house. They entered through the kitchen area where she was to Epstein's ho • knows because they both attend Royal Pal Beach High Soho° The first The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by Det • who is personally known to me. Signature of Police facer . 117.10) State of Florida Court otPahn Reach Signatur Date: 05/01/2006 g Officer Page 40122 EFTA00231457
Al2 Probable Cause Affidavit Palm Beach Police Department Agawy OM PLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the sage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and stein had a verbal disagreement, at which time she left without being paid. She got with who was sittin in the kitchen and told her "let's ga." JS advised she received no money for that day. also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the 'more you do more you get paid. JS advised that several weeks later she agreed to be taken a second time by Haley Once they arrived at the residence, aitobson sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to touch her buttocks. M I was wearing tight Jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and &n. attempted to touch her breasts., then became upset again and told Epstein she didn't want to be touched. discontinued thmage and was paid S200.00. . then went downstairs where for her. She told was waiting she wanted to leave. I said she never returned to the house. stated she is thaw that her friend, _____. : was also at the house and had a problem with Epstein. 1- 1 later researched :, dob IIMS and met with her at her residence. During a sworn taped statement, T• ' ' lowing, on or aboalmember 2004, she was approached at Royal Palm Beach High School by a fellow student M asked - ' ' if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm'Beach. She was brwht into the kitchen area of the house. She further stated that follow Royal Palm Beach High School students MI and ' .) came with them. They were brought into the kitchen where she was introduced to Epstein and other females. _ . : stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told' • Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. . " ' I further stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. .: . ' ' was certain that she stayed in her thong underwear. ' ' continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed hero this 1" day of May, 2006 by p t . who is ersonally known to me. State of Florida of Palm Be h Signatur g Officer Signature of Police Office (F.S.S. 117.10) Date: 0510 12006 Pagel of 22 EFTA00231458
A13 Probable Cause Affidavit Palm Beach Police Department Agency OWN FLO 500600 table, straddling Epstein to massage his back. While doing this ' was instructed to return to the ground at which time Epstein turned to ve his chest rubbed. : . ' ' : advised she was sure he was masturbating based on his band movements going up and down on his penis area. :... • ' did not want to look at his penis area because she was.uncomfortable. Epstein re v a ' ' was next to the mesas e table and turned it on. :..,..2L L. stated Epstein began . Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked 1_2. ' how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, •_. : was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Dct and I met withSdob at her residence. As. was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted . to cooperate and consented to the interview: During a sworn taped statement, . stated the following: at the age of sixteen,Aring the month of September 2004 she was approached by Haley Robson for a chance to make money. . was friends with associates of and knew the same people, en previously told by her end Royal Palm Beach High School, what did for Epstein. called a person known to as M fsi ifir and scheduled the appointment. picked El up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . Th entered the kitchen area of the house and met with Epstein.. was introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that white going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft mused. Mi exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area Epstein asked her to get comfortable. M advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly e massage, Epstein removed his towel and laid on the massage table naked. As M arca, he attempted to reach down her pan to touch her buttocks area however was unable to due due to the tightness of the jeans and a tight belt. advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this 1" day of May, .21106 by Det , who ispersonally. known to me. Signature of Police dicer .Ss. 111.10) State of Florida Date: 05/01/2006 Page8of 22 EFTA00231459
A14 Signature of Poli e Office (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency 01W FLO 500600 , attempted to reach up her tank top and touch her breasts. epulled back and Epstein stopped, howev-slie kept masturbating until he climaxed. He cleaned himself wi I he was previously wearing. I. was paid $200.00 for the massage and left the area. She met with who was' waiting in the kitchen area and left the house. then explained she never provided another massage for Epstein. She did however, go to the house with and 1-_______ ;77.....; as they took another friend of Robson's. . advised she was present when . : went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for 1. ' ' ,. . advised while they waited for L • ' the house chef prepared lunch for them as it 'l unchtime when they went. When L.... ' was finished with the mass they left the asked if ever told her what would be expected when she provided a massage.. stated y told her that a massage would be expecte ossibly naked and possibly some touching Involved. ll has no formal training in providinssnassages. . spoke about a third and last time she went to Epstein's house. Robson ye another girl, M, (sixteen years of age) who is. friend, to Epstein's house.. stated . knew that had made money massaging stein and wanted to e oney herself took them in the kitchen i area of the house and introduced to and took . upstairs to the main m. III advised she doesn't know what happened as did not speak about what happened in the room. received $100.00 from for going with her to pstein's house and recommending . On October 6, 2005, at 11:45 am, I met with -. . :, dob a, at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. ...::_,; stated she had previously spoken with . , L.7 .... ' . who told she was interviewed by detectives. During a sworn taped statement, , stated she knew that worked for Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom She met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two ybars. I asked her if she had formal training in providing massages, which stated she had not advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue. - . began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. • explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained The foregoing instrument was sworn to or affirmed before me this ln day of May, 2006 by Bet , who is personally known to me. State of Florida ach Signatur Ing Officer Date: 0510112006 Pagelof 22 EFTA00231460
A 1 5 Probable Cause Affidavit Palm Beach Police Department Agency OFUN FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "Jeff would try to get away with more and more on each massage". 2:: stateStein would try to touch her more and on one occasion he at tett to use a massager/vibrator on her. dmve to the house for the original massage. LC_ left her cell phone number and every ti e stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and re arc the massage table. 2.: advised stein would ask her questions about herself Epstein knew she was and would be attending . I asked : if Epstein knew her real age. ,.stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked - if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch ber breasts, she would pull away from hint and he would stop. ; was asked if he ev used a vibrator on her. . was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, who informed her that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up. informed ' she would have the car for a month. . stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is • currently parked next to the Gym field. 1 asked her if she ever took any one to the house. . • explained sit. len of hers who attended Royal Palm Beach High School, who has relocated to to attend college. I asked if she ever allowed another female in the room. . :advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of Lynn. University and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September I I, 2005, w/f dob la was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or iffirmed before me this I" day of May, 2006 by Det who is personally known to me. Signature of Pali e Officer (F.S.S. 117.1 State of Florida Date: 05/01/2006 Pagel0of 22 EFTA00231461
Signature of Police Officer (P.S.S. 117.10) A16 Probable Cause Affidavit Palm Beach Police Department Agency ORD tIA) soda) for misdemeanor possession of marijuana. During the atrest. told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls frcim Epstein's residence, discarded papers were found which contained AH's name and cell phone number. On October. 11, 2005, Det and I met with and obtained a sworn taped statement explained she had been going to Epstein' e since 2002, when she was sixteen years of age. Since then she us has gone to the house hundreds of times. stated she became his "number one girl." She explained that on jafirst visit she was brought to the house by fellow Royal Palm eac chool classmate, . said she was brought through the en area where she met for the first time. Ewes led to the master bedroom, Epstein s room. explained that as she was walkin up the stairs she observed several photographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom, where Sarah prepared the room by setting up the massage table and provided the oils for her to tub on Epstein. IN explained she remembered the steam room area, which contained two large showers. Epstein entered the to from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. IN removed her skid and kept her shirt on. Epstein then instructed her to remove her shirt. removed her shirt and remembered she was not wearing a bra. stated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet All advised he turned over onto his back. Epstein touched her breasts and be an to masturbate. Epsteth ejaculated which meant the 1118S At the conclusion of the massage, was paid 5200.00. They walked thgether downstairs where MIIIM and were waiting. stated ..... received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number, that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back Epstein would toll onto his back and allow her to massase his chest area. stated Epstein would then began to masturbate himself and at with his fingers. •ex lained Epstein the same time would taut this process until he ejaculated. He would then advised that during her frequent visits Epstein asked for her real age, stated she was sixteen. anyone II her real age. advised that thin escalated within the home as Epstein with his female friend . ■ explained the that Epstein had at his disposal. and masturbate himself . Occasionally, Epstein would then join in Epstein advised her no would instruct and pa included Epstein would watch them The (ongoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida County of Palm Beach SIgnatu g Officer Date: 05/01/2006 Pageljof 22 EFTA00231462
A17 Probable Cause Affidavit Palm Beach Police Department Agency ORD, FLO sonata during ii ale on female intercourse and provide oral sex to bothEland Marcinkova. This occurred during the time r was sixteen years of age. advised this continued to evtalate during two years. The routine became familiar to Il. Epstein's assistant i would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit ork for Epstein. Each timeisiething new was introduced, additional monies were produced and offered for to allow the acts to happen.. consented to perform all these acts but was adamant that there was an understanding with ein that no vaginal penetration would occ . An explained that Epstein's penis was deformed, . explained that his penis was oval shaped. claimed when tut called stein's penis "egg-shaped." . stated Epstein would photo ph Epstein's penis was erect, it was thick ward i the bottom but was thin and siiiiiiithe head and her and proudly display the photographs within the home. in which she provided a massage to Epstein, his•female friend, stated during one visit to Epstein's house was also present • provided the massage in which and her would fondle each others breasts and kiss for Epstein to en o . Towards the end of this massage, Epstein tttabbed and c upset over this. She said her bead was . She screamed "Not" and Epstein stopped. She told him that she did not want to . Epstein did not eSulate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. stated she knows he still displays her photographs through out the house. On October 12, 2005, Det and I met with . , dob who stated during a sworn taped statement, that nothing happened between her and Epstein. , appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. _ , stated on several occasions she provided a massage to Epstein. Sherstated she was brought to the Epstein house in March of 2005. , a classmate at Royal Palm Beach Hi t School, approached her and asked her if she wanted to "work". made the arrangements with Epstein's assistant. , -, who has no formal training in providing massages, stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for Epstein. He identified himself as "Paul". and inquired about the police investigation, and left his telephone number for additional contact. • provided no additional information, as it appeared her responses were almost scripted. The foregoing instrumisvas sworn to or affirmed before me this 1" day 2006 by Act who is personally known to me. Signature of Police Officer I.S.S. 117.10) State of Florida Date: 05/01/2006 Page I 3)f 22 EFTA00231463
A18 Probable Cause Affidavit Palm Beach Police Department . Agency ORIN PLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with dob-, at the Palm Beach Police Department. 1::. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, .:. • advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approached by a girl, _ .1_, who was dating ' roommate, for an opportunity to make some quick money. 7 ; advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by ... that the massage would have to be done in her underwear. She advised "2. :3 drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and introduced himself as "Jeff" At Epstein's direction, , and , ; removed their clothing down to their panties, Epstein laid on his stomach area and they provided a massage on his legs and feet area. I asked if she had any formal massage training and she replied "no." .... advised she was topless and the panties she wore were the boy shorts lace panties. She and: ' continued the massage until the last ten minutes of the massage, Epstein, told to leave the mom so that' could finish the massage. • got dressed, and left the room as Epstein turned over onto his back. Epstein then removed the towel and laid naked . Epstein requested that . rub his chest S. - -gated as she did this, Epstein, began masturbating. stated Epstein pulled down her boy short panties, and be produced a ler e white vibrator • She stated it was within his reach in a drawer in his master bathroom. advised he never penetrated her vagina with the vibrator. He continued to nib hei vagina with the vibrator as he continued to masturbate. stated she was very uncomfortable during the • incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he bad on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing = • and paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. -irovided her cellular telephone number. was asked if she was recently contacted about this investigation by m the Epstein organization. She replied she was called but it VMS for work. She e was called by for her to return to "work" for Epstein. stated "work" is the term used bslito provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7, 2005, Det Mt and I mct with dob During a sworn taped statement, _ . stated she met Jeffrey Epstein through when ey were still The foregoing instrument was sworn to or affirmed before me this l" day of May, 2006 by Det who is personally knolwn to me. Signature of Police dfficer (F.S.S. 117.40) State of Florida Date: 05/01/2006 tcer Page r3o f 22 EFTA00231464
Probable Cause Affidavit Palm Beach Police Department Agency ORTN FL O 500600 attending Royal Palm Beach High School. M I would approach females who wished to work for Epstein. • stated she was offered to work for Epstein but declined — - explained that "work" means give massages. She was asked about any formal training in providing massages which she said "no." • said she accompanied and other females who were taken to Epstein's house to provide massages. ' further stated she had been to the house approximate) 4 or 5 times in the past year. She accompanied with M, and. Each time the girls were taken over, they were previously told they woulJ have to provide a massage, possibly naked. They were also told that should Epstein require them to do anything extra, and they were not comfortable just to tell him and he would stop. . .• . stated received $200.00 for each gid she E> ght over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, who was really young, fifteen years old at the most. • further stated each time she went to the house, s e sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught hcr attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pin , I met with ,, dob , at the Palm Beach Police Department. During a sworn taped statemen , a classmate at Royal Palm Beach stated she had met Epstein approximately two ago when she was first approached by School. High approached her about working for Epstein and providing a massage to him for $200.00. bad made the arrangements however was unable to take her the day the arrangements were made. had take , . • also attended Royal Palm Beach High School and was familiar with Epstein. , recalled she was brow t there and entered through the back kitchen door. She had met with an assistant and another assistant . brought her upstairs as she observed several photographs of naked females throughout the house. ;fated Epstein came in the room, wearing only a towel, and laid on the table. stated he picked out the oils he wanted her to use and requested she remove her clothing to provide the massage. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedromn/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein e vibrator which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by Oct . , who is personally known to me. Signature of Police Offieer P.S.S. 31 -1 ) State of Florida Date: 05/01/2006 Pageitiof 22 EFTA00231465
A20 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 numerous times. added she has no formal training in providing a massage. - stated she brought two females during her visits to provide massages. stated she brought a girl named ".' ." and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with . ' — W/F, at the Palm Beach Police Department. During a sworn taped statement' had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as had asked her if she wanted to make money providing massages to Epstein. — had heard that seve girls from 11.2. I Palm Beach High School were doing this and making money. She agreed and was taken to the house by had introduced her to and Epstein and bra ht her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected. left the room and waited downstairs for her. - stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was paid $200.00 for providing the massage. She also stated was paid $200.00 by Epstein for bringing - - stated she had gone a total of 15 times to Epstein's residence to rovide a massage and things had escalated from just providing a masse e. stein be an touchin and grabbed her closer to him as he masturbated. Epstein also and with his bands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated and be an and climaxed onto the massage table. , received $350.00 for her massage. I asked her if she had any formal training in providing masse es : stated she did of . continued to state on one other occasion, Epstein introduced his girlfriend, into the massage. was brought into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as ' ions, Epstei.trodueed the large white vibrator/massager in the massage. Epstein on as she provided the massage. On November 14, 2005, Dct and I met with , deb . During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her until he reached the point of The foregoing instrument was sworn to or affirmed befo e e this 1" day of May, 2006 by Oct who is personally known to me. Signature of Police Meer .S.S. 117.10) State of Florida Con of Palm Beach Signatur Officer Date: 05/01/2006 Page igif 22 EFTA00231466
A21--- Probable Cause Affidavit Palm Beach Police Department Agency ORiM PLO 500600 • as gated • brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. , • said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". • stated she returned to the house and was again led upstairs by Sarah. She provided the massage, clothed. . . was asked if she ever removed her clothing to provide a massage. Sated it MS not until the third time that she went that she removed her clothing. stated she was notified by that Epstein wanted her to come to work. She arrived at the house and was led upstairs by =. She started providing the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She sta ed in her thong panties and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the mas stated she believed he climaxed based on his breathing. She did not want to view either the or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by MM. to come to the house and "work". stated she was now dating het current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for her Christmas bonus. Subpoena results from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. .. received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Pet. and f met with dob 04/21/1988. During a sworn taped statement, ■ stated she met Jeffrey pstein over a year ago. e was sixteen years of age and was approached by ' , , a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. ' had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed trek " day eilMay, 2006 by Co Palm Bench ' Det who is ersonally known to me. Signature of Poll... Officer .S.S. 117.10) State of Florida Signatu fieer Date: 05/01/2006 Pagekof 22 EFTA00231467
A22, Probable Cause Affidavit Palm Beach Police Department Agency ORD/ FLO S00600 massagetopless. — '. made the arrangements with Epstein and his assistants and took. to the house.. stated — ' and she entered through a glass door that led into a kitchen. She was taken upstairs by ........4 to a master bedroom. She recalled the master bathroom had a large pink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. . and : ' removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both - and . provided the massage on his legs, back and feet. Forty minutes into tl massage, Epstein turned over onto his back and requested . , wai wnstairs in the kitchen area for IMI. Epstein instructed . to finish the massage. As : . ' of dress startingLubbing Epstein's chest. left the room, and Epstein began masturbating as . M stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated 1 he turned the towel around that the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. pof dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the manage. . stated she was aware that also received monies for the same thing. The second time she went to the house she was again approached by ... advised if she wanted to return to the house tchgovide another massage.. agreed and the arrangements were made by for her to return to the house. M stated , - drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house by one of the staff members. . led her upstairs to the master bedroom and master bathroom area. :-. _. I. left . this time to do the message alone. Epstein entered the room again wearing only a towel. 5 began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as . began massy his legs and back. As . finished with Epstein's back and legs, Epstein then turned over onto his back. M started to rub his chest and he began masturbatin . As rubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began and masturbating himself at the same time. 5 stated she as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rnately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself. MD stated Epstein climaxed onto the towel again and informed her that the massage was done. got dressed li and met with : _ _ who was waiting in the kitchen area. She received $200.00 for the massage. said she never returned to the house and had no desire to return to the house. 1.was asked if she received any formal massage training. She advised she had no formal training. 5 was asked if Epstein knew her real age. 5 stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. The foregoing instrument was sworn to or affirmed before me this day of May, 2006 by Det who is personally known to me. Signature of Polict Officer (F.S.S. 117.10) State of Florida Co f Palm Beach Signs ng Officer Date: 0 i 1/2006 Paget? f 22 EFTA00231468
A23 Probable Cause Affidavit Palm Beach Police Department Arg.aey ORI# PLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo•Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the bed of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by who signed the bottom of messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's bard drive was reviewed which showed several images of and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det and I met with ML, dob . During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. stated it was before Christmas last af r (2004) when an associate, approached her and ed if she needed to make money for Christmas.. made arrangements to take to the house and drove to the house to "work." They were encountered by a white female with long blond hair.. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to .a master bedroom and bathroom. The massage table was already set up in the bathroom. NI described the bathroom as a large spacious bathroom with a steam room and shower beside it.. was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach so that . may The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by pet who is personally known to me. Signature of Police r fficer .S.S. 117.10) State of Florida Signatur ng Officer Date: 05 s /2006 Page ler 22 EFTA00231469
A24 Probable Cause Affidavit Palm Beach Police Department Agency 0RDI Ft O 500600 massage his feet and calves. ■ started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. ■ began rubbing his back and got to the small of his back. Durinhe rubbing of his back, Epstein asked her to gLcomfortable. He requested she remove her pants and shirt removed her shirt and pulled her pants off. stayed in her bra and thong panties. As she finished massaging the small of Epstein's back, be then turned onto his back. Epstein instructed ■ to rub his chest and pinch his nipples. As she began to rub his chest, Epstein asked her questions about herself I. remembered telling him she attended Royal Palm Beach High School. Epstein asked her if she was sexually active. Before could answer, he also asked what sexu a e enjoy. 1. stated she was shy and didn't like talking about those things. She continued . Epstein reached her bra from the front. ■ expl and asked her if she like having d a front snapping deviee, Epstein • said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to . He an touchin his nis and en touched tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside.". She further explained Epstein co utiful and sexy she was. Epstein then moved ber thong panties to one side "He commented how c." He then She tried pulling back to Epstein and apologized for Dining this time, he kept his and continued to rub her vagina. stated he ribbed her really hard as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table, Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to YT, for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her. again. Epstein stated his assistant w uld contact her to work again soon. I asked her if she ever received any formal massage training to which IN stated she did not. stated it was the only time she ever went to work for. and knew what happened to her was wrong. She further stated that she had never been contacted fir any additional work. On January 9, 2006, I located and interviewed another victim, dob was identified as a potential vietim/witness from information obtained during trash pulls from Epstein's residence. stated she met Eps • was fifteen years of age. She was approached by a friend from Royal Palm Beac High School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed befo e this 1" day of May, 2006 by Det , who is personally known to me. Signature of PoliceOfficer (F.S.S. 117.10) State of Florida Co ach Signatur mg Officer Date: 05 /2006 Pagcoof 22 EFTA00231470
A25 Probable Cause Affidavit Palm Beach Police Department Agency 0RO FLO 500600 lo model lingerie for a wealthy Palm Reacher.. was taken to Epstein's house 1 on lloWay. introduced . to Jeffrey Epstein. Epstein had hilarsonal chef prepare dinner foli dand . At the conclusion of dinner, and Epstein brought . upstairs into a master bedroom area. obs . large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed. that they were oing to provide a massage on Epstein N asked why were they doing this instead of modeling lingerie, explained to. that this was his routine and to rub his calves and feet. Epstein had told. to get comfortable. removed her pants and blouse. CL stated she stayed only in panties as she did not wear a bra that evening. stated while rubbing his calves and feet, Epstein turned ve his back. Epstein told. to rub his chest and rub his ni les. stated that as she started Epstein began masturbating himself. Epstein and with his fingers. LLstein continued to masturbate himself as he . Epstein ejaculated on his towel and paid . $200.00 for the massage. stein told. that if she told anyone what happened at his house that bad things could happen. and =I were brought home by Epstein's houseman and . was afraid that Epstein knew where she lived, stated that several days later she received a telephone call from who coordinatectfor . to return to "work," . returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the morn wearing only a towel. Epstein had remove her clothing and provide the massy e naked.. began rubbing his feet and calves and Epstein turned over onto his back Epstein with his forgers. E in be an to masturbate himself with an upwards and downward motion on his penis. Epstein continued with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel be was wearing, the massage was over.. was paid $200.00 for the massage. Epstein again told. not to speak of what happened at his house or bad things would happen.. wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victitn through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by , and made appointments for the female's to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the The foregoing instrument was sworn to or affirmed State of Florida before me this I" day of May, 2006 by Del , who is personally known to mo. Signa ur er Signature of Police Officer (F.S.S. 117.10) Date: 0 7 /2006 Pag5t pf 22 EFTA00231471
Uge Lilt LUAU 1V:.71 JoAatKituuu A26 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 300600 He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. it was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, • chauffeur, chef, houseman, run errands for Epstein and provide for Epstcin's guests. I asked Rodriguez about masseuses coining to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entr into the kitchen area and offer them something 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. 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 often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Polie Office .SS. 117.10) State of Florida C Signs tu f Palm Beach ng Officer Date: 05/01/2006 Page21of 22 EFTA00231472
A27 I I ' MUG JO/ c.cU Signature of Folic Officer (F.S.S. 117.10) Probable Cause /Affidavit Palm Beach Police Department Agency 010K FLO 500600 bed. On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach High School after AB high school drama performance. Also in that same note was direction to rent a car for. and direction to extend the rental contract During the course of the investigation, subpoenas were obtained for cell hone and home phone records from several victims and witnesses along with the cell phone records of An anal sis of these records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made arc consistent with the dates and times they % victims/witnesses stated they were contacted. Specificall , The phone records showed called during the exact times and dates wh victi advised the incident occurred. also coordinated the encounters with E, . stated they ocarred. and x , during the time frame the girls Pursuant to a lawful subpoena l obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were compared to the cell phone records of made to e victims were in the days just prior to their • ' g the time E stei This comparison found that all the phone calls was in Paint Beath in, who at the ti f 'dents was fifty one years of age, did have vaginal intercourse either lail or digitally with, and I _ ...., who were minors at the time this occurred, end who at the time of the incident was fi two ars of age, did use of SG, a fourteen year old minor. Therefore, as coordinated and aided in the recruitment of minors to frequent Epstein's house so that sexual services were provided to Epstein, scheduled the said minors to return to the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors, there is sufficient probable cause to charge with four counts of Principal in the I" degree Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1) , a second degree felony and there is sufficient probable cause to charge her with Lewd and lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The. foregoing instrument was sworn to or affirmed before me this I" day of May, 2006 by Oct , who is personally known to me. State of Florida Signet tang Officer Date: i /01/2006 Page2Lof 22 EFTA00231473
A28 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated July 23, 2006 v -v• le a eLgo.b•J 14. 01 UJJ ...EPSTEIN, JEFFREY ALIAS PLUME OVER tunics. O JACKET ft: 0338617 - -7 t 2006036744 NONE. SUndsy, July 23. 2006 20244 AM INCARCERATION DATEMLIE 07/23/2006 1:56 PRISONER TYPE LOCAL CHARGES DOB: 01/20/1953 WPA AGE 63 HEIGHT: BROM 53N: WEIGHT: 180 ADDRESS: 358 EL BRILLO WY A: 20080723017 SID ALIEN 0: FBI P: POUCH 1291 AFIS: U.S MARSHAL If: oust ARREST ADDRESS3228 GUN CLUB ROAD ARREST DATE: 07/23/2000 BKG. DATE 0723/2006 WARRANT/CASEO: 06009454CFA99 W ARREST WINGER: CASTILLO TRANS OFFICER: SELF SURRENDER :ASE TYPE: FELONY cite STATUTE COUNTSESCRIPTIOR PALM BEACH SHERIFFS OFFICE BOOKING CARD 0103.1.0C: MDC INTAKE 8103 ID*: 6199 MR COLOR GRY EVE COLOR Ku CRY: PALM BEACH STATE: FL ZIP: 33480 NCIC: DOC INCIDENT ft CITY: WPB STATE: in. ZIP: 33406 ARREST TIME 1:30 EKG. TIME 1:56 CURRENT BOND' $3,000.00 COURT DIVISION: T - MARX, KRISTA ARREST AGENCY: 01 • P/3130 TRANS. AGENCY: CASE RAG 796.01 22 (FT) 1 PROSTITUTION-OFFER COMMIT ENGAGE 3RD SUMO OFF 0 0 0 "SEALED INDICTMENT" NO INFORMATION GIVEN" SEALED INDICTMENT JUDGE KROLL 0 CTI) FELONY SOLICITATION OF PROSTITUTION (3F) 1OLDS: HOLD °AMENS HOLD BY: HOLD DEPT.: KID REILDATERNE: HOW RDA. BY: HOLD RE/4. DEPT: ALERT DESCRIPTION: ALERT NARRATIVE: VER 3 ALERTS: KEEP SEPARATE FROM: NONE VER 6 NAMES: SSIGNED HOUSING: NTA DATFJTIME: NTA LOC: CIC INTAKE: NCIC RELEASE: P.P.ENTERED: en' ARMS REU PHOTO ID: CIASSIPICATION: 11LID.O.EAR IN' ED. CLEAR Ate RELEASE MOVE: ?LEASE DATER1ME: . RELEASE INFORMATION: 3URT DATEMME: COURT LOCATION CLERK 0 WARRANTS D STATE Ally U CENTRAL RCOS 1] CLASS Ill EFTA00231474
A29 2006 Grand Jury Indictment of Felony Solicitation of Prostitution - Jeffrey E. Epstein [pp. A29-A301 us..rine...0W £4:J1 OvI.J.J41U4J 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 and 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 (96.07(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. Assistant State Attorney of the Fifteenth Judicial Circuit of the ' of Florida, prosecuting for the said Stale EFTA00231475
A30 GRAND JURY FOREPERSON DATE Jeffrey E. Epstein, Race: White, Sex: Male, OOB: January 20, 1953, Issue Warrant EFTA00231476
A31 Information for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 26, 2008 STATE OF FLORIDA vs. JEFFREY E EPSTEIN, W/M, 01/20/1953, IN THE CIRCUIT-COURT OF THE FIFTEENTH TUDICM CIRCUIT • IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION "W" (LB) OYCF 9 3P / MUSES FROM BOOKING NO.: 2006036744 / INFORhiATION FOR: 1) PROCURING PERSON UNDER 18 FOR PROSTITUION al r- - O m ==. (.4 In the Name and by Authority of the State of Florida: rOrTi 00 00 BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach Pfnty1Florida, by and through his undersigned Assistant State Attorney, charges that JEFFREY E EPSTEIN on or about or between the day of August in the year of our Lord Two Thousand and Four and October 9, 2005, did blowing!), and unlawfully procure for prostitution, or caused to be prostituted, gm a person under the age of 18 years, contrary to Florida Statute 796.03. (2 DEG FEL) P. O. FL. BAR NO. 0776726 Assistant State Attorney STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me, LANNA BELOHLAVEK Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being first duly sworn, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to asjae, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good M, and certifies that testimony under oath has been received from the material witness or wltnesgds for the off 7 Assistant State Attorney Dawes P'na Olutenatt 00120191 £10211 LB/dp • AUVLIIt 2, 2010 le1/4 KOCOMVIICIIMINOULWX .c FCIC REFERENCE NUMBERS: 1) FELONY SOLICITATION OF PROSTITUTION 3699 Sworn to and subscribed to before me thiatti4Lday ofJune, 2008. r(Intniu:O NOTARY PUBLIC, e of Pion a eifiA II IN 9 A noon EFTA00231477
A32 Guilty Plea for Felony Solicitation of Prostitution and Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 I Lame... PLEA in THE CIRCUrt COURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMEN1 Name: Jeffrey E. Epstein Plea: May _X Ca-re•S GITAtZi Count Lesser _11:.qtM 06CF009454AM8 Felony Solicitation of Prostrtution 1 No 3 FEL 08CF003381AM8 Procuring Person Under 18 for ProstRuflon 1 No 2 Fri PSI: Watvednibt Required _X RequIrechRequested kIL L±Dfl110M: Adjudicate [x J SENTENCE: On 06c80094.54AMEI, the Oeferadant Ls sentenced to 12 months in the Palm Beech County Detention Facility, with crecla fort (one) day tent served, On 08CFC09361AMB, the 13efendent in seirtnntaad to 6 morntniln the Patin Beach County Detention Facility, with credit for 1 (one) day time served. This 6 month sentence Is to he served consecutive to the 12 month sentence In 06CF0094S4AMEL Following thls 8 month sentence, the Defendant wit be placed on 12 months Community Control 1 (one). The cone/bens of community control are attached hereto and Incorporated Well. 0ThErt COMMENTS OR CtONDMONS: As a special conclAbn of his community control, the Defendant Is to have no 'ninon/heel contact with minors, and the supervhIng adult must be approved by the Depa.tient cf Correctlerns, The Defendant designated as a Sexual Offender pursuant to Fbrida Statute 943.0435 and must abide by al the corresponding requirements of the shrtuto, a copy of which trt attached hereto and incorporated herein. The Defendant must provide a DNA sample In court at the time of EFTA00231478
DA A33 Judgment for Procuring Person under 18 for Prostitution, dated June 30, 2008 04/26/2018 14:51 3553626 CIRCUIT CRIMINAL PAGE 06/20 ("HEQR NAL DIVISION OF THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA. IN AND FOR PALM ElEAC14 COUNTY CASE NO. OUTS Ha STATE OF FLORIDA f i ff-yey C r erft;n EFEN ANT RACE TH GENDER I I COMMUNITY CONTROL VIOLATOR II PROBATION VIOLATOR CPR 20080267252 OR BR 22760 PG 0565 RECORDED 97/17/2•08 eat 06s 42 Pali Bract County, Florida Sharon R. Bock, CLERK IL CORPTROLLER Pa 0565; (lpg) JUDGMENT The above Defendant being riersonally before this Court represented b I V V I J Having been tried and kund rainy of the following erime(sk tyl, Having entered a plea of guilty to the folios. ing crime(s): ( ) Having entered a plea of nolo contcsadero to the following erimc(s): 5.01/k atame COUNT ;Isr, f Iv o l fastAduk, OFFENSE STATUTE NtiMBER(S) 711/.0 DECREE ZDF >c I I and no cause having been shown why the Defendant should nor bc adjudicated guilty. IT IS ORDERED THAT the Defendant is hereby ADJUDICATED GUILTY of the shove erimeks. and 113%bIlS ban entitled or fond guilty of. or having entered n plea of nolo contenders or guiltyscrudksi of adjudication. to initnIptS ar orgenses relating to icnnal baticti Wt. 794). kwd and lascivious conduct (ch. 300). or manor (s. 78.1.0-1). aggravated Snug CA. 734.0.1 ). burglary (s. 31Ø.0P. catjaeking (s. 1313.1.131. or Mme imØsion fhhhCfy 613.1351. or any roha offense specified in"Section 943.325. the defendant shall he required to submit blood specimens. • I I and good Cann being shown. IT IS ORDERED THAT ADJUDICATION OF GUILT BE WITHHELp JUN 4 u SENTENCE I I The Court herds, stays and withholds IMPOShiOft of sentence al to auras' and Ones the Defendant art . • STAYED ) Probation andtfor I I Community Control under the supervision of the Dept of Carreeinik (conditions af probation set forth in separate order). SENTENCE DEFERRED I I The Court hereby deters impurites' of sentence until The Defendant in Open Coon was advised of his right to appeal from the Judgment by fling notice of Ciptlini with the Clerk of Court within thin) days Miming the date sentence is imposed or probation is mitered pursuant to this adjudication. The defendant was aka advised rif his tight to the af$1,1:111CC of maul In taking said appeal at the expense or the State upon showing of indigency. VE AND ORD D in Open Courtin Palette eh County. Florida. this 3 7) day tari-a.in.-4 . 200 ri flacon. enr rItT RIDGE. JUL U Pl3" EFTA00231479
A34 Sentence for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAC£ 07/20 IN THE CIRC.' COURT OF THE FIFTEENTH ALL CIRCUIT. IN AND FOR PALM BEACH COUNTY, FLORIDA SENTENCE (As to Count(s) ) DefendanDE Aey Ep 4?)-) Case NumbeCAUger 93314-14( °FITS Number The Defendant, being personally before this Coon, accompanied by the defendant's attorney of record, ‘Z -7 rankle< and having been adjudicated guilty herein, and the Court having given the Defendant an opportunity to be heard and to offer matters in mitigation of sentence, and to show cause why defendant should not be sentenced as provided by law, and no cause being shown, IT IS THE SENTENCE OF THE COURT that The Defendant pay a fine of $ pursuant to § , Florida Statutes, plus all costs and additional charges as outlined in the Order assessing additional charges, costs and fines as set forth in a separate order entered herein The Defendant is hereby committed to the custody of the I ',Department of Corrections (4 Sheriff of Palm Beach County, Florida ( J Depament of Corrections as a youthful offender for a term of (1t47O5 . It is further ordered that the Defendant shall be allowed a total of / days as credit for time incarcerated prior to imposition of this sentence. Eris further ordered that the composite term of all sentences imposed for the counts specified in the order {hall run ()(1 consecutive to ( J concurrent with (check one) the following: Any active sentence being served. JUN 3 y Specific sentences: arn forf - 77.70,90( In the event the above sentence is to the Department of Corrections. the Sheriff of Palm Beach County, Florida is hereby ordered and directed to deliver the Defendant to the Department of Corrections together with a copy of the Judgment and Sentence, and any other documents specified by Florida Statute. Additionally, pursuant to 4947.16(4), Florida Statutes, the Court retains jurisdiction over the Defendant. I 1 Pursuant to §§322.055, 322.056. 322.26. 322.274, Fla. Stat., the Department of Highway Safety and Motor Vehicles is directed to revoke the Defendant's pnvilcgc to drive. The Clerk of the Court is Ordered to report the conviction and revocation to the Department of Highway Safety and Motor Vehicles. Die defendant in Open Court was advised of the right to appeal from this Sentence by fi ling notice of appeal within .hirty days from this date with the Clerk of the Court. The Defendant was also advised of the right to the assistance of :ounsel in taking said appeal at the expense of the State upon showing of indigency. ()ONE AND ORDERED in Open Court at West Palm Beath, Palm . 2oe. diLA'4 h a -h County. rids thist y of Form Circuit 5 (rev 8/2000) n CIRCUIT COURT JUDGE . EFTA00231480
A35 Community Control Standard Conditions, dated June 30, 2008 (pp. A35-A46J 04/26/2010 14:51 3553626 PAGE 09/ 20 criactscr CRIMINAL Kama o *Lump nua yop sum. COMPLY WITH TEE FOLLOWINGSNDITIONS•OF SUPERVISE:) It. .• /. • • ci.4MUNITY CONTROL AINDAPD CONDMONS: • • You will remain confined to your residence except one but hour before and after you approved ounoloym„r, community service work. or any other activities approved by your probation officer. You will maintain an barfly ucouotiog of all your actiMties on a daily log which you will submit to your supervising officer upon :squad. • The Dedurnent of Carnations. may it its discretion, places you on Electronic Monitoring during the term of your Community Control. If placed on Mecum& Monitoriug, you will wear ► monitor et all times. y ou will maintain a private phone line, be financially responsible for any lost or damaged equipment and follow all rules and regulations as instracted. The telephone will be available within five working days of being platten Electronic Monitoring Program. • white on electronic monitoring you will remain confined to your residence and are prohibited from being outside the residential walls. : (d) If while being monitored and the monk* is found to have been tampered with you be taken into custody immedi fitly, if the officer determines that your were not at your schedules place of work or school while allowed to be outside the residence then in that event you Shall be taken into custody immediately. If taken into custody, you shall be held without bond and shall, on the next working day, brought before a ludee treat:ling over his or her cue for further ) If placed on Electrordc Monitoring you will pay to the Sam of Florida, for the east of Electronic Monitoring 31.00 per A'S•1 day, perFS. 946.09, ..1. De fencitAft. 4. (Asa be. fc Ci ' 4-:11 I. IT Way, • ; oln— (c) It CONDITIONS (a) Yon will submit to sod, unless otherwise waived, be fmancially responsible for drug testieg, urinalysis at least on a monthly basis, and counseling if dernird appropriate by your supervising officer. (b) You will eater and successfully complete a trothsesure or inpatient drug treatment program if deemed appropriate by yow officer. • (o) Yoe will comply with any curfew restrictions, confinement approved residence or travel istrictions' as instructed by your officer and approved by the Officer's Supervisor. sos•oFemmail-rmthwhime-e.et-mirierisr 51 you shall submit to amnia curfew from 10:00 PM to 6:00 AM . . (if the victim maunder the age of Ilyears) you shall not live within 1000 feet of a school, day care center. park, playgroand. or other place where children regularly congregate.. (C) you shall 'teat actively participate in. and succcssfuily complete isex offender rre rogram with a theapiit perticularly trained to treat sex offender. at probatiowa's or communitycontrolets . no shall Dothan any comet with the vialfaCdirectly or Indirectly. including through a third person, unless approaed by the victim, the thetapist and sentencing court . . . (if the victim was wader the ago of 18 years) you shall not, until you successfully auend end complete the sex offender progrini, have any utanpervirod contact with a child under the age of 18 years, ortled authorized by the sentencing court, without an adult present who is responsible Sr the child's welfare sad which adult has been advised of the crime • • and is approved by the sentencing court • . the victim was under the age of IS years) you shall not woik for pay or as a volunteer to any school, day care center, Irlefers-etheaadmindinalietiady—txrannempleyosuislad-by. a wk. playground, or other place where children regularly congregate. Re.- the enennui . or posses any obscene, pornographic or steamily stimulating Meal or auditory material, including telephone. t:l hn epahonucet view. . electronic media, computer programs or computer rate= that ire relevatto your deviant behavior patter° Yob shall submit two specimens of blOod to the FloridaDepartment of Lai Enfacement to be registered with the DNA ' (1) You Mall Make restitution to the victim as ordered by this court pursuant to P.S. 775.029 for all necessary medical and related prof:earnest service relating midis phYsical, psychiatric and psirs.hoiorical eve of the victim. You shall submit to a iclaantleSS search by your probation officer or community control officer of r5 moo t ) cal.:tun, or vehicle. . . , CO groAr••• 1/4 8.Jetfe 0 . Ddakdtah: 1- 413 k9- - - ca -4 -eiWi- te..) taft- L-Z 1 TfaelAS6O" -- ifieCCA 1 tit- a- rYt.i.A.;An. 1/41 An, b,!,.6- 11 ALS 6k- • tArCeek-• • y 0 Dtkn Qat*" 0 7 . laCref t- grill .4.1 Sejeq Ot ft Weld okji 61 -‘) ACn kaC471.41/ OA An.. nr./A Fe • EFTA00231481
A36 rt 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAGE 10/20 you shall submit to a mandatary curfew from 10:00 PM to 6:00 AM <if the victim was under the age of 18 years) you shall not live within 1000 feet of a school. day care center. park. playground, Or other place where children regularly congregate. (u) you shalt enter, actively participate in, and successfully complete a sex offender treatment program with a therapist particularly trained to treat sex Offender, at probationer's or community contrition expense (d) you Shall not have any contact with the victim, directly or indirectly, including through a third person, Unless approved by the victim. the therapist and sentencing court. (e) (if the victim was under the age of 18 years) you shall not. until you successfully attend and complete the scroffehder program, have any unsupervised contact with a child under age of 18 yeari, unless authorized by the sentencing ,.....--‘,.. court, Without an adult present who is responsible for the child's welfare and which adult has been advised of thecrimc • and is wproved by the sentencing court. . . VI 0 (if the Pedro was under the age of 18 years). yoti shall not work for pay or es a volunteer it any school, daycare center. park, playground, or other place where children regularly congregate. p (g) Unless otherwise indicated in the treatment plan provided by the sexual offender treatment program, you shall not view. 1• own, or posses any obscene, pornographic at sexually stimulating visual or auditory material, including telephone, electronic media, comptiter programs or computer services that are relevant to your deviant behavior patient. 1 (hi You shall submit two spite ens of bloodso the fltmida Data Bank. (1) ' You shall make restitution to-the victim as ordered by this court pursuant to F.S. 775.089 for all necessary medical and related professional. modem relating to the physical, psychiatric and psychological'cere of the victim. ‘ ---1' 6 ) You shall submit to a Warrantless search by your probation officer or community control officer of yens person, ------ resideaccor vehicle_ - -------WthrifiAl, as part of a treatment program. participate once/lance annually in polygraph examination to obtain information uncesary for risk management and treatment and to educe your denial mechanisms-. Your polygraph examinations must be conducted by a polygraphs trained specifically in the use of polygraph for monitoring Mx Offendeseattd It shall be paid by you. The results of the polygraph examination shall not be used as evidenced in court to prove that a violation .of coma:amity supervision occurred. . . You stall maintain a driving log, you shall not drive &Motor vehicle while alone without prior approval of your supervising officer. . . . . fug i, (if there was seXual contact) you shall submit to, at probationer's or community contralti's expense, an FEY test with . . the results to be released to the victim,. or the victim's parents or guardian. . • • You will not obtain or use a Post Office Box without the prior approval of the supervising officer. ( Yoti.will submit to electronic monitoring what deemed necessary by the community control or probation officer and his or her supervisor, and ordered by the court at the recommendation of the Department of Corrections.' . . • bet • 1/2.6 COURT RpsygRVBS THE RIGHT TO RESCIND, MODIFY, OR REWOR.E S ONE AND oRDORED AT West Pak:IIeach, Palm Beach County. Florida, this one Pro Tunic: .1211O05... lY int TO t•IT PROVIDED DY LAN 0. Honorable Sandra It McSorter Jod,gc; Circuit Court have received a copy of the terms and conditions of toy supervision. I have toad and understand these coedit:Tun n- agree to report to the Deportment of erections probation Office for further instructions. Also. I hereby consent to the disclosure of any alcohol and abase ratient roc •-di. the cooRdennality ( which is isssicopy regulated under 42CPR, Pod If, for the duration of my u Trion (:: 1 DATE UCTED BY EFTA00231482
A37 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAGE 11/20 S 948.101 Teen and conditions of community control and criminal quarantine community control — (1) The court shall determine the tams and conditions of community control. Conditions specified In this subsection do not require and pronouncernunt at the tine of sentoncing and may ba considered standard conditions of community control. at) The court shall require intensive supervision and unilateral for an offoridor placed into community control, which may include but Is not limit:rad to: I. Specified contact with the parole and probation officer. I. Cr:incitement to en agreed-upon roddonco during hours away from employment and public sonic* act:leftism 3. Mandatory public service. 4. Supervision by the Departnsast of Conatiuns by means of an electronic monitoring dovIca or system. 5. The standard conditions of probation set forth in s. 944.03. (b) For an eftander plead on criminal cperentine community control, the court shell coquina: 1. eloc-trordc monitoring 24 hours per day. 2. Cordirtement to a designated residence during declaimed hours. (2) The entameation of specific kinds of terms and condition does not prevent the court from adding thereto any other tarn or conditions that the court considers proper. flowervor, the sentencing court may only Immo a condition of supervision allowing an offondor convicted of 5. 794.011 L 800.04 s. 127.071 or s. 847.0145 to reside In another state If the ardor stipulates that it Is contingent upon the approved of the readying Mate Intorstato compact authority. The coat may ,.scrod or modify at any time the term and conditions thasitoforo imposod by It upon the offondur in carrimunity motel. fioWenter. If the court withholds adjudication of guilt or Imposes it period of incur rotation as a condition of community control, the period may not woad 364 days, and Incarceration shell be restricted to a county a probation and restitution cants under the jurisdiction of the Department of Corrections, a Probation Program drug punishment phase I seams residential troebnont institution, or a commtmity reside stial facility owned or opureted by any entity isivvidire such services. 13) The court may place a defendant who is being sweated for criminal transmission of MN in violation of s. 775.0177 on criminal quarantine community rtwitml. The Department of Corrections shaU develop and administer a criminal quarantine community control program emPhadoing intombe supervision with 24-frotr per-day electronic monitoring. Criminal Tarantino caMintrilty control status roust InTcludo cured Lance and may Include oder measures normally ainectotrad with community control, except that specific comfitions necessary to monitor this population may be ordered. EFTA00231483
A38 04/2E/2010 14:51 3553626 • CIRCUIT CRIMINAL PAGE 12/20 '943.0414 Sexual &ganders required to rimester with this department penalty-.. (1) As used in this section, tho tarm: (a)l. 'Sexual %Wonder moans a parson who moots tho criteria In sub-subparagraph a., sub- subparagraph b., sub-subparagraph c., ar sub-subparagraph d., as follows: a.(1) ties been conslctad of committing, or attempting, soliciting, a conspiring to commit, any of the criminal offenses proscribed In the following statutes In this stet* or similar ottoman in anottmer jurisdiction: s. 787.01, s 787.02, ors 787.025(2)(I, whore the victim Is st minor and the doh: meant fs not the victim's parent or guardian; s. 794.011 *selecting 1. 794.011(10); s. 794.05; s. 796.03• s. 796.035' s. 800.04; s. 825.1025; s. 877.071* t. 847.0133* s. 847:0i 35, oncluding s. 847.0135(4); s. 847.0137- s. 847.01387s. 847.0145- or s. 485.701(0; or any similar offense committed in this slate which has bean redesignated from a forme statute number to ono of those listed in this sob-subssubssieregraph; and ibm bean rotamed on or after October 1, 1997, from the sanction Imposed for any conviction of an offense described In subsub-subparagraph (I). For purposes of sub-stels- subparagraph (i), le sanction imposed In this stets or in any other jurisdiction includes, but is not limited to, a fine, probation, community control, payola, conditional release, control redeem, or Incarceration in a state prison, foderal prison, private corroctionel facility, or local detention facility; b. establishes: or maintains a renderco in this state and who has rot ban designated as a awed predator by a court of this state but who has bean delis/noted as a sexual predator, as a "mouelly distant predator, or by another seined offend& designation In enothor states or jUirildiction and was, as a mutt of such designation, subjactod to raghtration or community nr public notification, or both, or would be if de person were a resident of that state or jurisdiction, without regard to whathar the parson others/due meets the criteria for registration as a sexual offlinelor; c. estabtishin or maintains a residence in this state who Is In the custody a control of, or under the supervision of, any other stater or jurisdlcdon as a result of a conviction for committing, ar attenptIne, soliciting, ar conspiring to commis, any of the criminal offenses proscribed In the following statutes or similar efforts, In another jurisdiction; s. 787.01, s. 787.M m. s. 787377.5(2)(c), whin the victim fs • minx and the defendant Is nohvctim's ~ant or guanfing s 794.011, excluding s. 794.011(10); s. 794.05 t 796.03; s 796.035. s. 800.04; s. 825.1025- s. 027.071' s. 847.013). s. 847.0135, excluding s. 847.0135(4); t. 847.til37; s. 847.01311; s. 847.0145' ors. 985.70111h or any similar &ferns committed in this stato which has boon nedaiignebed from a forme statute number to one of those flood In this suk-subnatier•Ph; or d. On or after July 1, 2007, het been adjudicated delinqu a for committing, attempting, soliciting, or conspiri commis, any of the criminal offense[ proscribed in the following statutes in this state or tnflar offenses in another jurisdiction whim the juvenile was 14 years of age or older at the time of tun offers.: (I) Section 794.011, excluding s. 794.011( I 01; (11) Section 8(flp411)ib) whore the victim is under 12 years of ago or wiser* the) court finds sexual activity by the use of force or coercion; fill) Section 800.04(5)(c)1. when the court finds molestation involving unclothed gonna EFTA00231484
A39 04/26/2010 14:51 3.55:1626 I CIRCUIT CRIMINAL PAGE 13/20 (IV) Section 800.O4(5)(d) whom the colas finds the too of force or coercion and unclothed genitals 2. Inc all qualifying offonsos listed in sub-subparagraph )(a ltd., the court shall make a written finding of the ago of the ofTsndor et the time of the, °thort s'. fa each violation of a qualifying offoma Listed In this subsection, the court shall make a written finding of the ago of the victim at the lima of tho offense. for a violation of t. 800.04(4), the coirt 31.41 additionally make a writton finding indicating that the offo■ did or did riot imolso son* activity and Indkating that the offense did or did not involve force or coercion. For a violation of s. 300.04(9, tho court shall additionally make a *Titian finding that the offense did or did not Imolae unclothed genitals or genital aro, and that the offense did or did not involve the uses of force or coercion. (b) 'Convicted" moron that than has boon a datormination of silt al a rosult of a trial or the orrery of a plea of guilty or nolo contoortona, niggard's'. of whothar adjudication is withheld, and includn an aditofication of definquoncy of a "uvanila as specified In this 'action. Conviction of a similar off ine' includes, but Is not limited to, a conviction by a federal or military trIbtrud, Including courts-martial conducted by the Aimed Forces of the United Staten, and Includes a conviction or entry of a plea of guilty or nolo contender* resulting in a sanction in any state of the United States or other jurisdiction. A sanction Includes, but is not limited to, a fine, probation, cormunity control, parole, conditional release, control release, or incarceration Ina state prison, federal prison, private correctional facility, or tote detention (c) 'Permanent residence- and "temporary residence have the carne moaning ascribed /7S.21_. (ct) institution of higher( education .mans a trainer coated, cOMMunity collogo, college, state university. 0: indopondere postsecondary institution. (o) 'Chicly in onnsitITIOnt or employment Sinful- moans the commencement or termination of urnaltrant or ornplaymont, ore choir in location of ortroliment of oloplornOnt. (f) -Lloctrnitic mall address" ha the same rnocurirg as provided fn s. 668.602. (g) instant message roamer morn an idardifior that allows a person, communicate to tool time with anothor panon using the Intornot. (2) A sexual offorrior (a) Racal in parson at the sheriffs officer 1. In the county in which the offender ostablIchen ti maintains a permanent or temporary residence within AS hours a. Establishing permanent or tompantry resitionso in this state; or b. tong released from tho custody, control, or lurarrvislon of the Onpartment of Corrections or from the custody of a private torrortional facility; or 2 In the county whore be or the was ronvictod within VI hOlitt after being convicted for a qualifying offense for agistration undue tilts toction if the offender fs not In the rottotly or EFTA00231485










































