,I/17/2007 3:)s Ill FP.Oli: William L. Richey, F William L. Richey, P.A. TO: 1- PAGE: 001 OF 00- FGJ 07.103 (WPB) William Riley and Riley Kiraly ("Riley"). by and through undersigned counsel, hereby move to seal the following filings: (I) this Motion; (2) the order granting this Motion; (3) the Motion of William Riley and Riley Kiraly for an Extension of Time Num• Pro Tune to File Their Reply; (4) the Order Granting the Motion of William Riley and Riley Kiraly for an Extension of Time Nunc• Pro nine to File Their Reply (provided that the Court enters that Order); and (5) the Reply of William Riley and Riley Kiraly to the Goverrunent's Response to the Motion to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel. In support thereof. Riley states as follows: The above-listed documents contain information relating to an ongoing wand jury investigation: thus, pursuant to Fed. R. Crim. P. 6(c)(6), all records and orders related to the grand jury proceedings must be kept under seal to the extent and as long as necessary• to prevent the unauthorized disclosure of a matter occurring before the grand jury. WHEREFORE. William Riley and Riley Kiraly respectfully request that the aforementioned documents be sealed until further Order of this Court. Respectfully submitted, WILLIAM L. RICFIEY, P.A. 201 South Biscayne Boulevard 34". Floor, Miami Center Miami, Florida 33131 Tel: Fax: William L. RI. Fla. Bar No. William L Richey, P.A. 201 South Biscayne Boulevard. 34th Floor, Miami Center, Miami, Florida 331314325 •- Facbimile EFTA00179167

.4/17/::007 CA(M: William L. RIchry, F W1111.3. L. Richey, F.A. TO: PAGE: 00!. CT 007 FG.107-103 (WPB) CERTIFICATE OF SERVICE I hereby certify that on August 17. 2007, the foregoing document will be served via facsimile and U.S. Mail on counsel, as listed on the attached service list. This document was not tiled using CM/ECF because it is being filed under seal. liam L. Richey-1- ‘---> -3- William L Richey, P.A. 201 South Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 33131-1325 - Facsimile EFTA00179168

a/17/2007 3:3a PH FROM: William L. Richey, P William L. Richey, P.A. TO: I PAGE: 996 OF 007 FGJ 07-103 (WPB) Service List In re: Grand Jury Subpoenas FGJ 07-103 (WPB) United States District Court, Southern District of Florida Assistant US Attorney 500 South Australian Avenue, Suite 400 West Palm Beach F orida 33401 Fax: Roy Black, Esquire Black Srebnick Komspan & Stumpf 201 South Biscayne Boulevard. Suite 1300 Miami. Florida 33131 Fax: Wlllam 1. Richey. P.A. 201 South Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 33131-4325 • • Facsimile EFTA00179169

x/17/:;007 5:7F PH PAW: Vallun L. Richey, P WilliAA L. Richey, P.A. TO: 1 PAGE: OT: OF 04- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FGJ 07-103 (WPB) IN RE GRAND JURY SUBPOENAS I)UCES TECUM NUMBERS FILED UNDER SEAL OLY-63 & OLY-64 ORDER GRANTING MOTION OF WILLIAM RILEY AND RILEY KIRALY TO FILE DOCUMENTS UNDER SEAL THIS CAUSE came before the Court on the Motion of William Riley and Riley Kiraly to File Documents Under Seal. Upon review of the Motion. it is hereby ORDERED AND ADJUDGED that good cause has been shown and the Motion is GRANTED. The following documents SHALL BE FILED UNDER SEAL until further Order of the Court: I. Motion of William Riley and Riley Kiraly to File Documents Under Seal: 2. This Order: 3. The Motion of William Riley and Riley Kiraly for an Extension of Time Nunc Pro Tune to File Their Reply; 4. The Order Granting the Motion of William Riley and Riley Kiraly for an Extension of Timc Nunc Pro Tune to File Their Reply (if subsequently entered): and 5. The Reply of William Riley and Riley Kiraly to the Government's Response to the Motion to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel. DONE AND ORDERED in chambers this day of , 2007: at West Palm Beach, Florida. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE cc: William L. Riches, Esutti c Roy Black. Esquire EFTA00179170

(Rev. 06/2005)5^Iled Document Tracking Form Case Number: In to 'Vane, Jury Plaintiff bpot ruts Du (Cs feat Vv) 0 L.) - Go% and OW- 64 UNITED STATES DISTRICT COURT Southern District of Florida F6) T 0 q lo 3 (tAJP71) SEALED DOCUMENT TRACKING FORM Party Filing Matter Under Seal Name: R,09 (3 LA CV , e seR • Address: 101 S.$isco,ti he, sun) 4*- '200 M t avvit 33/3 Telephone: 50c - 3 4.! - C042.1 On behalf of (select one): hevitnit„.nOY-O Plaintiff 42—Defetulent. Jef-f rec.' e psi° rl Date sealed document filed: g -• ILE — 0 '4 If sealed pursuant to statute, cite statute: If sealed pursuant to previously entered protective order, date of order and docket entry number: The matter should remain sealed until: O Conclusion of Trial O Arrest of First Defendant O Case Closing O Conclusion of Direct Appeal arOther: Y,t)1nC(USIO In DE petn eld JUrtj p vocted yui r -f no inotithenai fir'Permanently. Specify the authorizing law, rule, court order is affunettoli pleachols-lortmem4 gem led ixierrctocn-l-ti please The moving party requests that when the sealing period expires, the filed matter should be (select one): O Unsealed and placed in the public portion of the court file O Destroyed O Returned to the party or counsel for the party, as identified above 'FOY' lAni BIZ for:Skate , Salon VSYMpail aftAd StiA m pa( , PA. 0" hei-uxq of- Iv4ervortor J-tffietti eps4ein EFTA00179171

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS ) DUCES TECUM NUMBERS ) CASE No. FGJ 07-103(WPB) OLY-63 and OLY-64 ) ) UNDER SEAL EFTA00179172

UNDER SEAL NOTICE OF UNAVAILABILITY OF COUNSEL FOR INTERVENOR Jeffrey Epstein has moved to intervene in this matter and to quash grand jury subpoenas to investigator William Riley and his firm, Riley Kiraly. Mr. Epstein is represented by undersigned counsel Roy Black. The issues raised by the motions to intervene and to quash have been briefed and the parties await a hearing date from the Court. Undersigned counsel would like to inform the Court that he is out of the jurisdiction on a family vacation until September 1, 2007. We respectfully request that any hearing the Court may scheduled in this matter be scheduled after September 1, 2007, at the Court's discretion. Undersigned counsel spoke with the prosecutor, who indicated that the government objects. Respectfully Submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, PA. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Ph: — Fax: E-Mail: By: .Fve_ R BLACK, Florida Bar No. Counsel for Jeffrey Epstein 2 Black. Srebnick, Kornspan 2015. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131. Phone: • Fax • ,Auw.RoyBlaciccom EFTA00179173

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on fruti • lg. zoo* a true and correct copy of the forging motion was furnished by email and by U.S. mail to: United States Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach, FL 33401. This pleading was not filed using the CM/ECF system because it pertains to a grand jury investigation and therefore it has been filed under seal. By: )S1401146, Foie. ROY BLACK, ESQ. Counsel for Jeffrey Epstein 3 Black. Srebnick, Kornspan 8 O1 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131. Phone: • Fax: • www.RoyBlack.com EFTA00179174

(Rev. 06/2005)Sealed Document Tracking Form UNITED STATES DISTRICT COURT Southern District of Florida Case Number: FGJ07-103 (WPB) OLY-63 & OLY-64 IN RE GRAND JURY SUBPOENA DUCES TECUM ISSUED TO WILLIAM RILEY v. Plaintiff Defendant Party Filing Matter Under Seal On behalf of (select one): SEALED DOCUMENT TRACKING FORM Name: JEFFREY EPSTEIN, INTERVENOR Address: ROY BLACK, 201 S BISCAYNE BLVD, STE 1300, MIAMI, FL 33131 Telephone: Date sealed document filed: 9/12/2007 K Plaintiff K Defendant If sealed pursuant to statute, cite statute: GRAND JURY PROCEEDING If scaled pursuant to previously entered protective order, date of order and docket entry number: The matter should remain scaled until: K Conclusion of Trial K Arrest of First Defendant K Case Closing K Conclusion of Direct Appeal 0 Other: GRAND JURY MATTER IS CONCLUDED K Permanently. Specify the authorizing law, rule, court order: The moving party requests that when the sealing period expires, the filed matter should be (select one): K Unsealed and placed in the public portion of the court file K Destroyed K Returned to the party or counsel for the party, as identified above EFTA00179175

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FILED UNDER SEAL IN RE GRAND JURY SUBPOENA DUCES TECUM ISSUED TO WILLIAM RILEY FGJ 07-103 (WPB) OLY-63 & OLY-64 M.B.D. No. SURREPLY OF JEFFREY EPSTEIN TO UNITED STATES' SURREPLY TO REPLIES FILED BY WITNESS WILLIAM RILEY AND INTERVENOR JEFFREY EPSTEIN RE: MOTION TO QUASH GRAND JURY SUBPOENAS I. In its Surreply, the government, for the first time, after the parties have filed numerous pleadings directed to the enforceability of the challenged subpoena, announced that it was in fact seeking only physical possession of the computers at issue and that it thereafter intended to obtain a search warrant to search the contents of the computers. This Court should not permit the government to substitute a secret ex parte process for the adversarial litigation process between the parties which has been ongoing. Instead of leaving the government free to rummage at will through the contents of the computers based upon the ex parte issuance of a search warrant, the Court should require the government to particularize the subpoena to identify the documents which it is seeking. The government's doing so would enable movants to provide it with the documents falling within the particularized categories so identified, in the same manner as one responding to a particularized document subpoena would do. The process should be no different because the documents are contained within a computer than it is with respect to hard copy documents in the hands of the subpoenaed party. Black. Srebnick, Komspan & Stum 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131- Phone: • Fax: • www.RoyBlack.com EFTA00179176

Contrary to the suggestion of the government, see United States' Surreply at 2, the overbreadth and particularity protections embodied in the Fourth Amendment reasonableness command with respect to subpoenas do not recognize an exception which permits the government to utilize an unlimited, overbroad, and unparticularized grand jury subpoena to obtain custody of a container which it wishes thereafter to search pursuant to a warrant. The particularity and overbreadth arguments which have been advanced by Epstein cannot be mooted by the government's now contending that the purpose of the subpoena is only the seizure of the computers and not their search. The commands of the Fourth Amendment and Rule 17 remain the same: the subpoenaed items must be relevant to the grand jury's investigation, and the items sought must be particularized in the subpoena. Just as the government could not simply serve a subpoena on a business directing that it produce all its file cabinets to the grand jury, neither can it use a grand jury subpoena to compel a citizen to turn over the entire contents of his computers to the grand jury. As has been stressed in prior pleadings directed to this issue, computers contain vast realms of personal documents, information, and data which are simply none of the government's business and should not be exposed to its inspection absent a particularized description of the categories of documents and other information which the government believes relevant to the grand jury's investigation.' The court in In re Grand Jury Subpoena Duces Tecum Dated November 15, 1993, 846 F.Supp. 11 (S.D.N.Y. 1994), was confronted with a similar issue in the context of a grand jury subpoena for the production of all hard drives of computers supplied by X Corporation to certain officers and employees, as well as all computer-accessible data, including all floppy disks, created by the specified officers or employees or their assistants. The Court, drawing upon the See Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law at 19-26. 2 Black. Srebnick. Komspan & Stum 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131. Phone: • Fax: • www.RoyBlack.com EFTA00179177

Second Circuit's narrowing of a subpoena demanding the production of the entire contents of three file cabinets to exclude categories of documents with no conceivable relevance to any legitimate object of investigation in In re Horowitz, 482 F.2d 72, 79-80 (2d Cir. 1973),2 concluded that the subpoena should be interpreted as seeking categories of documents, not categories of computers, and that it was the former category — the documents sought by the government — which was required to be particularly described. 846 F.Supp. at 13. The Court held that, because there were ways in which the government could have narrowed the subpoena to relevant documents, such as documents containing certain key words, the subpoena at issue unnecessarily demanded documents irrelevant to the grand jury inquiry and was, therefore, unreasonably broad under Rule 17. Because the government opposed modification of the subpoena, the Court quashed the subpoena in its entirety, without prejudice to the grand jury's ability to issue a properly narrowed subpoena. Id. at 13-14. See also In re Amato, 2005 WL 1429743 at *11-1'12 (D.Me. June 17, 2005)(granting motion to quash with respect to paragraph of subpoena requesting production of all computers and computer related equipment: "Inasmuch as Category 10 . . . in essence requests the turnover of all computers (and related objects) of both corporations with no express safeguard against a subsequent rummaging through, and seizure of, 2 In Horowitz, the government initially served a grand jury subpoena on the target's accountant, requiring the production of seven categories of documents. Learning from the accountant's grand jury testimony that the target had had three file cabinets of documents removed from his corporate offices and stored at another location, the government issued another grand jury subpoena to the accountant requiring the production of the three file cabinets. The accountant turned the file cabinets over to the United States Attorney's office subject to the agreement that the cabinets would remain unopened until the litigation of a motion to quash. The accountant inventoried the contents of the file cabinets and then moved to quash the subpoena, as later did the targets. Id. at 74-75. On appeal, the Second Circuit noted that the alleged fraud began in 1966, but the file cabinets contained documents dating back to 1951, and therefore limited the enforcement of the subpoena to documents beginning in 1966, with the proviso that earlier- dated documents would be producible if the government made a showing of relevance. The Court also left it open to the targets to demonstrate that a particular category of documents could have no conceivable relevance to any legitimate investigative object. Id. at 79-80. 3 Black. Srebnick, Kornspan 8 mt.1 201S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131- Phone: • Fax: • m4m.RoyBlack.com EFTA00179178

irrelevant as well as relevant data, it cannot withstand Fourth Amendment reasonableness scrutiny"). In the context of the seizure for off-site review of intermingled computerized evidence pursuant to a search warrant, the Ninth Circuit recently stated: In the case of a lawful and reasonable seizure of intermingled computer records for off- site review, . . . our precedents and the general reasonableness mandate of the Fourth Amendment require the supervision of a magistrate. It is not reasonable to allow the government to seize an indeterminately bounded array of computer data only later to set its own standards for review and retention thereof. United States v. Comprehensive Drug Testing, Inc., 473 F.3d 915, 938 (9th Cir. 2006)(emphasis added). Thus, even in the Comprehensive Drug Testing case, in which the government gained possession of the computer data through seizure pursuant to a warrant rather than through a grand jury subpoena, the Court did not hesitate to condemn a governmental fishing expedition through the acquired computer data. Here, where the process was initiated by subpoena, it is only appropriate and proper that the party whose privacy interests are at stake should be able to respond to a determinate, particularized subpoena rather than to an open-ended, limitless subpoena such as the one presently at issue in this case. Movants should not be required to turn over the entire computers to the government for its unfettered rummaging but instead only the particularized relevant documents called for in a properly tailored subpoena. Another peril of the warrant alternative would be the myriad new issues requiring resolution: at issue would be not simply whether there was probable cause for the search of the computers, see United States' Surreply at 2, but also the Fourth Amendment's particularity and overbreadth protections. It does not suffice that, should Epstein be indicted, he would have the opportunity to challenge the probable cause for the search on a motion to suppress. No motion to suppress can ever 4 Black. Srebnick. Kornspan 8 ro rm 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: • Fax: • www.RoyBlack.com EFTA00179179

cure an unwarranted intrusion on personal privacy which lays bare before the government a citizen's private life for its unguided scrutiny and permits government agents to read private materials to which they never should have had access in the first place. The Court must act now to prevent such wholesale intrusion from taking place. The government's overbroad and unparticularized subpoena should be quashed. The government should not be permitted to substitute secret proceedings for participatory ones or review of the computers' contents by F.B.I. agents for the more orderly process triggered by a valid subpoena. H. The government's act-of-production privilege argument, United States' Surreply at 2-3, is facially inconsistent with its contention that it intends, once it has the computers in its custody, to seek a warrant to search their contents. Obtaining such a warrant would require the government to demonstrate probable cause to believe that evidence of the alleged offenses under investigation would be found on the computers, evidence which the government seeks for the purpose of using it against Mr. Epstein if it exists.3 Production of the computers would constitute a testimonial communication that they were in fact the computers which were removed from Mr. Epstein's home, a necessary step in the authentication of any contents found therein which the government might seek to use against Mr. Epstein. It is not the subpoenaed item itself which must be potentially incriminating, but the act of producing that item. See United States v. Ponds, 454 F.3d 313 (D.C.Cir. 2006); see also Reply of Jeffrey Epstein to United States' Response to His Motion to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel ("Epstein Reply") at 5-8. 3 The government's effort at reductio ad absurdum is not well-taken. See United States' Surreply at 2 n.2. If the subpoenaed party's act ofproducing his mother's coffee cake recipe were potentially incriminating, then the act of production would constitute a compelled testimonial communication as to which the subpoenaed party would have the right to assert a Fifth Amendment act-of-production privilege. Black. Srebnick, Komspan & Stumpf 201S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 - drone: -• Fax: • www.RoyBlack.com EFTA00179180

Epstein should not be required to make unprotected assertions that anything in the computers is incriminating as a precondition to asserting the act-of-production privilege. See Ohio v. Reiner, 532 U.S. 17, 21 (2001)("[W]e have emphasized that one of the Fifth Amendment's basic functions . . . is to protect innocent men . . . who otherwise might be ensnared by ambiguous circumstances" (emphasis in original)); Hoffman v. United States, 341 U.S. 479, 486 (1951)("The privilege . . . not only extends to answers that would themselves support a conviction under a federal criminal statute but likewise embraces those which would furnish a link in the chain of evidence needed to prosecute the claimant for a federal crime"). As to the Riley Kiraly billing records, see United States' Surreply at 4, if the subpoena is to be enforced, Riley Kiraly will produce them in redacted form, with material encompassed within the work product privilege deleted. See Epstein Reply at 10-11. The work product privilege belongs jointly to Epstein, and he has rightly asserted that privilege. There can, therefore, be no question of waiver here. Clearly, the government wants more from the billing records than simply the numbers; it has issued an all-encompassing demand, leading to Mr. Epstein's contention that the request is overbroad. Lastly, the government complains that Mr. Riley did not appear to testify even though no motion to quash his testimony had been filed. See United States' Surreply at 1-2. Had such a motion been filed, the government would no doubt have argued that it should be denied as an impermissible blanket assertion of privilege. Mr. Riley will assert the attorney-client and/or work product privilege as necessary on a question-by-question basis during his grand jury appearance. Black. Srebnlck. Kornspan & Stum f 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • done: • Fax: • www.RoyBlack.com EFTA00179181

CONCLUSION The government began this process as an adversarial one — one which afforded Mr. Epstein both notice and an opportunity to be heard. It should not now be permitted to unilaterally convert that process to a secret ex pane search warrant application process and to thereby completely extinguish Mr. Epstein's ability to protect his legitimate his privacy interests. Mr. Epstein is entitled to be involved in this process before - not after — his interests are irreparably injured. Respectfully submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, PA. 201 South Biscayne Boulevard, Suite 1300 Miami, Florida 33131 Ph.: -- Fax: E-Mail: By: ROY LACK Florida Bar No.: Counsel for Jeffrey Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September 12, 2007, a true and correct copy of the forging motion was furnished by facsimile and U.S. mail to:=I=, Esq., U.S. Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach, FL 33401. By: RO k LA K, SQ. Counsel for Je ey Epstein Black. Srebnick. Komspan & Shim 201 S. Biscayne Boulevard. Suite 1300 • Miami, Florida 33131 • Phone: Fax • www.RoyBlack.com EFTA00179182

(Rev. 06/2005)Scakd Document Tracking F- In Re Grand Jury Subpoenas Duces Tecum Numbers OLY-63 and OLY-64 UNITED STATES DISTRICT COURT Southern District of Florida Number: FGJ 07.103 (WPB) c.' 4/S I EX PARTE DECLARATION #2 IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH Party Filing Matter Under Seal On behalf of (select one): SEALED DOCUMENT TRACKING FORM Name: lea u.S. Attorney's Ono Address: 500 S. Australian Ave. Suite 400, WestPalm Beach, FL 33401 Telephone:' ID Plaintiff K Defendant Date sealed document filed: 7/31/2007 If sealed pursuant to statute, cite statute: Fed. R. Grim. P. 6(e) (Grand Jury Material) If sealed pursuant to previously entered protective ogler, date of order and docket entry number: The matter should remain sealed until: K Conclusion of Trial K Arrest of First Defendant CI Case Closing 0 Conclusion of Direct Appeal K Other: ID Permanently. Specify the authorizing law, rule, court order: The moving party requests that when the sealing period expires, the filed matter should be (select one): 0 Unsealed and placed in the public portion of the court file 0 Destroyed 0 Returned to the party or counsel for the party, as identified above Attorney for: Movant Unit(Vttates of America EFTA00179183

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 / FGJ 07-103(WPB) EX PARTE DECLARATION NUMBER TWO IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO OUASH SUBPOENAS FILED UNDER SEAL EFTA00179184

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 FGJ 07-103(WPB) UNDER SEAL ,EX PARTE DECLARATION NUMBER TWO IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO OUASH SUBPOENAS I, Patrick Paige, state that the following is true and correct to the best of my information and belief: 1. I am a duly appointed Deputy Sheriff for Palm Beach County, and have all the powers and duties of a law enforcement officer in and for Palm Beach County, Florida. I have been a Law Enforcement Officer since 1986, after completing training in the Law Enforcement Academy. From 1986 to 1989, I served with the Delray Beach Police Department as a Patrol Officer. From 1989 to present, I have been serving with the Palm Beach County Sheriff's Office. Since 2000, I have been working in the Computer Crimes Unit as a Detective, working as a computer forensic analyst and investigator. Most of my investigations involve child exploitation. I am an instructor for Guidance Software Inc., the creators of EnCase@ computer forensic software, and am an EnCase@ Certified Examiner (EnCE). I have instructed other law enforcement officers with the local, state and federal governments in the area of computer forensics as an instructor for Guidance Software. Page 1 of 3 EFTA00179185

2. I received a phone call from David Kleiman on the morning of July 25, 2007. Mr. Kleiman advised me that he was hired by attorney Roy Black to make three bit-stream copies and one EnCase@ image for each of three computers. Mr. Kleiman asked me if he would be able to use one of the Sheriff's Office's hard drive duplication devices. It may be noted that Mr. Kleiman is former law enforcement and has assisted the Sheriffs Office in computer related examinations and seizures in the past. Mr. Kleiman further stated that he was told the job needed to be done as soon as possible. Mr. Kleiman was meeting with a private investigator who worked with Mr. Black on July 26, 2007 in the morning at Mr. Kleiman's place of employment in Boca Raton. Mr. Kleiman described the investigator as an "old-time New York cop-type." Mr. Kleiman was told the computers had not been used since 2005 so he was trying to determine the size of the hard drives that were in the computers. Mr. Kleiman told me he was going to purchase several 120GB hard drives to do the job. I told Mr. Kleiman that the Logicube machine he wanted to use was not reliable. Mr. Kleiman made the decision to purchase a hard drive duplication device online from a company named Digital Intelligence and have it shipped overnight to his place of employment in Boca Raton. Mr. Kleiman was told someone would be standing by while the process was being completed. Mr. Kleiman advised the private investigator it would take at least 10 hours or more to complete the process. 3. I have not been involved in the investigation of Jeffrey Epstein, but have worked on other cases with Special Agent Special Agent Page 2 of 3 EFTA00179186

and I had lunch together on July 25, 2007, and Roy Black's name came up during our conversation. At that time, I relayed to Special Agent what Mr. Kleiman had told me. I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this 1 n day of July, 2007. Detective Palm Beach County Sheriffs Office Page 3 of 3 EFTA00179187

(Rev. 061200.()Scakd Document Tracking Fon, UNITED STATES DISTRICT COURT Southern District of Florida Number: FGJ 07-103 (WPB) In Re Grand Jury Subpoenas Duces Tecum Numbers OLY-63 and OLY-64 EX PARTE DECLARATION NI IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH SEALED DOCUMENT TRACKING FORM Party Filing Matter Under Seal , Name:'— U.S. Attorney's OMee On behalf of (select one): Address: 500 S. Australian Ave, Suite 400, West Palm Beach, FL 33401 Telephone: a Plaintiff 0 Defendant Date sealed document filed: 7/3112007 If sealed pursuant to statute, cite statute: Fed. R. Grim. P. 6(e) (Grand Jury Maisnal) If sealed pursuant to previously entered protective order, date of order and docket entry number: The matter should remain sealed until: K Conclusion of Trial O Arrest of First Defendant • Case Closing O Conclusion of Direct Appeal O Other: E3 Permanently. Specify the authorizing law, rule, court order: The moving party requests that when the sealing period expires, the filed matter should be (select one): O Unsealed and placed in the public portion of the court file O Destroyed El Returned to the patty or counsel for the party, as identified above Attorney for: !Nonni United Sign of America EFTA00179188

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 FGJ 07-103(WPB) EX PARTE DECLARATION NUMBER ONE IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH SUBPOENAS FILED UNDER SEAL EFTA00179189

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 / FGJ 07-103(WPB) UNDER SEAL EX PARTE DECLARATION NUMBER ONE IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH SUBPOENAS I, state that the following is true and correct to the best of my information and belief: 1. I am currently employed as a Special Agent with the Federal Bureau of Investigation ("FBI") and have been so employed for the past ten years. I am assigned to the Miami Division, Palm Beach County Resident Agency, and for the past three years, I have been assigned to investigate mostly child exploitation cases. 2. In the Spring of 2006, Detective kith the Town of Palm Beach Police Department ("PBPD") contacted me about the investigation of Jeffrey Epstein's solicitation of minors to engage in prostitution and his lewd and lascivious conduct with minors. The FBI opened a case file in July 2006, and I am the case agent assigned to the investigation. 3. At around the same time that the FBI opened its investigation, the U.S. Attorney's Office began a grand jury investigation. I am one of the agents on the Federal Page 1 of 9 ) EFTA00179190

Rule of Criminal Procedure 6(e) list, that is, someone who is authorized to have access to the facts of the investigation and the materials related thereto. 4. As part of the grand jury investigation, a subpoena was issued for all of the physical evidence obtained by PBPD during the course of its investigation, including the evidence seized when PBPD executed the search warrant at Jeffrey Epstein's home in October 2005. 5. From my review of the photographs from the execution of the search warrant and my conversations with Detective , I believe that certain items were purposely removed from Mr. Epstein's home in anticipation of an execution of a search warrant. This includes the three computers which are the subject of grand jury subpoena numbers OLY-63 and OLY-64. 6. I believe that the computers will be helpful to the grand jury investigation in several ways. First, one of the possible crimes that Mr. Epstein has committed is the travel in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor, in violation of Title 18, United States Code, Section 2423(b). Another possible offense is the use of a facility of interstate commerce to persuade, induce, or entice a minor to engage in prostitution or other illicit sexual conduct, in violation of Title 18, United States Code, Section 2422(b). A telephone is a facility of interstate commerce, so evidence of the use of the telephones to arrange appointments for sexual activity is evidence of a violation of Section 2422(b). Page 2 of 9 EFTA00179191

7. From items recovered during the PBPD investigation and the FBI's own investigation, I know that some member or members of Mr. Epstein's staff documented daily messages for Mr. Epstein, to include telephonic and electronic mail messages, utilizing the URL (Uniform Resource Locator) address, http://domsrv0l/foxhaven/wc.dll?Gmax—Msg- Display. Computer printouts displaying this information were recovered by PBPD from the trash located at Mr. Epstein's residence, 358 El Brillo Way, Palm Beach, Florida. One of the electronic message logs on the computer printouts documented a message left for Mr. Epstein on April 11, 2005 at 4:29pm by la, Mr. Epstein's assistant, regarding the availability of an identified underage female to "work". Review of cellular telephone records indicated telephonic contact between telephones utilized by.. and the same identified underage female on April 11, 2005 at 4:24pm. The electronic message logs recovered also displayed other types of appointments and travel plans. 8. Therefore, a review of Mr. Epstein's computers may provide additional electronically stored message logs which could be further evidence of Mr. Epstein's intent to travel to engage in sexual activity with teenagers he recruited from five Palm Beach County high schools. Based upon the investigation, I believe that someone other than Mr. Epstein prepared the computerized calendar and telephone messages. Thus, Mr. Epstein would not be required to authenticate any such documents recovered from the computer. 9. The second way that the computers will assist the grand jury is the possibility that photographs of the crime victims and/or child pornography may appear. I know from Page 3 of 9 EFTA00179192

Detective that, at one time, Mr. Epstein had a security system that automatically downloaded images from surveillance cameras onto a computer. Detective learned about that in an unrelated theft investigation in October 2003. In October 2005, during the execution of the state search warrant at Mr. Epstein's residence, PBPD investigators observed pre-existing surveillance cameras in place but disconnected from recording equipment. The disconnected cables were located in an area where computer equipment appeared to have been removed. The FBI investigation has determined that Mr. Epstein was actively involved in lewd and lascivious conduct with minor females as early as March 2004. To the extent that Mr. Epstein tries to deny that any or all of the victims ever visited his home, video footage of them at the house would rebut such a claim. 10. During the interview of another identified crime victim, it was revealed that Mr. Epstein had taken a picture of her standing near a marble bathtub. She was naked and looking over her shoulder. Mr. Epstein took that photograph at his Palm Beach residence in what the identified crime victim described as a bathroom in Mr. Epstein's master suite. 11. Also, during the FBI's investigation, I interviewed a young woman, "M," who had known Mr. Epstein several years ago, when she was in her late teens/early twenties. The woman was a struggling artist in New York who was specializing in painting nude portraits. Prior to preparing a portrait, "M" would take several photographic studies. Mr. Epstein was very interested in her work and her photographs, and also expressed an interest in the artist's younger sister, "A," who was 16 years' old at the time. Page 4 of 9 EFTA00179193

12. Mr. Epstein and his associate, Ghislaine Maxwell, made arrangements and paid for "M" to fly home to Arizona for the primary purpose of taking artistic photographs of her family members in the nude. This included the artist's younger siblings, that is, two sisters ("A" and a younger sister, age 9 or 10), and her two brothers. Due to the sensitive nature of the photographs, "M" created a photo log to document each image and the order in which it was taken. Later, "M" learned that seven photographs, two of "A" and five of the 9- or 10- year-old, were missing. "M," who was very upset, contacted Mr. Epstein's office and asked for one of Mr. Epstein's assistants to look for the missing photographs. "M" also confronted Mr. Epstein and Ms. Maxwell about the missing photographs, which they claimed they did not possess. A few weeks later "M" received a telephone call from an unidentified caller who stated that the missing photographs were in Mr. Epstein's briefcase. The missing photographs have never been recovered and "M" believes that Mr. Epstein is in possession of them 13. Mr. Epstein and Ms. Maxwell also made arrangements and paid for "A," "M"'s younger sister, age 16, to travel to one of his homes, located in New Mexico. One morning during that visit, Mr. Epstein got into bed with "A." Mr. Epstein told "A" that he felt like "cuddling." "A" described Mr. Epstein's actions as "spooning" and constantly hugging her. 14. During the FBI interview with "A," she became visibly disturbed when recalling an incident with Mr. Epsein at his ranch in New Mexico. "A" stated that one evening Mr. Epstein had come into her bedroom and sat on the bed. Mr. Epstein stroked her Page 5 of 9 EFTA00179194

hair and told her she was beautiful. "A" was unable to recall the remainder of the events for that evening. 15. I have interviewed "M" and "A" about their experiences with Mr. Epstein. Both "M" and "A" are reluctant to divulge their experiences publicly. "M" has also expressed her concern about speaking publicly against Mr. Epstein for fear of reprisals against her or her family. 16. Further evidence of Mr. Epstein's potential interest in underage females and child pornography was the open display of three photographs in his Palm Beach residence which were seized during the execution of the state search warrant. Attached hereto as Exhibit A is a photograph which depicts a prepubescent female toddler exposing her genitalia. Attached hereto as Exhibit B is a photograph which depicts a prepubescent female pulling down her underwear exposing her left buttock. Attached hereto as Exhibit C is a photograph which depicts Mr. Epstein attempting to bite the clothed buttocks of a prepubescent female (the prepubescent female's skirt is raised exposing her underwear). 17. Based upon this information, I believe a review of Mr. Epstein's computers may reveal images depicting crime victims and/or child pornography. In light of "M"' s fear of testifying against Mr. Epstein, the computer's contents may be the only admissible evidence of Mr. Epstein's interest in child pornography at trial (assuming that such evidence is discovered). 18. The information related to the computers also would be helpful to the grand Page 6 of 9 EFTA00179195

jury in trying to determine if any evidence exists that may indicate Mr. Epstein's involvement in the obstruction of justice through the tampering with or destruction of evidence. Additionally, evidence related to the computers may indicate Mr. Epstein's knowledge of guilt. Case law states that attempts to flee or hide or destroy evidence can be considered as evidence of a guilty mind. 19. Other crimes that the grand jury is investigating, which were not the subject of the state investigation, are promotion money laundering, in violation of 18 U.S.C. §§ 1956 and 1957, and aiding and abetting unlawful money transmitting by a financial institution, in violation of 18 U.S.C. § 1960. Both of these offenses involve the transmission of funds between different banking accounts owned by Mr. Epstein in order to promote prostitution. Through the grand jury investigation, documents from bank accounts have been obtained that show transfers of large sums of money (as much as $250,000 on a single day) from one personal Epstein account into an account purportedly owned by JEGE, Inc. (an entity created for the sole purpose of holding Epstein's personal Boeing 727 aircraft), and then to another personal Epstein account. It is believed that the computers may hold information related to those bank accounts and bank transactions. 20. With respect to the computers that are the subject of the pending grand jury subpoenas, through the grand jury investigation, I was asked to interview Janusz Banasiak, the property manager for Jeffrey Epstein's Palm Beach home. Banasiak worked in that position during the time of the execution of the search warrant. I asked Banasiak whether Page 7 of 9 EFTA00179196

he had removed the computers from the Epstein household. He stated that he had not, and that 'ME' and a private investigator, "Paul," had come to the house and taken the computers away. I know from the investigation that `IIIM" is , also known as who sometimes worked as a personal assistant to Jeffrey Epstein. Ms. is considered a target of the investigation, but neither Ms. nor Mr. Epstein is aware of that classification at this time. I know from the investigation that "Paul" is Paul Lavery, a private investigator who has had contact with several identified victims. 21. A grand jury subpoena was served on Mr. Lavery at his residence in Hialeah, Florida. Mr. Lavery hired an attorney and initially refused to respond to the subpoena. Eventually, based upon conversations between Assistant United States Attorney and counsel for Mr. Lavery, a telephonic interview was conducted of Mr. Lavery. During that interview, Mr. Lavery stated that he had traveled to Jeffrey Epstein's home in the fall of 2005 and that a woman (whom he believed was MI) had given him the computer equipment, already in boxes. Mr. Lavery stated that he had the computers for a few days, probably over a weekend, before he delivered the computers to William Riley. Mr. Lavery stated that he did not tamper with the computers while they were in his possession. 22. Based upon the interview of Paul Lavery, grand jury subpoenas were prepared for William Riley and the Custodian of Records of his firm, Riley Kiraly. Riley Kiraly is an independent private investigation firm, with its own offices in Miami, Florida. Attached hereto as Exhibit D are copies of printouts from the Riley Kiraly website, explaining the Page 8 of 9 EFTA00179197

services offered. Neither Mr. Riley nor Riley Kiraly works exclusively for Roy Black or any other lawyer or law firm. 23. The grand jury subpoenas were served via acceptance of fax by William Riley. He did not indicate whether he still had custody of the subpoenaed computers. Based upon the foregoing facts and the additional facts set forth in the Declaration of Detective Patrick L. Paige, Palm Beach County Sheriff's Office, I believe that Mr. Riley either currently has the computers in his possession or knows who has them. At the very least, Mr. Riley can relay to the grand jury his actions concerning the computers that were removed from Mr. Epstein's residence. I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this 3 4h day of July, 2007. Special Agent Federal Bureau of Investigation Page 9 of 9 EFTA00179198

EFTA00179199

GOVERNMENT EXHIBIT C EFTA00179200

GOVERNMENT EXHIBIT B EFTA00179201

Contact Us Page 1 of 1 HOME I COMPANY INFO I CASE MANAGERS I SERVICES I LINKS I NEWS I CONTACT US Riley Kiraly ..Navigate our Site Las News F Al. O. Contact Us News Box r.'7 nflia Contact Us Contact us by e-mail, or phone 24 hours E-Mail Phone Fax Web Site www.rileykiraly.com A License 0001308 Address Commercial Center of Miami 6135 N.W. 167 Street E-26 Miami, FL 33015 William Riley Stephen Kiraly Email of Principals GOVERNMENT D EXH http://www.rileykiraly.conn/contact_us.htm 7/30/2007 EFTA00179202

Company Info Page 1 of 2 HOME I COMPANY INFO I INVESTIGATORS I SERVICES I LINKS I NEWS I CONTACT US ..Navigate our Site Ir ,f 4-....A.fy:t News Box ?mt."' 11104 History Since 1979, Riley Kiraly has provided investigative and case preparation assistance to attorneys and corporate management in the United States, Europe, and Central and South Americas. The firm has an active local, national and international investigative practice, and serves clientele that includes multi-national banks, corporations, law firms and major insurance underwriters. A bilingual staff of fifteen (15) specialists bring many years of experience and expertise from various disciplines. Riley Kiraly has earned a reputation for relentless attention to detail, and is recognized as one of the leading investigative firms in the United States. Riley, Kiraly's commitment to excellence is reflected in every aspect of the firm's operation, from its experienced and qualified support staff to its state- of-the-art communication and production equipment. All resources are utilized to deliver the utmost professional service. The Principals Riley Kiraly is owned by William H. Riley and Stephen N. Kiraly. William H. Riley began his professional investigative experience in 1966 when he joined the City of Miami Police Department. He spent eight years working undercover investigating drug smuggling and money laundering cases throughout the United States, Central and South America. In 1968 he was named Officer of the Year and awarded a Gold Medal for Valor, the department's highest honor, for his undercover work as a Special Investigator for three Dade County Grand Juries, in Mexico and South America. In 1976 Mr. Riley became the Chief Investigator for the Organized Crime / Public Corruption Prosecution Unit of the Dade County State's Attorney's Office. Here he handled major white-collar crime, complex financial, organized medical fraud and corruption investigations resulting in numerous arrests and convictions. In 1979, Mr. Riley left public service and entered the private sector and started his own investigative firm handling investigations dealing with internal theft, bankruptcy fraud, securities fraud and white-collar crimes. Mr. Riley also specializes in locating and evaluating assets and records on a worldwide basis, particularly in complex financial investigations. On Augusts 9, 1999, he was the featured front-page story in USA Today. Email William Riley Stephen N. Kiraly has over thirty-four years of investigative experience in both the public and private sectors. Mr. Kiraly's background Includes extensive experience assisting in complex civil and criminal investigations http://vvww.rileykiraly.com/company_info.Man 7/30/2007 EFTA00179203

Company Info Page 2 of 2 around the world. Mr. Kiraly works with numerous law firms and corporations within the United States and internationally on high profile, complicated litigation matters involving fraud, internal theft, asset location, and recovery as well as a broad spectrum of additional issues arising from criminal and civil matters. Mr. Kiraly began his professional career in 1969 when he joined the Miami Police Department. He spent seven years working narcotic and drug smuggling cases and was assigned to the United States Department of Justice Task Force on Narcotics. He has extensive investigative experience as a Miami Police Department Homicide Detective. Mr. Kiraly has been featured in print and electronic media including the August 9, 1999 front page story on investigators in U.S. Today, on CNN as an investigative expert with Gretta Van Sustern, as well as other national and local television coverage. Email Stephen Kiraly IMp://www.rileykiraly.com/company_info.htm 7/30/2007 EFTA00179204

Services Page 1 of 2 HOME I COMPANY INFO I CASE MANAGERS I SERVICES I LINKS I NEWS I CONTACT US ...Navigate our Site Services t I I News Box We now have bomb and drug dogs available. Services Investigations The central concentration of our Investigative services is on very complex international crime and asset location, high impact litigation preparation, and specialized critical amid( management for corporations. Corporations, law firms and financial institutions look with confidence to Riley Kiraly for consultation and direction in the most sensitive matters affecting business risk. Securitl and systems design is offered to corporate clientele. Personal Protection and safety trail is provided to Individuals. Financial - We are capable of locating and seizing assets worldwide. We have expert experience with asset location and Mareva actions. We are often retained by financial institutions, governments and law firms to provide tactical investigative support in Antor Piller actions. Surveillance Operations - We regularly monitor and video record the activities of thos under investigation. Surveillance can be accomplished at any time in almost any state c country. Invaluable evidence and facts are gathered for litigation, asset location, custoc issues, internal theft or any tome you simply need to know. Background Investigations - Detailed background Investigations of witnesses, litigant parties in M&A matters, employees or prospective partners or employees. Locates - Whether a person is a witness, defendant, debtor, suspect, or fugitive, we ha. the experience and expertise to locate them. Labor Related Investigations - We routinely assist management in matters involving internal theft, allegations of misconduct, sexual harassment, workplaCe violence, misuse company computer systems and critical incident handling. http://www.rileykiraly.con-ilservices.htin 7/30/2007 EFTA00179205

Services Page 2 of 2 Physical Security and Risk Analysis - Our detailed security surveys and penetration studies allow management to control risk, evaluate existing security procedures. We provide expert, unbiased reports on internal or contract security operations, budgeting 2 staffing. Electronic Countermeasures Survey - This service is provided to corporations who suspect their phones or business has been Illegally monitored in violation of law. Countermeasure services are also available to those in domestic litigation who feel the o party tapped their phones. Personal and Executive Protection - Michael Soppelsa supervises other highly trainer professionals in providing protection for our clients who require a secure environment at home or while traveling. We train our clients and their employees in personal security measures. Individual firearms training is also available. Air Travel Security - We develop and Implement airport and air travel security and dru interdiction programs for airlines and corporations flying to and from the United States a South and Central America. http://www.rileykiraly.com/services.htm 7/30/2007 EFTA00179206

(Rev. 06/2005)Sealed Document Tracking For UNITED STATES DISTRICT COURT Southern District of Florida Number: FGJ 07-103 (We) In Re Grand Jury Subpoenas Ducts Tecum Numbers OLY-63 and OLY-64 -n r- F- a rri •-• C-- to Cr.- -4 7 1' DECLARATION OF IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH '411 Party Filing Mailer Under Seal On behalf of (select one): SEALED DOCUMENT TRACKING FORM Name: , u.S. Attorneys Office Address: 500 S. AusSallan Ave, Stile 400. West Palm Beach, FL 33401 Telephone: 0 Plaintiff 0 Defendant Date sealed document filed: 713112007 If sealed pursuant to statute, cite statute: Fed. R. Grim. P. 6(e) (Grand Jury Material) If sealed pursuant to previously entered protective order, date of order and docket entry number: The matter should remain sealed until: 0 Conclusion of Trial K Arrest of First Defendant Case Closing 0 Conclusion of Direct Appeal El Other: o Permanently. Specify the authorizing law, rule, court order: The moving party requests that when the sealing period expires, the filed matter should be (select one): 0 Unsealed and placed in the public portion of the court file 0 Destroyed El Returned to the party or counsel for the party, as identified above Attorney for: Movant United Sties of America EFTA00179207

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 I DE LARATION OF FGJ 07-103(WPB) FILED UNDER SEAL EFTA00179208

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 FGJ 07-103(WPB) UNDER SEAL DECLARATION state that the following is true and correct to the best of my information and belief: 1. I am currently employed as a detective with the Town of Palm Beach Police Department ("PBPD") and have been so employed for the past 16 years. 2. Beginning in September, 2005, I was the lead investigator in PBPD's investigation ofJeffrey Epstein's solicitation of minors to engage in prostitution and his lewd and lascivious conduct with minors. 3. Prior to my involvement in that investigation, as part of my employment with PBPD, I was asked to go to Jeffrey Epstein's home in October of 2003, to assist in an investigation of a possible theft. While present in Mr. Epstein's home, I was asked to assist in the installation of some temporary surveillance cameras. I also observed the pre-existing security system, which included the automatic downloading of the images from the pre- existing security cameras onto a personal computer. This personal computer was located in an area that appeared to be office. I know from my investigation that Sarah Page 1 of 4 EFTA00179209

works as a personal assistant to Mr. Epstein. After completing the theft investigation, the temporary surveillance cameras were removed, but I believe that the pre-existing security cameras remained. 4. While present in the house, I also observed two other computers — one in an area I refer to as "Jeffrey Epstein's office," and the other in the pool cabana. 5. In October 2005, as part of my investigation of Jeffrey Epstein, I approached the Palm Beach County State Attorney's Office ("SAO") about obtaining a search warrant. I know that, prior to that date, Mr. Epstein was aware of an ongoing criminal investigation conducted by the Palm Beach Police Department. 6. On October 18, 2005, with the help of the SAO, I prepared a Search Warrant Application and Affidavit and presented them to Judge Laura Johnson for her signature. The judge granted the warrant and it was executed on October 20, 2005. Attached hereto as Exhibit R-1 is a true and correct copy of the warrant application and the warrant signed by Judge Johnson. Among the items that I was authorized to search for and seize was: (1) Computers, including any electronic magnetic, optical, electrochemical, or other high speed data processing device performing logical, arithmetic, or storage functions; data storage facilities such as magnetic tape, hard disk, floppy disk or drum, or cd rom; communications facilities directly relating to or operating in conjunction with such device; devices for printing records of data; and such records or data Page 2 of 4 EFTA00179210

produced in various forms; manuals, documents, or instructional material relating to such devices. (2) Computer, personal computers, computer peripherals, modems, computer printers, floppy disk drives, hard disk drives, diskettes, tapes, computer printouts, software, computer programs and applications, computer manuals, system documentation. 7. When the search warrant was executed, several items were conspicuously absent. For example, there were several hanging file folders that had their contents removed, and the pre-existing security cameras that I had observed during my last visit to Mr. Epstein's residence were in place but were not connected to recording equipment. In addition, at each location where a computer had been present, computer monitors, printers, and other peripheral devices were present but the computers (CPU-Central processing unit) themselves were removed. 8. Attached hereto as Exhibit R-2 is a photograph taken at the time of the execution of the Search Warrant of the desk in the area that I believe was Jeffrey Epstein's office. 9. Attached hereto as Exhibit R-3 is a photograph taken at the time of the execution of the Search Warrant of the desk in the area that I believe was office. Also located in that office were cables connected to surveillance recording equipment located throughout the home. The cables were not connected to any computer, but were near Page 3 of 4 EFTA00179211

the area from which the CPU was removed, leading me to believe that they had been connected to the removed CPU. 10. Attached hereto as Exhibit R-4 is a photograph taken at the time of the execution of the Search Warrant of the desk in the pool cabana. 11. One older CPU was discovered during the search, which contained video segments showing the presence of various persons in the house, including possibly one or more victims from the security cameras. There also was a video segment showing Jeffrey Epstein working at his desk in his office. 12. In the Spring of 2006, I approached the Federal Bureau of Investigation ("FBI") about assisting in the investigation of possible federal charges against Mr. Epstein. The FBI began an independent investigation. I have been called upon to provide background information, but I have not been actively involved in the FBI's investigation. I am not aware of the present location of the computers removed from Mr. Epstein's home. I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this , 0 day of July, 2007. Detective Town of Page 4 of 4 ce Department EFTA00179212

AFFIDAVI"A LND APPLICATION F R SEARCH WARRANT IN THE CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA THE STATE OF FLORIDA, ) COUNTY OF PALM BEACH ) BEFORE ME: Honorable Judge Laura Johnson in and for Palm Beach County, personally appeared this day: Detective d COPY who being by me first duly sworn, deposes and says that he believes and has good reason to believe that a certain Premises located in Palm Beach Florida, described as follows, to-wit: 358 El Brillo Road Palm Beach, Florida 33480 To reach the premise desired to be searched, begin at the middle span of the Royal Park Bridge and travel East on Royal Palm Way approximately .6 (six tenths) of a mile until you reach South County Road. At South County Road, make a right or southbound turn and travel approximately .8 (eight tenths) of a mile to El Brillo Way. At El Brillo Way, make a right or westbound turn and travel approximately .1 (one tenth) of a mile to the last house on the South side of El Brillo clearly marked with the number 358. The premises desired to be searched is two story, single family residence made of CBS construction. The residence is pink in color with white trim and has a white concrete tile roof. The residence has two separate driveway entrances from El Brillo paved in large white tiles. The eastern most driveway is separated by a large white in color concrete wall with black in color numbers "358" clearly displayed from El Brillo and leads to the east side of the residence. On the east side of residence, there are three single car garage doors, which are white in color and an entry door also white in color to South. Each driveway entrance has a white in color call box, which is fixed on the east side of the driveways. The western most driveway leads to the North side of the residence, to a large white in color double door on the first floor. The second story of the North side of the residence shows a small walkway with a white in color metal railway, and leads to three glass jalousie style doors. On the South East corner of the residence is a single story structure, made of CBS construction and is white in color with a white concrete tile roof. To enter and search the afore described place and premise together with the yard and curtilage thereof, and any and all outbuildings and vehicles thereon, and any persons residing therein, and any other person therein reasonably believed to be connected with said illegal activity. This is a complete description of the residence desired to be searched, including the curtilage attached thereof. being the Premises occupied by or under the control of: Jeffrey Epstein W/M Date of Birth GOVERNMENT OMNI R-1 Page I EFTA00179213

and there is now being kept or "‘e above described Premises certain. 1) Computers, including any electronic magnetic, optical, electrochemical, or other high speed data processing device performing logical, arithmetic, or storage functions; data storage facilities such as magnetic tape, hard disk, floppy disk or drum, or cd rom; communications facilities directly relating to or operating in conjunction with such device; devices for printing records of data; and such records or data produced in various forms; manuals, documents, or instructional material relating to such devices. 2) Computers, personal computers, computer peripherals, modems, computer printers, floppy disk drives, hard disk drives, diskettes, tapes, computer printouts, computer software, computer programs and applications, computer manuals, system documentation. 3) Cameras, photographs, negatives, motion pictures, videotapes, magazines, books, and all other depictions of minors in sexual activity . 4) Any device or equipment that can be used to transfer images to a computer readable format. 5) Any written documentation or item containing password or encryption codes. 6) Any notes, ledger, personal phone books, roladex, books and any form of recording data of records of payments, telephone numbers and names of girls that have frequented the house. 7) Any sexual devices to which was used on the witness/victims. 8) Any hair fiber, semen, or other bodily fluids. which is being kept and used in violation of the laws of the State of Florida, to-wit: the laws prohibiting: I. Sexual Activity with certain minors FSS 794.05(1) r degree Felony 2. Lewd and Lascivious Molestation FSS 800.04(5c2) 2"d degree Felony That the facts establishing the grounds for this application and the probable cause for believing that such facts exist are as follows: On 03/15/2005, Det went to where she met with a fourteen year old white female. The female will hereinafter referred to as "The Victim." Also present was Kathy Back, the victim's thera ist. During an audio taped interview, spoke with the victim who admitted to knowing that worked for a wealthy man and possibly did sexual favors for him. She also admitted that had offered her an opportunity to make money. The victim identified boss as a white male named "Jeff who lived in Palm Beach Later positively identified as Jeffrey Epstein). The victim ex lained that she was first approached by to go with her to Jeff's house. The victim stated told her that she would pick her up at the victims house on Sunday. The victim was not sure of the exact dates but knew it was a Sunday. According to the victim along with a Hispanic female, later identified as MI picked her up at her fathers house on The victim told her father that they were going shopping. It was later confirmed by the victim's father picked his daughter up on February 6, 2005. According to the victim's father, drove that Page 2 EFTA00179214

a pick up truck. drove t" victim to Palm Beach. Sometime on the way there, a conversation occurred between and thL . ictim whereas reportedly told , victim that if Jeff asked her (the victim) age, she should say she was eighteen. The victim recalled that Jeff's house was on a dead end street. The victim described Epstein's house as a two story pink house with a Cadillac Escalade parked in the driveway. The girls walked up a driveway, past what appeared to be a small guard/security room. In fact, the victim recalled a male approaching them asking what they wanted. stated they were there to see Jeff. The male allowed them to continue walking up to the house. The victim stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly after, Epstein and a woman, described as white with blond hair entered the kitchen. The victim believed the woman was Epstein's assistant. The victim added that the woman did not seem friendly and kept her responses short and direct. Epstein introduced himself to the victim as Jeff . The victim described Epstein as being approximately forty-five years old, a long face, and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving the victim alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. The victim stated the woman instructed her to follow her upstairs, which she did. The victim recalled walking up a flight of stairs, lined with photographs, to a room. Upon entering the room there was a large bathroom to the right. The victim recalled a hot pink and green sofa in the room. There was a door on each side of the sofa. The victim recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. According to the victim, the woman led her to a room that had a massage table in it. The woman started to fix up the room, putting the covers on the table and taking lotions out. She then told the victim that Epstein would be up in a second. The woman left the room, and soon after, Epstein walked in wearing only a towel and told the victim to take off her clothes. The victim stated he was stem when he told her to take off her clothes. The victim said she did not know what to do as she was the only one there in the room. The victim took off her shirt leaving her bra on. Epstein, had removed his towel and told the victim to take off everything . The victim stated Epstein exposed himself when he took his towel off, placing it on the floor as he laid down on the table. The victim stated she removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. As the victim began to give Epstein the massage, he told her to get on his back. The victim stated she straddled herself on Epstein s back. The victim stated her exposed buttocks were touching Epstein s bare buttocks. The victim said Epstein was specific in his instruction to her on how to massage, telling her to go clockwise, etc. Epstein then turned over and instructed the victim, to massage his boobs. The victim resumed massaging his chest area. The victim was now standing on the ground. Epstein turned to his side, started to rub his penis in an up and down motion. The victim stated Epstein held on to the small of her back as she massaged his chest and shoulder area. Epstein pulled out a purple vibrator and began to massage her vaginal area. The victim stated there was no penetration as the vibrator was on top of her underwear. The victim recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. E stein then left the room and the victim got dressed. She went back downstairs where she met with . The victim admitted to getting paid three hundred dollars in cash from Epstein. Before they left, Epstein asked the victim to leave her phone number. As they were leaving the house, stated she received only two hundred dollars that day for bringing her. Page 3 EFTA00179215

On October 3, 2O051S.1 T responded to the address of and viewed her vehicle parked in the driveway. Sgt. and I kn, xed on the door and met with was told that we were investigating a claim involving Jeffrey Epstein of El Brillo in Palm Beach. was asked if she wanted to accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. Upon entry in the unmarked Detective vehicle, I placed a tape recorder within the vehicle to record any conversations within the vehicle. During the ride back to the police station, advised she is attending I in the and is majoring in journalism. Upon our arrival at the police station, was brought to the interview room in the Detective Bureau. I explained to that I appreciated her willingness to assist us and informed her that should she desire to leave at any time she may do so. I further explained the interview room door is only closed for privacy. stated she understood. During the taped sworn interview was asked how she became in co tact with Epstein. stated back when she turned 17 of age she was approached by a friend in the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. (Unknown last name) and MIII(Un known last name) picked her up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as M. She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom . -arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. then left the room and informed her Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He laid on the table onto his stomach and picked a massage oil for to rub on him. During the massage, stated "He tried to touch me and I sit him." I asked how did he tried to touch her. He grabbed her buttocks and she felt uncomfortable. MI also stated Epstein has a vibrator which is large and white in color. told Epstein, I'll massage you but I don't want to be touched. stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200.00 for the massage. He explained, I know ou're not comfortable, but I'll pay you if you bring some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. was asked how many girls did she brio in total to stein. stated six that she can remember. stated she brought MIMS i. (16 female), IN (16 female), and at the time they were brought to Epstein's house, all the girls were 14 through 16 years of age. I asked which one was the youn est. advised the victim was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and some touching. I asked her if the victim was aware. She stated every girl she brought knew what to expect. She explained she knew the victim wanted to make money . She approached the victim and explained about going to work for Jeff. The victim agreed and arrangements were made to.1 the victim to Epstein's house on a weekend. stated that she and (Later identified as Figueroa) picked up the victim at the victim's house. They traveled to E ns House and entered through the kitchen door. They met with the house chef and Epstein's assistant M. The victim was introduced to Epstein while they were in the kitchen area. mg led the victim upstairs and Epstein went upstairs. When the massage was over, the victim returned to the kitchen area. Page 4 EFTA00179216

atated she was paid $200 n^ for bringing the victim to Epstein's hnnse. atated the victim told her she was paid $300.00 the massage. Back in the vehicle, oson asked the victim what happened. The victim told her about the massage and they went shopping. =stated the victim was the last person she brow ht to Epstein. She further stated that she had changed her cellular number to avoid being contacted She continued that when Epstein announces to his assistant that he is traveling to Palm Beach, would contact to arrange girls for Epstein. MEstated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. further stated that =still tries to call the house and leaves messages. With the assistance of we were able to' tify , DOB "NM DOB MIE" DOB a and I DOB Sgt "Illentered the room and explained that based on her own statements, she had implicated herself by bringing underage girls to Epsteins house. was aware of what she had stated and wished to assist further in hopes to receive a lesser charge . provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As =was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment "I'm like a Heidi Fliess". (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. Sgt and I went to speak with We met with "Mother) at the front door. We explained the ongoing in vesti ation and felt tha may have additional information as we had information that she had "worked" for Jeff . ntroduced us to her husband and allowed us entry into the home. We sat in the dining room and met with Date of Birth As she was under the age of eighteen, was advised we would be speakin with her. She expressed if her daughter had information, she wanted to assist. As we interviewed ig she denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's House with approximately eight months ago, and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that a was withholding information from us. She made several comments as to she has put the entire incident behind her. I left my direct telephone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask her again after we left as to what happened at Epstein's house. I informed her thathad my telephone number and hopefully she would call. On October 4, 2005, Det and I drove to the home and met with Connie al . During a sworn taped statement, stated she was taken to house by She was told she could make money working for Jeff. She was told she would have to provide a massage to Jeff. stated upon her arrival to the house she was brought to the kitchen area by They met with the house chef who was already in the kitchen area. stated would wait for her in the kitchen. She was introduced to is Jeff's assistant, and was brought upstairs to the mater bedroom. Mprepared the room and se table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she kept her clothes on during the massage. She advised sometime during the massage, Epstein grabbed her buttocks and pulled her close to him. said she was uncomfortable by the incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massa e. I asked if she has any formal training in massages to which she replied no. I asked her if received any monies for taking her to perform the massage. Page 5 EFTA00179217

stated also recei• i money for Lakin_ received for bringing he. .o Epstein. occassion with and another girl, I ME, while was taken upstairs by uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that Shad attempted to reach via cell phone. A voice mail messa e on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as .who requested to call her back reference the police questioning. This voice mail message was recorded onto a micro cassette. rovided the incoming telephone number as 1 . 1 stated she inadvertently told about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Jeff. asked her what was going on at the house that the police would be asking questions. stated then called Jeff and Eland asked what was going on reference the ongoing police investigation. According to , . a contact Eland do not provide any more information to has since then been trying to contact her to ask about the I instructed not to as she would notify Jeff Epstein and. what was transpiring. On October4, 2005, I made telephone contact with .who had left several messages on voice mail. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to_speak of this incident in front of her mother. At approximately 15:48 pm I made telephone contact with II. During a taped recorded statement, . stated the following: Approximately a year ago, when she was sixteen years of age, took her to Jeff's house twice. The first time she went, her there but was i—sure in the amount of monies stated she retume, o Epstein's house on another UM stated she waited in the kitchen with stated she only did the massage once as she was drove to the house. They entered throsigt the kitchen area where she was introduced to and Jeff. She was taken upstairs to a bedroom by IM and set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wearing a towel . He laid on the table and picked out a lotion forgo rub on him. At one point during the massae, he tried to remove her shirt at which point she became very upset and discontinued the massage. I Both and Jeffrey had a verbal disagreement at which time she left without being paid. no money for that day. also said that had told her if she was uncomfortable with what was She got with who was sittin in the kitchen and told her "let's go." ,advised she received going on, to let him know and he'll stop. She knew that the more you do the more you get paid. 'advised that several weeks later, she agreed to be taken a second time by Once they arrived at the residence, sat in the kitchen, and. took her upstairs to the master bedroom again. .set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wearing a towel. He laid on the.table and picked out a lotion foil to rub on him. At one point during the massage, he tried to touch her buttocks. As was wearing tight jeans and had a tight belt on Jeff was unable to touch her buttocks. Jeff then rolled onto his back during the massa e, he attempted to touch her breasts. II then became upset again and told she didn't want to be touched. discontinued the massage and was paid $200.00. I then went downstairs where was waiting for her. She told she wanted to leave. said she never returned to the house. stated she is aware that her friend, was also at the house and had a problem with Jeff. She provided a telephone number for The interview was concluded and the micro cassettes were turn in as evidence. Page 6 EFTA00179218

I later researched= id discovered she resides in Royal Pp'—) each. Det= and I drove to Royal Palm Beach and mt., withwithl at her residence .. . in Royal Palm Beach. agreed to speak with us in the kitchen area. During a sworn to d statement, stated the following: On or about November 2004, She was approached by and asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. = picked her up and drove her to a house in Palm Beach. She was brought into the kitchen area of the house. She further stated that... and )came with them. They were brought into the kitchen where she was introduced to Jeff and other females= stated she was introduced to a female helper of Jeff, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with... The assistant brought her upstairs intoser bedroom area. The assistant set up the massage table and put out lotions to be used. She told, Jeff would be available in a minute. Jeff entered the room wearing only a towel. Jeff removernsel, exposing himself , laid on the massage table and picked a lotion to rub on his thighs and back. further stated la the massage, Jeff asked her to remove her clothes. She complied and reseither pants and blouse. didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massa e and at one point she straddled him to massage his back, which touched his buttocks with hers. was instructed to return to the grow a which Jeff turned to have his chest rubbed. advised she was unsure if he was masturbating. did not want to look at his penis area because she was uncomfortable. Jeff removed a large white vibrator which was next to the bed and turned it on. stated he began rubbing the vibrator over her thong underwear on her vagina area. Shortly thereafter, Jeff ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, was paid either $350.00 or $400.00. She stated she wasn't sure , but knows it was close to $400.00. At the conclusion of the interview, stated she never returned to provide a massage for Jeff. She advised she was ashamed and uncomfortable with the situation. At approximately 2:10 pm, Det and I rut with II at her residence. As Ill was only seventeen years of age, I had notified her mother-I , that she would be interviewed reference'an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted■ to cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen, during the month of September 2004 she was approached by for a chance to make money. Ill was friends did for Jef f. with the friends had been previously told by her friends of and knew the same people. called a person known to as. and scheduled the appointment. picked up and drove her to Palm beach to a street called Brillo Way. They drove to the end of the street and entered a large driveway. They entered the kitchen area of the house and met with Jeff. li was introduced to Jeff. Elstated she observed numerous photographs of naked young girls throughout the house. led upstairs to the main bedroom area and set u the room with a massage table and set out the oils. dimmed the lights and turned on soft music. exited the room and Jeff entered the room wearing only a towel. Jeff picked a oils and instructed her to rub his legs, under his buttocks, back and chest area. Jeff asked her to get comfortable. III advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly area. Page 7 EFTA00179219

During the massage, Jeff removed his towel and laid on the massage table naked. Aarubbed his chest area, Jeff attempted to reach do her ants through the buttocks area h !.ver was unable to due to the tightness of the jeans and a tight belt. liadvised Jeff began to masturbate as she rubbed his chest. Jeff moaned as she rubbed his chest. She observed he was continuing to masturbate and attempted to reach up her tank top and touch her breasts. i pulled back and Jeff stopped. However, he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. I asked Mif she knew the difference about circumcised and not circumcised meant. She explained she knew and advised Jeff was circumcised. MI was paid $200.00 for the massage. And left the area. She met with MMI who was waiting in the kitchen area and left the house. then explained she never provided another massage for Jeff. She did however, go to the house with and as they took another friend of Robsons. Madvised she was present when went to work for Jeff. She advised she rode over and sat in the kitchen area with to wait for a advised while they waited for I= the house chef prepared lunch for them as it was almost lunchtime when they went. As was finished with the massage, they left the area. I asked if ever told her what would be expected when she provided a massage. Mstated yes, told her that a massage would be expected possibly naked and possibly some touching involved. has no formal training in providing massages. II. spoke about a third and last time she went to Jeff's house. drove another girl, who is friend, to Jeff's house, stated knew that had made money, massaging Jeff and wanted to make money herself. took them in the kitchen area of the house and introduced to ll and -took upstairs to the main bedroom. advised she doesn't know what happened as did not speak about what happened in the room received $100.00 from for going with her to Jeff's house and recommending la was unable to remember telephone number. The interview was concluded and we left the area. On October 6, 2005, at 11:45 am, I met with at j and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previously ti n with statement, stated she knew thatwho told her she was interviewed by detectives. During a sworn taped worked for Jeff in Palm Beach. advised she has been there a lot of times for massages. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing massages and would have to remove clothing but if she felt uncomfortable just to say so and Jeff would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Jeff a pervert and he kept pushing to go further and further. explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently, admitted to removing her clothes and staying in her thong underwear to provide a massage. explained he wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "Jeff would try to get away with more and more on each massage". Originally, MII drove her to the house for the original massage. left. her cell phone number and every tirrVner would come into town,. would call her for an appointment. Each time she went, would meet her at the kitchen door area. She would bring her upstairs and prepare the massage table. advised Jeff would ask hesiestions about her. He knew she was a soccer player and would be attending . I asked = if he knew her real age, stated Jeff didn't care. The most recent massage she provided was on October 1, 2005. Page 8 EFTA00179220

During the massage, she asked Jeff if she could borrow one of his vehicles to visit her family and boyfriend in Orlando. Jeff had told her she ild borrow one of his vehicles but late ated he would rent her a car. She continued with the massage as Jeff grabbed her buttocks and caressed the buttocks checks. I asked if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. =was asked if he ever used a vibrator on her. Illwas aware of the vibrator but advised she never would allow him to use the vibrator on her. She described the vibrator as the large white vibrator with alise head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. = advised she had been doing the massage for approximately two years which meant she would have started doing massages for Jeff at the age of sixteen. In stated she was contacted by Non October 3, 2005. =had informed her that Jeff had rented her a new Nissan Sentra and she should come by the house to pick it up. .informed she would have the car for a month. gm stated Jeff knew her car was not working properly and had missed appointments in the past because of her car being inoperable. =explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house. explained she took I , a friend of hers who has returned to Orlando to attend college. I asked if she ever allowed another female in the room. MI advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the Gym area of and located the Silver Nissan Sentra bearing Florida . The vehicle is registered to Dollar rent a car out of the Palm Beach International Airport. t g On October, 11, 2005, Det and I had traveled to Jacksonville, Florida and met with date of birth, explained she had gone to E steins house since she was sixteen. She explained she was brought to the house to perform a massage by Once she began explaining that the massage immediately escalated to other things, she further explained she had gone to the house hundreds of times. Instated she became his "number one girl." She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massage his chest area. li stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers.. explained Epstein would continue this rocess until he ejaculated. He would then utilize a vibrator/massager on her vagina until. ejaculated. advised that during her frequent visits, Epstein asked for her real age,. stated she was sixteen. Epstein advised her not to tell anyone her real age. li advised that thin s escalated within the home as Epstein would pay M to have intercourse with his assistant, Epstein would watch and masturbate as he was watchin . Occasionally, Epstein would then join in during the intercourse and provide oral sex to both II and This occurred during the time. was sixteen years of age. I n advised this continued to escalate and occurred during two years. The routine became familiar to M. Epstein's assistant III would telephone her every time Epaein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. = stated Epstein would photograph them naked and having sex and proudly display the photographs within the home. I continued to come to the house and was paid a stated during a massage involving massage bed and inserted his penis into her vagina. vagina. III became upset over this . roximately $400.00 to $600.00 every time she went. , Epstein turned on to her stomach on the stated Epstein began to pump his penis in her Page 9 EFTA00179221

She said her head was being held against the bed forcibly, as he continued to pump inside her. She screamed no and Epstein stopped. She t him that she did not want to have 1 Denis inside of her. Epstein apologized for his actions and subsequently paid her a thousand dollars for that visit. =stated she knows he still displays her photographs through out the house. Your affiant recalled working a previous case within Epstein's residence on October 5, 2003, when Epstein reported a theft from within his house. A former, disgruntled houseman was suspected in stealing monies from the house. At that time, I observed several covert cameras which, would capture and record images of anyone within the residence. Epstein had purchased covert cameras which were built in wall clocks and table clocks. These images were then downloaded onto a proprietary spy ware.software for later viewing. WHEREOF, affiant make this affidavit and pray the issuance of a search warrant in due form of law for the search of the above described premises for the said property, heretofore described, and for the seizure and safe keeping of the property, subject to the order of this Honorable Court or such other Court having jurisdiction over the offense, by the duly constituted officers of the law. Sworn to and subscribed before me this le day of October, 2005 . 7Th JUDGE in and for Palm Beach County, Florida Page 10 EFTA00179222

(ATTACH TO AFFIDAVIT) f5CUPY SEARCH WARRANT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA THE STATE OF FLORIDA ) COUNTY OF PALM BEACH ) IN THE NAME OF THE STATE OF FLORIDA, TO ALL AND SINGULAR: The Sheri ff of Palm Beach County, Florida, and his lawful Deputies, All Police Officers in Palm Beach County, Florida, The Commissioner of the Florida Bureau of Law Enforcement or any of his Duly Constituted Agents to-wit: Detective WHEREAS, complaint on oath and in writing, supported by affidavit of a credible witness, or witnesses, to wit: Detective- which is attached hereto and made a part hereof, has this day been made before the undersigned: Judge Laura Johnson (Circuit)(County) Court Judge in and for Palm Beach County, Florida, and WHEREAS, said facts made known to me and considered by me have caused me to certify and find that the facts set forth in said affidavit show and constitute probable cause for the issuance of this warrant and the Court being satisfied of the existence of said grounds set forth in the affidavit and that the laws of the State of Florida have been violated on or in a Premises known and described as follows, to-wit: 358 El Brillo Road Palm Beach, Florida 33480 To reach the premise desired to be searched, begin at the middle span of the Royal Park Bridge and travel East on Royal Palm Way approximately .6 (six tenths) of a tni le until you reach South County Road. At South County Road, make a right or southbound turn and travel approximately .8 (eight tenths) of a mile to El Brillo Way. At El Brillo Way, make a right or westbound turn and travel approximately . I (one tenth) of a mile to the last house on the South side of El Brillo clearly marked with the number 358. The premises desired to be searched is two story, single family residence made of CBS construction. The residence is pink in color with white trim and has a white concrete tile roof. The residence has two separate driveway entrances from El Brillo paved in large white tiles. The eastem most driveway is separated by a large white in color concrete wall with black in color numbers "358" clearly displayed from El Brillo and leads to the east side of the residence. EFTA00179223

On the east side orresidence, therr v three single car garage doors, which ar tithe in color and an entry door also white in color to South. Each anveway entrance has a white in color call buA, which is fixed on the east side of the driveways. The western most driveway leads to the North side of the residence, to a large white in color double door on the first floor. The second story of the North side of the residence shows a small walkway with a white in color metal railway, and leads to three glass jalousie style doors. On the South East corner of the residence is a single story structure, made of CBS construction and is white in color with a white concrete tile roof. To enter and search the afore described place and premise together with the yard and curtilage thereof, and any and all outbuildings and vehicles thereon, and any persons residing therein, and any other person therein reasonably believed to be connected with said illegal activity. This is a complete description of the residence desired to be searched, including the curtilage attached thereof. being the premises occupied or under the control of: Jeffrey Epstein W/M Date of Birth and there is now being kept in the above described (vehicle)(premises) certain: 1) Computers, including any electronic magnetic, optical, electrochemical, or other high speed data processing device performing logical, arithmetic, or storage functions; data storage facilities such as magnetic tape, hard disk, floppy disk or drum, or cd rom; communications facilities directly relating to or operating in conjunction with such device; devices for printing records of data; and such records or data produced in various forms; manuals, documents, or instructional material relating to such devices. 2) Computers, personal computers, computer peripherals, modems, computer printers, floppy disk drives, hard disk drives, diskettes, tapes, computer printouts, computer software, computer programs and applications, computer manuals, system documentation. 3) Cameras, photographs, negatives, motion pictures, videotapes, magazines, books, and all other depictions of minors in sexual activity . 4) Any device or equipment that can be used to transfer images to a computer readable format. 5) Any written documentation or item containing password or encryption codes. 6) Any notes, ledger, personal phone books, roladex, books and any form of recording data of records of payments, telephone numbers and names of girls that have frequented the house. 7) Any sexual devices to which was used on the witness/victims. 8) Any hair fiber, semen, or other bodily fluids. which is being kept and used in violation of the laws of the State of Florida, to-wit the laws prohibiting: I. Sexual Activity with certain minors 2. Lewd and Lascivious Molestation FSS 794.05(1) FSS 800.04(5c2) 2° degree Felony 2nd degree Felony EFTA00179224

NOW THEREFORE, you, or 'ter of you are hereby commanded with per and necessary assistance, in the name of the State of Florida, m the daytime or in the nighttime, or on Sunaay, to forthwith search the said premises hereinbefore specified, for the property specified, and if the same, or any part thereof shall be found in said premises then you are authorized and commanded to seize the same and to bring the property and any person arrested in connection therewith before the Magistrate or any other Court having jurisdiction of the offense, to be dealt with according to law, and to forthwith make return of your doings upon executing this warrant, which you are hereby commanded to execute as the law directs within ten (10) days from the date thereof. You are further commanded, in the event that you seize any of the said property hereinbefore described, to make up, at the time and place ofseizure, a full, true and itemized list and inventory of all things seized and taken, in duplicate, signed by you, and to then and there give and deliver the said duplicate copy thereof to the person from whom possession shall be taken, if taken from the possession of anyone, together with a duplicate of this warrant, and if not taken from the possession of anyone, then to any person in charge of said premises, and in the absence of any such person, to leave the same on or in the premises. The original of this warrant, together with the original inventory, shall be returned and filed with the Clerk of the Court as stated above within ten (10) days of the issuance of this warrant. Further any property seized or taken shall be impounded for use as evidence at any trial of any criminal or penal cause growing out of the having or possession of said property. WITNESS my hand and seal this 18th day of October, A.D., 2005. JUDGE of the Circui Court of the Fifteen Judicial Circuit in and for Palm Beach County, Florida. EFTA00179225

ti 1 if 8 EFTA00179226

GOVERNMENT RD0i- 114 EFTA00179227

t i EFTA00179228

\ficv.06/20O)Scaled Document Tracking Form UNITED STATES DISTRICT COURT Southern District of Florida Number: Fal 07-103 eNPB) In Re Grand Jury Subpoenas Duces Tecum Numbers OLY-63 and OLY-64 SUPPLEMENT TO EX PARTE DECLARATION NI IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH SEALED DOCUMENT TRACKING FORM Party Filing Matter Under Seal On behalf of (select one): Name: u.S. Alternates Office Address: 500 S. Australan Ave, Suite 400, West Palm Beach, FL 33401 Telephone: K Plaintiff K Defendant Date sealed document filed: 813112007 If sealed pursuant to statute, cite statute: Fed. R. cram. P. 8(e) (Grand Jury Material) If sealed pursuant to previously entered protective order, date of order and docket entry number: The matter should remain sealed until: K Conclusion of Trial K Arrest of First Defendant Case Closing K Conclusion of Direct Appeal K Other: K Permanently. Specify the authorizing law, rule, court order: The moving party requests that when the sealing period expires, the filed matter should be (select one): K Unsealed and placed in the public portion of the court file K Destroyed 0 Returned to the party or counsel for the party, as identified above Attorney for: United Stat6 of America EFTA00179229

( UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 / FGJ 07-103(WPB) SUPPLEMENT TO EX PARTE DECLARATION NUMBER ONE IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH SUBPOENAS FILED UNDER SEAL EFTA00179230

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS FGJ 07-103(WPB) DUCES TECUM NUMBERS OLY-63 and OLY-64 UNDER SEAL SUPPLEMENT TO EX PARTE DECLARATION NUMBER ONE IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO OUASH SUBPOENAS state that the following is true and correct to the best of my information and belief: 1. I am currently employed as a Special Agent with the Federal Bureau of Investigation ("FBI") and have been so employed for the past ten years. I am assigned to the Miami Division, Palm Beach County Resident Agency, and for the past three years, I have been assigned to investigate mostly child exploitation cases. As explained in my earlier declaration, I am the case agent assigned to the investigation of Jeffrey Epstein's solicitation of minors to engage in prostitution and his lewd and lascivious conduct with minors. 2. After filing the Declaration in Support of the United States' Response to the Motion to Quash Subpoenas, I located and interviewed another girl, Jane Doe, who was recruited to engage in prostitution with Jeffrey Epstein. 3. In 2001, Jane Doe, age 14, was recruited by another female, "V", to provide Page I of 3 EFTA00179231

Epstein with a personal massage. The first time that "V" brought Jane Doe to Epstein's home at 358 El Brillo Way, Palm Beach, Florida, "V" and Epstein engaged in sexual intercourse in front of Jane Doe. "V" was seventeen years old at the time. "V's" first contact with Epstein, at the age of 15, was for the purpose of providing him with personal massages. 4. Jane Doe estimates that she returned to Epstein's home approximately 100 times between 2001 and 2003. Epstein masturbated in Jane Doe's presence during all but three of the massages she provided. During additional visits, Epstein tried to engage Jane Doe in more and more sexual behavior. On one occasion, Epstein introduced an unidentified female who performed oral sex on Jane Doe while Epstein had sexual intercourse with the unidentified female. At the end of each massage, Jane Doe was paid $200 to $400 by Epstein. 5. On one occasion, when Jane Doe was approximately 16 years' old, Epstein's assistant, telephoned Jane Doe and told her that Epstein wanted to photograph her. Jane Doe traveled to Epstein's Palm Beach home where took a series of nude photographs of Jane Doe posing at several locations on Epstein's property. Jane Doe was paid $500 for posing nude for the photographs. Jane Doe reported that used a digital camera to take the nude photographs. 6. This information further leads me to the believe that the computers that are the Page 2 of 3 EFTA00179232

subject of the grand jury subpoena are likely to contain evidence of Jeffrey Epstein's solicitation of minors to engage in prostitution and may contain child pornography. I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this day of August, 2007. Special Agent Federal Bureau of Investigation Page 3 of 3 EFTA00179233