Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 5 of 8 vs. Epstein, et at. Case No.: 08-CV-80811-CIV-MARRNJOHNSON Plaintiffs Motion for Protective Order condition "in controversy" such that it operates as a waiver of the psychotherapist- patient privilege. WHEREFORE, Plaintiff, MI, , respectfully requests that this Court enter a protective order preventing the discovery of Plaintiffs treatment records from the Parent-Child Center, Inc. and Dr. Serge Thys until such time as the Court decides whether the statutory damages pursuant to 18 U.S.C. §2255 are available to a victim of an enumerated sexual offense on a per incident basis. CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 Counsel for the movant conferred via telephone with counsel for the Defendant and counsel for the Defendant is not in agreement with Plaintiff's Motion For Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys and Incorporated Memorandum of Law. s/ Jack P. Hill 5 EFTA00182848

Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 6 of 8 . vs. Epstein, et al. ase No.: 08-CV-80811-CIV-MARRNJOHNSON Plaintiffs Motion for Protective Order CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 5th day of June, 2009, I electronically filed the foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. istlank P Hill Jack Scarola Florida Bar No.: Jack P. Hill Florida Bar No.: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm 6409 Phone: Fax: Attorneys for Plaintiff 6 EFTA00182849

Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 7 of 8 Mit. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAIJOHNSON Plaintiffs Motion for Protective Order COUNSEL LIST Richard H. Willits, Esquire Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, Phone: Fax: Robert Critton, Esquire Burman Critton Luther & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm B 4 Phone: Fax: Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South West Palm Brat Fl 3340 Phone: Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm B Phone: Fax: 7 EFTA00182850

Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 8 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON VS. Plaintiff, JEFFREY EPSTEIN and Defendants. ORDER ON PLAINTIFF, C.M.A'S MOTION FOR PROTECTIVE ORDER REGARDING TREATMENT RECORDS FROM PARENT-CHILD CENTER, INC. AND DR. SERGE THYS AND INCORPORATED MEMORANDUM OF LAW This matter came before the Court upon the Plaintiff's Motion For Protective Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys and Incorporated Memorandum of Law. Having considered the motion, it is hereby ORDERED and ADJUDGED that: Plaintiffs Motion for Protective Order is hereby GRANTED. DONE AND ORDERED this day of June, 2009. KENNETH A. MARRA United States District Judge Copies to all Counsel of Record EFTA00182851

Case 9:U8-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-801 I 9-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. EFTA00182852

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 2 of 15 JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, CASE NO.: 08- CV-80993-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08- CV-8081 I -MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE, CASE NO.: 08- CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendant. DOE II, CASE NO.: 08-CV- 80469-MARRA/JOHNSON VS. 2 EFTA00182853

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 3 of 15 JEFFREY EPSTEIN et al., Defendant. JANE DOE NO. 101, CASE NO.: 08- CV-8059 I -MARRA/JOIINSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 102, CASE NO.: 08- CV-80656-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS JANE DOES 2-7'S RESPONSE TO DEFENDANT'S MOTION TO COMPEL AND/OR IDENTIFY PLAINTIFFS IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS "SUA SPONTE", WITH INCORPORATED MEMORANDUM OF LAW Plaintiffs, JANE DOES 2-7, hereby serve their Response to Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua Sponte", With Incorporated Memorandum of Law, and state as follows: I. The lawsuits filed by JANE DOES 2-7 involve private, intimate facts pertaining to their own childhood sexual abuse and exploitation by Defendant Jeffrey Epstein. 3 EFTA00182854

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 4 of 15 2. Jane Does 2-7 filed their suits under a pseudonym' to prevent public disclosure of the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a well-known forensic psychiatrist with an expertise in the field of child trauma, has met with and evaluated each of Jane Does 2-7 and opined that public disclosure of their real names would create a substantial risk to them of further psychological harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D. 4. Dr. Kliman opines as follows: Releasing names of the plaintiffs to the public will reenact experiences of powerlessness and helplessness in the face of a boundary violation. Repetition and reenactment represent central features of Criterion I3 in the DSM-IV-TR diagnosis of posttraumatic stress disorder trauma. In effect, release of their identity and public intrusion into their personal life represents a reenactment of the shame of sexual traumatization. Repetition and reenactment arc central pathologies that afflict sexual trauma survivors. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial, as a defensive means to manage overwhelming affects associated with the sexual trauma. Each of the plaintiff girls has employed some variation of this defense, both during the massages and then subsequently following disclosure of the abuse. Primitive, maladaptive responses of this nature will become additionally reinforced as a result of public disclosure. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is that the trauma was associated with human design factors (such as cruel intention to do harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A policy of deliberate revelation of the names of the victims would reinforce the sense of design, pattern and policy of human intentions. It is my opinion, with a reasonably high degree of medical certainty that the defense motion to allow public disclosure of the plaintiffs' identity is clinically Defendant and his counsel are aware of the real names of Jane Does 2-7. 2 A copy of the curriculum vitae of Dr. Gilbert Kliman is attached hereto as Exhibit "B". 4 EFTA00182855

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 5 of 15 and ethically a wrongful plan. The act of revealing their identity against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering an aggravation of existing diagnostic concerns. It is more probable than not that releasing personal identities will foster an exacerbation and magnification of symptoms lending to increased risk of revictimization and retraumatization. See Exhibit "A", ¶¶ 13-15, 21 5. Given the private nature of the allegations in this lawsuit and the serious risk of harm to the mental health of Jane Does 2-7 if a public disclosure of their identities were required, Jane Does 2-7 should be permitted to continue using a pseudonym in this lawsuit. 6. Notably, in one of the cases consolidated for purposes of discovery, Jane Doe v. Jeffrey Epstein, Case No. 08-80893, this Court recognized the harm likely to result from public disclosure of the victims' identities in these cases, and allowed the Plaintiff in that case to "proceed in this action under the pseudonym 'Jane Doe' ", by Order dated October 6, 2008. 7. Jeffrey Epstein sets forth no facts to support his bare contention that Jane Does 2- 7 use of a pseudonym in these proceedings interferes with his "constitutional due process right." See Motion to Compel, p. 3. Defendant and his counsel know the identities of these Plaintiffs. 8. Defendant also requests the Court's permission to use the real names of Jane Does 2-7 in various third-party subpoenas for discovery purposes. Defendant does not identify any of the entities or persons to whom he intends to send subpoenas. An order granting the relief requested without limitations would essentially nullify Jane Does 2-7's right to proceed anonymously. Jane Does 2-7 therefore object to the issuance of third-party subpoenas, and submit that Defendant can obtain the discovery he seeks by alternative means that will preserve the confidentiality of the Jane Does 2-7's identities. 9. If this Court were to permit third party subpoenas or records custodian depositions using the existing captions and identifying Jane Does 2-7 in the body of the 5 EFTA00182856

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 6 of 15 subpoena by their names, due to publicity surrounding the Defendant's crimes, then Jane Does 2- 7 would effectively be revealed as abuse victims in these cases against Defendant Epstein. Any subpoenas or notices to third parties therefore should not disclose the type of action or the Defendant's identity. There are alternatives which would preserve Jane Does 2-7's anonymity and be more efficient and cost-effective at the same time. For instance, Defendant can obtain records from various non-party sources through Plaintiffs' counsel, who can certify that they have obtained the records through authorizations signed by Jane Does 2-7. Another means to obtain non-party records concerning Plaintiffs is the appointment of a special master, who would verify authenticity and completeness of the records. 10. Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black's Law Dictionary 1437 (7th ed.1999). Thus, the definition of sua sponte does not fit these circumstances, because the Court is being prompted by Epstein's Motion. Velchez v. Carnival Corp:, 331 F.3d 1207 (11th Cir. 2003). In any event, there is no basis or authority to support a dismissal of these cases. WHEREFORE, Plaintiffs Jane Does 2-7 respectfully request that (i) this Court deny Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua Sponte", in its entirety; (ii) Plaintiffs Jane Does 2-7 be permitted to continue using their pseudonyms in this litigation; (iii) this Court order that records from non-parties relating to Jane Does 2-7, including medical and employment records, only be obtained through Plaintiffs' counsel by means of signed authorizations that do not include the caption or identify Epstein as the party seeking records, or alternatively, appoint a special master to obtain the 6 EFTA00182857

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 7 of 15 records, who would verify authenticity and completeness of the records; and (iv) all other relief this Court deems just and appropriate. MEMORANDUM OF LAW I. PLAINTIFFS JANE DOES 2-7 SHOULD BE PERMITTED TO PROCEED ANONYMOUSLY IN THIS CASE DUE TO THE SENSITIVE, PRIVATE NATURE OF THE UNDERLYING FACTS AND THE RISK OF PSYCHOLOGICAL HARM TO THE PLAINTIFFS Federal courts permit a party to proceed under a pseudonym when special circumstances warrant anonymity. See, e.g., Roe v. Aware Woman Cm for Choice, Inc., 253 F.3d 678, 685-87 (11th Cir.2001); Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th Cir.2000); James v. Jacobson, 6 F.3d 233, 238-39 (4th Cir.I 993); Ill v. New York Blood Center, 213 F.R.D. 108, 110-12 (E.D.N.Y.2003); Javier v. Garcia-Botello, 211 F.R.D. 194, 196 (W.D.N.Y.2002); Doe v. Smith, 105 F.Supp.2d 40, 43-44 (E.D.N.Y.1999); Doe v. United Servs. Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988). Sexual assault victims are a paradigmatic example of those entitled to a grant of anonymity. See Doe No. 2 v. Kolko, 242 F.R.D. 193 (ED. N.Y. 2006); Doe v. Blue Cross & Blue Shield United of Wisc., 112 F.3d 869, 872 (7th Cir.1997) ("fictitious names are allowed when necessary to protect the privacy of... rape victims, and other particularly vulnerable parties or witnesses"); see also Doe v. City of Chicago, 360 F.3d 667, 669 (7th Cir. 2004). The decision whether to allow a plaintiff to proceed anonymously is within the court's discretion. See Aware Woman Cir., 253 F.3d at 684; Javier, 211 F.R.D. at 195; t 213 F.R.D. at 110. As set forth above, this Court exercised its direction in one of the consolidated cases, Jane Doe v. Jeffrey Epstein, Case No. 08-80893, to allow a plaintiff to proceed under the pseudonym "Jane Doe" in an Order dated October 6, 2008. 7 EFTA00182858

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 8 of 15 Courts will permit a party to proceed under a pseudonym where "the party's need for anonymity outweighs prejudice to the opposing party and the public's interest in knowing the party's identity." Does I Thru /VC II, 214 F.3d at 1068; see Javier, 211 F.R.D. at 195; EW, 213 F.R.D. at III; As set forth herein, the balancing test in this case weighs in favor of permitted plaintiff to continue to proceed anonymously: In undertaking this balance, courts have considered such facts as (I) whether the plaintiff is suing the government or a private person; (2) whether the plaintiff would be compelled to disclose intimate information; (3) whether plaintiff would be compelled to his or her intention in engage in illegal conduct, thereby risking criminal prosecution; (4) whether the plaintiff would risk injury if identified; (5) whether the party defending against a suit brought under a pseudonym would thereby be prejudiced; (6) the ages of the parties whose identity is to be suppressed; (7) the extent to which the identity of the litigant has been kept confidential; (8) whether, because of the purely legal nature of the issues presented or otherwise, there is an atypically weak public interest in knowing the litigants' identities; and (9) the public interest in guaranteeing open access to proceedings without denying litigants access to the justice system. Doe v. Del Rio 241 F.R.D. 154, 157 (S.D. N.Y. 2006) The public has a strong interest in protecting the identities of sexual assault victims so that other victims will not be deterred from reporting such crimes. See Doe v. Evans, 202 F.R.D. 173, 176 (E.D.Pa.2001) (granting anonymity to sexual assault victim); Doe No. 2 v. Kolko, 242 F.R.D. 193 (E.D. N.Y. 2006). That is particularly true in these consolidated cases where there are numerous victims with similar claims. Although these cases have gained considerable media attention, there appears to be little public interest in knowing the specific identity of each of the victims. With regard to the second factor, courts have granted anonymity to protect against disclosure of a wide range of issues involving matters of the utmost intimacy, including sexual 8 EFTA00182859

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 9 of 15 assault. See, e.g., Aware Woman Cir., 253 F.3d at 685 (abortion); ■ 213 F.R.D. at III (infection with hepatitis B); Doe v. Evans, 202 F.R.D. 173, 176 (E.D.Pa.200 I) (sexual assault victim); Smith, 105 F.Supp.2d at 42 (sexual assault victim); WGA v. Priority Pharmacy, Inc., 184 F.R.D. 616, 617 (E.D.Mo.1999) (status as AIDS patient); Doe v. United Servs. Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988) (sexual orientation); see also Blue Cross, 112 F.3d at 872 (recognizing rape victims as entitled to anonymity). It cannot be reasonably denied that a person's sexual history — especially during their childhood — is an intimate fact. When the childhood sexual history includes criminal sexual contact by an adult, the facts are even more intimate and personal. In the electronic age in which we live, these concerns are heightened. As federal courts have recognized in this context, it is now possible to "determine whether a given individual is a party to a lawsuit in federal court anywhere in the country by the simplest of computer searches, to access the docket sheet of any such case electronically, and ... that entire case files will be accessible over the Internet." Doe v. City of New York, 201 F.R.D. 100, 102 (S.D.N.Y.2001) (denying anonymity where any injury was purely reputational and case did not involve private or intimate matter); see 213 F.R.D. at 112-13. As Dr. Kliman explains in his Declaration, disclosure of Jane Does 2-7's identities will place these Plaintiffs "at-risk of having their personal lives scrutinized by friends, extended family, spouses, children, fellow students, employers and fellow employees, the media and general public. This type of exposure humiliates many victims and represents another betrayal of trust. Public exposure places the plaintiff's at further risk of stigmatization, shame and retraumatization." See Exhibit "A" at ¶ 3. Dr. Kliman also finds it of no consequence that some of the plaintiffs are now legally adults in that "[d]ue to traumatization the plaintiffs are arrested in their development, and even those who are now legally adult are arrested in part to adolescent 9 EFTA00182860

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 10 of 15 aspects of psychology." Id. at ¶ 4 The policy of protecting victims of sexual misconduct from undue embarrassment and disclosure of their private affairs is firmly established in Fed.R.Evid. 412. The protections of Rule 412 are designed to "encourage victims of sexual misconduct to institute and participate in legal proceedings against alleged offenders." (Committee Notes to 1994 Amendment). Likewise, many states in this country, including Florida and New York, have similarly enacted laws to protect the anonymity of sexual assault victims. See Fla. Stat. §§794.024, 794.026 (2008); N.Y. Civil Rights Law § 50-b (McKinney 2009). In 1994, the Florida Legislature passed The Crime Victims Protections Act. The legislative stated purpose for the Act was "to protect the identity of victims of sexual crimes." Fla. AGO, 2003-56, 2003 WL 22971082 (Dec. 15, 2003). Under §794.024, Florida Statutes, court records that identify the name and/or address of a victim of a sexual crime are presumed to be confidential and exempt from public access. Id. Similarly, upon approving New York's rape shield law, then Governor Mario Cuomo stated, "sexual assault victims have unfortunately had to endure a terrible invasion of their physical privacy. They have a right to expect that this violation will not be compounded by a further invasion of their privacy." 1991 McKinney's Sessions Laws of N.Y., a! 2211-2212 (quoted in Deborah S. v. Diorio, 153 Misc.2d 708, 583 N.Y.S.2d 872 (N.Y.City Civ.Ct.1992)); see also Coker'. Georgia, 433 U.S. 584, 597, 97 S.G. 2861, 53 L.Ed.2d 982 (1977) ("Short of homicide, [rape] is the ultimate violation of self'). As to the fourth factor of risk injury, Dr. Kliman has evaluated Jane Does 2-7, and has concluded that the childhood sexual abuse at issue has caused features of post-traumatic stress disorder (PTSD), including shame, guilt, helplessness, and powerlessness. See Exhibit "A" at ¶¶ 4-7. Dr. Kliman further states, "it is more probable than not that releasing personal identities I0 EFTA00182861

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 11 of 15 will foster an exacerbation and magnification of symptoms lending to increased risk of revictimization and retraumatization." Id. at ¶ 21. Thus, this is not a case analogous to those cited by defendant in which the plaintiffs were merely at risk of "personal embarrassment." Instead, there is a genuine and immediate risk of psychological harm. None of the cases cited by Defendant where courts denied a plaintiff's request for anonymity involved victims of childhood sexual assault or evidence of emotional or psychological harm that would result from disclosure of the plaintiffs identity. See Doe v. Hartz, 52 F.Supp.2d 1027 (N.D.lowa 1999); Doe v. Shakur, 164 F.R.D. 359 (E.D.N.Y.1996); Doe v. Bell Atlantic Bus. Sys. Servs., 162 F.R.D. 418 (D.Mass.1995); Doe v. Univ. of Rhode Island, 28 Fed.R.Serv.3d 366, 1993 WL 667341 (D.R.I. Dec. 28, 1993). As to the factor of prejudice, the Defendant does not identify how his ability to conduct discovery or impeach Jane Does 2-7's credibility has been or will be impaired if these Plaintiffs are permitted to proceed under a pseudonym. See a 213 F.R.D. at 112, Smith, 105 F.Supp.2d at 44-45. Other than the need to make redactions and take measures not to disclose these Plaintiffs' identities, Defendant will not be hampered or inconvenienced merely by Plaintiffs' anonymity in court papers. As set forth above, Defendant already knows their true identities. See Aware Woman Center, 253 F.3d at 687 (no prejudice where plaintiff offered to disclose her name to defendant); e 213 F.R.D. at 112; Smith, 105 F.Supp.2d at 44-45. II. DEFENDANT SHOULD NOT BE PERMITTED TO USE THE REAL NAMES OF JANE DOES 2-7 IN THIRD-PARTY SUBPEONAS EXCEPT FOR THOSE ISSUED TO PERSONS WHOM PLAINTIFFS HAVE ALREADY DISCLOSED THEIR SEXUAL ABUSE As for the use of Jane Does 2-7's real names in subpoenas issued to non-parties, a party may obtain discovery of any non-privileged matter that is relevant to a claim or defense of any party. Fed.R.Civ.P. 26(b)(1). However, a district court may limit discovery "for good cause 11 EFTA00182862

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 12 of 15 shown" by making "any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense," including that the discovery not be had or that it be had only by a method other than that selected by the party seeking discovery. Fed.R.Civ.P. 26(c). Jane Does 2-7 have articulated a specific and substantial harm from disclosure of their identities. If this Court were to permit Defendant to issue third-party subpoenas containing Jane Doe 2-7's real names, the identity of the Defendant, and/or facts pertaining to the nature of the case to whomever Defendant wants, it would be akin to requiring these Plaintiffs to use their real name in the pleadings. Instead, Jane Does 2-7 propose to voluntarily execute authorizations (which would not contain the case names or the identity of the Defendant) to allow Defendant to obtain education, employment, and medical records to be used for purposes of this litigation only.3 Alternatively, Defendant can obtain the records through a special master, who would verify authenticity and completeness of the records. Either of these approaches would not only place Jane Does 2-7 at less risk of psychological harm, but would also be more cost-effective and efficient. CONCLUSION Based on the foregoing, Plaintiffs Jane Does 2-7 respectfully request that Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua Sponte" be denied in its entirety, and that Plaintiffs Jane Does 2-7 be permitted to continue using their pseudonyms in this litigation. Additionally, to avoid public disclosure of the Plaintiff's identities in non-party records discovery, Plaintiffs Jane Does 2-7 request that such 3 Defendant and Plaintiff have previously agreed that education records can be obtained in this 12 EFTA00182863

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 13 of 15 discovery be obtained either through Plaintiffs' counsel by means of written authorizations, or by the appointment of a special master. Dated: June 8, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. Adam D. Horowitz (FL Bar No. MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs. Jane Doe Nos. 2-7 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: Fax: manner in lieu of subpoenas. 13 EFTA00182864

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 14 of 15 CERTIFICATE OF SERVICE I hereby certify that on June 8, 2009, 1 electronically filed the foregoing document with the Clerk of the Court using CM/ECF. 1 also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ Adam D. Horowitz 14 EFTA00182865

Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 15 of 15 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Robert D. Critton, Esq. Bradley James Edwards Isidro Manuel Garcia Jack Patrick Hill Katherine Warthen Ezell Michael James Pike Paul G. Cassell Richard Horace Willits Robert C. Josefsberg /s/ Adam D. Horowitz 15 EFTA00182866

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 1 of 23 professional publications include books and peer-reviewed medical journal articles on mass disasters, most recently concerning the Attack on America. He was extensively interviewed in 1997 by CBS Dallas TV regarding psychiatric testimony concerning eleven altar boys, testimony which had resulted in a record-making jury verdict against the Archdiocese of Dallas. In April, 1998, Dr. Kliman was interviewed by Channel Four anchorwoman, Linda Yee, concerning his Salvation Amy project providing the Cornerstone form of psychoanalytic psychotherapy for homeless preschoolers and toddlers,. The Cornerstone project itself was viewed on the Channel II Five O'Clock News. KGO TV interviewed Dr. Kliman concerning a forensic testimony, with a focus on a Stanford football player who had allegedly become a child molester. During the Lewinsky-Clinton matter, Kliman was interviewed by Channel 12/20 concerning psychoanalytic views of leaders having exceptional sexual access to partners and the risk of a position of power overcoming the judgments of such leaders. During 2001 following the World Trade Building terrorism, Dr. Kliman was interviewed by Channel II News and appeared on five occasions thereafter through 2003 concerning the Afghanistan and Iraq wars. In May 2003, he was discussant with U.N. Secretary General Olaru Otonu, featured on Dhubai Business TV concerning the plight of children in war. In 2004, together with the International Psychoanalytic Association, Dr. Kliman helped organize, establish and supervise a therapeutic preschool project in Buenos Aires. "Cornerstone Argentina" is now in its second year of treating severely disturbed and impoverished preschoolers, with his continuing collaboration. Following the hurricane disasters of 2005 he collaborated with Mercy Corps and the Children's Psychological Health Center to produce a mental health resource. The result, "My Katrina and Rita Story", a guided activity resource of families who had to deal with the hurricanes. Mercy Corps is distributing copies to 20,000 families. In 2005, RE DISTURBED PRESCHOOLERS Dr. Kliman helped organize, establish and supervise a therapeutic project in Piedmont California, at the nonprofit Ann Martin Center. In 2007, RE HOMELESS CHILDREN: Dr. Kliman helped establish a Reflective Network Therapy service for homeless preschoolers in Seattle. He provided four days of training in that method for the Family Service Center of King County (located in Seattle), and created an organizational link between The Family Services Center and The Children's Psychological Health Center, Inc. of San Francisco in order to continue serving homeless children in Seattle. In 2008, Dr. Kliman activated the Reflective Network Therapy services for preschoolers in Seattle. He supervises there in person and by phone and video. In 2008, RE DISASTER SERVICES: Following the Sichuan Earthquake Disaster of May 12, 2008, Dr. Kliman established a link between Children's Psychological Health Center, Inc., Mercy Corps, and The China America Psychoanalytic Alliance. He created mental health resources (see Publications) which were licensed for mass distribution in China by Mercy Corps. In 2008, Dr. Kliman helped found a new non-profit organization called Teach with Africa and is a member of its Board of Directors. 2 EFTA00182867

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 3 of 23 Foundation, The Dreyfus Foundation, The Seth Sprague Foundation, The Gralnick Foundation, The Harris Foundation, U.S. Trust, and The Scheuer Family Foundation. Most recent grants: 1996-2002: Support from The Office of Education, Division of Special Education, San Mateo County, California. 1996 The Windholz Foundation, San Francisco, for video documentation of an experimental project concerning treatment of disturbed and traumatized preschool patients in a public education special education division. 1999 Morris Stulsaft Foundation for video-recording facility to document treatment in The Cornerstone Therapeutic School. 1999-2001 The Cadence Corporation - for early childhood treatment services 2000-2001 The Harris Foundation for Cornerstone Therapeutic School. 2000 Funding and Recognition by the State of California: In 2001, The Department of Education, Division of Special Education, certified the Cornerstone Therapeutic School as a nonpublic special education school, allowing public entities to fund the school by contracts with Unified School Districts. 2001 The San Francisco Day Care Corporation — for Cornerstone Therapeutic School. 2001 The Sophie Murvis Foundation for Training of Teachers and Therapists in the Cornerstone Method. 2002, 2003. The Five Bridges Foundation for development of The Cornerstone Therapeutic Preschool 2003. 2005 The Sophie Murvis Foundation grant for Training of Teachers and Therapists in the Cornerstone Method. 2005 Mercy Corps for creation of "My Personal Story about Hurricanes Katrina and Rita" 2008 Mercy Corps for creation of "My Sichuan Earthquake Story" JANUSZ KORCZAK INTERNATIONAL LITERARY PRIZE: First place, International Literary Prize including an award of one thousand dollars, for "World's Best Book Concerning the Well-Being of Children"—Awarded to Gilbert Kliman, M.D. and Albert Rosenfeld, co-authors of Responsible Parenthood, published by Holt, Rinehart and Winston, New York, 1980 PUBLISHED PAPERS AND BOOKS: 4 EFTA00182868

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 5 of 23 23. "Mourning, Memory, and Reconstruction: The Analysis of a Four-Year-Old Maternally Bereaved Girl at Age Sixteen Months" (With Thomas Lopez, Ph.D.), in The Psychoanalytic Study of the Child, Volume 34, The New York Times Press, New York, 1979. 24. "Facilitation of Mourning During Childhood," in Gerber, I., Wiener, A., Kutscher, A., et al., Perspectives on Bereavement, MSS Information Corporation, New York, 1979. 25. "The Cornerstone Treatment of a Preschool Boy from an Extremely Impoverished Environment" (with Thomas Lopez, Ph.D.), The Psychoanalytic Study of the Child, Vol. 35, The New York Times Press, New York, 1980. 26. Responsible Parenthood: The Child's Psyche Through the Six-Year Pregnancy, Holt, Rinehart, and Winston, New York, 1980. 27. "Death: Some Implications in Child Development and Child Analysis," in Advances in Thanatology, Vol. 4, No. 2, Amo Press, New York, 1980. 28. "Children in Foster Care: A Preventive Service and Research Program for a High Risk Population" (with M. Harris Schaeffer, Murray J. Friedman, and Bernard G. Pasquariella). The Journal of Preventive Psychiatry, Volume I: 1, 1981. 29. Editorial(s). The Journal of Preventive Psychiatry. Volume I, 1981-1982, Volume II, 1983-4, Volume III, 1985-7, Volume IV, in press 30. Preventive Mental Health Services for Children Entering Foster Family Care: An Assessment (with M. Harris Schaeffer, and M. Friedman). The Center for Preventive Psychiatry, White Plains, New York, 1982. 31. "Summary of Two Psychoanalytically Based Service and Research Projects: Preventive Treatments for Foster Children" with M. Harris Schaeffer, Ph.D. J. of Preventive Psychiatry, Vol. II, No. 1, 1983. 32. "Three New Areas in Litigation on behalf of Children," in Child Psychiatry and the Law, Diane Schekty, Editor, Volume 2, Bruner/Mazel, New York, 1985. 33. Preventive Psychiatry: Early Intervention and Situational Crisis Management, co- editor, with S.C. Klagsbrun, M.D., E.J. Clark, Ph.D., others. The Charles Press, Philadelphia, 1989. 34. My Earthquake Story: A Guided Workbook for Children, Parents and Teachers, with Harriet Wolfe, M.D. and Edward Olden, M.D. Psychological Trauma Center Press, Kentfield, CA. October, 1989. 35. "Facilitation of Mourning During Childhood," chapter in Preventive Psychiatry: Early Intervention and Situational Crisis Management (Eds) S. Klagsbrun, G. Kliman, E. Clark, A. Kutscher, R. DeBellis, C. Lambert. The Charles Press, Philadelphia, 1989. 36. "Toward Preventive Intervention in Early Childhood Object Loss," chapter in Noshpitz, H. and Coddington, D. (Eds) Stressors and Clinical Techniques in Child Psychiatry. Charles Thomas, NY, 1990. 37. "Brief Report: Loss of Parental Services—A Guide to Categorization." J. Preventive Psychiatry and Allied Disciplines 4:1, 1990. Human Sciences Press, NYC. 38. "A Methodologic Breakthrough: The Saga of Delivering Effective Primary Preventive Psychotherapy to Groups of Foster Children." J. Preventive Psychiatry and Allied Disciplines 4:1, 1990. Human Sciences Press, NYC. 39. "The Rise of Adolf Hitler and Other Genocidal Leaders—Psychoanalytic and Historical Symposium (Summary)," J. Preventive Psychiatry and Allied Disciplines 4:1,1990. Human Sciences Press, NYC. 6 EFTA00182869

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 7 of 23 57. "My Hurricane Story" A Guided Activity Workbook to help Children Cope. The Children's Psychological Health Center. Sept 21, 2008 WORKS IN PROGRESS: available in Draft: IQ Rise among Preschoolers with Pervasive Developmental Disorders. Child Psychoanalytic Contributions to Civil Justice System, submitted by invitation, to Psychoanalytic Inquiry Books in Draft: 1. Reflective Network Therapy: Early Childhood Psychotherapy in the Classroom 2. A Unifying New Theory of Posttraumatic Stress Disorder PRESENTATIONS: 01. "Specific Traumas: Selective Review of Literature," presented at the Ernst Kris Study Group, New York Psychoanalytic Institute, New York, 1965. 02. "Psychoanalysis of a Four-Year-Old in a Preschool Group," presented at the American Psychoanalytic Association, Atlantic City, New Jersey, May, 1966 03. "Covert Suicidal Impulses in Maternally Deprived Children" (with Harriet Lubin, M.S.W.), presented at the American Association of Psychiatric Services for Children, Boston, Massachusetts, November, 1969. 04. Children's Reactions to National Events: The 1968 Federal Elections," presented at the American Orthopsychiatric Association, Washington, D.C., 1969. 05. "Facilitation of Mourning During Childhood," presented at the Chicago Psychoanalytic Institute, May 1973. 06. "Preventive Approaches to Preschool Psychiatric Disorders: Some Assessments," presented at the Academy of Child Psychiatry, Washington, D.C., October, 1973. 07. "Biological Drive Derivative Cycles in Preschool Patients," presented at the New York Psychoanalytic Institute Research Seminar, 1974. 08. "Children in National Disasters," presented at the International Association for Child Psychiatry, Philadelphia, Pennsylvania, 1974. 09. "Childhood Mourning: Some Social Aspects," presented at Yeshiva University, New York, October, 1974. 10. "The Center for Preventive Psychiatry's Interventions with Bereaved Children," presented at the second annual conference on "The Impact of Bereavement and Grief on the Family," Yeshiva University, October 15, 1975. 11. "Death: Implication for Psychoanalytic Theory and Practice," presented at The Association for Psychoanalytic Medicine, New York, 1977. 12. "A Psychoanalytic View of an Ancient Mass Disaster: The Mayan Exodus," The Center for Preventive Psychiatry, 1977. 8 EFTA00182870

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 9 of 23 33. Seminar on "New Areas in Forensic Psychiatry," at the Robert Cartwright law firm, San Francisco, 1986. VIDEOTAPE AVAILABLE 34. "Children's Reactions to the Challenger Shuttle Disaster," on 20/20 (Television Broadcast), 1986. VIDEOTAPE AVAILABLE 35. The Fathering of Adolf Hitler," Grand Rounds, McAuley Neuropsychiatric Institute, St. Mary's Hospital, San Francisco, 1986. 36. "Child Sexual Abuse: Psychoanalytic and Forensic Approaches," Children's Hospital, San Francisco, 1986. VIDEOTAPE AVAILABLE 37. "Preventive Psychiatry for Children," Training Seminar at McAuley Neuropsychiatric Institute, St. Mary's Hospital, San Francisco, 1987. VIDEOTAPE AVAILABLE 38. "Multi-Victim Child Sexual Abuse," San Francisco Psychoanalytic Institute Extension Division, October 1987. VIDEOTAPE AVAILABLE 39. "Children in Foster Families: Advances in Preventive Psychiatry," Continuing Education Program for Psychiatrists, U.C. Davis, 1988. 40. "The Mothering of Adolf Hitler," Grand Rounds. McAuley Neuropsychiatric Institute, St. Mary's Hospital, San Francisco, Dec. 1988. 41. "Adolf Hitler's Mothering: A Child Psychoanalytic View," Westchester Psychoanalytic Society, New York Hospital, January, 1989. 42. "The Personal Life History Book: Preventive Psychotherapy for Children in Chaos." Department of Child Psychiatry, Harlem Hospital, New York, NY, January, 1989. 43. Chairman: Symposium April 20-21, 1989. The Rise of Adolf Hitler and Other Genocidal Leaders. Interdisciplinary Unit for Study of Mass Violence and Genocide. St. Mary's Hospital Department of Psychiatry, San Francisco. 44. "The Mothering of Adolf Hitler," Symposium above. VIDEOTAPE AVAILABLE 45. "The Fathering of Adolf Hitler," Symposium above. VIDEOTAPE AVAILABLE 46. Public Media: Following the October 17th earthquake, Dr. Kliman and his Psychological Trauma Center associates appeared on KRON-TV, KFAS, KQED and public service radio network to offer advice and respond to call-in questions regarding earthquake stress and trauma. His Earthquake Story guided workbook (see above) was distributed as a public service by San Francisco Community Mental Health Services and the Oakland Bureau of Education to 11,000 teachers in Oakland and San Francisco. 47. Marin Psychoanalytic Society: (April 1990) "Simultaneous child and couple therapy: emergence and interpretation of congruent unconscious themes." 48. University of California College of Medicine, Department of Psychiatry, Irvine. (June 1990) "Prevention of Psychopathology among Children: Systematic Projects with Foster Children." 49. Preventive Interventions with Traumatized Children," Grand Rounds California Pacific Hospital Department of Psychiatry, October 20, 1992. VIDEOTAPE AVAILABLE. 50. Altered Interpersonal Schemas After Life Threatening Childhood Trauma," Center for Study of Consciousness, UCSF, October 1992. 51. Alterations of Pre-Traumatic Memory and Post Traumatic Schemas," Child Analysis Colloquium, San Francisco Psychoanalytic Institute, November 1992. 52. Toward A New Theory of Post Traumatic Stress Disorder," Control Mastery Group, San Francisco Psychoanalytic Institute, December 1992. 53. Severe Psychological Trauma in Very Young Children," Grand Rounds at the Menninger- San Mateo County Hospital Psychiatric Residency Program, March 23, 1993. 54. Psychological Crises Among Preschoolers," Department of Health, City of San Francisco, April 1993. 55. Child Analysis Colloquium," San Francisco Psychoanalytic Institute, May 1993. 10 EFTA00182871

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 11 of 23 79. "Operational Confirmation of a Psychoanalytic Hypothesis: Detecting and Interfering with The Repetition Compulsion," Cleveland Psychoanalytic Institute and Anni Katan Center for Child Development, October 28, 1995. 80. The Personal Life History Book Method: Reducing Transfers Among Foster Family Homes," The Center for Preventive Psychiatry, White Plains, NY, October 30, 1995. 81. "A New Theory of Posttraumatic Stress Disorder," Grand Rounds, Baylor University School of Medicine, Houston, November 8, 1995. 82. "Raising IQ's in a Therapeutic Nursery: The Cornerstone Method. How it works as illustrated by video clips of the therapist and patients in the classroom," The Houston Psychoanalytic Institute and Stedman West Child Development Center, Houston, TX, November 8, 1995. 83. "The Difficult Client: Accredited Continuing Legal Education seminar for California Attorneys." The Psychological Trauma Center, The Psychological Trauma Center, 1996. 84. "Catastrophic injuries and psychological trauma: Accredited Continuing Legal Education seminar for California Attorneys." The Psychological Trauma Center, 1996. 85. "Why Small Clients Get Large Awards: Proving and Disproving Psychological Injuries in Childhood. Accredited Continuing Legal Education seminar for California Attorneys." 1996 86. "A New Public Health Approach in Public Special Education: Presentation to The San Mateo Board of Education," San Mateo, CA. April 17, 1996. 87. A new model for special education of preschoolers: The Cornerstone Method -- for synergy between early childhood education and psychotherapy. California State Dept. Education, Division of Special Education September 1996, Red Lion Hotel, Orange County Airport, CA. 88. "Synergy Between Special Education and Psychotherapy in the Classroom: Special Education Learning Program Administrators," San Mateo, CA. October 10, 1996. 89. "The Role of Psychoanalyst as Forensic Expert in Catastrophic Psychological Trauma Cases." American Psychoanalytic Association, Winter Meeting, Waldorf Astoria, NY. December 1996 90. "Controlled Assessment of a Psychoanalytically Derived Psychotherapy." American Psychoanalytic Association, Winter Meeting, Waldorf Astoria, NY December 1996. 91. "Child Psychotherapy Course: Several preschool patients with different diagnosis, treated in a preschool therapeutic nursery, showing response to interpretations, with discussions of the role of teacher, parents and medications." San Francisco Psychoanalytic Institute, March 4, II, 18, 1997 92. "Synergy between Psychotherapy and early childhood special education" SELPA Administrators, April 17, 1997 93. "Analyst in the Nursery: The Cornerstone Method," San Francisco Psychoanalytic Institute, May 21, 1997 94. "Psychological Trauma Among Preschoolers," San Francisco Psychoanalytic Institute, May 15, 1997 95. ACT for Mental Health, April 17, 1997 96. "New Theory of Posttraumatie Stress Disorder," Fifth European Conference on Traumatic Stress, European Society for Traumatic Stress Studies, July 1, 1997. 97. The Cornerstone Method: Intensive Preschool Psychotherapy in Public School Special Education Classes. California State Federation/Council for Exceptional Children 48th Annual Conference & Special Education Fall Conference, San Francisco, CA, October 21- 24, 1998. 98. Research and treatment with highly traumatized preschoolers. Wright Institute, Berkeley, Feb. 4, 2002. 12 EFTA00182872

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 13 of 23 110. Presentations of video-taped child treatment sessions: The Child Analysis Study Group of the San Francisco Psychoanalytic Institute, six occasions 2001-2002. 111. New Theory and New Treatments of Children. Northern California Society of Mental Health Professionals. Feb 8, 2002. 112. Treatment of Children in their Real Life Spaces. Ann Martin Center, Berkeley, CA February 2, 2002. 113. Treatment of children in community school settings. Workshop on Community Child Psychiatry. American Academy of Child and Adolescent Psychiatry. October 2002. 114. Treatment of preschoolers in real life space — The Cornerstone Method. A two day training workshop for the L.A. County Dept. of Mental Health. October 2002. 115. The Cornerstone Method. The American Psychoanalytic Association, Workshop on Early Childhood. January 2003, New York. 116. Treatment of Three Autistic Preschoolers: The American Psychoanalytic Association. June, 2003. Boston. 117. The Personal Life History Book: A Preventive Therapy for Foster Children. A day-long workshop at Counseling4Kids, Los Angeles, September 2003. 118. A new method of treatment of autistic preschoolers. The Chinatown Child Development Center, San Francisco, December 4, 2003. 119. Results of the Cornerstone Method: Pervasive Developmental Disorder with eight month to 37 year followup. The M.I.N.D. Institute, U.C. Davis, December 19, 2003. 120. Procedures for preventing and reducing psychopathology among foster children. Joint Committee of AACAP and Child Welfare League, November 2003, with Marilyn Benoit, M.D. 121. The Role of Child Psychiatrists in Prevention of Child Abuse: Forensic Child Psychiatry as a Societal Influence. Mensa Society, January 2004. 122. Psychoanalysis Confronts Autism. The L.A. and SoCal Psychoanalytic Institutes, February 22, 2004. 123. Child Psychiatric Testimony and the Leading Edge of Social Change. American College of Forensic Psychiatry, March 28, 2004 124. The Cornerstone Method of Treating Autism. American Psychoanalytic Association, Boston, Mass., January 2005. 125. An evidence based method for in-classroom treatment of disturbed preschoolers. Child Welfare League of America. New Orleans, May 2005. 126. Two evidence-based methods for treating foster children. International Psychoanalytic Association, Rio de Janeiro, Brazil, July 2005. 127. A novel evidence-based method for treatment of Asperger's Disorder. Lorman Educational Seminars, Redding, CA. November 18, 2005 128. "Applications of The Cornerstone Method to Children with Autism Spectrum Disorders" American Psychoanalytic Association, New York, New York. January 18, 2006 129. "Applying The Cornerstone Method in Public Schools" Philadelphia Board of Education April 28,06 DVD FORMAT AVAILABLE 130. "Crises Intervention Techniques Within Schools: What you Need to Know When Large or Small Scale Disasters Strike" Lorman Educational Seminar, Sacramento, CA Oct. 6, 2006 131. "Saying Goodbye: Termination in Psychotherapy" 53rd Annual Meeting of The American Academy of Child and Adolescent Psychiatry, San Diego, Ca October 28, 2006 132. Lawrence LE, Viron M, Johnson JE, Hudkins A, Samples G, Kliman G: A school-based mental health recovery effort. Poster session presentation at the 58th Institute on Psychiatric Services Annual Meeting, New York, NY, October 5-8,2006. 14 EFTA00182873

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 15 of 23 Member, Joint Committee on Foster Care: Academy of Child and Adolescent Psychiatry and the Child Welfare Association. PROFESSIONAL COMMENDATIONS: A letter of commendation regarding clinical work in the classroom within a public school system: December 3, 2001 To Whom It May Concern: This is to report that the San Mateo County Office of Education, Special Education programs, has benefited from the services of The Children's Psychological Health Center, specifically its Cornerstone Therapeutic School Project. We have worked together for the past six years. Under the leadership of Gilbert Kliman, M.D., the Center has trained members of our teaching and school psychology staff to carry out a mental health service on our premises. We now have a collaborative project in its sixth year for our special education preschool children with Pervasive Developmental Disorders (PDD) and for those with Serious Emotional Disorders (SED) which interfere with their education. As an alternative to sending children to a private nonpublic special education school for extremely intensive mental health services at significant cost, this project has created and provides just such intensive service within a public preschool special class program at 65 Tower Road, San Mateo. To my knowledge, among the 30 children served so far under the collaborative project, we are seeing cognitive, social and human gains which have decreased the gap between these children and their typically developing peers. Several families and children are thriving with less intensive special education service or returned to regular education class. Not only has the family and child suffering been reduced, the burden to taxpayers is also reduced. The children have been able to remain in the community, and some who were fiinctioning as severely autistic and retarded now appear to be developing within a somewhat normal range. We are pleased with the quality of special education services our County provides for preschoolers with PDD or SED. We are also gratified with the research results provided by The Children's Psychological Health Center. We recommend the Cornerstone project to other school systems, so that they consider it an important opportunity should they be able to collaborate similarly with The Children's Psychological Health Center. At California's common cost of $15,000 to $40,000 or more a year, for a special education child who needs full time special education services and auxiliary intensive help, the savings for even one child's 12-year career of intensive services in special education can be substantial. The savings from one of the successes we have seen may equal the costs of the entire Cornerstone project with the 30 children helped so far. 16 EFTA00182874

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 17 of 23 to rescue himself. The foster father's partner was negligent, Dr. Kliman opined. The judge agreed and awarded the child compensation for psychological damages. Does vs. Archdiocese of Los Angeles. Dr. Kliman was the lead psychiatric witness. The case settled after six days of his deposition testimony. Does vs. Salesian Order Western Region. Dr. Kliman was the lead psychiatric witness. The case settled after nine days of his deposition testimony and two days of trial. Does v South Dakota School for the Deaf. Multiple boys were molested by an older student. The state school administration was allegedly negligent and major psychological damages were claimed. Dr. Kliman served as the principal plaintiffs' expert on administrative liability issues and psychological damages. The case settled with major compensation for the plaintiffs during the time of jury deliberations. CHILD PSYCHIATRIC EXPERT TESTIMONY: Dr. Kliman helped set legal precedents for the inclusion of psychiatric testimony in matters concerning wrongful death of a parent and loss of parental services, in both New York State and California. He has testified in over 275 cases including over 100 trials. A Federal Rule 26 list is available on request and on www.expertchildpsychiatry.com. His courtroom and deposition testimony experience includes cases of institutional negligence of children leading to psychological trauma, negligent foster care, loss of parental services due to wrongful deaths, psychological trauma as part of personal injury of adults and children, childhood molestation, sexual harassment, termination of parental rights, and disputed custody. Since 2000 about 30% of his forensic work has been requested by defense, about 70% by plaintiffs, with the defense tasks increasing markedly in recent years. Dr. Kliman's evaluations and testimony regarding 16 children negligently cared for and abused at The Kiwanis' OK Boys' Ranch, Olympia, WA, helped lead to settlements and awards, totalling $25,000,000. Responding to disclosures in that case, many improvements have occurred in the publicly funded and licensed institutional care of children throughout the State of Washington, according to newspaper accounts. Dr. Kliman's evaluations and opinions, together with that of The Children's Psychological Trauma Center team led by Robert Wynne MFCC, led to record-making $8,000,000 loss of parental and other services compensation for 17 bereaved subsistence-economy Alaskan Inupiat Native Americans (Smith vs. Ryan Airlines, Anchorage, 1997). Principal expert regarding institutional negligence and psychological damages in Does vs. Rudolph Kos and the Diocese of Dallas, Dallas 1997. The Catholic Church of Dallas was held liable for institutional negligence, testimony concerning the need for major psychiatric treatment planning was accepted by the jury, and $119,000,000--including punitive damages against the Church--was awarded to the 11 plaintiffs, by unanimous decision. 18 EFTA00182875

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 19 of 23 Archive of Videotaped Seminars and Events: — Gilbert Kliman, M.D., Medical Director THE CHILDREN'S PSYCHOLOGICAL TRAUMA CENTER (A division of the Children's Psychological Health Center, Inc. ) Archive of Videotaped Seminars and Events: CONTINUING LEGAL EDUCATION TAPES: California MCLE credit is available to attorneys for study of these tapes. Unless otherwise indicated, Gilbert Kliman, M.D. was the sole or principal speaker. Contact Edith Lee at for MCLE credit fulfillment associated with study of these tapes. 01. True and False Allegations ofSexcal Molestations, 1987. 1.5 hrs. 02. Loss of Parental Services, May 6' 1992 Elina Wayrynen and Gilbert Kliman, M.D. 2.0 hrs. 03. Abuse in Institutions, August 1995, 2.0 hrs. 04. Catastrophic Accidents with Lifetime Psychological Damage December 5ih 1995 2.5 hrs. 05. Evaluating Psychological Trauma in Catastrophic Accidents (Grosvenor Hotel. San Francisco) 1996, 2.5 hrs. 06. Loss of Parental Services (HolidayInn), January 9th 1996, 2.5 hrs. 07. Loss of Parental Services, May 12th 1993 1.5 hrs. 08. True and False Allegations of Sexual Abuse June 7th 1993, 1.5 hrs. 09. Catastrophic Psychological Traumas in Childhood, February 1994, 2.5 hrs. 10. The Difficult Client, February 27th 1996, 2.5 hrs. 11. The Difficult Client (at Wells Fargo). February 6th 1996, 2.5 hrs. 12. Evaluating the Validity of Recovered Memories; Perspective of a Forensic Expert February 29'h 1996, 1.0 hr. 13. How Small Clients Get Large Awards, Psychological Trauma in early childhood produces life time consequences in some cases. Defense and plaintiff considerations. 2.5 hrs. 14. Giving Powerful Voices to Children in Court: I, March 20th 1998. Windle Turley, Esq. With Gilbert Kliman, M.D., 2.5 hrs. 15. Giving Powerful Voices to Children in Court III May 8th 1998, John Connelly, Jr. with Gilbert Kliman, M.D., 2.5 hrs. 20 EFTA00182876

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 21 of 23 The Children's Psychological Health Center Archive of Videotaped Seminars and Events: — Gilbert KIlman, M.D., Medical Director CLINICAL AND SCIENTIFIC TAPES: STARRED (*) TAPES BELOW ARE A PRECIOUS ARCHIVE OF INFORMATION ABOUT PROBLEMS AND TREATMENT OF SEVERELY STRESSED CHILDREN. THEY ARE NOT FOR SALE OR COMMERCIAL DISTRIBUTION. THEY MAY BE STUDIED AT CPHC ON-SITE. WITH ASSISTANCE OF OUR STAFF BY QUALIFIED RESEARCHERS, CLINICIANS, SPECIAL EDUCATION TEACHERS, ADMINISTRATORS OF NONPROFIT CLINICAL ORGANIZATIONS AND SCHOOLS FOR CHILDREN, SCIENTISTS AND STUDENTS OF RELEVANT DISCIPLINES BY APPOINTMENT AT CPTC HEADQUARTERS. CREDENTIALS, REFERENCES AND CONFIDENTIALITY AGREEMENT ARE REQUIRED COLLABORATIVE RESEARCH ARRANGEMENTS CAN BE CONTRACTED FOR WITH CONFIDENTIALITY AGREEMENTS AND LONG TERM USE OF THE TAPES. Childhood Post Traumatic Stress Disorder (California Pacific Hospital Grand Rounds). 1992 *2. New Theory of Post Traumatic Stress Disorder, Gilbert Kliman, M.D. December 4th 1992, International Association of Child and Adolescent Psychiatry and Allied Disciplines, Fairmont Hotel, San Francisco. *3. Severe Psychological Trauma in very Young Children March 23d 1993 *4. Post Traumatic Stress Disorder: Child & Adult September 27th 1993 5. Cost Effectiveness: Mental Health Services for Foster Children September 28th 1993 6. Preventive Child Psychiatry Mc Aulev St Marv's October I6th 1993, *7. New Theory of Post-Traumatic Stress Disorder, for Int. Association of Child and Adolescent Psychiatry, July 25th 1994 *8. Cornerstone Method Conference. Wells Fargo. January 30th 1996 *9. Cornerstone Conference: Control - Mastery Group, San Francisco Psychoanalytic Institute. February 9th 1996 22 EFTA00182877

Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 23 of 23 Francisco and Seattle, private therapeutic preschool in San Francisco, and Cornerstone Argentina 24. Thirty four year follow-up of a Cornerstone Treated autistic child, now recovered. Presented at The San Francisco Psychoanalytic Institute, Child Analysis Study Group, 2001. Pcrmission for public viewing granted by the patient. Excerpts may be viewed on www.childrens s chol ical. or the entire video obtained from *25 Orientation of the Family Services Center of King County. Four days in December, 2007, in Seattle. Six DVD's. Scientific and Educational Video Archives under Dr. Kliman's supervision: With parental permission, The Children's Psychological Health Center, under Dr. Kliman's leadership, is collecting unedited treatment documents of a special method of treatment in a real life space, called "The Cornerstone therapeutic preschool method." Now totaling over 200 video archive hours, eight different California therapists working with various educator teams have recorded their Cornerstone therapeutic preschool method work. Beginning in 1995, this archive started with Gilbert Kliman, M.D. working for a year as daily in-classroom therapist in a public special education school. He was assisted by Leanne Runyan and Gail Hernandez as the teachers at the San Mateo Early Childhood Education Center, a preschool special education facility of The County of San Mateo. A second team under his supervision included work at The San Francisco Unified School District (Vanessa Vigilante and Esther Kronenberg). Third and fourth teams were at The Salvation Army Gateway Shelter (Vanessa Vigilante as therapist and Lynda Byrd as teacher, Deanna Reardon as therapist and Lynda Byrd as teacher). A fourth was at The Cadence Cornerstone Site at Mt. Pleasant School, San Jose (Karita Hummer, therapist and Kathy Krall, teacher). Fifth team therapy was provided by Jane Christmas. The sixth team therapists was Dr. Miquela Diaz Hope, the seventh Molly Franklin, MFT. All have been extensively videotaped carrying out the method. An eighth team was assembled in late 2002, when Linda Hirshfeld Ph.D. joined as Fellow in Cornerstone Therapy. In 2001 Mikc McDonald, Ed.D. became Special Education Director of Cornerstone School. All the treatments arc have been under principal supervision of Dr. Kliman with additional supervision by Mali Mann, M.D., Myrna Frankel, Ed.D., and Jan Baeuerlen, M.D. Linda Hirshfeld, Ph.D. of the Ann Martin Center is conducting the archival work for her Cornerstone Services. A professional researcher/ training confidentiality agreement is required to study this archive. SAOK Private Forensic 7.I3-04\CVPPA CVAGilbed Kliman CV ppa 06 02 0S.doc 24 EFTA00182878

A/05/2009 09:41 FAX ROTHSTEIN ROSENFELT ADLE ?]001/011 AIM Rothstein Rosenfeldt Adler Attorneys at Law TO: FAX NUMBER: FROM: DATE: FACSIMILE COVER SHEET Esq. Bradley J. Edwards, Esq. and William J. Berger, Esq. June 4, 2009 RE: State of Florida v. Jeffrey Epstein Our File No. 09-22784 MESSAGE: as you probably know, the Palm Beach Post filed a separate Motion to unseal the NPA. We noticed that the Post did not notice you personally, so I have enclosed a courtesy copy of that Motion and Notice. I hope this finds you well. # OF PAGES (1 (including cover sheet) THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE. THANK YOU. Reply To: Las Olas City Centre • 401 East Las Olas Boulevard • Suite 1650. Fort Lauderdale, Florida 33301 Telephone: FORT LAUDERDALE • BOCA RATON • TAMPA • TALLAHASSEE • NEW YORK CITY • LOS ANGELES • Fax: EFTA00182879

06/05/2009 09:41 FAX ROTHSTEIN ROSENFELT ADLE 141002/011 06-04-'09 15:18 FROM-THOMAS & LOCICEPO 8139843070 T-997 P001/003 F-849 THOMAS LOCI GER° BRALOW 400 N. Ashley Deve•Suite 1100•Tam a FL 33602 (Phone (Fax) Toll Free: • I . facsimile transmittal To: R. Alexander Acosin, Esq. Fax: Judith Stevenson Arco, Esq. Michael McAuliffe, Esq. Jack Alan Goldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. From: Deanna K. Shullman, Esq. Date: 06/04/2009 Re: State I. J. Epstein Pages: 6 Cc: Marilyn Judicial Assistant to Judge Colbath Urgent O For review K Please comment O I jjejl!!llelythlPlasse recyc O 1 Please see attached Motion to Intervene and Petition for Access CONFIDP.NTIALITY STATEMENT This electronic message transmission contains information from the law firm of Thomas, LoCicero & PL and is confidential or privileged. The information is intended robe for the use of the individual or entity named above. If you are not the intended recipient. be aware Mat any disclosure. copying. drstributi ^ contents &this inhumation is prohibited. If you have received this electronic transmission in error, please nOtiry us by telephone immediately. Thankyou for your cooperation IRS Circular 230 Disclosure. To the extent this correspondence contains federal tax advice. such advice was not intendedto be used, and cannot be used by any taxpayer. for the purpose of ii) avoidng penalties under the Internal Revenue Code or (i) promoting. marketing, or recommending to another party any transaction or matter addressed heroin. If you would like us to prepare written tax advice designed to provide penalty protection, please comet us and we will be happy to discuss the matter with you m more detail confidential EFTA00182880

OS/OS/2009 09:42 FAX ROTHSTEIN ROSENFELT ADLE 0003/011 06-04-'09 15:19 FROM-THOMAS & L0CICER0 8139843070 T-997 P002/003 F-849 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION STATE OF FLORIDA Plaintiff, vs. JEFFREY EPSTEIN Defendant. Case Nos.: 2006-CF9454-A3OC 2008-9381CF-AXX NOTIa OF REARING PLEASE TAKE NOTICE that Palm Beach Newspapers, Inc., el/b/a The Palm Beach Post will call up for hearing its Motion to Intervene and Petition for Access before the Honorable Jeffrey Colbath, Palm Beach County Courthouse, 205 N. Dixie Hwy., Room 11F, West Palm Beach on June 10, 2009 at 10:40 a.m. or as soon thereafter as counsel may be heard. Time reserved: 10 Minutes THOMAS, LOCICERO & BRALOW PL atm K. Shullman Florida Bar No.: James B. Lake Florida Bar No.: Nal 400 North Ashley Drive, Suite 1100 P.O. Box 2602 (33601) Tampa, FL 33602 FacTelephone: simile: Attorneys for The Palm Beach Post EFTA00182881

06/05/2009 09:42 FAX ROTHSTEIN ROSENFELT ADLE la004/011 06-84-'09 15:19 FROM-THOMAS & L0CICER0 8139843070 T-997 P003/003 F-849 State v. Epstein Case No. 2006-CF9454 & 2008-9381CF Notice of Hearing on Palm Beach Post's Motion to Intervene CERTIFICATE O1P SERVICE WE HEREBY CERTIFY that a true end correct copy of the foregoing has been furnished via Z.S. Mail; /Facsimile; O Overnight Delivery to R. Alexander Acosta, United States Attorney's Office - Southern District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401; Judith Stevenson Arco, Esq., State Attorney's Office - West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401; William J. Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Ste. 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Ste. 1650, Fort Lauderdale, FL 3394; Jack Alan Goldberger, Esq., Atterbury Goldberger, et al., 250 yh S. Australian Ave., Ste. 1400, West Palm Beach, FL 33401 on this 7 — day of June, 2 09. cc: Judicial Assistant (Via Fax and U.S. Mail) Esquire Court Reporting Atto 2 EFTA00182882

00/05/2009 09:42 FAX ROTHSTEIN ROSENFELT .IDLE 000Sion 06-01-'09 15:35 FROM-THOMAS & LOCICERO 8139843070 T-989 P001/007 F-845 THOMAS I OCICERO BRALOW 400 N. Ashley Brits*Suite I I 00•Tam a OL 33602 1113-9843060 (Phone • (Fax) Toll Free: facsimile transmittal To: R. Alexander Acosta, Esq. Fax: Judith Stevenson Arco, Esq. Michael McAuliffe, Esq. Jack Alan Goldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. From: Deanna IC. Sbullman, Esq. Date: 06101/2009 Re: State v. J. Epstein Pages: 6 Please reticle K Please see attached Motion to Intervene and Petition for Access CONFIDENTIALITY STATEMENT This cicamnic message transmission contains information from the law Arm of Thomas. LoCiocro & Alaimo PL. and Is confidential or privileged. The infomiltion is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying. distnbuti use of the contents of this information is prohibited. If you have received this electronic transmission in error, please nod& us by telephone immediately. Thank you for your cooperation IRS Circular 230 Disclosure. To the extant this correspondence contains federal tax advice, such &dole* was not intcndod to be used, and cannot be ad by my taxpayer. fOr the purpose of (i) avoiding penalties under me Internal Revenue Code or (ii) promoting, marketing, or recommending to another parry any transaction or matter addressed herein. If you would like us to prepare written tax advice designed to provide penalty protecticr. please cent= us and we will be happy to discuss the matter with you in more deter) confidential EFTA00182883

06/05/2009 09:42 FAX ROTHSTEIN ROSENFELT ADLE 0006/011 06-01-'09 15:35 FROM-THOMAS & L0CICER0 8139843070 T-989 P002/007 F-845 THOMAS June 1, 2009 I OC ICERO BRALOW VIA FEDERAL EXPRESS OVERNIGHT MAIL The Honorable Jeffrey Colbath Fifteenth Judicial Circuit-Palm Beach Palm Beach County Courthouse Main Judicial Complex 205 N. Dixie Highway, Room 11F West Palm Beach, FL 33401 Re: Dear Judge Colbath: Tampa 400 N. Nib* Dr., Ste. 1100, Tampa, FL 38602 P.O. Sox 2602, Tam D2 0.813-sefseso b iota Ft. Lauderdale 101 N.E. 710r0 Ave., Ste. 1500 ;11Sitaiiims tow fa New York City 220 EOM Si, 10W Floor t/Ww.11elewlare oa" Deanna K o mi Direct Dial: Deann0.9hullment0tIolawfmn.com Reply To Tampa Enclosed is a courtesy copy of non-party Palm Beach Newspapers, Inc. d/b/a The Palm Beach Post's (the "Post") Motion to Intervene and Petition for Access to certain court records in this case. It is our understanding that Bradley Edwards and William Berger ofa in Rosenfeldt Adler have filed a similar motion on behalf of a non-party known " and that S motion is set for hearing on June 10, 2009. The Post requests an opportunity to be heard on the issue of access to these records at that time. Thank you for your consideration in this matter. Please do not hesitate to contact me with any questions or comments. Sincerely, THOMAS, LOCICERO & BRALOW PL Deanna K. Shullman cc: Counsel of Record 94141-ene -__ EFTA00182884

06/05/2009 09:43 FAX ROTHSTEIN ROSENFELT ADLE 06-01-'09 15:36 FROM-THOMAS & L0CICE80 8139843070 gh007/011 T-989 P003/007 F-845 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION STATE OF FLORIDA vs. JEFFREY EPSTEIN Case Nos.: 2006-CF9454-AXX & 2008-9381CF-AXX PALM BEACH POST'S MOTION TO INTERVENE M4D PETITION FOR ACCESS Palm Beach Newspapers, Inc., cl/b/a The Palm Beach Post (the "Post") moves to intervene in this action for the limited purpose of seeking access to documents filed under seal. The documents relate directly to the Defendant's guilty plea and sentence. Thus, the sealed documents go to the heart of the disposition of this case. But in requesting that Judge Pucillo seal these documents, the parties failed to comply with Florida's strict procedural and substantive requirements for sealing judicial records. In addition, continued sealing of these documents is pointless, because these documents have been discussed repeatedly in open court records. For all of these reasons, the documents must be unsealed. As grounds for this Motion, the Post states: 1. The Post is a daily newspaper that has covered this matter and related proceedings. In an effort to infomi its readers concerning these matters, the Post relies upon (among other things) law enforcement records and judicial records. 2. As a member of the news media, the Post has a right to intervene in criminal proceedings for the limited purpose of seeking access to proceedings and records. See Barron v. Florida Freedom Newspapers. Inc„ 531 So. 2d 113, 118 (Fla. 1988) (news media have standing to challenge any closure order); Miami Herald Publ'g Co. v. Lewis 426 So. 2d I, 7 (Fla. 1982) (news media must be given an opportunity to be heard on question of closure). EFTA00182885

06/05/2009 09:43 FAX ROTHSTEIN ROSENFELT ADLE 06-01-'09 15:36 FROM-THOMAS & L0CICER0 8139843070 Q008/011 T-989 P004/007 F-845 3. The particular documents under seal in this case are a non-prosecution agreement that was docketed on July 2, 2008, and an addendum docketed on August 25, 2008. Together, these documents apparently restrict any federal prosecution of the Defendant for offenses related to the conduct to which he pleaded guilty in this case. Judge Pucillo accepted the agreement for filing during a bench conference on June 30, 2008. The agreement, Judge Pucillo found, was "a significant inducement in accepting this plea." Such agreements and related documents typically are public record. See Oregonian Publishing Co. v. United States District Court, 920 17.2d 1462, 1465 (9th Cir. 1990) ("plea agreements have typically been open to the public"); United States v. Kopistra, 796 F.3d 1390, 1390-91 (11th Cir. 1986) (documents relating to defendant's change of plea and sentencing could be sealed only upon finding of a compelling interest that justified denial of public access). 4. The Florida Constitution provides that judicial branch records generally must be open for public inspection. See Art. I, § 24(a), Fla. Const. Closure of such records is allowed only under narrow circumstances, such as to "prevent a serious and imminent threat to the fair, impartial and orderly administration of justice," or to protect a compelling governmental interest. See Fla. R. Jud. Admin. 2.420(c)(9)(A). Additionally, closure must be effective and no broader than necessary to accomplish the desired purpose, and is lawful only if no less restrictive measures will accomplish that purpose. See Fla. R. Jud. Admin. 2. 420(c)(9)(B) & (C); Lewis, 426 So. 2d at 3. 5. In this case, the non-prosecution agreement and, later, the addendum were sealed without any of the requisite findings. Rather, it appears from the record, the documents were sealed merely because the Defendant's counsel represented to Judge Pucillo that the non- prosecution agreement "is a confidential document." See Plea Conference Transcript page 38 2 EFTA00182886

06/05/2009 09:43 FAX ROTHSTEIN ROSENFELT ADLE 2009/011 06-01-'09 15:36 FROM-THOMAS & LOCICERO 8139843070 1-989 P005/007 F-845 (June 30, 2008). Such a representation falls well short of demonstrating a compelling interest, a genuine necessity, narrow tailoring, and that no less restrictive measures will suffice. Consequently, the sealing was improper and ought to be set aside. 6. In addition, at this time good cause exists for unsealing the documents because of their public significance. Since the Defendant pleaded guilty to soliciting a minor for prostitution, he has been named in at least 12 civil lawsuits that — like the charges in this ease — allege he brought and paid teenage girls to come his home for sex and/or "massages."' At least 11 cases are pending. In another lawsuit, one of the Defendant's accusers has alleged that federal prosecutors failed to consult with her regarding the disposition of possible charges against the Defendant2 State prosecutors also have been criticized: The Palm Beach Police Chief has faulted the State Attorney's handing of these cases as "highly unusual" and called for the State Attorney's disqualification. Consequently, this case — and particularly the Defendant's agreements with prosecutors — are of considerable public interest and concern. 7. The Defendant's non-prosecution agreement with federal prosecutors also was important to Judge Pucillo. As she noted in the June 2008 plea conference, "I would view [the non-prosecution agreement] as a significant inducement in accepting this plea." See Plea Conference Transcript page 39. Florida law recognizes a strong public right of access to documents a court considers in connection with sentencing. See Sarasota Herald Tribune Div. See, e.g., Doe v. Epstein Case No. 08-80069 (S.D. Fla, 2008). Doe No, 2 v. Epstein, Case No. 08-80119 (S.D. Fla. 2008): Doe No. 3. v. Epstein, Case No. 08-80232 (S.D. Fla. 2008); Doe No. 4. v. Epstein, Case No. 08-80380 (S.D. Fla. 2008)' Poe No. 5 v. Epstein, Case No. 08- 80381 (S.D. Fla. 2008);[.... v. Epstein, Case No. 08-80811 (S.D. Fla. 2008); Doe v. Epstein, Case No. 08-80893 (S.D. Ha. 2008); Doe No. 7 v. Epstein, Case No. 08-80993 (S.D. Fla. 2008); Doe No. 6 v. Epstein, Case No. 08-80994 (S.D. Fla. 2008); Doe II v. Epstein, Case No. 09-80469 (S.D. Fla. 2009); Poe No. 101 v. Epstein Case No. 09-80591 (S.D. Fla. 2009); Doe No. 102 v. Epstein, Case No. 09-80656 (S.D. Fla. 2009); Doe No. 8 v. Epstein, Case No. 09-80802 (S.D. Fla. 2009). 2 See In re: Jane Doe, Case No. 08-80736 (S.D. Fla. 2008). 3 EFTA00182887

06/0S/2009 09:44 FAX ROTHSTEIN ROSENFELT ADLE 06-01-'09 15:37 FROM-THOMAS & LOCICERO 8139843070 Z010/011 T-989 P006/007 F-845 of the New York Times Co. v. Holtzendorf 507 So. 2d 667, 668 (Fla. 2d DCA 1987) ("While a judge may impose whatever legal sentence he chooses, if such sentence is based on a tangible proceeding or document, it is within the public domain unless otherwise privileged."). In this case, no interest justifies continued sealing of these "significant" documents that Judge Pucillo considered in accepting the plea and sentencing the Defendant. The lack of any such compelling interest — as well as the parties' failure to comply with the standards for sealing documents initially — provide good cause for unsealing the documents at this time. 8. Finally, continued closure of these documents is pointless, because many portions of the sealed documents already have been made public. For example, court papers quoting excerpts of the agreement have been made public in related federal proceedings.3 As the Florida Supreme Court has noted, "there would be little justification for closing a pretrial hearing in order to prevent only the disclosure of details which had already been publicized." Lewis, 426 So. 2d at 8. Similarly, in this case, to the extent that information already has been made public, continued closure is pointless and, therefore, unconstitutional. 9. The Post has no objection to the redaction of victims' names (if any) that appear in the sealed documents. In addition, insofar as the Defendant or State Attorney seek continued closure, the Post requests that the Court inspect the documents in camera in order to assess whether, in fact, continued closure is proper. 3 See, e.g., "Defendants Jeffrey Epstein andig..Motion for Stay," =. v. Epstein, Case No. 08.80811 (S.D. Fla. July 25, 200 c publicly Jan. 7, 2009). 4 EFTA00182888

06/05/2009 09:44 FAX ROTHSTEIN ROSENFELT ADLE 06-01-'09 15:38 FROM-THOMAS & L0CICER0 8139843070 e011/011 T-989 P007/007 F-845 WHEREFORE, the Post respectfully requests that this Court unseal the non-prosecution agreement and addendum and grant the Post such other relief as the Court deems proper. Respectfully submitted, THOMAS, LOCICERO & BRALOW PL ( canna K. Sh Florida Bar No.: James B. Lake Florida Bar No.: 101 N.E. Third Avenue, Suite 1500 Fort Lauderdale, FL 33301 Telephone: Facsimile: ett, ri A Fati t ifi) f Attorneys for The Palm Beach Post CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via facsimile and U.S. Mail to: R. Alexander Acosta, United States Attorney's Office - Southern District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401 (fax: Michael McAuliffe, Esq., and Judith Stevenson Arco, Esq., State Attorney's Office - West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401 (fax: Ell=11; Jack Man Goldberger, Esq., Atterbury Goldberger, et al., 250 S. Australian Ave., Ste. 1400, West Palm Beach, FL 33401 (fax: MIMI; and Bradley J. Edwards, Esq. and William J. Berger, Esq., Rothstein Rosenfeldt Adler, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, FL 33394 (fax: Oa on this 1st day of June, 2009. 5 EFTA00182889

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 18 U.S.C. § 371 18 U.S.C. § 1591(a)(1) 18 U.S.C. § 1591(a)(2) 18 U.S.C. § 2422(b) 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 2423(b) UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, " and Defendants. INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: I. Defendant JEFFREY EPSTEIN employed defendants MI , aikia ' " and to perform, among other things, services as personal assistants. EFTA00182890

2. Defendants JEFFREY EPSTEIN and paid.., H.R., and A.F. to perform, among other things, recruiting services. 3. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 4. Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a Delaware corporation. JEGE, INC.'s sole business activities related to the operation and ownership of a Boeing 727-31 aircraft bearing tail number N908JE. 5. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 6. Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. 7. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 8. Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older who engages in sexual activity with a person 16 or 17 years of age commits a felony of the second degree." For purposes of "this section, `sexual activity' means oral, anal, or vaginal penetration by, or union with, the sexual organ of another; however, sexual activity does not include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states 2 EFTA00182891

that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide belief that such person is over the specified age [shall] be a defense." 9. Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult "who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious molestation," which is a felony of the second degree if the victim is 12 years of age or older but less than 16 years of age. 10. Pursuant to Florida Statutes Sections 800.04(6Xa) and 800.04(6)(b), an adult "who [i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or lascivious conduct," which is a felony of the second degree. 11. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who: (1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual physical or sexual contact with the victim, including, but not limited to . . . the simulation of any act involving sexual activity in the presence of a victim who is less than 3 EFTA00182892

16 years of age, commits lewd or lascivious exhibition," which is a felony of the second degree. 12. Pursuant to Florida Statutes Section 800.04(2), "[n]either the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]." 13. Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide belief of the victim's age cannot be raised as a defense in a prosecution under [Section 800.04]." 14. Pursuant to Florida Statutes Section 800.02, a "person who commits any unnatural and lascivious act with another person commits a misdemeanor of the second degree." 15. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical license. 16. During the period of her involvement with the Defendants, Jane Doe #4 attended Wellington High School and County. 17. in Palm Beach During the period of her involvement with the Defendants, Jane Doe #5 attended Wellington High School in Palm Beach County. 4 EFTA00182893

18. During the period of their involvement with the Defendants, Jane Does # 6, 8, and 12 attended in Palm Beach County. 19. During the period of her involvement with the Defendants, Jane Doe #7 attended in Palm Beach County. 20. During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 17, 18, and 19 attended 21. attended in Palm Beach County. During the period of her involvement with the Defendants, Jane Doe #10 in Palm Beach County. 22. During the period of her involvement with the Defendants, Jane Doe #11 attended in Palm Beach County. 23. During the period of her involvement with the Defendants, Jane Doe #13 attended in Palm Beach County. COUNT 1 (Conspiracy: 18 U.S.C. § 371) 24. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 25. From at least as early as 2001, the exact date being unknown to the Grand Jury, through in or around October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendants, 5 EFTA00182894

JEFFREY EPSTEIN, a/k/a ' " and did knowingly and willfully combine, conspire, confederate, and agree with each other and with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, and entice individuals who had not attained the age of 18 years to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b). Purpose and Object of the Conspiracy 26. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. Manner and Means 27. The manner and means by which the Defendants and other participants sought to accomplish the purpose and object of the conspiracy included the following: (a) It was part of the conspiracy that Defendants , a/k/a ' ,, and other participants would contact minor females via the use of cellular and other telephones to 6 EFTA00182895

arrange appointments for minor females to travel to 358 El Brillo Way to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. (b) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, , a/k/a 1.1 and other participants would make payments to, or cause payments to be made to, minor females in exchange for engaging in lewd conduct. EPSTEIN, (c) It was further a part of the conspiracy that Defendants JEFFREY a/k/a ," and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, a/k/a " and other participants would make payments to, or cause payments to be made to, the recruiters for bringing additional minor females to 358 El Brillo Way to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (e) It was further a part of the conspiracy that Defendant JEFFREY EPSTEIN would pay minor females to engage in lewd conduct with Defendant to satisfy Defendant JEFFREY EPSTEIN's prurient interests. 7 EFTA00182896

Overt Acts 28. In furtherance of this conspiracy and to effect the objects thereof, there was committed, by at least one of the co-conspirators herein, at least one of the following overt acts, among others, in the Southern District of Florida, and elsewhere: Jane Does #1 and #2 (I) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity with Jane Doe #1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (2) In or around 2001, Defendant led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (4) In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, who was then a fourteen-years-old girl, to pinch his nipples while he masturbated. (5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. (6) In or around 2001, Defendant placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. 8 EFTA00182897

(7) In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse with an unidentified female in the presence of Jane Doe #2, who was then a fourteen- year-old girl. (8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. (9) On or about March 11, 2003, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #2. (10) In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who would be interested in engaging in similar sexual activities with him. (11) In or around 2003, Defendant- of Jane Doe #2, who was then a sixteen-year-old girl. (12) In or around 2003, Defendant took nude photographs made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. (13) In or around 2003, Defendant told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked to take nude photographs of Jane Doe #2. 9 EFTA00182898

(14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a sixteen-year-old girl. (15) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a sixteen-year-old girl. (16) In or around 2003, Defendant placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. (17) On or about April 23, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. (18) On or about May 2, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. Jane Doe #3 (19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #3, who was then a fifteen-year-old girl. (20) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. (21) On or about October 26, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. 10 EFTA00182899

(22) On or about October 30, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. (23) In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe #3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and to touch the adult female's breasts. (24) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of an adult female in the presence of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. (25) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. (26) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #3 to rub his nipples. (27) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. (28) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. 11 EFTA00182900

(29) On or about November 8, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #3 that read: "I have a female for him." (30) On or about January 14, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #3. (31) On or about January 29, 2005, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #3 that read: "I have a female for him." Jane Does #4. #5, and #6 (32) In or around the first half of 2004, Defendant led Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (33) In or around the first half of 2004, Defendant JEFFREY EPSTEIN learned that Jane Doe #4 was seventeen years old when he asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. (34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, and Jane Doe #5, who was then a seventeen-year-old girl. 12 EFTA00182901

(35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his nipples. (36) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her clothing. (37) In or around the first half of 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #4, who was then a seventeen-year-old girl. (38) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #4. (39) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #5. (40) In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #6 what high school she attended. (41) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone. (42) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl. 13 EFTA00182902

(43) In or around the first half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #6, who was then a sixteen-year-old girl. (44) In or around the first half of 2004, Defendant JEFFREY EPSTEIN placed a large vibrating massager on the vagina of Jane Doe #6, who was then a sixteen-year-old girl. (45) In or around the first half of 2004, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #6. Jane Does #7 and #8 (46) In or around July 2004, Defendant JEFFREY EPSTEIN led.., who was then a fifteen-year-old girl, and Jane Doe #7, who was then a sixteen-year-old girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom. (47) On or about July 4, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #7. (48) On or about July 5, 2004, Defendant placed a telephone call to a telephone used by M. (49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #8, who was then a seventeen-year-old girl. 14 EFTA00182903

(50) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #8, who was then a seventeen-year-old girl. (51) In or around July 2004, Defendant JEFFREY EPSTEIN paid approximately $200 to Jane Doe #8. (52) In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to M. for recruiting Jane Doe #8 to travel to 358 El Brillo Way. (53) In or around July 2004, Defendant told Jane Doe #8 that Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a friend. (54) On or about July 15, 2004, Defendant telephone call to a telephone used by Jane Doe #7. (55) On or about July 15, 2004, Defendant telephone call to a telephone used by Jane Doe #8. (56) On or about July 15, 2004, Defendant telephone call to a telephone used by (57) On or about July 16, 2004, Defendant more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004, Defendant telephone call to a telephone used by.. 15 placed a placed a placed a placed one or placed a EFTA00182904

(59) On or about July 17, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from.. that read: "Me & [Jane Doe #7] can come tomorrow any time or [M.1 alone". (60) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #7, who was then a sixteen-year-old girl. (61) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #7, who was then a sixteen-year-old girl, to rub his nipples. (62) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #7, who was then a sixteen-year-old girl. (63) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #7. (64) In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe #7 that if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN's home, bad things could happen to her. (65) On or about July 24, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. Jane Does #9 and #10 (66) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. 16 EFTA00182905

(67) On or about July 16, 2004, Defendant caused Jane Doe #9 to make a telephone call to a telephone used by Jane Doe #10. (68) On or about July 17, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (69) On or about July 18, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (70) On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (71) In or around July 2004, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #9, who was then a seventeen-year-old girl. (72) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #9, who was then a seventeen-year-old girl. (73) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #9. (74) On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #10. (75) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and engaged in oral sex and sexual intercourse in the presence of Jane Doe #9, who was then a seventeen-year-old girl. 17 EFTA00182906

(76) In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly inserted his penis into the vagina of Jane Doe #9, who was then a seventeen- year-old girl. (77) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #9. (78) In or around the last half of 2004, Defendant JEFFREY EPSTEIN rubbed the vagina of Jane Doe #10, who was then a seventeen-year-old girl. (79) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #10. (80) On or about November 28, 2004, Defendant JEFFREY EPSTEIN arranged for one of his employees to provide an envelope filled with cash to Jane Doe #9. (81) On or about December 4, 2004, Defendant provided a written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 9 and 10, stating: "[Jane Doe #10] would like to work @ 4:00 pm if possible. [[Jane Doe #9] is scheduled for 5:00 today.] the movie is @ 7:30". (82) On or about December 29, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (83) On or about December 30, 2004, Defendants JEFFREY EPSTEIN and caused the purchase of Broadway tickets as an eighteenth birthday gift for Jane Doe #9. 18 EFTA00182907

(84) In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen- year-old girl. (85) In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #10, who was then a seventeen-year-old girl. (86) On or about January 14, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #10. (87) On or about January 27, 2005, Defendant placed one , a/k/a ," placed one or more telephone calls to a telephone used by Jane Doe #10. (88) On or about January 28, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (89) On or about February I, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (90) In or around February 2005, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #9 for recruiting Jane Doe #16 to travel to 358 El Brillo Way. 19 EFTA00182908

Jane Doe #11, (91) In or around the summer of 2004, Defendant led Jane Doe #11 and ■. from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's master bedroom suite. (92) In or around the summer of 2004, Defendant JEFFREY EPSTEIN paid $200 to M. for bringing Jane Doe #11 to 358 El Brillo Way. (93) In or around the summer of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #11, who was then a fifteen- or sixteen-year- old girl. (94) In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #11 to rub his chest and pinch his nipples while he masturbated. (95) In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #11 to write her telephone number on a notepad in his master bedroom suite. (96) In or around the summer of 2004, Defendant JEFFREY EPSTEIN learned Jane Doe #11's true age when he asked Jane Doe #11 how old she was and she responded truthfully. (97) In or around the summer of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #11 that he did not care how old she was and that he did not like girls older than eighteen. 20 EFTA00182909

(98) In or around the second half of 2004, Defendant JEFFREY EPSTEIN placed a vibrating massager on the vagina of Jane Doe #11, who was then a sixteen- year-old girl. (99) In or around the second half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated the vagina of Jane Doe #11, who was then a sixteen-year-old girl. (100) On or about August 6, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. (101) On or about August 18, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. (102) On or about October 29, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. (103) On or about November 5, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. (104) On or about February 14, 2005, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #11 that read: "Please! Call her back". (105) On or about February 14, 2005, Defendant a telephone call to a telephone used by Jane Doe #11. (106) On or about February 21, 2005, Defendant a telephone call to a telephone used by Jane Doe # II. 21 placed placed EFTA00182910

(107) On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #11. (108) In or around the second half of 2005 or the first quarter of 2006, Defendant JEFFREY EPSTEIN offered to pay $400 to Jane Doe #11, who was then a sixteen-year-old girl, if she would engage in oral sex, or $500 or more if she would engage in sexual intercourse. (109) In or around the second half of 2005, Defendant JEFFREY EPSTEIN offered to pay $100 to Jane Doe #11 if she would bring other girls to 358 El Brillo Way. Jane Does #12 and #13 (110) On or about August 2, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from M. and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #13] too". (111) On or about August 21, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #13. (112) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #12, who was then a seventeen-year-old girl. (113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #12, who was then a seventeen-year-old girl. 22 EFTA00182911

(114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to place a massaging device on the vagina of Jane Doe #12, who was then a seventeen-year-old girl. (115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #12. (116) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #12, who was then a seventeen-year-old girl, about her age. (117) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #12 that he would take her to Los Angeles when she turned eighteen. (118) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #12 to recruit Jane Doe #13 to travel to 358 El Brillo Way. (119) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence ofJane Doe #13, who was then a seventeen-year-old girl. (120) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #13, who was then a seventeen-year- old girl. (121) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #13. (122) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #13, who was then a seventeen-year-old girl. 23 EFTA00182912

(123) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13, who was then a seventeen-year-old girl, about her age. (124) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #13 that he wanted to take her to Paris but he could not because Jane Doe #13 was not yet eighteen years old. (125) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #I3 to bring her friends to his home, especially "girls who looked like [Jane Doe #13]." Jane Doe #14 (126) In or around the last half of 2004, Defendant led Jane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (127) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #14 to provide her telephone number. (128) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples. (129) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #14, who was then a seventeen-year old girl. (130) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #14. 24 EFTA00182913

(131) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeen- year-old girl. (132) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl, whether she had any plans for her eighteenth birthday and acknowledged that she had not yet turned eighteen. (133) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #14. (134) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #14, who was then a seventeen- year-old girl. (135) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doe #14, who was then a seventeen-year-old girl. (136) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl. (137) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $600 to Jane Doe #I4. (138) On or about January 8, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. 25 EFTA00182914

(139) On or about January 9, 2005, Defendant a/k/a ," placed a telephone call to a telephone used by Jane Doe #14. (140) On or about January 26, 2005, Defendant a/k/a ," reviewed a written telephone message prepared by one of Defendant JEFFREY EPSTEIN's employees regarding a call received from Jane Doe #14 that read: "She is confirming for 5:30". (141) On or about January 26, 2005, Defendant a/k/a " placed a telephone call to a telephone used by Jane Doe #14. (142) On or about February 1, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #I4. (143) On or about March 1, 2005, Defendant a/k/a `1 CI ," placed a telephone call to a telephone used by Jane Doe #14. (144) On or about March 21, 2005, Defendant a/k/a ," placed a telephone call to a telephone used by Jane Doe #14. (145) On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. Jane Doe #15 (146) On or about December 6, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. (147) On or about December 14, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. 26 EFTA00182915

(148) In or around the first half of 2005, Defendant led Jane Doe #15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (149) In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #15, who was then a seventeen-year-old girl, to pinch his nipples while he masturbated. (150) In or around the first half of 2005, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #15. (151) In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #15. (152) On or about January 7, 2005, Defendant a/k/a " placed a telephone call to a telephone used by Jane Doe #15. (153) On or about February 4, 2005, Defendant telephone call to a telephone used by Jane Doe #15. (154) On or about February 10, 2005, Defendant a telephone call to a telephone used by Jane Doe #15. (155) On or about February 21, 2005, Defendant a telephone call to a telephone used by Jane Doe #I5. (156) On or about February 24, 2005, Defendant a telephone call to a telephone used by Jane Doe #15. 27 placed a placed placed placed EFTA00182916

(157) On or about March 17, 2005, Defendant telephone call to a telephone used by Jane Doe #15. (158) On or about March 30, 2005, Defendant telephone call to a telephone used by Jane Doe #15. (159) On or about March 31, 2005, Defendant telephone call to a telephone used by Jane Doe #15. (160) On or about March 31, 2005, Defendant placed a placed a placed a a/k/a " placed a telephone call to a telephone used by Jane Doe #15. (161) On or about April 1, 2005, Defendant JEFFREY EPSTEIN reviewed a note prepared by one of his employees that read: "10:30 [Jane Doe #15]/[Jane Doe #10] on Fri around 2'Oclock". (162) In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane Doe #15 with a gift of Victoria's Secret lingerie for her eighteenth birthday. Jane Does #16 & #17 (163) In or around February 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #16, who was then a seventeen-year-old girl. (164) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #16 to place a telephone call to Jane Doe # 17 to ask her to travel to 358 El Brillo Way. 28 EFTA00182917

(165) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN caused a payment to be made to Jane Doe #16 for recruiting Jane Doe #17 to travel to 358 El Brillo Way. (166) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #17, who was then a sixteen-year-old girl. (167) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her clothing. (168) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #17, who was then a sixteen- year-old girl. (169) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #17, who was then a sixteen-year-old girl. (170) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #16, who was then a seventeen-year-old girl. (171) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, how old she was, and she responded that she was seventeen years old. 29 EFTA00182918

(172) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN engaged in sexual activity with Defendant in the presence of Jane Doe #16, who was then a seventeen-year-old girl. (173) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #I6, who was then a seventeen-year-old girl, to touch the breast of Defendant (174) On or about April 11, 2005, Defendant a/k/a ," placed a telephone call to a telephone used by Jane Doe #16. placed a 'i (175) On or about April 11, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (176) On or about April 11, 2005, Defendant left a message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] can work tomorrow at 4pm." (177) On or about May 19, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (178) On or about June 30, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (179) On or about July 2, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (180) On or about July 22, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 30 EFTA00182919

(181) On or about August 18, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (182) On or about August 19, 2005, Defendant `1 placed a a/k/a ," placed a telephone call to a telephone used by Jane Doe #16. (183) On or about August 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (184) On or about September 3, 2005, Defendant '1 a/k/a ," placed a telephone call to a telephone used by Jane Doe #16. (185) On or about September 18, 2005, Defendant a telephone call to a telephone used by Jane Doe #16. (186) On or about September 19, 2005, Defendant text message to a telephone used by Jane Doe #16. (187) On or about September 29, 2005, Defendant a telephone call to a telephone used by Jane Doe #I6. (188) On or about September 30, 2005, Defendant dil placed sent a placed , a/k/a ' placed a telephone call to a telephone used by Jane Doe #16. (189) On or about October 1, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #15] confirmed at 11 AM and [Jane Doe #16] — 4PM". (190) On or about October 2, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 31 EFTA00182920

(191) On or about October 3, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (192) On or about October 3, 2005, Defendant placed a left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #I6] will be 'A hour late". (193) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doe #16, who was then a seventeen-year-old girl. (194) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN made a payment of $350.00 to Jane Doe #16, who was then a seventeen- year-old girl. (195) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN provided a gift of Victoria's Secret lingerie to Jane Doe #16 for her eighteenth birthday. Jane Does #18 and #19 (196) In or around the last half of 2003, Jane Doe #18 was approached by A.F. and was asked whether she would be willing to provide a massage to Defendant JEFFREY EPSTEIN in exchange for $200. (197) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to provide her telephone number. 32 EFTA00182921

(198) On or around August 27, 2003, Defendant placed a telephone call to a telephone used by Jane Doe #18. (199) In or around the last half of 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #18, who was then a seventeen-year-old-girl. (200) On or around November 16, 2003, Defendant placed a telephone call to a telephone used by Jane Doe #I8. (201) In or around the last half of 2003, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #18, who was then a seventeen-year-old-girl. (202) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to recruit other females to travel to 358 El Brillo Way. (203) On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #19, who was then a seventeen-year-old girl, to leave when she refused to remove her shirt. (204) On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally reprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she was not willing to undress for him. The Defendants' Travel (205) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, , and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 33 EFTA00182922

(206) On or about August 6, 2004, Defendants JEFFREY EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (207) On or about August 19, 2004, Defendants JEFFREY EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (208) On or about October 29, 2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (209) On or about February 21, 2005, Defendants JEFFREY EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (210) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (211) On or about September 18, 2005, Defendants JEFFREY EPSTEIN, and a/k/a ' " traveled from Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 34 EFTA00182923

(t) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, , a/k/a` "and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. All in violation of Title 18, United States Code, Section 371. COUNTS 2 THROUGH 11 (Sex Trafficking: 18 U.S.C. § 1591(a)(1)) 29. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 30. On or about the dates enumerated as to each count listed below, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and foreign commerce, recruit, entice, provide, and obtain by any means a person, that is, the person in each count listed below, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1): Count Dates Minor Involved Defendants 2 2001 - 2004 Jane Doe ti2 JEFFREY EPSTEIN 3 January 2004 through July 2004 Jane Doe 114 JEFFREY EPSTEIN 35 EFTA00182924

Count Dates Minor Involved Defendants 4 July 2004 through December 29, 2004 Jane Doe #9 JEFFREY EPSTEIN 5 July 2004 through January 31, 2005 Jane Doe #10 JEFFREY EPSTEIN 6 Mid-2004 through March 2005 Jane Doe #11 JEFFREY EPSTEIN 7 Mid-2004 through April 22, 2005 Jane Doe #12 JEFFREY EPSTEIN 8 August 2004 through May 27, 2005 Jane Doe #13 JEFFREY EPSTEIN 9 November 2004 through March 2005 Jane Doe #14 JEFFREY EPSTEIN a/Ida ' 10 December 2004 through June 5, 2005 Jane Doe #15 JEFFREY EPSTEIN a/lc/a ' I I February 2005 through first week of October 2005 Jane Doe #16 JEFFREY EPSTEIN a/k/a All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2. 36 EFTA00182925

COUNT 12 (Sex Trafficking: 18 U.S.C. § 1591(a)(2)) 31. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 32. From at least as early as in or about 2001 through in or about October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, , a/k/a " and did knowingly benefit, financially or by receiving anything of value, from participation in a venture, as defined in 18 U.S.C. § 1591(c)(3), which had engaged in an act described in violation of 18 U.S.C. § 1591(a)(1), that is, the recruiting, enticing, providing, and obtaining by any means a person, in or affecting interstate commerce, knowing that the person or persons had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title IS, United States Code, Sections 1591(a)(2), 1591(6)(2), and 2. COUNT 13 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 33. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 37 EFTA00182926

34. From in or around the spring of 2003 through on or about October 2, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #3, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is violations of Florida Statutes Sections 800.04(5)(a), 800.04(6)(a), and 800.04(7)(a); in violation ofTitle 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 35. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 36. In or around July 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #7, who was a person who had not attained the age of 38 EFTA00182927

18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 15 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 37. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 38. From in or around July 2004 through in or around October 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #8, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 16 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 39. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 40. From in or around July 2004 through on or around December 29, 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, 39 EFTA00182928

JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #9, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 17 (Enticement of a Minor: 18 U.S.C. § 2422(0) 41. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 42. From in or around July 2004 through on or about January 31, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #10, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. 40 EFTA00182929

COUNT 18 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 43. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 44. From in or around the middle of 2004 through in or about March 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #11, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 19 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 45. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 46. From in or around the middle of 2004 through on or about April 22, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and 41 EFTA00182930

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #12, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 20 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 47. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 48. From in or around August 2004 through on or about May 27, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #13, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 21 (Enticement of a Minor: 18 U.S.C. § 2422(0)) 49. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 42 EFTA00182931

50. From in or around November 2004 through in or around March 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and , a/k/a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #14, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 22 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 51. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 52. From in or around December 2004 through on or about June 5, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a/lc/a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #15, who was a person who had not attained the age 43 EFTA00182932

of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 23 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 53. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 54. From in or around February 2005 through in or around the first week of October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, ,, and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce or entice Jane Doe #16, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 24 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 55. Paragraphs I through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 44 EFTA00182933

56. From in or around February 2005 through in or around April 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a/k/a ' ft did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #17, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 25 (Enticement of a Minor: 18 U.S.C. § 242200) 57. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 58. From in or around August 2003 through in or around February 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #18, who was a person who had not attained the age 45 EFTA00182934

of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 26 (Conspiracy to Travel: 18 U.S.C. § 2423(e)) 59. Paragraphs 1 through 23 of this indictment are re-alleged and incorporated by reference as fully set for the herein. 60. From at least as early as 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, the Defendants, JEFFREY EPSTEIN, a/k/a ' " and did knowingly and willfully conspire with each other and with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(1), with another person, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e). COUNT 27 (Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d)) 61. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 62. From at least as early as in or about 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendant, 46 EFTA00182935

did, for the purpose of commercial advantage or private financial gain, arrange and facilitate the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d). COUNTS 28 THROUGH 35 (Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b)) 63. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 64. On or about the dates enumerated as to each count listed below, from a place outside the Southern District of Florida to a place inside the Southern District of Florida, the Defendants listed below traveled in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in 18 U.S.C. § 2423(f), with a person under 18 years of age, that is, the person(s) listed in each count below: Count Date Minor(s) Involved Defendants 28 7/16/2004 Jane Doe V Jane Doe #8 Jane Doe #9 Jane Doe #10 JEFFREY EPSTEIN 29 8/6/04 Jane Doe #9 Jane Doe #11 JEFFREY EPSTEIN 30 8/19/04 Jane Doe #9 Jane Doe #10 Jane Doe #11 JEFFREY EPSTEIN 47 EFTA00182936

Count Date Minor(s) Involved Defendants 31 10/29/04 Jane Doe #10 Jane Doe #11 Jane Doe #13 JEFFREY EPSTEIN 32 2/21/05 Jane Doe #11 Jane Doe #14 Jane Doe #15 JEFFREY EPSTEIN a/k/a ' 33 3/31/2005 Jane Doe #11 Jane Doe #14 Jane Doe #15 Jane Doe #16 JEFFREY EPSTEIN a/k/a ' 34 9/18/2005 Jane Doe #16 JEFFREY EPSTEIN ii/k/a ' 35 9/29/05 Jane Doe #16 JEFFREY EPSTEIN a/k/a ' All in violation of Title 18, United States Code, Sections 2423(b) and 2. FORFEITURE 1 Upon conviction of the violation alleged in Count 1 of this indictment, the defendants, JEFFREY EPSTEIN, a/k/r "and shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. 48 EFTA00182937

Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21, United States Code, Section 853. If the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, ailda " and (1) (2) (3) (4) (5) difficulty; it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendants up to the value of the above forfeitable property. All pursuant to Title ited States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Titl 21)U ted States Code, Section 853. FO EITURE 2 Upon conviction of any of the violations alleged in Counts 13-35 of this indictment, cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with a third person; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or has been commingled with other property which cannot be subdivided without the defendants, JEFFREY EPSTEIN, n and anda shall forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other proceeds obtained from such 49 EFTA00182938

offense; and any property, real or personal, used or intended to be used to commit or to promote the commission of such offense, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 2253. If any of the forfeitable property described in the forfeiture section of this indictment, as a result of any act or omission of the defendants JEFFREY EPSTEIN, a/k/a " and cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third person; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or 50 EFTA00182939

(e) has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to Title 18, United States Code, Section 2253(o), to seek forfeiture of any other property of said defendant up to the value of the above forfeitable property. Pursuant to Title 18, United States Code, Section 2253. FORFEITURE 3 Upon conviction of any of the violations alleged in Counts 2-12 of this indictment, the defendants, JEFFREY EPSTEIN, n and a/k/a `M shall forfeit to the United States any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such violation; and any property, real or personal, constituting or derived from any proceeds that such person obtained, directly or indirectly, as a result of such violation, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the 51 EFTA00182940

West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 1594(b). A TRUE BILL. FOREPERSON - Th YaMEIC7cCOST4 UNITED STATES ATTORNEY ASSISTANT UNITED STATES ATTORNEY 52 EFTA00182941

INDICTMENT SUMMARY CT DATE(S) kEFENDANT(S) VICTIM(S) STATUTES/CHARGE 1 2001 - October 2005 NEPSTEIN Jane Does 1-19 18 U.S.C. §§ 371 and 2 Conspiracy to use a facility or means of interstate commerce to persuade, induce, or entice minors to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense 2 2001 - 2004 ,\EPSTE1N Jane Doe #2 18 U.S.C. §§ 1591(a)(1) and 2 (Carolyn A.) Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 4 3 January 2004 - Jane Doe #4 18 U.S.C. §§ 1591(a)(1) and 2 July 2004 . 11 1 1 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 4 July 2004 - \EPSTEIN Jane Doe #9 18 U.S.C. §§ 1591(a)(1) and 2 December 29, 2004 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. Page 1 of 9 EFTA00182942

CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 5 July 2004 - January 31, 2005 EPSTEIN t Jane Doe #10 18 U.S.C. §§ 1591(a)(1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 6 Mid-2004 - April 22, 2005 NIPSTEIN a Jane Doe #12 18 U.S.C. §§ 1591(a)(1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 7 Mid-2004 - April 22, 2005 i lc r IEIN Jane Doe #12 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 8 August 2004 - May 27, 2005 \ tPSTEIN Jane Doe #13 18 U.S.C. §§ 1591(a)(1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. Page 2 of 9 EFTA00182943

CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 9 November 2004 - March 2005 --a N EPSTEIN ..NEPSTEIN Jane Doe #14 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 10 December 2004 - June 5, 2005 Jane Doe #15 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 11 February 2005 - October 2005 \EPSTEIN Jane Doe #16 18 U.S.C. §§ 1591(a)(1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 12 2001 - October 2005 Jane Does 1-19 18 U.S.C. § 1591(aX2) Benefitting, financially or by receiving any thing of value, from participation in a venture which had engaged in the recruiting, enticing, providing, or obtaining by any means a person, knowing that the person or persons had not attained the age of 18 years and would be caused to engage in a commercial sex act Page 3 of 9 EFTA00182944

CT DATE(S) FENDANT(S) VICTIM(S) STATUTES/CHARGE 13 Spring 2003 - October 2, 2005 \EPSTEIN Jane Doe #3 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 14 July 2004 N.E.PS;;EIN %\ P Jane Doe #7 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 15 July 2004 to October 2004 STEIN Jane Doe #8 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 16 July 2004 - December 29, 2004 \S TEIN Jane Doe #9 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense Page 4 of 9 EFTA00182945

CT DATE(S) EFENDANT(S) VICTIMS) STATUTES/CHARGE 17 July 2004 - January 31, 2005 IN \ EPSTEIN Jane Doe #10 18 U.S.C. §§ 2422(6) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 18 Mid-2004 - March 2005 Jane Doe #11 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 19 Mid-2004 - April 22, 2005 • STEIN \ Jane Doe #12 18 U.S.C. §§ 2422(6) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 20 August 2004 - May 27, 2005 ii iel s1 Jane Doe #13 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense Page 5 of 9 EFTA00182946

CT DATE(S) DFENDANT(S) VICTIM(S) STATUTES/CHARGE 21 November 2004 - March 2005 IIPSTEIN Jane Doe #14 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 22 December 2004 - June 5, 2005 . 'N PSTEIN Jane Doe #15 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 23 February 2005 - October 2005 ItPSTEIN Jane Doe #16 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 24 February 2005 - April 2005 \STEIN Jane Doe #17 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense Page 6 of 9 EFTA00182947