—_ oO ODN OOO Fw ON —_ > WwW NY ~0929104. TXT 119 THE WITNESS: Yeah. BY MR. TEIN: Q. And your father filed a lawsuit, the first lawsuit for fifty million dollars against Mr. Epstein without consulting you, correct? Q. And your father had a lawyer file the first fawsuit on your behalf for fifty million dollars against Mr. Epstein without your knowledge, correct? A. Correct. Q. And you don't trust your father, do you? A. Correct. Q. And you believe he’s trying to manipulate you for his own gain, don't you? A. Sort of. Q. Well, you know that your mother filed a statement, an affidavit, saying that you don't trust your father and that you believe he's trying to manipulate you for his own gain; isn't that correct? A. Correct. Q. You agree with that statement, don't you? A. Uh-huh. Yes. Q. Do you trust your stepmother? A. My stepmother, no. Q. You think she's also trying to steal your 120 Epstein lawsuit money away from you, don't you? A. | would like to clarify something. You keep saying my Epstein lawsuit money. | don't have any money, and it's just a lawsuit at the moment. So | just Page 102 HOUSE_OVERSIGHT_012497
~0929104. TXT 5 don't trust her. 6 Q. Okay. You think that your stepmother is 7 ~=trying to take advantage of this lawsuit to try to get 8 money from Mr. Epstein that belongs to you, right? 9 A. Yes. 0 Q. Did your stepmother tel! you why she was 11 arrested? 12 A. No. 13 Q. Did your stepmother tell you that she's 14 ever been arrested? 15 A. No. 16 Q. Did she tell you she was arrested for 17. ~~ «~fraud? 18 A. Never. 19 Q. Did she tell you that she was fired from 0 21 A. No. 22 Q. Did she tell you that whe was fired from 23 £0" stealing? 24 A. No. 25 MR. TEIN: Let's take a break. 121 1 (Thereupon, a recess was taken.) BY MR. TEIN: Page 103 HOUSE_OVERSIGHT_012498
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO oO Oo VN OD HN BF WwW NN ~0929104. TXT A. Two. Q. How old were they? A. Zack JJ being one year older than me, and then the other person was two years older than me. Q. What was his name? A. Ryan | Q. How old were you when you first had sexual intercourse? Q. How many -- before you met Epstein, how many different men had you had any type of sexual activity with? Q. Are you saying you never kissed a man other than those two? MR. LEOPOLD: Objection to the form of the question. 122 THE WITNESS: Yes, | had kissed people before. BY MR. TEIN: Q. Before you met Epstein, had you ever had oral sex? A. No. Q. Ever in your Jife, have you exchanged sex for something of value? A. No. MR. TEIN: We're done. THE WITNESS: Oh, okay. MR. LEOPOLD: We'll read. MS. BELOHLAVEK: | don’t have any Page 104 HOUSE_OVERSIGHT_012499
O™ 14 15 16 17 18 19 20 21 22 23 24 25 — oO Oo Oo SI ODO oO Be WwW FH ~0929104. TXT questions. Thank you. MR. LEOPOLD: Before we go off the record, it's my understanding -- Mr. Goldberger can correct the record, but we have stipulated that color copies of the documents that were identified for identification certainly will be attached to the deposition and counsel! will be taking the photographs across street so that they can be laser color copied so that we have a copy, and I'm assuming he'!l1 get a copy to the court reporter, too, to attach, actually a certified copy to the deposition. MR. GOLDBERGER: Done. MR. LEOPOLD: That's if you agree to that. If not, then | want to pull each one out and put exhibit labels on them, which we should do before we leave. MR. GOLDBERGER: We're not going to do either. I'll have copies sent to the court reporter and she can attach them to the deposition. MR. LEOPOLD: So you're not going to agree to what we talked about during the break then. MR. GOLDBERGER: I'm not quite sure what your asking me to do. Let me finish. MR. LEOPOLD: Okay. Sure. That's fine. MR. GOLDBERGER: Okay. If you want me to go over to Ms. Belohlavek's office and make copies and then I'll give those to the court reporter, Page 105 HOUSE_OVERSIGHT_012500
18 19 20 21 22 23 24 25 ol o Oo ON OD oO Fe WY PY ~0929104. TXT fine. Al! I'm saying is that | would avoid that process. | would send copies to the court reporter. But if it will make you happier -- MR. LEOPOLD: I'm not? MR. GOLDBERGER: Let me finish. MR. LEOPOLD: I'm not interrupting now. MR. GOLDBERGER: But if it will make you happier if | go over to Ms. Belohlavek's office 124 and make a copy of those photos that were part of this deposition and then |'1I!t give them to the court reporter, I'l! be happy to do it. MR. LEOPOLD: | trust you implicitly, however you with to do it. However, the documents, before they leave this room, need to have an exhibit sticky on them with the appropriate -- MR. GOLDBERGER: Want to go get some? We don't have any. MR. LEOPOLD: 1 will do that. Excuse me. Let me finish the record, please. You can't do that to the court reporter. She's going to stroke out. You can’t do that. You have to let me -- MR. TEIN: Finish your sentence, Ted. You are the most long-winded lawyer I've ever seen in my life. Finish your sentence. MR. LEOPOLD: Jack, tell him not to raise his voice, please. MR. TEIN: Finish your sentence. Is there going to be a period at the end of the sentence or is it just going to be comma after comma after Page 106 HOUSE_OVERSIGHT_012501
-_ 23 24 25 = oo Oo OA NN OO on BR WB PLY ~0929104.TXT comma? Go ahead, lawyer. MR. LEOPOLD: All right. The exhibits, | 125 can't prevent you from taking them, but | wil! object and | will be bringing. it to the court for sanctions. You cannot take the exhibits out of the room without them being marked. | want them marked, because you cannot identify in the record what was used. And with all due respect to Mr. Goldberger, | do not -- the way this deposition is going, | do not want to rely on Counsel from Miami to mark the appropriate exhibits. | will not do that. Jt cannot prevent you from taking them. But if you do, | will be bringing the matter to the court with appropriate sanctions, because that is improper. That is improper. When you use something in a deposition, they are to be marked. And you have refused to do that throughout for what ever reason. MR. TEIN: You're wrong. Finish your sentence because you're talking about something you have no idea. Every single one is marked, Ted. Every single one is already marked. But you want to argue about everything. Ever single one is already marked. Isn't that silly, Ted? MR. GOLDBERGER: Thirty years of doing this and | have never had an argument over this. Page 107 HOUSE_OVERSIGHT_012502
— oo Oo WD NY ODO oO BP WwW NN &k WwW DM ~0929104.TXT 126 MR. TEIN: You've made -- Ted, you are obstructionist, you are a liar. You have lied and misrepresented things, for the record. You are grandstanding. MR. LEOPOLD: You need to back up. MR. TEIN: No, no. I'm going to finish. MR. LEOPOLD: You can finish, but don't hover over me. MR. TEIN: No one is hovering over you. Stop trying to make a lying record. Let me say something else. Don’t you dare threaten me with sanctions, after you lied in a letter to my co-counsel about the fact -- be quiet. Be quiet and let me finish. You lied in a letter to my co-counsel, Mr. Leopold, in which you said -- it was a complete and utter lie -- that you were unavaifable this morning because you had a hearing. That was a lie. | have never seen each lawyer deign to do something like that. So you will get the ex -- be quiet. Let me finish. You behave. MR. LEOPOLD: Don't point your finger at me. MR. TEIN: Listen. Be quiet and | won't 127 have a need to point it at you. MR. LEOPOLD: Don't point your finger at -- MR. TEIN: Mr. Leopold -- MR. LEOPOLD: Don't point your finger at Page 108 HOUSE_OVERSIGHT_012503
— on Oo on FF WwW DY ~0929104. TXT me. MR. TEIN: Mr. Leopold, let me finish. MR. LEOPOLD: Don't raise your voice either. MR. TEIN: Mr. Leopold -- MR. LEOPOLD: Jack, do you want to take care of this? MR. TEIN: Let me finish my sentence. The exhibits are marked. We are walking out of here. You are someone who misrepresents the record. It is absolutely atrocious what you do. That is not how a lawyer should behave. This deposition is over. You will get your exhibits, Mr. Leopold. MR. GOLDBERGER: | understand what you're saying, Michael, and | understand Ted's position. Just so there's -- we're going to have tots offer issues in this case. We're going to have lots of reasons to disagree. I'm going to take it over now and 1|'m going to make copies and I'm going to give them to 128 Ms. Consor. If you want to go find some exhibit labels and put some exhibit labels on it, be my guest. But that's what I'm offering to do. THE WITNESS: Let me say two things, because | am happy to always disagree and with you, | have no problem; we could always do it professionally. | want to say two things so the record is Page 109 HOUSE_OVERSIGHT_012504
oo 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO OO OD NN OD oO FF WwW YN ~0929104 .TXT very clear. Since for whatever reason | have not been able to look at exhibits because they have been refused to have been shown to me -- MR. TEIN: That's a lie. MR. LEOPOLD: Jack, if you represent that the documents have the appropriate exhibit numbers or some identifying markings, 25, 30.000, whatever they may be, then you can take them, make copies, send me a copy, make sure the court reporter gets a copy and then send me a bill for my copy, that's fine. | didn't know that they are marked that way because | haven't been able to look at them. MR. GOLDBERGER: They are barcoded and the number that we've made reference to in the deposition coincides with the barcoding. MR. LEOPOLD: That's fine. Eight by eleven color laser copies are fine. 129 MS. BELOHLAVEK: The State Attorneys Office iS not going to charge anybody for color copies | print out. MR. LEOPOLD: That's fine. He's going to take them back to his office . Secondly -- and | will be more than happy to do it, because it sounds !ike you all know more about it than |, but |'m happy to get affidavits from Mr. Pincus, Judge Stern, everybody else about what happened with this hearing today, because | know very [ittle about it. But my representations are what they are. MR. GOLDBERGER: They stay -- Page 110 HOUSE_OVERSIGHT_012505
14 15 16 17 18 19 20 21 22 23 24 25 —_ oo oOo OD SN OD oO F WwW ED ~0929104. TXT MR. LEOPOLD: Let me just finish for the record. Representations or comments about what happened, representation about this hearing this morning, | know very little about it. I -- MR. GOLDBERGER: !'11 take your word on that. MR. LEOPOLD: No, no, no. I! just put it on the record. | will get an affidavit -- I'm assuming it sounds like you need it -- from Mr. Pincus. | have no clue about what happened and why it was canceled. All | was told when | was 130 out of town yesterday was that the hearing this morning was cancelled. MR. GOLDBERGER: I’!] take your word for MR. LEOPOLD: If you want an affidavit, I'tl get it for you. MR. GOLDBERGER: It's a personal issue for me because | had to disrupt a vacation and if it was done just because it wasn't convenient for you, then i'm offended by that. But if you're telling me that it was planned and it didn't happen, |'!f take your word for it. MR. LEOPOLD: | am more than happy to get you an affidavit, because | don't know the reason why it was canceled other than the fact that I'm assuming since my deposition was taken for four hours on Monday for preparation for the hearing Page 111 HOUSE_OVERSIGHT_012506
18 19 20 21 22 23 24 25 —_ o oO An OD ao BF WwW DN ~0929104 . TXT today, for whatever reason it was canceled, | am told it is being re-noticed. Why it was canceled 1 have no idea, but if your co-counse! wishes an affidavit to that effect from Mr. Pincus, |'m more than happy to get it. But | don’t know the reason why it was canceled. MR. TEIN: | don't need it. But what | do take issue with is regardless of why it was 131 canceled, you owed us the courtesy of saying, you know what? We can start earlier this morning. MR. LEOPOLD: | owe you nothing. MR. TEIN: {! don't care. Don't interrupt me. Because Jack canceled his vacation plans because of you. MR. GOLDBERGER: That's all right, that's all right. MR. TEIN: And you're selfish. And this deposition is over. Good-by Mr. Leopold. MR. GOLDBERGER: You can go off the record. Page 112 HOUSE_OVERSIGHT_012507
23 24 25 —_ oO Oo ON ODO ON eR WwW DY ~0929104. TXT 132 CERTIFICATE The State of Florida, ) County of Palm Beach. ) | hereby certify that | have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of _ , 2008. Page 113 HOUSE_OVERSIGHT_012508
oo — oOo ON DH F&F WN = b WwW WN ~0929104 . TXT 133 DATE: [!MONTH2] DATE2, 2008 X X X, Florida X IN RE: CASENAME CASE NO.: 2006 CFOS454AXX Please take notice that on Wednesday, the DATE1 of [!MONTH1], 2008, you gave your deposition in the above-referred matter. At that time, you did not waive signature. It is now necessary that you sign your deposition. “ Please call our office at the below-listed number to schedule an appointment between the hours of 9:00 a.m. and 4:30 p.m., Monday through Friday. “As a professional courtesy, I am enclosing a condensed copy of your deposition transcript. a As previously agreed to, the transcript will be furnished to you through your counsel. Please read the following instructions: At Page * of the transcript, you will find an errata sheet. AS you read your deposition, any changes or corrections that you wish to make should be noted on the errata sheet, citing page and line number of said change. DO NOT write on the transcript itself. Once you have read the transcript and noted any changes, be sure to sign and date the errata sheet and return these pages. You need not return the entire transcript. If you do not read and sign the deposition within a reasonable time, the original, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your signature, sign your name in the blank at the bottom of this letter and return it to us. Very truly yours, Judith F. Consor, FPR Consor & Associates Reporting and Transcription 1655 Palm Beach Lakes Boulevard, Suite 500 West Palm Beach, Florida 33401 | do hereby waive my signature: SAIGE GONZALEZ 134 ce via transcript: JACK A. GOLDBERGER, Esquire LANNA BELOHKLAVEK, Esquire MICHAEL R. TEIN, Esquire file copy Page 114 HOUSE_OVERSIGHT_012509
oO nt mn ao PF WwW DH ~0929104. TXT 135 ERRATA SHEET IN RE: CASENAME DEPOS|TION OF: [MM = TAKEN: [!MoNTH1] DATE1, 2008 DO NOT WRITE ON keene - ENTER CHANGES HERE PAGE # LINE # CHAN REASON Page 115 HOUSE_OVERSIGHT_012510
am 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO Oo Oo 4 DO oO BF WwW NW ~0929104. TXT Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. Under penalty of perjury, | declare that | have read my rITYPEY and that it 1s true and correct subject to any changes in form or substance entered here. DATE: SIGNATURE OF DEPONENT: 136 THE STATE OF FLORIDA, ) COUNTY OF PALM BEACH. ) 1, the undersigned authority, certify that EE Dersona! ly appeared before me on the DATE1 of [!MONTH1], 2008 and was duly sworn. WITNESS my hand and official seal this DATE2 day of [!MONTH2], 2008. Page 116 HOUSE_OVERSIGHT_012511
—_, 14 15 16 17 18 19 20 21 22 23 24 25 oc O@ ODO NN DO oO FPF W DY = re a rn On Oo a DO oO BP W NY = ~0929104. TXT Judith F. Consor, FPR Notary Public - State of Florida CERTIFICATE The State Of Florida, ) County Of Palm Beach. ) |, Judith F. Consor, Court Reporter and Notary Public in and for the State of Florida at large, do hereby certify that | was authorized t stenographically report the [!TYPE] of that a review of the rranscr ipt was not requested; and that the foregoing pages, numbered from 1 to *, inclusive, are a true and correct transcription of my stenographic notes of said [!TYPE]. | further certify that said [!TYPE] was taken at the time and place hereinabove set forth and that the taking of said [!TYPE] was commenced and completed as hereinabove set out. | further certify that | am not an attorney or counsel of any of the parties, nor am ! a relative or employee of any attorney or counsel of party connected with the action, nor am | financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by an means unless under the direct control and/or direction of the certifying reporter. DATED this DATE2 day of [!MONTH2], 2008. Page 117 HOUSE_OVERSIGHT_012512
a \ 18 19 20 21 22 23 24 25 ~0929104. TXT Judith F. Consor, Court Reporter Florida Professional Reporter Page 118 HOUSE_OVERSIGHT_012513
TAB 14 HOUSE_OVERSIGHT_012514
nsor & Associates : Reporting and Transsalgtiea, Ja. THE STATE OF FLORIDA, COUNTY OF PALM BEACH, JEFFREY EPSTEIN. / SWORN STATEMENT rh! Friday, March 21, 2008 4:00 p.m. - 4:20 p.m. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 Reported By: Judith F. Consor, FPR Notary Public, State of Florida Consor & Associates Reporting and Transcription West Palm Beach Office Phone — 561.682.0905 HOUSE_OVERSIGHT_012515
nsor & Associates Baporing and Transcription, Ins. APPEARANCES: On behalf of the Defendant: JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 WEST PALM BEACH, FLORIDA 33401 561.659.8300 ALSO PRESENT LILLY ANN SANCHEZ, ESQ. FOWLER WHITE, ATTORNEYS AT LAW HOUSE_OVERSIGHT_012516
ssor & Associate ' Reporting and Transeription, inv. Page 3 Statement taken before Judith F. Consor, Court Revorter and Notary Public in and for the State of Florida at Large, in the above cause. Thereupon, having been first duly sworn or affirmed, was examined and stated as follows: THE WITNESS: BY MR. GOLDBERGER: Q. Would you state your name for the record, Okay. po where do you live now? Address? Sure, Q. Do you Live there alone or do you live with somebody there? A. My father. Q. Very good. And are you working now or not working? Sometimes you work and sometimes you don’t? A, When I want to. Okay. And how old are you today? HOUSE_OVERSIGHT_012517
sor & Associates ‘Reporting and Transesiptics, Ins. Twenty-one. Very good. What we're going to do today is we're going to take what's know as a sworn statement from you. And | my court reporter just put you under oath. So ail I want you to do is tell the absolute truth today. d A. Right. i Q. I don't want you to color what you're saying in any way. Really, the only thing that will be of any use to anyone is if you just tell the absolute truth. ; : C 2 < Right. : ~ F So those are the instructions, okay? A. Okay. Q. All right. And sometimes -- I've been : doing this for a lot of years and sometimes I talk like a lawyer too much, and if you don't understand what I'm -- As That's your job. 5 Q. I guess. But if you don't understand what I'm saying at some point, just say, "Jack, say it in English," and I'll make it better for you. Okay? A. Okay. QO. So tell me how you First met Jeffrey ql HOUSE_OVERSIGHT_012518
o~ nsor & Associates Reporting and Transeuptioa, ine. Page 5 : And | ES a frienc of yours at the A. Yes. Q. Okay. And tell me a little bit about the introduction, how PR introduced you to Jeffrey. Okay. So let's break that down a little She toid you you could go over there to Jeffrey Epstein's hovse and give a massage? A. Right. Q. When she said go give a massage did she tell you what she meant by that? A. Just are -- no. Just a massage. She didn't really give me any details. Q. Okay. Let me ask it to you another way. A. Okay. Ou Was there any suggestion that what you were being offered the opportunity to do would be sexual in any way? HOUSE_OVERSIGHT_012519
sor & Associates Reporting and Treseription, Ine. ToDo Page 6 Q. Okay. So as far as you understood it and as far as what told you, you would be going over to Mr. Epstein's house and just giving him a normal therapeutic massage? A. Right. Q. Okay. And I assume Ji 010 you you would be paid for it? i A, Yes. ; 0. Did she tell you how much you would be : Rx Yes. Two hundred. Q. Okay. When was the first time that you went to Jeffrey Epstein's house? Was it after you spoke to Alex? A. Yes. Q. Okay. And the first time that you went to Mr. Epstein’s house, that was in response im talking to you in person. In other words, she said -- avernp rae you saw her somewhere, be it at the store that you worked at or around the neighborhood, she said to you in person, "Do you want to go over to Jeffrey Epstein's house?” Right? HOUSE_OVERSIGHT_012520
msor & Associates * Reporting and Trensexipticn, Ine. 0. And I take it you said okay and you went over there? A, Yes. Qs All right. Now at the time that you went over there, you were not yet 18, but you were almost 18? A. Yes. Q. You were within a couple of months of being 18 years old? A, Yes, I do believe so. Q. Okay. And what dic re you about if asked, how old you should tell anyone you were when you went over to his house? Was that a bad question? A. Repeat that. HOUSE_OVERSIGHT_012521
Snsor & Associates ” Reporting and Trenscziption, inc, Page 8 : Before you went cver to Jeffrey's house after you net ii in person, did she tell you if anyone asked you how old you were, how old you were supposed to Say you were? A. Q. She didn't give you a script and say as soon as you walk in the house you're supposed to say, "I'm 18," right? A. No. Q. And I assume if you were asked, you wanted to be convincing that you were cver the age of 18, because you wanted to do the work, right? A, Right. QO. By the way, were you ever asked? Eventually. Okay. A. Not the first day, I don't believe. Q. Okay. Was it Jeffrey or someone else that asked you whether you were over the age of 18? HOUSE_OVERSIGHT_012522
nsor & Associates " Reporting and Transcription, (ae. Page 9 Bre It was probably Jeffrey. I don't remember very clearly. Q. A. Yes. Q. Okay. Now the first time that you went to Jeffrey's house did you give him a massage that day? A. Uh-huh. MS, SANCHEZ: Answer yes or no so the record is clear. THE WITNESS: Yes. Okay. (Discussion keld off the record.) BY MR. GOLDBERGER: Q. Okay. So you go to Jeffrey's house and you meet him and you're going to do a massage that day, right? HOUSE_OVERSIGHT_012523
sor & Associates * Reporting aod Transsrigies, Jas, QO. one offered you any drugs to do a massage? A. Q. one offered you any alcohol to doa message? A. HOUSE_OVERSIGHT_012524
—_ . ‘Reporting and Trusciption, Ino, Right. Q. Okay. So aid tell you what to expect when you went there, as far as keeping your clothes on or taking your clothes off? A. It was no problem. He wouldn't be upset. Q. All right. so told you there would be no pressure on you whatsoever? Right. Yes, And if you didn’t want to do something, you All right. And in your experiences with HOUSE_OVERSIGHT_012525
insor & Associates ‘Koportiog and Transcription, ine, C Page 12 i Mr. Epstein, by the way, was there ever a time when that didn't play out, when he tried to force you to do i 1? something that you didn't want to do? Q. All right. Now the first time that you went there do you remember whether you gave Jeffrey a massage with your clothes on or your clothes off? < A. At the beginning, it was with all my clothes on. Q. Uh-huh. A. But the most that -- I mean I was still in my bra and panties. Q. Okay. The whole time? A. Yes, Q. Right. A. I'm pretty sure, yes. Q. Did you see during that massage -- did he try and touch you in any way during that massage? A. No. Q. Did he use any kind of device on you in any ( way Guring that massage? HOUSE_OVERSIGHT_012526
nsor & Associates Reporting snd Treasoription, Inc, A. No. Q. Do you knew -- he was wearing a towel through that massage? A. Yes. 9. Do you know whether he touched himself in any way, his penis or anything like that, during the massage? Yeah, like towards the end. Okay. Do you know whether he masturbated? Oh, my gosh, QO. If you don't know, you don't know. A. I mean probably, but I don't know. I can't remember exactiy. It was so long ago. Q. Okay. There was nothing that you were uncomfortable with in this massage? A. No. Yeah. And like I said, he also, you know, reassured if I wasn't comfortable with anything, then just tell him and -- Q. He would stop? A. -- that would be the end of it. Q. Okay. Now after that first time you met at Jeffrey’s house, you left. And did there come other times that you went to Jeffrey's house? A, Yes. And how would that occur? How would that HOUSE_OVERSIGHT_012527
snisor & Assaciates ‘Reporting and Trensauption, Inc, Q. So would it be primarily Jf that would call or would there be others? A. Most of the time. Okay. Unless I didn't answer my phone. HOUSE_OVERSIGHT_012528
_~* Hees comtittiswat tn da Page 15 £ SUTRAS Memon a er Sy 7 Q. Never, ever suggested, right? No. A. 9 . Q. Okay. The only thing that ever occurred on any of these phone calls was, "Are you willing to come 11 over," or, "Would you like to come over and give a massage?" aS EAST 17 Q. Okay. The phone call from or any other assistant would always -- it would be sporadic, right? They always said, "Jeffrey's going to be in town. Do you want to come over this afternoon at four o'clock?" Pl A. Yeah, yeah. It wasn't -- 22 Q. There was nothing regular about it? No. A. 24 Q. Okay. Other than Si who else would have called you to ask whether you wanted to come over and HOUSE_OVERSIGHT_012529
sor & Associates Storage and Traseription, tne, Page 16 resrasaee cake 1 give a massage? 2 A. If it wasn't | | then I believe P| : 3 maybe one other person I don't know the name of. Just -- é And PY I spoke to a time I mean it was mostly | or two. 6 O. Okay. Now when you would go over to Jeffrey's house after getting a phone call, you would go DAMA Sah ere rial eee DNS and you'd go to give him a massage, right? A. Yes. 10 Q. And occasionally would there be more than a massage that occurred? 12 A. It happened a few times. 13 Q. Okay. And the few times that it happened, though, it was very sporadic and it was nothing that was 15 planned? ARTES aT 16 Bes No way. Q. It just occurred? ape (ssi: beer erereraieysei di 18 A. Right. Q. So it wasn't like there was a phone call, you know, "Today we want you to come over and do more than just a massage with Jeffrey"? OG A. Right. 23 Q. When anything more occurred you'd be over there and it would be totally voluntary on your part? 25 A. Yes; definitely consensual, SAV TL TOSENN BT aiTG he Ae EPO TE Hane Pe We eee Ur TN EC ARNTRE ET CRT NY CTE PY 2 TS Ae OTN EE LYASE TLE YEN or Teale ECO eee HOUSE_OVERSIGHT_012530
( Page 17 | Q. Okay. Now when we're talking about more than just a massage, what sort of conduct are we talking about that might have occurred? A. It was probably mostly -~ maybe not, not particularly oral, but, Q. Okay. So let's put it into perspective. You certainly never had intercourse with him, right? A, No. Q. And did you actually ever really have oral sex with him? C A. Maybe once or twice. I barely even remember that. Okay. I mean it was all just mostly -- I'm sorry. Mostly what? A. Mostly like hand oriented. Q. Okay. So on occasion you would touch his penis with your hand? A, It's happened a few times, Q. Okay. And anytime that occurred it would be totally voluntary on your part? A. HOUSE_OVERSIGHT_012531
Page 18 1 Q. And it would just be totally random and it would occur during the moment? A. Uh-huh. 4 Q. Okay. There was nothing that was planned in advance concerning that? A. No. 7 QO. And it didn’t become every time you went over there that would happen, right? A. Yean. No. 10 Q. No, no. I mean just you would go over and give a massage one day and the phone call would be the 12 same, "Do you want to come over and give a massage,” and maybe -~ A. Yes. 15 0. -- maybe another time you woutd get a phone call, "Do you want to come over and give a massage," and just because of the day it was or whatever was going on, it may have gone a little further where they may have been some touching, correct? 20 A. Right. 21 QO. And then the next time you could go over there and it could have been a regular massage again, right? Uh-huh. Okay. So the point that I guess I'm trying HOUSE_OVERSIGHT_012532
nsor & Associates ‘Reporting and Trenserintion, fas, Page 19 f to make was that there were never phone calis that would come to you and they would say, "Do you want to come over and give a massage," and you just assumed it would be to go have sex? That was not the case? A. No. QO. Never, never, never, right? A. Yes. Q. All right. There were times when you would be away and not be in Palm Beach and —— I mean you very much thought that Jeffrey was your friend? You treated him as a friend? A. Yes, definitely. I felt that he was my friend. Q. And there were times when maybe you were out of town and for whatever reason, you found yourself in a situation where you needed some money, correct? A. Yes. Q. Okay. And you felt that the relationship was such that you could call Jeffrey and it never had anything to do with a massage or anything. You would say, "Listen, I could use a couple of dollars. I have a problem.” A. Yes. Q. And would he ever hesitate to help you out? HOUSE_OVERSIGHT_012533
nsor & Assaciates Reporting and Transeription, inc. Page 20 # QO. And in fact, did he not tell you that, listen ~- he would talk to you about life and about -- A. Yes. Q. -~ about what you wanted to do with your Yes. And he said, "If you ever find yourself in trouble, you have a friend in me and you can give me a cali"? A. Yes. Q. Okay. If you had to guess -- and recognizing that there can be no accuracy here -- if you had to guess, how many times do you think you went over to Jeffrey's house? A. I would say at least five, less than ten. QO. Okay. I think that's kind of a fair range. And during those five to ten times that you went there, was there ever anything uncomfortable, in your mind, that occurred over at Jeffrey's house? A. No. Q. Okay. I know we've touched on this, but just Lilly, the detail person, makes sure that we get everything. After you met Jeffrey the first time did you ever talk to him on the telephone about arranging a massage or anything like that? HOUSE_OVERSIGHT_012534
ooo ” Reporting and’ Transoriptiva, fun. A. No. Q. Okay. And you never e-mailed him or anything like that? A. No, no. Q. Never text-messaged him? A. No. Q. Okay. Now at times when you would go over to give a massage, Jeffrey, while he was getting the massage, would be preoccupied doing a lot of things, right? A. Yes, very often. Q. He was a busy guy? Bos Yes. Q. He would be on-the telephone talking to folks while you were giving a massage? A. Yes. Sometimes it would be just a massage and he'd be pretty much doing business the whole time. Q. Right. Certainly it wasn't sex or anything like that? A, No. Q. He would be doing business and you'd be massaging hin? A. Yes. Q. Okay. Give me one second. (Discussion held off the record.) HOUSE_OVERS TD DEIN recand acer tv cara Cara ITN AP RCV IY AH ore eT eT amir naa oe, laters ONL ACCEL ETSI EINE FTI IGHT_012535
nsor & Associates Reporting and Transeuiptioa, Ins. Page 22 ' BY MR. GOLDBERGER: Q, Every time you went back to Jeffrey's house you went back there because you wanted to, right? A. Uh-huh, yes. Q. No one -- certainly Mr. Epstein never tried to persuade you or induce you or entice you or coerce you to engage in any kind of sex? A. No. QO. And no one representing Jeffrey Epstein ever tried to persuade or induce you to engage in sex? A. No. Okay. Like there was no ifs, ands or buts about Q. There was a time when there was a concert or a show down in Fort Lauderdale and Jeffrey got you tickets to go to that show because it was your birthday, right? Correct. HOUSE_OVERSIGHT_012536 Sev SU es ecaee Tae are Tarienrnaae Mason nahn
oo wor & Associates \ Reporting and Transeripiion, foe. I tried not to like even touch upon But I know you didn't try and touch upon Okay. Great. Here's the lawyer talking now. I didn't try to influence you in any way to say anything, did I? Bes No. Q. In fact, all I asked you to do is tell me the absolute truth here today? A, Yes. And that's what you've done? HOUSE_OVERSIGHT_012537
fe A. 2 Q. Ckay. And you've understood all my questions, have you? A» Yes. 5 MR. GOLDBERGER: Okay. I thank you very much for coming in today and it really made it much easier for us to do it this way. So thanks a lot. (Thereupon, the sworn statement was concluded at 4:20 p.m.) HOUSE_OVERSIGHT_012538
oo nsor & Associates ” Reporting and Trenseriptiva, fas. pease ai rety THE STATE OF FLORIDA, } COUNTY OF PALM BEACH. } Manca aD SRST OIAM CP FF OH EST I, the undersigned authority, certify that 6 .--:-2227 appeared before me on the 21 of March, 2008 and was duly sworn. z Ae reserva crise WITNESS my hand and official seal this 22nd day of March, 2008. Judith F. Consor, FPR i Notary Public - State of Florida i HOUSE_OVERSIGHT_012539
Snsor & Associates ~~ Reporting and Trenspripiiog, ins. SINISE aay CERTIFICATE Ee The State Of Florida, ) County Of Paim Beach. ) I, Judith F. Consor, Court Reporter and Notary Public in and for the State of Florida at large, do hereby certify that I was authorized to and did stenographically report the sworn statement of PF P| that a review of the transcript was requested; and that the foregoing pages, numbered from 1 to 24, MRIS Spe rete ITC E SDs inclusive, are a true and correct transcription of my stenographic notes of said sworn statement. Hiiihaltalccceanlal 1 further certify that said sworn statement was taken at the time and place hereinabove set forth and B that the taking of said sworn statement was commenced and completed as hereinabove set out. I further certify that I am not an attorney or counsel of any of the parties, nor am I a relative or reste [art] Cissaicear ese tsy employee of any attorney cr counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any EB means unless under the direct control and/or direction of the certifying reporter. SEU Pee TAG DATED this 22nd day of March, 2007. Judith F. Consor, Court Reporte Florida Professional Reporter ° i 3; Sha es RGN AAT td RIM 8 HE G8 AS TMP EMPL ERI OS EE BET PD SD SIE A ATTA LEAT AE URNS REL EAE AUS PY SEED fi ripe EERE ASL Ee OP OY RENT NSE A FATTO TO ery | HOUSE_OVERSIGHT_012540
snsor & Associates Roparting and Teenseiption, Ino. rates Eb AEST eS ASSLT MIAME MSA en eS EE EEL TOTS CTR Be Poa Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012541
Page 28 Ph, 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012542
sor & Associates Reporting and Trensesipiion, Inn. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012543
AOS Reporting and Transoription, Inc. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012544
TAB 15 HOUSE_OVERSIGHT_012545
: nsor & Associates .. denoning aml Transeripsinn daa... THE STATE OF FLORIDA. COUNTY OF PALM BEACH. JEFFREY EPSTEIN, CONTINUED SWORN STATEMENT OF March 26, 2008 6:05 p.m. to 6:22 p.m. South 86th Terrace West Palm Beach, Florida Reported By: Maria C. Powers, Notary Public State of Florida J. Consor & Associates Reporting & Transcription West Palm Beach Office Phone 561.682.0905 ORIGINAL F A ( Ph. 561.682.0905 - Fax. 561.682.1771 meen tn woes ees sone! «FD Palth Beach Lakes’ Bivd.;Stite 500°- West Palm Beach, FL 33401 °° ~*: s77~ ONY Shao dela AE a Sie Hehe an ae OOO HOUSE_OVERSIGHT_012546
ensor & Associ ates MO § Heporting and Trenseripiion, Ine -- APPEARANCES On Behalf of the Defendant: JACK A. GOLDBERGER, ESQ.. ATTERBURY, GOLDBERGER & WEISS 250 South Australian Avenue Suite 1400 West Palm Beach, Florida 33401 [PRR DPE MUNITY SEE OOS STIL EE CLS EE ED STIS TOSE PSNR DESLERTIC TINY SUE DOT TET EEE A ETRE IIET SESE SPOTS FTE EDL ERGY Oto SET WA ENE LATELY RY CLOSET SRL PREP SELLY WEE SETI Ph. 561.682.0905 - Fax. 561.682.1771 “1655 Palit Beach Lakes Bivd.; Suite 500 - West’Palin Bédch, FL 33401" "tn i HOUSE_OVERSIGHT_012547
ESSERE AT nsor & Associ ates | rel Reparcing and Trenscriptinn, Ine. gu WITNESS: DIRECT By Mr. Goldberger DS 2 EEC LEO BDL RICE SEE BEE TA LOSI EST DET CENT SET EEE ETS 59 SEES SEBO ESA GI EN CALIECCES SCOP TET 372297 COSSLAE LET ETSI TES TEN MEETS PRETEND Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palfri Beach Lakes’BlVd-; Suite 500°- West Palm Beach, FL 33401" vt et HOUSE_OVERSIGHT_012548
nsor & Associates | Aeporsing onl Jrznseription, Ins. ‘ Page 4 Sworn Statement taken before Maria Powers, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. Thereupon, F i having been first duly sworn, was examined and H testified as follows: DIRECT EXAMINATION BY MR. GOLDBERGER: Q P| as you remember, my name is Jack f iE fg Goldberger. I think we met last Friday, actually. You voluntarily came in and gave a sworn C ) statement to me concerning your knowledge and your friendship with Jeffrey Epstein. I would like to very, very, briefly continue that statement today, and just focus on one area that we forgot to question you about last Friday. A Yes. : Q All I want you to tell me is the absolute truth here this evening. There's no right answer, | other than the truth, okay? : LA Right. | Q I haven't promised you or asked you to do ! anything, one way or the other, have I? | fos A No. | 7 7 Ph. 561.682.0905 - Fax. 561.682.1771 oe "1655 Pali Beach Lakés Blvd; Suité 500 - West Pali Beach, FL33401°° “tt HOUSE_OVERSIGHT_012549
, nsor r & Associates: < \ Page 5 So, we covered a lot of ground last time. One area that I didn't ask you about is contact that -you've had with either the FBI or the U.S. Attorney's Office, within the last two or three years. Can you guess or estimate how many times someone from the FBI or the U.S. Attorney's Office or some other law enforcement agency, has attempted to contact you in the last couple of years? A I'd have to say -- well, maybe five or six meetings with, and more than that with phone contact. Q Let's try to break it down by meetings and f : | a 7 phone contacts. I think that would be the best way to Of the actual meetings that you've had with | someone from law enforcement or from the U.S. | Attorney's Office, who do you remember being present at those meetings? — | ; ! A Nesbith was at all of them. | Q When we're talking about "Nesbith”" we're | | talking about an FBI agent by the name of "Nesbith | Kurkendali"? | A Yes. : Q And Nesbith was present at all those | meetings? | ’ ; i f ee PF ptbsatowdis Wen mcltiie Wauansk Wi wacaesee te on wee FREEING EIEN REE REL NTL RSE ENS EE SIE TCTSES OO E SEH TEN PSOE T ICES Ds WORE CEU BULAN OSMOSIS TOUTES | * Ph. 561.682.0905 - Fax. 561.682.1771 | ome "1655 Parti Béachi Lakes’ Bivd.; Suite 500°- West Palrn’Béach, FL'33401 7 “ty HOUSE_OVERSIGHT_012550
sensor & Associates Page 6 Q Okay, go ahead. A The first one was a guy, I'm not sure of his name. And then there's another one that had -- another lady with the victim's rights. fe) She was victim's right representative? A Yes. Q We talked about a lawyer by the name "Marie Villafona;" do you know whether she was present during any of those meetings? A I'm not sure of the name. Q The first time that you met with Nesbith, where did that take place? A Here, in my backyard. Q In your backyard, at your home in Western Palm Beach County, right? A Yes. Q Did she announce to you that she was coming, or did she just show up? A She showed up. Q Unannounced? A Yes. Q During that time, I assume that you told her about your relationship with Jeffrey Epstein and any contact you've had with him, correct? A Correct. nen occ oe Ee roe Ph. 561.682.0905 - Fax. 561.6 ar nt Eg rch ted nb ed ne Mea EEE a aD NE Eh TD 82.1771 "1655 Palfh Beach Lakes’Blvd;, Suité 500°- West ‘Palin Beach, FL’ 33401 “ro HOUSE_OVERSIGHT_012551
nsor & Associates ae ‘Reporting and -Tranzeriptinn, Inc. Page 7 Q Did she tell you anything about whether you were a victim in this case, or anything like that, at that meeting? A Yes, she said I was a victim/witness in this, and that there’s victim rights that I'm entitled to, which include counseling and whatnot. Q Did you tell her, at that time, that you didn't feel that you were a victim at all, and that anything that you've done with Jeffrey Epstein was totally voluntary? A Yeah, I did tell her that everything was, you know, consensual with everything, and I don't agree with anything that's going on. Q Did she try and pressure you into being a victim in this thing, when you were not a victim? A I wouldn't say that she pressured me, but tried to be as convincing as possible. Q Maybe the use of the word "pressure" is too strong. But she was trying to change your opinion of what the relationship was with Jeffrey? A Yes, she was trying to make me feel bad about it, in a way, about what was going on. Q And you didn't feel bad about it, you felt everything was okay, but she was trying to make you feel bad, like something wrong had occurred? rea nena Wenn OE I Te AE wT RES Lee UN Bet Ga ert ETE PROSSER TC RSEIEL EIT ET FCAT S FSD BRT COCO ST ELT SPE EEOC Ph. 561.682.0905 - Fax. 561.682.1771 *"™ 1655 Palm Beach Lakes Blvd.’ Suite 500 - West Palm Beach; FL’33401° °°" **"" HOUSE_OVERSIGHT_012552 i ee a a a
ansor & Associates — + Hepocing ond Trsascrigina, Ine. , Yeah. How long did that meeting go on for? Probably about -- at least an hour. Q When was the next time that you had contact with Nesbith or someone else from law enforcement? A I'm not sure, probably a month or later. I mean, she probably called me and let me know that she was going to -- you know, she wanted to meet sometime soon, to deliver the victim's rights papers to me. Q So there was a time, after you first met, where, despite the fact that you said, I don't consider myself a victim in this, she called you and said, I want to bring you some paperwork that talks about your victim's rights? A Yes, 0) What was your response to her when she told you that? A I told her I would meet with her, 'cause she wanted me to meet with the other woman involved. And they gave them to me. I took them, but I never really told them I needed counseling or anything like that. Q Where did that meeting take place? A I believe it was Panera Bread in Wellington. SESE SBS EES ht SEIT CE EN IIS SSeS TY SES SRC LE ESEES ERE IE TOE LIED D 2 EPR Ph. 561.682.0905 - Fax. 561.682.1771 "1655 Palm Bedch Lakes Blvd.; Suite’500 - West’Palm Beach, FL°'33401°" “te eo HOUSE_OVERSIGHT_012553
oo™ es a snsor & Associates ee ie Heporting and TranseripiinnJow. . - Page 9 |: 0) She actually came and sought you out at a restaurant? A Well, I told her to meet me there. Q Were you working there or were you just -- A No, I was just there. Q So she called you and said, I really, really want to see you. And you said, if you want to see me, meet me at Panera Bread? A Yes. Q Did you feel if you didn't meet her, she wasn't going to go away, that you had to deal with her? A Well, I mean, it wasn't particularly that. I knew that she was going to contact me because of this case. Because, whether I want to be involved or not, I have to be. Q Okay. That's two meetings that I know of. I think you indicated that, if you had to guess, there were maybe a total of five meetings. Are there other meetings that we haven't talked about that occurred? A Yeah, but they were very vague. They weren't anything of importance. And, I mean, it was just her -- or of importance to me, anyway. Would she call you and say, listen, I really, Fax. 561.682.1771 "1655 Palm’Beach Lakes Blvd.; Suité 500 - West’Palm Beath; FI 33401: °°" HOUSE_OVERSIGHT_012554 SE PRET MITE Y OATS TLE SERS OS SM CY TUBB EAT RECITES SE SS ESCNEE E7CSTNAY SSPCESTESSPOOCHOE|
- touch upon the fact that if I need any help or "1655 Palty Beach Lakés Blvd:, Suite’500°- West Palm’ Beach, FL 33401°° "> oT tere nsor & Associates — \ Reporting and Transeription, Jne:. Page 10 : really, want to talk to you about being a victim or -- A It wasn't always directly about being a victim. And, every*time we talked, she would always i so-on-and-so-forth, because I am a victim in this case. 5 Q I assume, based on what you're telling me, you continued to tell her, I'm not a victim? A I just let her say what she said. I never got counseling. But she knows from the beginning, and, I continued to reassure her, that I don't feel that way. Q So, the first time you met with her, when you spent about an hour with her and you went through all your contact with Jeffrey, that's what occurred at that meeting, and she talked to you about being a victim at that meeting? A Yes. Q And then there was this second meeting, where she brought a victim's rights person with her, and that took place at Panera Bread, right? A Yes. Q And you had the same response, listen, you think I'm a victim. You could give me the information, but I don't need that information, right? SEIS TET ERS OR PEATE TS ST DOTS CEE EEE SSCL BPSD AOE TS ONE TOTP OT TEREST Ph, 561.682.0905 - Fax. 561.682.1771 HOUSE_OVERSIGHT_012555
ansor & Associates” ~. henarting onl Transcription, Jvc. - A Right, pretty much. Q And then there were some other contacts. Would she call you and want to talk to you about the specific facts about the case? I mean, why would she contact -- A Yeah, I mean, just to re-question me about certain things, because she wasn't sure that the answers were -~ Q Were those in-person meetings? A I mean, a lot of them were on the phone. mean, it wasn't very often that we would meet. 6) Was there any other time that you did meet? We talked about two times that you actually did meet, once here at your home and once at Panera Bread. Were there any other actual meetings, or did the others occur on the phone? A There were other meetings, but they were, like I said, not really important. Q Do you remember where they were that they took place? A They came to my job, I think, two times. Q When you say "they" -- A Well, it Nesbith the first time, and, the second time, it was the David Copperfield investigators Tape NL OOP SAIS Sant am ETS PF SEL BER DEOL SSE RL ORNS SLE ESN ePIC TEN EASES BLOT AR RELI TN On Py PEE SNES SE CTE SEES SOOTCE OOESDSESET Ba co PAL Lids Evin tea Reda Wonins. a? Boeke Riv Sal WP Re Aen Reeder, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Bedch Lakes Blvd." Suite’500 - West Palm: Beach, FL’33401" °° HOUSE_OVERSIGHT_012556 ee OE Te
with Nesbith. fo) Right. So, the third time that you met with Nesbith, she came to your job, and she wanted to talk to you about more facts of the case? A Ah-huh. Q And, during that meeting, she also talked to you about your rights as a victim again? 9 A Yeah, she always reassured me of my rights as a victim. Then there would have been a fourth time Q we're talking about now, where there were investigators from Washington coming down, concerning David and Nesbith introduced them to you, Copperfield, correct? 16 A Right. 17 Q I take it what you're telling me is that Nesbith seized the opportunity to talk to you again about being a victim, right? 20 A She always kind of comes out as asking if I'm okay, and if everything okay. And if I ever need any kind of help or anything, with -- you know, I could always have help. listen, I'm fine, Q Did you continue to say, there's no issues here? EERE ES ENS OPS EE RTE CRS aa ENN UE DCCC MESES BESS SNE TEERTOCEE ESOT S BT BTR CENCE TR SEIN PERN ESOP SEES TBC ETL POE ACTER MRSS A SCPTIS TRUELY ZEEE Ph. 561.682.0905 - Fax. 561.682.1771 T655 Palm Beach’ Lakes Bivd-, Suite 500°- West Palit’ Bédch, FL‘33401“*° -"°r* ' HOUSE_OVERSIGHT_012557
Tin Sateen cot ats Reeien OR! “"1655 Palm Beach’Lakes Bivd., Suite’500 - West Palm’ Beach, FL 3340f"" on ens ansor & Associates | PAPAS. deporting and ‘Transcription, ine>: Page 13 A I just -- I mean, I was never pushy on it. I just, like I said, she always knows. I may not tell her every time, but she always knows how I feel about this case. Q Meaning? I don't need anything. Q Meaning that you made it really clear to her that you didn't need any help? A Yeah, from the beginning, I was very, very reassuring about how I felt about it. And I wasn't. very happy. Q All right. I understand. Now, we're about four contacts with Nesbith -- your house, Panera Bread, work, the David Copperfield investigators. A ‘Yaa. Q Were there any other meetings that we have not spoken about? A There may have been like one or two. But they're -- I don't even remember. I mean, those are the ones, like, that remember the most. Q That you really remember, okay. Now, were there other telephone calls that occurred, where, kind of the same kind of conversation would occur? You know, there's help for you and you'd DPS Wa SoM dah cow te ce oi adhe A Sa SEY EBSD EPAPER EIS CEN L ECNO T Sate SCT RIN PETS TE MICS Ph. 561.682.0905 - Fax. 561.682.1771 Tyan Sea ts Panaderia HOUSE_OVERSIGHT_012558
snsor r & Associates Page 14 say, I'm really not a victim here? A Like I said, I was, like, okay. You know, she would always continuously tell me. I mean, but every time, it was the same thing. I mean I was never -- I mean, I was never mean to any of them. I never gave anybody attitude about anything. But, I mean, she knows that. She knows how I feel. Q I think what I hear you saying is that she knows how you feel, and you made it clear to her from the start, that you were not a victim? A Yeah, I mean, she pretty much, does it because that's what she has to do. She has te gortinne to tell me. And, you know, in a way, try to convince me that I am a victim. I just let her say what's she's going to say, and, then, you know, okay, goodbye. Q Do you think that's what she was trying to : do, is try to convince you to change your attitude as H | to how you felt? | A in away, yes. Q Is there anything else that we need to discuss that we haven't talked about? A No, I think that's mostly it. I appreciate your courtesies once again for Darel ee e8 att wa Ce teen aes a Te aa a ln a Si a le i Cia ham a Sa ae ie eee citi OE ad hia Sa Ro Nee eT Tea 2 ac Duper nE RCE Once aceecrerst } Ph. 561.682.0905 - Fax. 561.682.1771 “""1655°Palr Beach Lakés Blvd; Suite "500 -West’Pdlrn Bédth; FI33402"~"" tm ees HOUSE_OVERSIGHT_012559
ed "1655 Palfiv Beach Lakés BIVa:, “Suite 500 -'West' Palni Beach; FL 334047" 8" or en msor & Associates af APIAS Boporing andl Teenseription, Jas. Page 15 seeing me oné more time, and doing this voluntarily. And, thanks so much for making yourself available today: A No problem. Q That will do it -- actually, one more time. Brittany, let me say one more time: Everything you've told me here today is the absolute truth, right? A Yes. Q I haven't tried to convince you to say one thing, one way or the other, have I? A No. All right. That's it. Thank you very much. (Thereupon, the sworn statement was concluded at 6:22 p.m.) Ph. 561.682.0905 - Fax. 561.682.1771 } IEE EET CSCS SEEPS EY EMT ak col SL Rois RED content Gann eres NE Eo a Os see aR ETRE OT EL, . | § t HOUSE_OVERSIGHT_012560
nsor & Associ ates: +. Reporking anal Transcripiiva; Ias.: -.-- a a THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that > <-sonaity appeared before me on March 26, 2008 and was duly sworn. WITNESS my hand and office seal this 26TH day : of MARCH, 2008. F | | Maria C. Powers, Court Reporter Notary Public - State of Florida | My Commission No. DD149010 | My Commission Expires: 9/10/10 | I Ph. 361. 682. 0905 - Fax. 561. 682. 1771 ) HOUSE_OVERSIGHT_012561
5 nsor & Associates ELS Heporting and-Transcripiiva, Jac. CERTIFICATE The State of Florida County Of Palm Beach I, MARTA C. POWERS, a Shorthand Reporter, State of Florida at Large, do hereby certify that was by me first duly sworn to testify the whole truth; that I was authorized to and did report said deposition in stenotype; and that the foregoing pages, numbered from 1 to 17 inclusive, are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said proceeding was commenced and completed as hereinabove set out. I further certify that I am not an attorney or counsel of any of the parties, nor am Ia relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means, unless under the direct control and/or direction of the certifying reporter. IN WITNESS WHEREOF, I have hereunto set my hand this 26TH day of MARCH, 2008. Maria C. Powers, Notary Public In and for the State of Florida My Commission No. DD149010 My Commission Expires: 9/10 Tenet EN oee ae Eee Sey ee eee EE RCN ITE ERT SPIED PUTT EEC rE Ee Be aN NTS TLE AR AER ern cas a TOR oHA Fca oechch ans pera” Poa APARNA Foe Ph. 561.682.0905 - Fax. 561.682.1771 HOUSE_OVERSIGHT_012562 “"""T655 Palm Beach Lakes Bivd:, Suite 500- Wést Palm Beach, FL'33401 °° “no
sor & Ass ociates r | ring and ‘Tra Jne EEE ST EE EEN COE EEE EY RES RPES REELS SST EES Ph. 561.682.0905 - Fax. 561.682.1771 | HOUSE_OVERSIGHT_012563
Sonne SIPTRTN TD re FS RAST IE SEPT - Ph. 561.682.0905 - Fax. 561.682.1771 : , ome" T6855 Palit’ Beach Lakés Blvd., Suite 500°- West Palm Beach, FL'33401" °°" ~* > me HOUSE_OVERSIGHT_012564
‘ ‘eparting anni 1: r2nzeription, ies - “pee Ph. 561.682.0905 - Fax. 561.682.1771 ome"1655 Paliti Beach Lakes Bivd.,Suité500°-"West Palin’ Beach, Fi 33401 @ “nr teeter HOUSE_OVERSIGHT_012565
TAB 16 HOUSE_OVERSIGHT_012566
14/16/2006 16:31 FAX 5618021787 USAO WPB FL 002 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-6777 November 16, 2006 VIA FACSIMILE Lilly Ann Sanchez, Esq. Fowler White Bumett 1395 Brickell Ave Fl 14 Miami Florida 33131-3300 Re: Jeffrey Epsteim Dear Ms. Sanchez: Thank you for your letter and voicemail. 1 will plan to direct all correspondence fo you unless you provide other instructions. In tum, please direct all future communications with the Office to my attention. As I mentioned in my voicemail, Mr. Lewis stated that Mr. Epstein is willing to provide documents and information that we deem necessary to the investigation. I would appreciate if you would forward the documents and information Listed below to my attention or, if you prefer, to Special Agent E. Nesbitt Kuyrkendall, Federal Bureau of Investigation, 500 South Flagler Drive, Suite 500, West Palm Beach, FL 33404. If yourequire a grand jury subpoena for any of the items, please let me know. i, Documentation related to the ownership of the property located at 358 El Brilio Way, Palm Beach, Florida, including the purchase agreement and any mortgages, liens, or other encumbrances. 2. Documentation related to the ownership of Gulfstream Aircraft NS09JE, Model G1159B, and Boeing Airctaft N908JE, Model 727-31, including purchase information, lease agreements, liens or other encumbrances, and payments for maintenance and storage. 3. All documents and information provided to the Palm Beach County State Attomey’s Office in connection with its investigation of Mr. Epstein. 4. Bank information, account numbers, bank statements and billing statements for any bank accounts and/ot credit cards used by Mr. Epstein (or any of his employees) to pay for Mr. Epstein’s personal expenses, from January 1, 2004 to the present. 00269 HOUSE_OVERSIGHT_012567
11/16/2008 16:31 FAX 5618021787 USAO WPB FL (003 LILLy ANN SANCHEZ, ESQ. NOVEMBER 16, 2006 PAGE 20F 3 5. Information and billing statements for any “fand lines,” cellular telephones, Blackberry units, e-mail addresses, webpages, or the like for Mr. Epstei and all of - his personal assistants (including but not Hmited to [J and from January 1, 2004 to the present. 6. The computers, hard drives, CPUs, and any other computer media (including CD- ROMs, DVDs, floppy disks, flash drives, etc.) removed from 358 El Brillo Way, Palm Beach, Florida prior to the execution of the search warrant at that premises in October 2005. 7. Al! calendars, diaries, and address books kept by Mr. Epstein and alll of his personal assistants from January 1, 2004 to the present, including electronic calendars and _ address books, whether stored on computer, PDA, or cellular telephone. g. For persons in his employ at any time from January 1, 2004 to the present, employment and/or separation agreements between Mr. Epstein (or his company) and his personal assistants, airplane pilots, personal chefs, and for anyone who worked at 358 El Brillo Way, Palm Beach, Florida. 9. The names and contact information of all persons who performed “massage services” for Mr. Epstein at 358 El Brillo Way, Palm Beach, Florida or at his residences in New Albany, Ohio, Little St. James, U.S.V.I, and New York, NY; and documentation of payments made to or gifts given to any such persons, 10. Wageand earnings statements and other tax documents forall individuals referenced in items (8) and (9), supra. 11. Mr, Epstein’s tax retums for 2004 and 2005. 12. From January 1, 2004, to the present, flight manifests and passenger lists for travel via Gulfstream Aircraft N9O9JE, Model G1159B and Boeing Aircraft N9OSJE, Model 727-31 (to the extent not already provided). 13. Documentation regarding any other interstate or interational travel undertaken by Mr. Epstein from January 1, 2004, to the present, including but not limited to aisplane tickets, car rental records, and hotel receipts. After I have a chance to review the documents, I will contact you to set up a time to interview Mr. Epstein. 00270 HOUSE_OVERSIGHT_012568
14/16/2008 18:32 FAX 5618021787 USAC WPB FL oo LILLY ANN SANCHEZ, ESQ. NOVEMBER 16, 2006 PAGE 3 OF3 Thank you for your assistance with this matter, and I look forward to working with you and Mr. Lefcourt. Sincerely, R. Alexander Acosta United States Attorney 5 4 By: e A. Marie Villafatia Assistant United States Attorney HOUSE_OVERSIGHT_012569
TAB 17 HOUSE_OVERSIGHT_012570
. JUN-26~-26@7 11:18 FRI WEST PALM BEACH RA P.@L FU-448 (Kev. -2-¥/) FBI FACSIMILE F COVER SHEET PRECEDENCE CLASSIPICATION 1 immediate LJ Top Seeret Time Transmitted: CI Priority LI Secret Sender's Initials: jxr Routine CJ Confidential Number of Pages: _ 5 ; C1 Sensitive (including cover sheet) IX] Unclassified ; To: William Riley Date: 06/20/2007 Name of Office Facsimile Number. 954-905-4922 Attn: . Name | Room Telephone « . From: FBI Name of Office Subject: Service of Federal Grand Jury Subpoenas Special Handling Instructions: Originator's Name: SA Jason Richards Telephone: 561-833-7517 Originator's Facsimile Number: 561-833-7970 Approved: Brief Description of Communication Faxed: Two subpoenas: 1) William Riley and 2) Custodian of Records, Riley Kiraly . WARNING ( Informotion attached fo the cover sheet is U.S. Goverment Property. If you arc not the intended recipient of this information, disclosure, reproduction, distribution, ot use of this information is prohibited (18.USC, § 641), Please notily the ~ . originator or the local FBI Office immediately to arrange for proper disposition. ‘ HOUSE_OVERSIGHT_012571
JUN-28-2607 11:18 FBI WEST PALM BEACH RA P.@2 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: | Custodian of Records | SUBPOENA TO TESTIFY Riley Kiraly BEFORE GRAND JURY Commercial Center of Miami Miami, FL 33015 SUBPOENA FOR: PERSON DOCUMENTS OR OBJECTIS} ‘YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time specified below. ROOM: Grand Jury Room PLACE: United States District Courthouse 70] Clematis Street West Palin Beach, Florida 33401 DATE AND TIME: July 10, 2007 100 pm* YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): THE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT A. *Please coordinate your compliance with this subpoena and confirm the date, time, and location of your appearance with S/A Nesbitt Kuyrkendall, Federal Bureau of Investigation, Telephone: (561) 822-5946. This subpoena shall remain in effect until you are granted Jeave to depart by the court or by an officer acting on behalf of the court. June 18, 2007 (BY) DEPUTY CLERK Name, Address and Phone Number of Assistant U.S, Attomey Aun Marie C, Villafaiia, Assistant U.S. Anomey . 500 So. Australian Avenve, Suite 400 West Palm Beach, FL 33401-6235 Tel: (561) 820-8711 x3047. Fax; (561) 802-1787 To be uset in Bon of ADLIO FORM ORD-237 ‘ JAN.86 Thie subpoena is issued wpon application of tha United States of America *)f not applicable, enter “none.” HOUSE_OVERSIGHT_012572
‘JUN-26-2007 11:19 FBI WEST PALM BEACH RA P.@3 ATTACHMENT A SUBPOENA TO PAUL A. LAVERY I, Al} computer equipment and electronic storage media removed from the residence located at 358 El Brillo Way, Palm Beach, Florida, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. 2, All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, inchiding but not limited to ceniral processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. 3. All documents and information related to the nature of the selationship between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; ' billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates of communications with Mr. Epstem {or with a third party on Mr. Epstein’s behalf); appointment calendars/datebooks and the like (whether in hard copy or electronic form) for any period when work was performed on behalf of Mr, Epstein or when any communication was had with Mr. Epsiem (or with a third party on Mr. Epstein’s behalf); and records of fee arrangements and payments received for work performed on Mr, Epstein’s behalf, HOUSE_OVERSIGHT_012573
JUN-28-2687 14:19 _ FBI WEST PALM BEACH RA P.@4 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: William Riley SUBPOENA TO TESTIFY Raley raly BEFORE GRAND JURY Commercial Center of Miami Miami, FL 33015 SUBPOENA FOR: PERSON DOCUMENTS OR OBJECTS] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District Court at the place, date and time specified below. ROOM: Grand Jury Room PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 DATE AND TIME: ’ ‘July 10, 2007 1:00 pm* YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): THE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT A. *Please coordinate your compliance with this subpoena and confirm the date, time, and location of your appearance with S/A Nesbitt Kuyrkendall, Federal Bureau of Investigation, Telephone: (361) 822-5946. This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court. June 18, 2007 " (BY) DEPUTY CLERK Name, Address and Phone Number of Assiatant U.S. Attormey Ann Marie C, Villafafiz, Assistant U.S. Attomey 500 So. Australian Avenue, Suite 400 West Paim Beach, FL 33401-6235 Tel: (561) 820-8721 23047 Fax: (561) 802-1787 *I{ noi anpligabls, enter “none.” ; Tobe nsed in Tits of AQUIO : , FORM OR[TR227 JAn_B6 This subpoena is issued upon application ofthe United States of America HOUSE_OVERSIGHT_012574
JUN-20-2007 «11:19 FBI WEST PALM BEACH RA P.@5 ATTACHMENT A SUBPOENA TO PAUL A. LAVERY 1. All computer equipment and electronic storage media removed from the residence located at 358 E] Brillo Way, Palm Beach, Florida, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, ‘printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. 2. All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, ie diskettes, digital cameras, and memory cards. 3, All documents and information:related to the nature of the relationship between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; _ billing statements (whether submitted directly to Mr, Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates of communications with Mr. Epstem (or with a third party on Mr. Epstein’s behalf); appointment calendars/datebooks and the like (whether in hard copy or electronic form) for any period when work was performed on behalf of Mr, Epstein or when any communication was had with Mr. Epstein (or with a third party on Mr. Epstein’s behalf); and records of fee arrangements and payments Teceived for work performed on Mr, Epstein’s behalf, TOTAL P.@5 HOUSE_OVERSIGHT_012575
TAB 18 HOUSE_OVERSIGHT_012576
\ is U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 December 13, 2007 DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: Tam writing not to respond to your asserted “policy concerns” regarding Mr. Epstein’ s Non- Prosecution Agreement, which will be addressed by the United States Attorney, but the time has come for me to respond to the ever-increasing attacks on my role in the investigation and negotiations. It is an understatement to say that I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement. For example, I brought to your attention that one potential plea could result in no gain time for your client; I corrected one of your calculations of the Sentencing Guidelines that would have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired; and I told you my suspicions about the source of the press “leak” and suggested ways to avoid the press. Importantly, I continued to work with you in a professional manner even after I learned that you had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded that solicitation of minors to engage in prostitution was a registrable offense and that you would “fool” our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is clear that neither you nor your client ever intended to abide by the terms of the agreement that he signed, I have never alleged misconduct on your part. The first allegation that you raise is that I “assiduously” hid from you the fact that Bert Ocariz is a friend of my boyfriend and that I have a “longstanding relationship” with Mr. Ocariz. HOUSE_OVERSIGHT_012577
JAY P. LEFKOWITZ, Eso. DECEMBER 13, 2007 PAGE 2 OF 5 I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people whom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and I spoke about this case, he did not know about my relationship with his friend. You suggest that I should have explicitly informed you that one of the referrals came from my “boyfriend” rather than simply a “friend,” which is the term I used, but it is not my nature to discuss my personal relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted to find someone whom I could trust with safeguarding the victims’ best interests in the face of intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz was that person. One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend. This is patently untrue and neither my boyfriend nor I would have received any financial benefit from Mr. Ocariz’s appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein’ s actions (as described below), he expressed a willingness to handle the case pro bono, with no financial benefit even to himself. Furthermore, you were given several other options to choose from, including the Podhurst firm, which was later selected by Judge Davis. You rejected those other options. You also allege that I improperly disclosed information about the case to Mr. Ocariz. I provided Mr. Ocariz with a bare bones summary of the agreement’ s terms related to his appointment to help him decide whether the case was something he and his firm would be willing to undertake. I did not provide Mr. Ocariz with facts related to the investigation because they were confidential and instead recommended that he “Google” Mr. Epstein’s name for background information. When Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I forwarded those questions to you, and you raised objections for the first time. I did not share any further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's decision to use a Special Master to make the selection and told him that the Office had made contact with Judge Davis. We have had no further contact since then and I have never had contact with Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to try to “lobby” him to select someone to your liking, despite the fact that the Non-Prosecution Agreement vested the Office with the exclusive right to select the attorney representative. Another reason for my surprise about your allegations regarding misconduct related to the Section 2255 litigation is your earlier desire to have me perform the role of “facilitator” to convince the victims that the lawyer representative was selected by the Office to represent their interests alone and that the out-of-court settlement of their claims was in their best interests. You now state that doing the same things that you had asked me to do earlier is improper meddling in civil litigation. Much of your letter reiterates the challenges to Detective Recarey’s investigation that have HOUSE_OVERSIGHT_012578
JAY P. LEFKOWITZ, Eso. DECEMBER 13, 2007 PAGE 3 OF 5 already been submitted to the Office on several occasions and you suggest that I have kept that information from those who reviewed the proposed indictment package. Contrary to your suggestion, those submissions were attached to and incorporated in the proposed indictment package, so your suggestion that I tried to hide something from the reviewers is false. I also take issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and witness statements that you like and we must accept as false those parts that you do not like. You and your co-counsel also impressed upon me from the beginning the need to undertake an independent investigation. It seems inappropriate now to complain because our independent investigation uncovered facts that are unfavorable to your client. You complain that I “forced” your client and the State Attorney's Office to proceed on charges that they do not believe in, yet you do not want our Office to inform the State Attorney’ s Office of facts that support the additional charge nor do you want any of the victims of that charge to contact Ms. Belohlavek or the Court. Ms. Belohlavek’s opinion may change if she knows the full scope of your client’s actions. You and I spent several weeks trying to identify and put together a plea to federal charges that your client was willing to accept. Yet your letter now accuses me of “manufacturing” charges of obstruction of justice, making obscene phone calls, and violating child privacy laws. When Mr. Lourie told you that those charges would “embarrass the Office,” he meant that the Office was unwilling to bend the facts to satisfy Mr. Epstein’s desired prison sentence — a statement with which I agree. I hope that you understand how your accusations that I imposed “ultimatums” and “forced” you and your client to agree to unconscionable contract terms cannot square with the true facts of this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed for more than five months to allow you and Mr. Epstein’s other attorneys to make presentations to the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you mention in your letter, I -a simple line AUSA ~ handled the primary negotiations for the Office, and conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled and experienced practitioners. As you put it, your group has a “combined 250 years experience” to my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcourt, whose experience speaks for itself. You and I spent hours negotiating the terms, including when to use “a” versus “the” and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times. In any and all plea negotiations the defendant understands that his options are to plead or to continue with the investigation and proceed to trial. Those were the same options that were proposed to Mr. Epstein, and they are not “persecution or intimidation tactics.”. Mr. Epstein chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel. You also make much of the fact that the names of the victims were not released to Mr. Epstein prior to signing the Agreement. You never asked for such a term. During an earlier meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and I did not have a chance to discuss the issue, but I had already conceived of a way to resolve that HOUSE_OVERSIGHT_012579
JAY P. LEFKOWITZ, Eso. DECEMBER 13, 2007 PAGE 4 OF 5 issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the agents and I have vetted the list of victims more than once. In one instance, we decided to remove a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided that the link to a payment was insufficient to call it “prostitution.” 1 have always remained open to a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is simply unfounded. Your last set of allegations relates to the investigation of the matter. For instance, you claim that some of the victims were informed of their right to collect damages prior to a thorough investigation of their allegations against Mr. Epstein. This also is false. None of the victims was informed of the right to sue under Section 2255 prior to the investigation of the claims. Three victims were notified shortly after the signing of the Non-Prosecution Agreement of the general terms of that Agreement. You raised objections to any victim notification, and no further notifications were done. Throughout this process you have seen that I have prepared this case as though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior to concluding the matter by plea or trial would only undermine my case. If my reassurances are insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of the integrity of the investigation.' ‘There are numerous other unfounded allegations in your letter about document demands, the money laundering investigation, contacting potential witnesses, speaking with the press, and the like. For the most part, these allegations have been raised and disproven earlier and need not be readdressed. However, with respect to the subpoena served upon the private investigator, contrary to your assertion, and as your co-counsel has already been told, I did consult with the Justice Department prior to issuing the subpoena and I was told that because I was not subpoenaing an attorney’s office or an office physically located within an attorney's office, and because the business did private investigation work for individuals (rather than working exclusively for Mr. Black), I could issue a grand jury subpoena in the normal course, which is what I did. I also did not “threaten” the State Attorney's Office with a grand jury subpoena, as the correspondence with their grand jury coordinator makes perfectly clear. With regard to your allegation of my filing the Palm Beach Police Department’s probable cause affidavit “with the court knowing that the public could access it,” I do not know to what you are referring. All documents related to the grand jury investigation have been filed under seal, and the Palm Beach Police Department’s probable cause affidavit has never been filed with the Court. If, in fact, you are referring to the Ex Parte Declaration of Joseph Recarey that was filed in response to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one should have access to it except the Court and myself. Those documents are still in the Court file only because you have violated one of the terms of the Agreement by failing to “withdraw [Epstein’s] pending motion to intervene and to quash certain grand jury subpoenas.” HOUSE_OVERSIGHT_012580
JAY P. LEFKOWITZ, Eso. DECEMBER 13, 2007 PAGE 5 OF 5 With respect to Ms. Miller, I contacted her attorney - who was paid for by Mr. Epstein and was directed by counsel for Mr. Epstein to demand immunity — and asked only whether he still represented Ms. Miller and if he wanted me to send the victim notification letter to him. He asked what the letter would say and I told him that the letter would be forthcoming in about a week and that I could not provide him with the terms. With respect to Ms. Miller’s status as a victim, you again want us to accept as true only facts that are beneficial to your client and to reject as false anything detrimental to him. Ms. Miller made a number of statements that are contradicted by documentary evidence and a review of her recorded statement shows her lack of credibility with respect to anumber of statements. Based upon all of the evidence collected, Ms. Miller is classified as a victim as defined by statute. Of course, that does not mean that Ms. Miller considers herself a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identified victims will not seek damages, but that does not negate their legal status as victims. I hope that you now understand that your accusations against myself and the agents are unfounded. In the future, I recommend that you address your accusations to me so that I can correct any misunderstandings before you make false allegations to others in the Department. I hope that we can move forward with a professional resolution of this matter, whether that be by your client’s adherence to the contract that he signed, or by virtue of a trial. Sincerely, R. Alexander Acosta United States Attorney By: s/A. Marie Villafaria A. Marie Villafafia Assistant United States Attorney cc: — R. Alexander Acosta, U.S. Attorney Jeffrey Sloman, First Assistant U.S. Attorney You also accuse me of “broaden[ing] the scope of the investigation without any foundation for doing so by adding charges of money laundering and violations of amoney transmitting business to the investigation.” Again, I consulted with the Justice Department’s Money Laundering Section about my analysis before expanding that scope. The duty attorney agreed with my analysis. HOUSE_OVERSIGHT_012581
TAB 19 HOUSE_OVERSIGHT_012582
AO110 (Rev. 04/07) Subpoena tn Testify Before Grand Jury 7 . ; cose UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA TO: P| SUBPOENA TO TESTIFY BEFORE.GRAND JURY FGJ 07-103 (WPB)-Tues. No. OLY-85/1 SUBPOENA FOR: W PERSON @ DOCUMENT(S) OR OBJECTIS) YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date, and time specified below. “[GOURTROOM Grand Jury Room United States District Court | 701 Clematis Street . [BATEAND TIME West Palm Beach, Florida 33401 7/1/2008 10:30 am YOU ARE.ALSO COMMANDED to bring with you the following document(s) or object(s):* ALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA. O Please see additional Information on revi jf This subpoena shall remain in ef{¢pi-uspt? behalf of the court. a “By dem Cee | "T NAME. ADDRESS AND PHONE NUMBER OF ASSISTANT US. ATTORNEY Ann Marie C. Villafafia, Assistant U.S. Attorney ie 1500 South Australian Avenue, Suite 400 + West Palm Beach, Florida 33401-6235 | Tel: (561) 820-8711, ext 3047 * if not applicable, enter “none”. | HOUSE_OVERSIGHT_012583
ATTACHMENT TO GRAND JURY SUBPOENA OLY-85/1 ADDRESSED TO PLEASE BRING THE FOLLOWING DOCUMENTS, ITEMS, AND INFORMATION WITH YOU TO YOUR GRAND JURY APPEARANCE: l. Any and.all notes, letters, cards, gifts, payments, photographs, or other items that you have received from Jeffrey Epstein, MM Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein. 2. Any. and all photographs, whether printed or digital, of Jeffrey Epstein, i Se Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein. 3, Any and all e-mails, instant messages, chats, text messages, voicemails, or telephone messages that_you_have sent_to_and/or received from Jeffrey Epstein, | — es Lesley Groff, Ghislaine Maxwell, and/or any other t employee or associate of J effrey Epstein. 4, A list of all telephone numbers (cellular and “land line”), e-mail addresses, screen names, addresses, and any other contact information that you have for the following persons during the period of January 1, 2003 to the present: a yourself: b Jeffrey Epstein; c d. €. g Lesley Groff; h Ghislaine Maxwell; i. any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine Maxwell; ‘ j. any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine Maxwell; k, any person(s) who communicated with you to arrange appointments to. meet with Jeffrey Epstein and/or Ghislaine Maxwell. 5, Any billing statements for telephone service (cellular and “land line”) for any telephone you used during the period of January 1, 2003 to the present. HOUSE_OVERSIGHT_012584
TAB 20 HOUSE_OVERSIGHT_012585
CONFIDENTIAL PLEA NEGOTIATIONS TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT Epstein pleads guilty (not nolo contendere) to an Information filed by the Palm Beach County State Attorney’s Office charging him with: (a) lewd and lascivious battery on a child, in violation of FI. Stat. 800.04(4); (b) solicitation of minors to érigage in prostitution, in violation of Fl. Stat. 796.03; and (c) engaging in sexual activity with minors at least sixteen years of age, in violation of Fl. Stat. 794.05. Epstein and the State Attorney’s Office make a joint, binding dation that E in pri Epstein agrees to waive all challenges to the information filed by the State and the right to appeal. Epstein agrees that, if any of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and the subject matter. Epstein will not contest that the identified victims are persons who, while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. After Epstein enters his state court plea and is sentenced, the FBI and the U.S, Attorney’s Office will close their investigations into violations of 18 UIS.C. §§ 1591, 2422, and 2423, HOUSE_OVERSIGHT_012586
Each count of §§ 1591, 2422(b) and 2423(6): Base Offerise Level under 261.3: 24 Offense-invelved sexual ‘contact: +2 Counts-do not group;'s6.add'5. [évels-for more:than 5 units, pursnant'te 3D 1.4. Offense Lével 31 Apply Repeat atid: Dangerous Sex Offender against Minors enhanoeriéitt af 4B1.5 ‘Total Offense Level 36 Assuring Criniinal History Category I, advisory guideline range is 188 - 235 months with lifetime supervised release, HOUSE_OVERSIGHT_012587
TAB 21 HOUSE_OVERSIGHT_012588
IN RE: INVESTIGATION OF JEFFREY EPSTEIN / NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney’s Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the “State Attorney’s Office”) have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter “Epstein”); IT APPEARING that the State Attorney’s Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the United States Attorney’s Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein’s background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 371; (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2; (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(8), with minor females; in violation Page | of 7 HOUSE_OVERSIGHT_012589
of Title 18, United States Code, Section 2423(b); and (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(1) and 2; and TT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney’s Office; IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attomey for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days’ of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney’s Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed. Page 2 of 7 HOUSE_OVERSIGHT_012590
Terms of the Agreement: 1, Epstein shall plead guilty (not nolo contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging one (1) count of solicitation of prostitution, in violation of Fl. Stat. § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney’s Office charging Epstein with an offense that requires him to register as a sex offender, that is, the 3 in violation of Florida Statutes Section 796.03 2. Epstein shall make a binding recommendation that the Court impose a thirty (0) month sentence to be divided as follows: (a) (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra. 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney’s Office and Epstein, the details of which are set forth in this agreement. 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney’s Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration. 5. Epstein shall waive all challenges to the Information filed by the State Attorney’s Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. 6. Epstein shall provide to the U.S. Attomey’s Office copies of all Page 3 of 7 HOUSE_OVERSIGHT_012591
10. 11. proposed agreements with the State Attorney’s Office prior to entering into those agreements. The United States shall provide Epstein’s attorneys with a list of Pi through that representative. If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, an Pp exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein’s signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. Epstein’s signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein’s signature on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 HOUSE_OVERSIGHT_012592
sentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008. 12. _ Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States’ request, Epstein agrees to provide an accounting of the gain time he eared during his period of incarceration. 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that the United States Attorney has n In consideration of Epstein’s agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal an against any potential co-conspirators of Epstein, including but not limited to | Lesley Groff, or nn Further, upon execution of this agreement and a plea agreement with the State Attorney’s Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain. grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, inviolate until all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn. Page 5 of 7 HOUSE_OVERSIGHT_012593
ao By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. , By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution, Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury’s investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury’s investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense. //T- /fl /f] Page 6 of 7 HOUSE_OVERSIGHT_012594
By signing this agreement, Epstein asserts and certifies that the above has been read and explained io him, Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated: vA i La Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 HOUSE_OVERSIGHT_012595
By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. Dated: Dated: Dated: 9 [> 07 Dated: R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY COUNSEL TONE FFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 HOUSE_OVERSIGHT_012596









































