Case 9:08-cv-80736-KAM Document 361-25 Entered on FLSD Docket 02/10/2016 Page 2 of 3 (USAFLS) From: Jeff (USAFLS) Sent: r 28, 2007 4:35 PM To: (USAFLS) Subject: w. pew Can u send Jay the proposed letter and redact the names? Thx, Jeff Sent from my BlackBerry Wireless Handheld Original Message Lefkowitz <[email protected]> , Jeff (USAFLS) (USAFLS) Sent: Wed Nov 28 16:29:09 2007 Subject: Re: Epstein Dear Jeff: I received your email yesterday and was a little surprised at the tone of your letter, given the fact that we spoke last week and had what I thought was a productive meeting. I was especially surprised given that your letter arrived on only the second day back to work after the Thanksgiving Holiday, and yet your demands regarding timing suggest that I have been sitting on my hands for days. You should know that the first time I learned about Judge selection of Podhurst and Josephsberg, and indeed the first time I ever eard their names, was in our meeting with you on Wednesday of last week. Nevertheless, I have now been able to confer with my client, and we have determined that the selection of Podhurst and Josephsberg are acceptable to us, reserving, of course, our previously stated objections to the manner in which you have interpreted the section 2255 portions of the Agreement. We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Without a fair opportunity to review and the ability to make objections to this letter, it is completely unacceptable that you would send it without our consideration. Additionally, given that the US Attorney's office has made clear it cannot vouch for the claims of the victims, it would be incendiary and inappropriate for your Office to send such a letter. Indeed, because it is a certainty that any such letter would immediately be leaked to the press, your actions will only have the effect of injuring Mr. Epstein and promoting spurious civil litigation directed at him. We believe it is entirely unprecedented, and in any event, inappropriate for the Government to be the instigator of such lawsuits. 2544 08-80736-CV-MARRA RFP WPB-001978 EFTA00184396
Case 9:08-cv-80736-KAM Document 361-25 Entered on FLSD Docket 02/10/2016 Page 3 of 3 Finally, we disagree with your view that you are required to notify the alleged victims pursuant to the Justice for All Act of 2004. First, 18 USC section 2255, the relevant statute under the Non-Prosecution Agreement for the settlement of civil remedies, does not have any connection to the Justice for All Act. Section 2255 was enacted as part of a different statute. Second, the Justice for All Act refers to restitution, and section 2255 is not a restitution statute. It is a civil remedy. As you know, we had offered to provide a restitution fund for the alleged victims in this matter; however that option was rejected by your Office. Had that option been chosen, we would not object to your notifying the alleged victims at this point. At this juncture, however, we do not accept your contention that there is a requirement that the government notify the alleged victims of a potential civil remedy in this case. Accordingly, for all the reasons we have stated above, we respectfully -- and firmly -- object to your sending any letter whatsoever to the alleged victims in this matter. Furthermore, if a letter is to be sent to these individuals, we believe we should have a right to review and make objections to that submission prior to it being sent to any alleged victims. We also request that if your Office believes that it must send a letter to go to the alleged victims, who still have not been identified to us, it should happen only after Mr. Epstein has entered his plea. This letter should then come from the attorney representative, and not from the Government, to avoid any bias. As you know, Judge Starr has requested a meeting with Assistant Attorney General Fisher to address what we believe is the unprecedented nature of the section 2255 component of the Agreement. We are hopeful that this meeting will take place as early as next week. Accordingly, we respectfully request that we postpone our discussion of sending a letter to the alleged victims until after that meeting. We strongly believe that rushing to send any letter out this week is not the wisest manner in which to proceed. Given that Mr. Epstein will not even enter his plea for another few weeks, time is clearly not of the essence regarding any notification to the identified individuals. Thanks very much, Jay Jeff (USAFL5)" • 11/27/2007 01:55 PM To "lay Lefko z" <[email protected]> cc (USAFLS)" Epstein 2545 08-80736-CV-MARRA RFP WPB-001979 EFTA00184397
Case 9:08-cv-80736-KAM Document 361-26 Entered on FLSD Docket 02/10/2016 Page 1 of 5 EXHIBIT 26 EFTA00184398
Case 9:08-cv-80736-KAM Document 361-26 Entered on FLSD Docket 02/10/2016 Page 2 of 5 DECLARATION OF 1. My name is and I was born 2. I was molested by Jeffrey Epstein as a minor on dozens of occasions in his mansion in Palm Beach, Florida from around 2002 to 2005. I understand that evidence collected from Mr. Epstein's home showed conclusively that I was there as a minor, along with many other underage girls. Given how many girls Epstein was abusing, there could not have been any doubt in anyone's mind that had access to the testimonial and other evidence that Epstein molested me (and many others). 3. I cooperated fully with the FBI while they investigated Epstein's illegal activities with minors. 4. During the investigation, Epstein had investigators following and, harassing me. I continued to cooperate with the investigation despite this intimidation. 5. In late 2007, FBI agents met in person with me. During this meeting, the agents explained that Epstein was also being charged in State court and may plea to state charges related to some of his other victims. I knew the State charges had nothing to do with me. During this meeting, the Agents did not explain that an agreement had already been signed that precluded any prosecution of Epstein for federal charges against me. I did not get the opportunity to meet or confer with the prosecuting attorneys about any potential federal deal that related to me or the crimes committed against me. 6. My understanding of the agents' explanation was that the federal investigation would continue. I also understood that my own case would move forward towards prosecution of Epstein. 7. Confirming my understanding, in about January 2008, I received a letter from the FBI that told me that "this case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation." My understanding of this letter was that my case was still being investigated and the FBI and prosecutors wcrc moving forward on the Federal prosecution of Epstein for his crimes against me. EFTA00184399
Case 9:08-cv-80736-KAM Document 361-26 Entered on FLSD Docket 02/10/2016 Page 3 of 5 8. At this time, I was not told about any non-prosecution agreement or any potential resolution of the federal criminal investigation I was cooperating in. If I had been told about a non-prosecution agreement, I would have objected. 9. Criminal prosecution of Epstein for crimes against me was extremely important to me. I wanted to be consulted by the prosecutors before any resolution. In light of the letter I had received, I had confidence that I would be contacted by the federal government before it reached any final resolution of the investigation into my case and that I would likely be needed to testify if the case went to trial, which I was willing and anxious to do. 10. When I had not heard from the prosecuting attorney for a while, I met with attorney Brad Edwards wanting him to find out when Epstein was going to be federally charged and prosecuted for the crimes he committed against me and others. Epstein's investigators were harassing me, and that interfered with my life dramatically. My attorney, Mr. Edwards, was hired to make sure the prosecutor knew how eager I was to have Jeffrey Epstein prosecuted, and I understand that he did convey that to the prosecutors numerous times in around June 2008. 11. At some point, I understood that Mr. Edwards was getting responses from the prosecutor that were making him suspicious of the motivations of the U.S. Attorney's Office. I then understood that Mr. Edwards' suspicions were that the prosecutors were conferring with Epstein and not with me and the other victims. 12. I authorized Mr. Edwards to do anything possible to ensure that Epstein was prosecuted, and that I was able to meet with prosecutors and participate in the process. I agreed to file a lawsuit against the U.S. Attorney's Office to get them to speak with me about any possible case resolution or the terms and to answer questions about the case, and to generally treat me fairly, to notify me about any court hearing, and to otherwise enforce my rights as a crime victim. EFTA00184400
Case 9:08-cv-80736-KAM Document 361-26 Entered on FLSD Docket 02/10/2016 Page 4 of 5 13. Towards the end of June, 2008, I did not attend Jeffrey Epstein's guilty plea hearing in state court involving another victim of Epstein's abuse. I did not have reasonable notice of the hearing, and I did not have any reason to attend that hearing because no one had told me that this guilty plea was related to the FBI's investigation of Epstein's abuse of me. I had always understood generally that the State and Federal criminal systems were different and that one had nothing to do with the other. Based on what the FBI had been telling me, I thought they were still investigating my case. If I had been told that this plea had some connection to blocking the prosecution of my case, I would have attended and tried to object to the judge and prevent that plea from going forward. Many other victims would have done the same. I think that after hearing from me and some of the other girls who were abused by Epstein, a judge would not have allowed such a plea deal to go forward. It is my belief that the US Attorney's Office and Epstein's attorneys conspired to prevent my attendance at this hearing as well as the attendance of the many other victims. 14. I learned about the existence of a secret non-prosecution agreement only in July 2008, after my lawyer had filed court pleadings trying to give me a chance to talk to prosecutors about my case. I would never have learned of that agreement if I had not authorized my attorney to sue the United States. Nobody would have. 15. I wanted to cooperate in the prosecution more than anything else in my life; I was scared of Epstein; I was scared of what he had done to me and others, and of how he was continuing to harass me, and also what he could do to me and others. The criminal case against Epstein was my main focus in life. 16. When I attended a court hearing with Mr. Edwards in federal court, I learned for the first time that my rights had been extinguished through a secret deal between the prosecutors and Mr. Epstein. I received no explanation about exactly how the deal occurred or about whether my rights were gone forever. The EFTA00184401
Case 9:08-cv-80736-KAM Document 361-26 Entered on FLSD Docket 02/10/2016 Page 5 of 5 prosecutors were, at that time, trying to even keep me from seeing a copy of the secret plea deal. I wanted to meet with the prosecutors and tell them why they should prosecute my case, but it became clear that without ever talking to me, they had bargained my case away. 17. In about 2.(10 I had the chance to meet with the U.S. Attorney, Mr. I told him all about how T had been mistreated in the process. Mr. -seemed to be interested in this, hut nothing ever came of the meeting. And unfortunately it seems to me that Mr. office is continuing to try to block me and other girls from learning anything about the secret deal with Epstein or how our rights were violated, even though they know what they did was wrong. 18. I later came to understand that crime victims in the federal system have the right to meaningfully confer with the prosecutor for the government in the case, which at least means to explain how my case would be concluded; the right to be heard at important hearings; and the right to be treated with "fairness." I strongly believe that the way I was treated was unfair and violated my rights. 19. I think that the secret non-prosecution agreement should be declared illegal and that I should have the right to have crimes against me prosecuted by the U.S. Attorney's Office, and that Mr. Epstein should be treated the same as other defendants with less money and connections are treated for these crimes. 20. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed this 2P — , day of January, 2015. EFTA00184402
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 1 of 4 EXHIBIT 27 EFTA00184403
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 2 of 4 DECLARATION OF 1. My name is • and I was born in 2. I was paid by Jeffrey Epstein to interact sexually with him as a minor on dozens of occasions in his mansion in Palm Beach, Florida from around 2002 to 2005, and also to bring him other girls who were my approximate age for the same purposes. I understand that evidence collected fi-om Epstein's home showed conclusively that I was there as a minor, along with many other underage girls. Given how many girls Epstein was sexually abusing, there could not have been any doubt in anyone's mind that had access to the testimonial and other evidence that Epstein sexually molested me as a minor (and many others). 3. My son was very young when the FBI came to speak with me the first time. I did not know what to do and I was scared. I called Epstein, who told me not to wofry and that he would hire an attorney for me. I believed that if I told the truth about what happened at Epstein's house, the police would take my baby from me. That made me really scared. 4. Through the attorney that Jeffrey Epstein obtained for me, it was arranged for me to give a statement to the prosecutor investigating Epstein. 5. While with the attorney Epstein obtained for me I gave a statement to the prosecutor that was favorable to Epstein. The prosecutors knew the truth because of the volume of evidence they had, and they continued to recognize me as a victim of Epstein's crimes. 6. I had been greatly intimidated, which is why I could not be truthful initially and I wanted to end the threat of the possibility of my child being taken. My involvement with Epstein from a very young age was a deep, dark secret and Epstein told me to keep it a secret. I knew that I was expected to keep it a secret. 7. The more I thought about what was going on, the more I realized that what Epstein had done to both me and my friends was wrong and that anyone who was not very wealthy would be punished. At this time, I EFTA00184404
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 3 of 4 wanted Epstein held accountable the same way anyone else would be. I spoke about this with one of my friends around May 2008. I then called an attorney, Brad Edwards, around June 2008, understanding that he was hired to get the prosecutors to talk to us and hear the truth from me. That was especially important to me because I was finally represented by someone other than Epstein's attorney and wanted to talk to the prosecutors about everything I knew. 8. The prosecutors had a lot of information revealing the truth about the situation at Epstein's house. I had lot of information, too, because I was one of the young teenagers who had brought many other young teenagers to Epstein for the purpose of getting paid by Epstein. I wanted to assist the prosecutors in the investigation. I hired Mr. Edwards to let them know that I was cooperative and ready to tell them all of the helpful information I had. I understood that Mr. Edwards did that. 9. I authorized Mr. Edwards to join me in the lawsuit against the U.S. Attorney's Office to enforce my rights and to try to get me my chance to confer with the prosecutors before Mr. Epstein took a plea or the case was resolved in any way. I just wanted to be treated fairly in the process. 10. When Epstein pled guilty to a state crime at the end of June 2008, no one notified me that his plea had anything to do with my case against him. I did not know, for example, that this plea had some connection to a crime he committed against me particularly. In fact, at this young age, I had no idea what was going on and nobody tried to explain it to me. 11. In July 2008, I attended a federal court hearing with Mr. Edwards. It was then that I learned for the first time at that hearing that the prosecutors worked out some sort of secret deal with Epstein that might block his prosecution for crimes against me. It also appeared that there was a lot of continued communication between Epstein and the U.S. Attorney's Office. I was really upset that the U.S. Attorney's Office seemed like it would not talk with me or the other victims about what was going on. It was easier to get them to talk to me when I was represented by Epstein's attorney. EFTA00184405
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 4 of 4 12. I wanted to see this secret deal that the Government had with Epstein, but they would not give it to me at the hearing. Later, the other victims and I finally got to see the secret deal after the judge forced the prosecutors to show it to us. 13. I understand that I did not initially help the investigation by speaking on Epstein's behalf untruthfully. But I was intimidated and had good reason to protect myself and my son — reasons that I think everyone who was talking to me could obviously see. Also, the agents and attorneys obviously had a lot of evidence that provided proof of what Epstein had actually done. Epstein was still supporting me, providing me a lawyer and in my mind protecting me, so I was in a position where I felt I had to say certain things. And Epstein expected me to say those things. 14. Once I wanted to cooperate and tried to cooperate, I was never given the opportunity to confer with prosecutors from the time they were informed by my attorney that I was a cooperating witness. I was never told about the secret deal until after it was already concluded. I would have had my attorney object if I had been given the chance. 15. I don't feel like I was treated fairly in this process. And I know Epstein got a really good plea deal because he is rich and powerful. That doesn't seem fair either. Executed this asS5Th , day of January, 2015. EFTA00184406
Case 9:08-cv-80736-KAM Document 361-28 Entered on FLSD Docket 02/10/2016 Page 1 of 3 EXHIBIT 28 EFTA00184407
Case 9:08-cv-80736-KAM Document 361-28 Entered on FLSD Docket 02/10/2016 Page 2 of 3 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave.. Suite 400 West Palm Beach, FL 33401 Facsimile: June 7, 2007 DELIVERY BY BAND Miss Re: Crime Victims' and Witnesses' Riehts Dear Miss Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are: (1 ) The right to be reasonably protected from the accused. (2) The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused. (3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding. (4) The right to be reasonably heard at any public proceeding in the district court involving release, pica, or sentencing. (5) The reasonable right to confer with the attorney for the United States in the case. (6) The right to full and timely restitution as provided in law. (7) The right to proceedings free from unreasonable delay. (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these rights are protected. If you have an concerns in this regard, please feel free to contact me at or Special Agent from the Federal Bureau of Investigation at You also can contact the Justice Department's Office for Victims of Crime in Washington, D.C. at That Office has a website at www.ovc.gov. You can seek the advice of an attorney with respect to the rights listed above and, if you believe that the rights set forth above are being violated, you have the right to petition the Court for relief. 08-80736-CIV-IvIARRA 000978 EFTA00184408
Case 9:08-cv-80736-KAM Document 361-28 Entered on FLSD Docket 02/10/2016 Page 3 of 3 MISS JUNE 7, 2007 PAGE 2 In addition to these nghts, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possible that someone working on behalf of thc targets of the investigation may contact you. Such contact does not violate thc law. However, if you arc contacted, you have the choice of speaking to that person or retbsing to do so. If ou refuse and feel that you are being threatened or harassed, then please contact Special Agent or myself. You also are entitled to notification of upcoming caseevents. At this time, your case is under investigation. If anyone is charged in connection with the investigation, you will be notified. Sincerely, United States Attorney By: A. Assistant United States Attorney cc: Special Agent Kuyrkcndall, P.B.I. OR-807364 :II-MAR RA 000979 EFTA00184409
Case 9:08-cv-80736-KAM Document 361-29 Entered on FLSD Docket 02/10/2016 Page 1 of 4 ( ( EXHIBIT 29 EFTA00184410
Case 9:08-cv-80736-KAM Document 361-29 Entered on FLSD Docket 02/10/2016 Page 2 of 4 JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES CASE NO: 08-80736-Civ-Marra/Johnson EXHIBIT I EFTA00184411
Cqse 9:08-cv-80736-KAM Cement 361-29 Entered on FLSD ket 02/.1 U.S. (Impartment of Justice Federal Bureau of Investigation FBI - Wesl Palm Beach Suite 500 505 South Flagler Drive West Palm Beach, Ft. 33401 Phone: Fax: May 70.200E Re: laalle Dear Your name was referred to the FBfs Victim Assistance Program as being a possible victim of a federal crime. We appreciate your assistance and cooperation while we are Investigating this case. We would like to make you aware of the victim services that may be available to you and to answer any questions you may have regarding the criminal justice process throughout the investigation. Our program is part of the FBI's effort to ensure the victims are treated with respect end are provided information about their rights under federal law. These rights Include notification of the status of the case. The enclosed brochures provide information about the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System (VNS). VNS is designed to provide you with information regarding the status of your case. This case Is currently under cnvetitigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation. As a crime victim, you have the foibwing rights under 18 United States Code § 3771: (1) The right to be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the alma or of any release or escape of the accused; (3) The right not to be excluded from any such public coin proceeding, unless the court, atter receiving clear and convincing evidence, determines that testimony by the victim would be materially altered If the victim heard other testimony et that proceeding; (4) The right to be reasonably heard at any public proceeding in the district court Involving release. plea, sentencing, or any parole proceeding; (5) The reasonable tight to confer with the attorney for the Government in the case; (6) The right to full and timely restihrtI0n as provided in law; (7) The right to proceedings tree from unreasonable delay, (8) The right to be treated v4th fatness end with respect for the victim's dignity and privacy. We will make our beat efforts to ensure you are accorded the rights described. Most of these rights pertain to events occurring after the arrest or Indictment of en individual for the crime, and it will become the responsibility of the prosecuting Untied States Attorney's Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights. The Victim Notification System (VNS) Is designed to provide you with direct information regarding the case as it proceeds through the criminal justice system. You may obtain current information about this matter on the Internet at WWW.Notify.USDOJ.GOV or frorn the VN5 Call Center at 1.856-DOJ-4YOU (1-856-365- 4968) (TDD/TTY: 1466-228-4619) (International:1-502-213-2767). In addition, you may use the Call Center or Internet to update your contact information andier change your decision about participation in the notification program. if you update your information to Include a current email address. VNS will send Information to that address. You H11I need the following Victim Identification Number (Vial) '2074381' end Personal identification Number (PIN) '1816' anytime you contact the Calf Center and the gra( time you log on to VNS on the Internet. In addition, the first time you access the VNS Internet see, you will be prompted to enter your last name (or business name) as currently contained in VN3. The name you should enter Is EFTA00184412
te2;s:e."6Oil-c_"-8.07-36-KAM Aliment 361-29 "L"nterescitin FLSD Edo kets0,2110S92.6 Fr,a1",./of 4 11 II you have additional questions which Involve this matter, please contact the office listed above. When you caU, please provide the file number loaned et the top of this letter. Please remember, your participation In the notlecation part of this program le voluntary. In order to continue to receive notifications, fl Is your responsibility to keep your contact information current. Sincerely, 4 1.0; (LA. 0. 1 1;tie Twiler Smith Victim Specialst TOTAL P.0? EFTA00184413
Case 9:08-cv-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 1 of 28 EXHIBIT 30 EFTA00184414
• casecgigOvefig4foWkAWPcnerthlifitli30ENWEfielfict itaigogfe2.414313)1Paeenct4224f IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 102, Plaintiff, VS. JEFFREY EPSTEIN, Civil Action No 09-80656 CIV-RYSKAMP MAGISTRATE JUDGE VITUNAC FILED by 133 D C INTAKE MAY - 1 2009 I STEVEN M. ‘ARIMORE CLERK U.S DIST CT 5.0. OF FLA. MIAMI COMPLAINT AND Defendant. DEMAND FOR JURY TRIAL COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, Jane Doe No. 102, brings this Complaint against Defendant, Jeffrey Epstein, and states as follows: PARTIES. JURISDICTION. AND VENUE 1. At all times material to this cause of action, Plaintiff, Jane Doe No. 102, was a resident of Palm Beach County, Florida. 2. This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doe No. 102, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor. 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida. 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is currently incarcerated in the Palm Beach County Stockade. 5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. Podhurst Orseck, P.A. 25 West Flagkr Street Sulk SOO, Miami., FL 33134 Warn EXHIBIT CA Fort Lauderdale 954.463.4346 www.podIturst.com EFTA00184415
castia4.154127eASWAPPetgiedThegt1-130EW-61-Aft.RDWARRititAlitkinOad'eclvsfW 6. This Court has jurisdiction over this action and the claims set forth herein pursuant to 18 U.S.C. § 2255. 7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a substantial part of the events giving rise to the claim occurred in this District. STATEMENT OF FACTS 8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, spanning the ages of 45 and 55 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing 727, as well as a fleet of motor vehicles. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East Side. Upon information and belief, he also owns a $6.8 million mansion in Palm Beach, Florida, a $30 million 7,500-acre ranch in New Mexico he named "Zorro," a 70-acre private island known as Little St. James in St. Thomas, U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous other locations both nationally and internationally. 9. Upon information and belief, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access to countless vulnerable and relatively economically disadvantaged minor girls, and sexually assaulted, molested, and/or exploited these girls, and then gave them money. 10. Beginning in or around 1998 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor girls to engage in a systematic pattern of sexually exploitative behavior. 2 Podhurst Orseck, P.A. 25 Welt Plaster Street, Suitt 800. Miami, FL 33130, Miami 305.358.2900 Fax 305358.2382 • Fort Lauderdale 954.463.4316 I www.pocilitustxten EFTA00184416
casecWwdEaNskARP93MA5130ERrseslagAbBees%/MBilOaga9s(429f II. Defendant's plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less fortunate minor girls to participate in various acts of sexual misconduct that he committed upon them. Defendant's scheme involved the use of underage girls, as well as other individuals, to recruit other underage girls. Upon information and belief, Defendant and/or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would call economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 12 years old, were transported to Defendant's Palm Beach mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with "massages." 12. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant's residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each "massage appointment," and, upon information and belief, take nude photographs and/or videos of the underage girls for Defendant with and/or without their knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars. 3 Podhurst Orseck, P.A. 25 Wert Flagkr Street, Suite SOO, Miami, FL 33130, Miami 305.356= Fax 305.358.2382 • Fort Lauderdale 951.463.4316 EFTA00184417
CaSeCUM50-ngal<ARebg leunrhati i M ENVOInTLWOSBoagtaiR/280(9 1RagPearof529f 13. Epstein designed this scheme to secure a private place in Defendant's Palm Beach mansion where only persons employed and invited by Epstein would be present, so as to reduce the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities. The girls were usually transported by his employees, agents, and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion. 14. Upon arrival at Defendant's Palm Beach mansion, each underage victim would generally be introduced to one of Defendant's assistants, who would gather the girl's personal contact information. The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower. The staircase leading to the room was plastered with nude photographs of young girls, including some photographs depicting two or more young girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such photographs in each of his six homes and/or on his computers. 15. At times, if it was the girl's first "massage" appointment, another female would be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant would start his massage wearing only a small towel, which eventually would be removed. Defendant and/or the other female would direct the girl to massage him, giving the minor girl specific instructions as to where and how he wanted to be touched, and then direct her to remove her clothing. lie would then perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vulva, vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution and/or 4 Podhurst Orseck, P.A. MI let Cl. I Cc. • C 16 OM %II I r• EFTA00184418
caseliNS-9P6Milaixt9EACAR3°EPFSIITI§619o9ailig8348629°1043V8f5r enticing the then minor girl to engage in sexual acts with another female in Defendant's presence. The exact degree of molestation and frequency with which the sexual exploitations took place varied and is not yet completely known; however, Defendant committed such acts regularly on a daily basis and, in most instances, several times a day. In order to facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily available. 16. Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution and to enable himself to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection. Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and described in paragraphs I 1 through the present paragraph occurred in all of Defendant's domestic and international residences and/or places of lodging and/or modes of transportation. 17. Consistent with the foregoing plan and scheme, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. A vulnerable young girl, Plaintiff was working as a changing room assistant at The Mar-A-Lago Club in Palm Beach making approximately S9 an hour when she was first lured into Defendant's sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen years old while attending to her duties at Mar-A-Lago, Plaintiff was recruited by Ghislaine Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked Plaintiff if she was interested in learning massage therapy and earning a great deal of money while learning the profession. Plaintiff's father, who was a maintenance manager at The Mar-A- Podhurst Orseck, P.A. 25 West Hagler Sine, Suite 800, Miami. FL 33130, Waal 305.3582800 Fax 305358.2382 • Fort Lauderdale 954.163.4316 envw.posthtus1.coot EFTA00184419
casvasuiwitwocasapoif30EipaesliK§baaaileadokopicad.3 Lago Club, was not apprehensive because he felt comforted that an older woman had approached Plaintiff with this opportunity. As a result, Plaintiffs father dropped off Plaintiff at Defendant's mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would provide transportation home for his teenaged daughter. Ghislaine Maxwell led Plaintiff up a flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on the massage table. Plaintiff was shocked, but, with no experience with massages, thought this could be massage therapy protocol. Ms. Maxwell then took off her own shirt and left on her underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff what she was expected to do. Ms. Maxwell then told Plaintiff to take off her clothes. The minor girl was apprehensive about doing this, but, in fear, proceeded to follow Ms. Maxwell by removing everything but her underwear. She was then ordered to remove her underwear and to straddle Defendant. The encounter escalated, with Defendant and Ms. Maxwell sexually assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations, including the steam room and shower. At the end of this sexually exploitive abuse, Defendant and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had "lots of potential." Defendant paid Plaintiff hundreds of dollars, told her it was for two hours of work, and directed one of his employees to drive her home. 18. Defendant and/or his procurers thereafter lured the then minor Plaintiff to his Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the transportation and scheduling for the following day's appointment. Additionally, Defendant telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make arrangements. Plaintiff was often times driven to and from Epstein's mansion by Epstein 6 Podhurst Orseck, P.A. cr....I...cr.... C..IM anri 11/111 win gem IL. ice 1291 • Cw r aft Pet Aul sin EFTA00184420
Casec.%943-6ggaam nn :KAKtictigiceunarItli30EpPinnclfrigliTolcVng/3i/ ii8W1hagleaPgf29I himself or his driver. Alternatively, Defendant or Ms. Maxwell would arrange and pay for Plaintiff's transportation home by taxicab. 19. During Plaintiff's second incident of being sexually exploited and assaulted by Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job at The Mar-A-Lago Club and travel with him to earn much more money while learning the massage profession. Thus, Plaintiff, an impressionable and vulnerable young girl of modest means, quit her job as a changing room assistant, was lured by Defendant, and continued to be victimized by Defendant, who immersed the minor Plaintiff into Defendant's lewd and abusive lifestyle. Under Defendant's dominion and control, Defendant continuously "groomed" the minor adolescent. Defendant's daily routine required the minor Plaintiff to perform sexually on Defendant multiple times per day and to provide Defendant massages multiple times per day. Plaintiff had absolutely no say as to when, how many times, or what was done during each sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a countless array of young women who would be brought to one of Defendant's homes for the sexual trysts and then be sexually exploited by Defendant. 20. The first time that Defendant transported Plaintiff to another state in order to engage in sexual acts with her occurred when she was merely fifteen years old and after only two weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to transport the minor Plaintiff to Manhattan, where he provided her with spending money and accommodations with him at his mansion. From the time that Plaintiff was 15 years old, Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and whatever was needed for her to travel with him and/or for him. Defendant transported Plaintiff in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, San Francisco, St. Louis, and numerous other domestic destinations, as well as international 7 Podhurst Orseck, P.A. 25 West Fla glee Street. Se 800, Miami. FL 33130, Miami 305.358.2800 Fax 3053581382 • Fort Lauderdale 954.463.4346 svww.pxthurst EFTA00184421
case&MASMIMAARecbgbeS4a43°E2Witargath90505i1018(PPagPeiiigf929f destinations, including Europe, the Caribbean, and Africa. He provided accommodations with him in order to have her available to him at all times wherever he went, including while transporting the minor Plaintiff on his private jet. Each time they would travel to one of these destinations, the same pattern of sexual abuse would occur, often with a vast army of aspiring models, actresses, celebrities, and/or other females, including minors, from all over the world. Upon information and belief, Defendant transported minor girls from Turkey, the Czech Republic, Asia, and numerous other countries, many of whom spoke no English. To Plaintiff's knowledge, the only females specifically excluded from Defendant's sexual escapades were African-Americans. 21. In addition to being continually exploited to satisfy Defendant's every sexual whim, Plaintiff was also required to be sexually exploited by Defendant's adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional and personal acquaintances. Whenever Defendant transported Plaintiff with him in his private jet to any destination, Defendant would pay Plaintiff a flat rate per day while he and/or his above- mentioned associates would sexually exploit and abuse minor Plaintiff. 22. Most of these acts of abuse occurred during a time when Defendant knew that Plaintiff was approximately 15, 16, and 17 years old, and, after years of daily sexual exploitation, continued into her adulthood. Despite Defendant's stating shortly before Plaintiff's sixteenth birthday that he soon would have to trade her in because she was getting too old, Defendant continued to sexually exploit Plaintiff until she fled at age 19. Defendant's predilection for young girls was well known to those who regularly procured them for him and to his circle of friends. On one of Defendant's birthdays, a friend of Defendant sent him three I2-year-old girls from France who spoke no English for Defendant to sexually exploit and abuse. After doing so, they were sent back to France the next day. 8 Podhurst Orseck, P.A. 25 West Fbgler StreeL Suite 800, Miami, FL 33130, Miami 305-358 28@ Fax 305358.2382 • Fort Lauderdale 951.10.4316 I www.podhunt.com EFTA00184422
Case eaR89145iggratWCSEG;n3Air 3.A 1 n nf ENtPer8 C0iMagaghtgillge PagPea ofr 23. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his own actions, and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action. knew and should have known of Plaintiff's age of minority. Defendant and Ms. Maxwell acknowledged and celebrated Plaintiff's 161h birthday. Defendant's preference for underage girls was well-known to those who regularly procured them for him. 24. As previously stated in paragraph 14, Defendant displayed nude photographs of underage girls throughout his homes in Ncw York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked at Defendant's home in Palm Beach. When she asked Defendant about it, he stated dismissively that he had naked photographs of her in all of his homes. 25. Upon information and belief, some of the photographs in Defendant's possession were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant may have taken lewd photographs of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. In addition, while Plaintiff was a minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff naked in different sexually explicit positions. Ms. Maxwell then presented these nude photographs of Plaintiff to Defendant as a birthday present for Defendant fmm Ms. Maxwell. 9 Podhurst Orseck, RA. 25 west Flash:TSUI-et Suite 800, Miami, FL 33130, Miami 305.358.2.1303 Fax 305.358.2382 • Port taudadale 954.463.4346 i www.podhurst.com EFTA00184423
caseem-649agtaapcbriaPrtiNtli3°Efgr gnTiratisgclegaiSielRasPelig (?)-?-29f Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs arc still in the custody of law enforcement. 26. It is virtually impossible to calculate the exact number of times that Defendant sexually exploited and abused Plaintiff. From the age of 15, Plaintiff was sexually exploited and abused by Defendant on a daily basis and, most often, multiple times each day. While some of the precise dates these acts occurred are unknown to Plaintiff; these dates are known to Defendant, as he is reported to have kept a written log of each instance in which he engaged in these lewd acts with then minor Plaintiff and others. Upon information and belief, these logs are also in the custody of law enforcement. 27. In or around September 2002, Defendant purchased a commercial round-trip airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to Thailand. While thousands of miles away from Defendant on this extended trip alone for the first time in more than four years, Plaintiff met, fell in love, and married a young man. She escaped from Defendant's abuse with the help and insistence of her new husband and, instead of returning to Defendant, boarded a plane to Australia with one suitcase. 28. Since November 2002, Plaintiff has lived a modest life in Australia, while maintaining lines of communication with her family and without contact with Defendant or any of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone calls from one of Defendant's agents. During these phone calls to Plaintiff, he repeatedly asked whether she knew anything about the civil cases against Defendant, whether she knew any of the females who were proceeding with the civil suits, whether she was planning on tiling suit, whether she was communicating and/or cooperating with anyone against Defendant, and whether 10 Podhurst Orseck, P.A. 'A wool Paolo, Shoot Co rho n Ialarni Rl lit in lama., Inc 1C/l MINI Fu, 1OJII Ilk, . con I woAae.l•lo ORA al AIM EFTA00184424
Case 8:21tivagl-Mg4 Kjaacument 361-30 _Entered on FLSD Docket 02/10/2016 Page 12 of uocument .0;zred on FLSD Docket 05/04/2009 Page 11 of 27 she would return to the United States to testify. Terrified by Defendant's demonstrated ability to track her down on her changed cell phone number halfway across the world, Plaintiff attempted to reassure Defendant's agent that she would remain quiet. During the course of one of these phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting involved. 29. Around January 2009, Plaintiff received a lever from the United States Attorney's Office for the Southern District of Florida, informing her of her potential civil claims against Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant. Unable to reach a settlement, this lawsuit followed. 30. As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's controlling and manipulating her on a daily basis for years into a perverse and unhealthy way of life. 31. Defendant, Jeffrey Epstein, committed the above-referenced acts upon Plaintiff in violation of federal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated II Podhurst Orseck, P.A. 25 West Hagler Street, Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 YrWW.pOdilUrStXem EFTA00184425
Case_9:08-9:09 -8073.6-KAM. _Document 361-30 Entered on FLED Dockgt 02/10/2016 ' aP2 13 of ease 9:09-v-a0555-kAm uocument 1 ErItgred on F-LED uocket u5/04/2009 Page 1 of 27 in 18 U.S.C. § 2421, § 2422(a), § 2422(h), § 2423(a), § 2423(6), § 2423(e), § 2251, § 2252, § 2252A(a)(1), and § 2252A(gX1). 32. In June 2008, after investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe No. 102. Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255. COUNT ONE !Cause of Action for Coercion and Enticement of Minor to Entine in Prostitution or Sexual Activity pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. S 2422(b)) 33. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs I through 32 above. 34. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 102, when she was under the age of 18 years, to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b). 35. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 12 Podhurst Orseck, P.A. 25 West Flagler Street Suite EILO, Miami, FL 33130, Miami 305193.21300 Fax 305,358.2382 • Fort Lauderdale 954.463.4146 I %rem .podhurst corn EFTA00184426
Casee9a:Ig-97 98_271..W4l .sf(Anfr ceurrig r511-30 Eriff rritgat a inni Seolaatillig/8a6f l IgagPeaff Mr 36. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT TWO (Cause of Action for Transportation of Minor with Intent to Eneale in Criminal Sexual Activity pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. 6 2423(an 37. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 38. Defendant, Jeffrey Epstein, knowingly transported then minor Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, in violation 18 U.S.C. § 2423(a). As previously stated in paragraphs 20, 21, and 27, 13 Podhurst Orseck, P.A. 25 West Flagler Street Suite 800. Miami, FL 33130, Miami 305358.2000 Fax 306.358.2382 • Fort Lauderdale 954.463.4346 1 www.podhuretcorn EFTA00184427
Case :08-cv-80736-KAM,Dcument 361-30 Entered on F1312 Docket 02/10/2016 Page 15 of ease 909-cv-a0bbb-KAn4 uocument 1 E2t9red on FLSD uocket 05/04/2009 Page 14 of 27 Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international borders numerous times from the time that Plaintiff was merely 15 years old through adulthood with the primary intent of sexually exploiting her. 39. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 40. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. 14 Podhurst Orseck, P.A. 25 West Flagkt Street. Suite 800. Miami, FL 33130, Mlaral 305358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4316 envw.podkurstcom EFTA00184428
Case.9:08-cv-80736-KAM..Qocu_ment 361-30 Entered on FLSD Docket 02/10/2016 Page 16 of Case 'Document 1 E2Wred on FLSD Docket 05/04/2009 Page 15 of 27 COUNT THREE 'Cause of Action for Travel with Intent to EBIZA2C in Illicit Sexual Conduct pursuant to 18 U.S.C. 6 225$ in Violation of 18 U.S.C. 6 2423(b)I 41. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs I through 32 above. 42. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate and/or foreign commerce with the intent to engage in illicit sexual conduct, as defined in 18 U.S.C. § 2423(), with minor females, including the then minor Plaintiff, in violation of 18 U.S.C. § 2423(6). 43. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 44. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 15 Podhurst Orseck, P.A. 25 West Plaster Street, Suite 800, Miami, PL 33130, Miami 306.3581800 Fax 305358.2392 • Fort Lauderdale 954.463.4346 I www.podlturst.com EFTA00184429
Case 9:08-cv-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 17 of Case 9:09-cv-80656-KAM Document 1 Eared on FLSD Docket 05/04/2009 Page 16 of 27 actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT FOUR %Cause of Action for Coercion and Enticement to Entine in Prostitution or Sexual Activity pursuant to 18 U.S.C. S 2255 In Violation of 18 U.S.C. S 2422(01 45. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 46. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, and/or coerced Jane Doe No. 102 to travel in interstate and/or foreign commerce to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(a). 47. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 48. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 16 Podhurst Orseck, P.A. 25 West Hagler Street Suite 800, Miami, FL 33130, Miami 305358.2900 Fax 305.358.2382 • Fort Lauderdale 954.4634316 www.podhuntcom EFTA00184430
cas9:08-1 .807gelt\ki°WatrleiR3°E4Pcieogi ngbWoEigibeth8Micur9ageiVoilff ase 9: 9-cv- 6- income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT FIVE (Cause of Action for Transportation with Intent to Engage in Criminal Sexual Activity pursuant to IS U•S.C. 6 2255 In Violation of 18 U.S.C. 8 24211 49. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 50. Defendant, Jeffrey Epstein, knowingly transported, or attempted to transport, Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in prostitution and/or in any sexual activity for which any person can be charged with a criminal offense, in violation of 18 U.S.C. § 2421. As previously stated in paragraphs 20, 21, and 27, Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international borders numerous times from the time that Plaintiff was merely 15 years old through adulthood with the primary intent of sexually exploiting her. 51. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 52. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 17 Podhurst Orseck, P.A. 25 Weat Flatlet Street. Suite BOO, Mturd, FL 33130. Miami 305.358.M00 Fax 305)58.2382 • Fon Lauderdue 951.163.4316 I www.podhuratcom EFTA00184431
Case 9:08-y-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 19 of Case 9:09-cv-80656-KAM Document 1 Eggrred on FLSD Docket 05/04/2009 Page 18 of 27 psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT SIX !Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 22511 53. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 54. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the then minor Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct, in violation of IS U.S.C. § 2251. As previously stated in paragraphs 14, 24, and 25, Defendant kept and displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked at Defendant's home in Palm I8 Podliurst Orseck, P.A. 25 West Flagkz Street, Suite 800. Miami, it 33130, Miami 305.358.Tb00 Fax 305355.2382 • Fort tsoderdale 954.463.4346 www.podhumt.com EFTA00184432
Case 9:08-cv-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 20 of Case 9:09-cv-80656-KAM Document 1 Egered on FLSD Docket 05/04/2009 Page 19 of 27 Beach. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement. 55. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 56. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 19 Podhurst Orseck, P.A. 7S Wed Masan SOTOM Gibe Alm. MIAMI. R. ail VI. Miami INS Wi min Paw Inc MR 7.1R7 • Fent laudsntal 9S4 4Al lit/ t www nrwIlmr. rents EFTA00184433
Casec9ag4c.6-98g_INAFIAVedaeurgt11-"EgailncgaWogailbethialiBladNeAvf income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT SEVEN (Cause of Action for Transport of Visual Depiction of Minor Enstaalna in Sexually Explicit Conduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. S 2252(a)(1)1 57. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs I through 32 above. 58. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit conduct, in violation of 18 U.S.C. § 2252(a)( I ). As previously stated in paragraphs 14, 24, and 25, Defendant displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked as a minor at Defendant's home in Palm Beach. As previously stated in paragraph 24, Defendant told Plaintiff that he had photographs of her naked in all of his homes. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and nude photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd 20 Podhurst Orseck, P.A. W...171.nien CrIves• C. .1 INA %Al *gni CI 11111 Mi..ni II1C VA /OM Raw IRS ICA 11A1 . Few. I wad...Asia RV AA' ALA ••••••••• nerthr.n.""en EFTA00184434
Casec9aidg3A-M<AVcBgleurrUr51;3°E4gaec§inAlbsagailig8iiii86flagNeoiir photographs of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement. 59. As previously stated in paragraph 23, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. Defendant's preference for underage girls was well-known to those who regularly procured them for him. 60. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 61. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and 21 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 805, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4146 EFTA00184435
Case 9:08-cv-607361KAM. _Document 361-30 Entered on FLSD Docket 02/10/2016 Page 23 of case 9:09-cv-oub56-KAm uocument 1 Egired on FLSD Docket 05/04/2009 Page 22 of 27 psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT EIGHT fCause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 6 2255 iq Violation of 18 U.S.C. ti 2252A(alITH 62. Plaintiff, Jane Doc No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 63. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography in violation of I8 U.S.C. § 2252A(a)(1). 64. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 65. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and 22 Podhurst Orseck, P.A. 25 West Flatter Sheet, Suite 800, Miami, FL 33130, Miami 305.358.7800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhumt.com EFTA00184436
5aseagavoggiligge lacument 363.-30 Entered ou F1,512 Docke_02/10/2016 Page 24 of uocument Enpred on Docket OW04/2009 Page 23 of 27 leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT NINE (Cause of Action for Eneseine in a Child Exploitation Enterprise pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. fi 2252/V211 66. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above and Counts One through Eight above. 67. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 U.S.C. § 2252A(g)(1). As more fully set forth above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§ 2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity in violation of 18 U.S.C. §§ 2421, 2422, and 2423). As more fully set forth above in paragraphs 9 through 32, Defendant's actions involved countless victims and countless separate incidents of sexual abuse, which he committed against minors, including Plaintiff, in concert with at least three other persons. 23 Podhurst Orseck, P.A. 25 West Flagler Street Suite BOO, Mixing. FL amso Miami 303356.2800 Fax 305.358.2382 • Fort Lauderdale 954.4614316 podhuratcom EFTA00184437
casec-W*.tf_97a6WARectmed-AaT30ErpniicraPRolleakriM44864110aaasaM, • 68. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 69. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Date: May I, 2009 fickla-A4 krs....-4-1,4,-,6 Robert C. Josefsb'erg, Bar No. 04085 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) rjosefsbergApodhurst.com 24 Podhurst Orseck, I? A. 25 West Flagler Street, Suite 80D, Mbiui, P1.33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podluustann EFTA00184438
caseegig-16607v0M<AwcieoWniV33° Epe rsgat8Bgg <V5VA/12%3816Palg:n (P2,1 • kezellarloodhurst.corn Attorneys for Plaintiff DEMAND FOR JURY TRIAL Plaintiff demands to have her cast tried before a jury. 41,360 etto ir Robert C. Jose rg, Bar No. 04 56 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) rjoscfsbere4podhurst.com keze110,podhurst.com Attorneys for Plaintiff 25 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 803, Miami, FL 33130, MIami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 054.463.4346 www.podhluet.cout EFTA00184439
caseM6YORTAge-6 1495 188a -13° EWera colrik rStaggIVAN8 1?, akpl9g g7 297f JS 44 (Res. 11103) CIVIL COVER SHEET 11m1544 civil cooa sheet andthe information contained herein neilM replace na supplement the filing and service ofpleadings orother papers as requirolby law, except as provided by local rules ofcourt. This form approved by the Judicial Conference of the United States in Seolonber 1974. accoutred for the ascot dmClerk of Court for the outpost of initiating the civil docket Sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below. I. (a) PLAINTIFFS Jane Doe No. 102 (b) County of Residence of FS Listed Plaintiff West Palm Beach tExcErr IN U.S. PLAINTIff CASES) (e) Attorney's (Firm Nut. Aden= ad lambent Numbed Robert C. Josefsbergy Esq./Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flagler St., Suite 800 Minima SI 1111A O81 OD Check County Where Action Arose 0 MIAMI. DADE CI MONROE vt3 BR &tut !CCM ANOS II. BASIS OF JURISDICTION t PI= an'X'' in One Box Only) III. C TIZENSHIP OF PRINCIPAL PARTIES(Plaoem'x-In one ao, for Nam& (For Dian*/ Casa Only) and One Box (or VeknclarsI O I U.S. Government VI 3 FederalQuestion PT! DEF PT! DFF Plaintiff (U.S. Gomm= Not a Pay) Citizen of TVs Sat C I :I Incorporator Next* Place of Stuarts' In na stye O 4 O4 0 2 U.S. Government Deferdant 0 4 Divinity Ordiese titiunship of Panics in Item III) Citizen °Mail= Sae 0 2 0 2 Incorporated ant Principal Place of Banns In Another State 0 5 0 5 titan or Subject 644 0 3 0 3 romp Notice 0 6 0 6 Penios Colwv 134c4510- • DEFENDANTS Jeffrey Epstein County of Residence of First Lined Defendant West Palm Beach (IN US. PLAINTIFF; riccP CV II NOTE: IN LAND CONDEMNATION ClAtra ga. LAND INVOLVED , iNTAKE Jack A. Goldberger, Esq., Atterbury Goldberger, 1 09 et al., 250 S. 20 Australian Ave., #1400, West Palm'BearetVEN3840/4110114obett -T Morays (1(1(nown) PALM BEACH 0 MARTIN 0 ST. LtICIE fl INDIWIRD s FLEI 11.11711101043E clip"! it run r 1 CONTRACT tants EillIFILIVREaltiALTY 0 MO Apicultige 0 62001M Food & Dug O 623 Ding Rawl Seizure of hope= 21 USC131 0 630 Liquor Laws 11 640 R.R. & Dock 0 650 Aldine Rey O 660 Ostyak's& SaferiHealdt 0 690 Other BANKRUPTCY enuartenars 0 400 State Resparttrana 0 410 Anima O 430 Banks end flanking 0 agitating= 0 460 Deportation 0 470 Racketeer Influenced and Cor=4 Onitamliont 0 480 Consumer Credit n 490 tatelSat TV O 810 San= Sere= O 830 SearitiatOrnmoditki/ Exchange 0 105 (unman Challenge 12 USC 1410 0 890 Other StstWory Anion 0 891 Agricultural Acts O 892 Economic Siabalmaion Act CI 893 Emanates= Mitten 0 894 Cagy Allocation Act 0 ICS Freedom of Information Au 0 900Appeal *Mt Determination Under Equal Amos .0 liwice 0 930 Constinsiondiry of Slat Slats 0 I1D Iran= 0 I 20 Marine 0 130 Milkv Au O latiNecotiribk Intinontal 0 150 Recovery of Overpayment & Enforcemas of lodatni 0 151 Medicine Act 0 I32 Recovery oft:kind= Sakai Loans (Excl. Wawa) O 133 Recovery a °yammers of Vtienn's Baths O 160 Slockhklea Suits 0 000thm footrace O 195 Carnet Plod= Liability 0 196 Franchise PERSONAL INJURY 0 310 Airplay 0 315Airplane Product Liabality 0 120 Assault Libel & Slander 0 310 Fat= Employas' L lability (7 340 Mmine 0 345 Mans Pia= Liability 0 350 Motor Veld= 0135 Motor Vehicle Product Liability I/ )60 Oiber Imo= Brit= PERSONAL INJURY n 362 Penoral Inkny - Met Maliattice O 365 Personal Injury • hodun Listary 0 368 Asbestos Personal Injury Proad Cl 472 Appeal NI USC ISE 0 423 Withdrawal 28 USC 137 ER J;r02.4 '141:1Cri 11 4 0 820 Copyright 0 830 Pt= 0840 Talmud' Liability PERSONAL PROPERTY 0 3700he Dad 0 371 Ina in Lending 11 11100thei tenon Property Canape f3 1115 'Napery Damage Product Liability L4ROR SOCIAL SECURITY 0 711:Wok LatoceStanlasdi Act 0 720 LabonMps. Relations 0 730 Labx/Mpraltmoning a Disclosum Act 0 740 Railway Labor MI 0 790 Orin's= Litiption 0 791 Encl. Ret. Inc. Scanty Act 0861 MIA (1393M 0 1162 Blmk Lung (92Il 0 863 DIWODIWW I405(10) 0 664 55113 Tide XVI 0 865 RSI (403(0) I REAL PROPERTY CIVIL RIGHTS PRISONERFESTOONS FEDERAL TAX SUITS 0210 Lend Coademnolice 0 220 Foreclosure 1 230 Rea tale & Eject/ant 1 240 Tons to Land 0 243 Ton Piston Liability 0 290All Other Real Popery O441 Voting 13 442 Eraployincat 0 443 Housing( Accommodation 0 444 Welfare 0 443 Amer. arDitabilitiet • natant= 0 446 Amer. tDitabititia • Other 0 440Other Civil Rights 0 510 Moderato Vacate Sentence Hams Corpm: CI 530 General 1 533 De= Pena& 0 540 Madam & Cala 0 SSOCivil Rislas C3 555 Prison Condition 1 870 faxes (U S Plana or Defenlan) Cl 871 IRS —Third Party 26 USC 7609 I. ORIGIN • 1 Original Proceeding (Place a in One Son Only) O 2 Removed from I 3 Re-filed- Stale Cow (see VI below) fiansfored flan O 4 Reinstated or 3 Dreary )strict O 6 Multidistrwt Reopened D Litigation Aupereal to DilITICI n 7 rn'm Magistrate Judirnan VI. RELATED/RE-FILED CASE(S). (Set inisevcoores scox4 pp): a) Re-filed Case CI YES 0 NO 6) Related Cases (OYES ONO JUDGE Kenneth A. Marra DOCKET See Attached NUMBER VII. CAUSE OF ACTION Cie the U.S. Civil Statute under which you arc filing and Write a Lind Slalomed of Cause (Do wt cite taritdiaionid statutes makes diversity): 18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(6), 2423(6). 2423(e), 225I, 2252, 2252A(aX1), 2252A(g)( I ) LENGTH OF TRIAL via 4 days estimated (far bath sides to try entire ease) VIII. REQUESTED IN O CHECK IF THIS IS A CLASS ACTION DEMANDS CHECK YES only if demanded in complaint JURY DEMAND: pi Yes r No COMPLAINT: UNDER R.0 P 23 ABOVE INFORMATION IS TRUE & CORRECT 10 THE BEST OF MY KNOWLEDGE SKIN fL . IRE OF ATTORNEY 0.F RFC DATE 1,4) R OFFICE LSI oNlye.„, AMOUNT` < Si% RECEIPTS .Ct .-/Oe-Z 4 Z D ck, kx/ EFTA00184440
Case HAP.. Ncifiya KRocument 361-30 _fltered on FLSD Docket 02/10/2016 Page 28 of uocument 1 qgered on FLSD Docket 05/04/2009 Page 27 of 27 r• UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION ATTACHMENT TO CIVIL COVER SHEET FOR: Jane Doe letv. Jeffrey Epstein VI: RELATED/RE-FIELD CASE(S): 08-80069 08-80119 08-80232 08-80380 08-80381 08-08804 08-80811 08-80893 08-80993 08-80994 08-80469 09-80591 EFTA00184441
Case 9:08-cv-80736-KAM Document 361-31 Entered on FLSD Docket 02/10/2016 Page 1 of 13 EXHIBIT 31 EFTA00184442
easse9901£8ew8ECT731f61414.11A CFiDucum ►tt21e1131Et rtecischcLIBIS Daitleket702011M316PRfige Cif (12 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CIV-Marra/Matthewman JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:* 1. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. 1. • The government's response is confined to Request No. 1 through Request No. 26 in the "Discovery Requested" section of the Request for Admissions and does not intend to respond to assertions in any other section of the Request for Admissions (including the "Background" section), none of which appear to separately state any matter calling for an admission. Nonetheless, the government denies the assertion that the government has declined the request of Jane Doe #1 and Jane Doe #2 to stipulate to undisputed facts in this case. 1 EFTA00184443
Casse€9333evARE0TE6149;411A Olcanaserbt2a81131ErEfatedaoh:ALPSISDcfitteke702N1522131,3 dfC112 13 2. (a) The government admits that, after Epstein's attorneys learned of the notification that the government planned to provide to Jane Doe #2, who claimed that she was not a victim, Epstein's attorneys contacted the USAO and objected to the procedures for notification and the legal bases therefor. The government further admits that the USAO considered those objections when evaluating what notification to provide to victims. Except as otherwise admitted above, the government denies Request No. 2(a). (b) Admitted. (c) The government admits that, as a result of objections lodged by Epstein's attorneys, the government reevaluated the notifications that it had intended to provide to victims and, as a result of that reevaluation, the USAO altered the scope, nature, and timing of notifications that it had contemplated providing to victims. With regard to Jane Doe #2, the government further admits that, as a result of representations made by Jane Doe #2 that she was not a victim and objections lodged by Epstein's attorneys, the USAO stopped making notifications to Jane Doe #2. Except as otherwise admitted above, the government denies Request No. 2(c). (d) The government admits that, after the USAO received objections to victim notifications from Epstein's counsel and reevaluated its victim notification obligations, the USAO altered the language that was ultimately contained in the July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards. Except as otherwise admitted above, the government denies Request No. 2(d). 2 EFTA00184444
026929333&agar/35614MM EITtawneabl23613.3ErEfetectiah:CLESISDOkete7021112021316Pan elf aft 13 (e) The government admits that, at least in part as a result of objections lodged by Epstein's lawyers to victim notifications, the USAO reevaluated its obligations to provide notifications to victims, and Jane Doe #1 was thus not told that the USAO had entered into a non-prosecution agreement with Epstein until after the agreement was signed. The government further admits that Jane Doe #2 was not told that the USAO had entered into a non-prosecution agreement with Epstein until after the agreement was signed, but denies that the USAO did not inform Jane Doe #2 as a result of any negotiations involving Epstein or any objections lodged by Epstein's lawyers; the USAO did not consider Jane Doe #2 a victim after she informed the USAO and the FBI that she was not a victim of any offense committed by Epstein, and, as a result, the USAO did not consider informing Jane Doe #2 about the non-prosecution agreement. Except as otherwise admitted above, the government denies Request No. 2(e). 3. Denied. 4. Denied. 5. The government admits that, during the negotiations with Jeffrey Epstein regarding the non-prosecution agreement, at least one experienced attorney within the USAO subscribed to the position that the CVRA required notifications to the victims in this case and that position was communicated to Epstein's counsel. To the extent that Request No. 5 seeks admissions regarding the positions held by attorneys within the USAO that were not communicated to non-government personnel regarding whether or not the CVRA ultimately required notifications to the victims in this case, the government objects to Request No. 5 as violative of the deliberative process privilege. 3 EFTA00184445
CasseC€038e€M€0726141PAIIA littecumeett23.61131ErEferedachzitSESDakelte702011XCIMEPailigt fef (112 13 6. (a) Denied. (b) Denied. (c) Admitted. (d) Admitted. (e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (0 Admitted. (g) Admitted. 7. The government admits that, on about January 10, 2008, when Jane Doe #1 and Jane Doe #2 were sent letters advising them that "this case is currently under investigation," the U.S. Attorney's Office had already signed a non-prosecution agreement with Jeffrey Epstein, but that, on that date, the non-prosecution agreement nonetheless remained in a state of some flux and was subject to being set aside as Epstein was challenging the propriety of the non-prosecution agreement and seeking further review from the Department of Justice. 8. Denied. 9. (a) The government admits that, at Epstein's insistence, the USAO agreed to a provision in the non-prosecution agreement that provided as follows: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure." Except as otherwise admitted above, the government denies Request No. 9(a). 4 EFTA00184446
caetasgameevggosmogai atoucureappantallErtfatedaphStP3LSDffloiteket702MaarlEPaficpeelf2 13 (b) Admitted. (c) Denied. (d) Denied. (e) The government admits that, during the period from September 24, 2007 through June 2008, the USAO did not notify Jane Doe #2 of the existence of the non- prosecution agreement. The government further admits that, although FBI agents notified Jane Doe #1 of the existence and substance of the agreement at the request of the USAO on or about October 27, 2007, no employee of the USA() personally notified Jane Doe #1 of the existence of the non-prosecution agreement during the period from September 24, 2007 through June 2008. Except as otherwise admitted above, the government denies Request No. 9(e). 10. (a) Admitted. Because Request No. 10 appears directed solely to the communica- tions between FBI agents and Jane Doe #1 during their meeting on or about October 26, 2007, the government responses to Requests No. 10(b) through 10(g) address only that meeting. (b) The government admits that, on or about October 26, 2007, FBI agents explained to Jane Doe #1 that Epstein would plead guilty to state charges for procuring minors to engage in prostitution; that Epstein would be required to register as a sex offender; that Jane Doe #1 would be entitled to seek damages from Epstein; and that, if she desired, Jane Doe #1 would be entitled to use the services of an attorney at no expense to her in seeking those damages from Epstein. The government denies that the FBI agents explained that the state charges "involv[ed] another victim." 5 EFTA00184447
Gasse9SONeev8E0731161413AM IDocioneerlit23.EilBlErEiettedschtRIBISDdithellaZealEPaityg& df Cl2 13 (c) The government denies that the FBI agents did not explain to Jane Doc #1 that an agreement had already been signed; denies that the FBI agents did not explain to Jane Doe #1 that the agreement resolved the investigation of the federal case involving Jane Doe #1; and denies that the FBI agents did not explain to Jane Doe #1 other terms of that agreement Except as otherwise admitted above, the government denies Request No. 10(e). (d) Denied. (c) Denied. (f) Denied. (g) Denied. 11. The government admits that, on or about November 28, 2007, A. V i I lafafta of the USAO sent a draft of a crime victim notification letter to Jay Lefkowitz, counsel for Jeffrey Epstein, and that the draft notification letter stated, in part: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . . . ." The government further admits that, in part as a result of objections lodged by Epstein's lawyers, the USAO reevaluated its obligations to provide notifications to victims, and, as a result of that reevaluation and other considerations and developments, the USAO never sent victims the draft notification letter that was sent to Jay Lefkowitz on or about November 28, 2007. Except as otherwise admitted above, the government denies Request No. 11. 12. The government admits that, prior to July 3, 2008, the USAO had already entered a binding non-prosecution agreement with Jeffrey Epstein. The government is without 6 EFTA00184448
GassaCeBeev8aTEMI4AVIA Cfitcaurnaht74E1131ErffititedziohoRIBISDatteliCet2917120816Pajagbadf2 13 knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S. Attorney's Office concerning the need to federally prosecute Epstein for sex offenses committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government denies the assertion that Edwards worked on that letter on July 3, 2008. Except as otherwise admitted above, the government denies Request No. 12. 13. (a) The government admits that, when Epstein pled guilty to state charges on June 30, 2008, Jane Doe #2 had not been infonned by the USAO of the existence of the non-prosecution agreement. The government further admits that, although the USAO, through FBI agents, had notified Jane Doe #1 of the existence of the non- prosecution agreement prior to Epstein's June 30, 2008 guilty plea, no employee of the USAO had personally notified Jane Doe #1 at that time of the existence of the non-prosecution agreement. Except as otherwise admitted above, the government denies Request No. 13(a). (b) The government denies that, by the time of Epstein's June 30, 2008 guilty plea, an attorney for the government working at the USAO had not already conferred with Jane Doe #1 and Jane Doe #2 about their opinions regarding how the federal investigation and potential prosecution of Epstein should proceed. The government admits that the USAO had not conferred with Jane Doe #2 about the non-prosecution agreement prior to Epstein's June 30, 2008 guilty plea. The government further admits that, although the USAO had communicated with Jane Doe #1 about the non-prosecution agreement through FBI agents prior to Epstein's June 30, 2008 guilty plea, no employee of the USAO had personally conferred with Jane Doe #1 about the non-prosecution agreement prior to 7 EFTA00184449
Maea9ClaSecoME073116141PAM FRI=Tomb 01131131E rEferteeeoh:RIBES D ettek 0702=0201. EP al!jacfr S(12 13 Epstein's guilty plea. Except as otherwise admitted above, the government denies Request No. 13(b). (c) Although the government was aware that Jane Doe #2 had been represented by counsel paid for by Epstein, the government is unaware of the extent of Epstein's defense attorneys' awareness of the USAO's communications with Jane Doe #1 and Jane Doe #2 about the agreement, as described in the responses to Requests No. 13(a) and 13(b), and therefore can neither deny nor admit Request No. 13(c). Except as otherwise admitted above and in the responses to Requests No. 13(a) and 13(b), the government denies Request No. 13(c). (d) The government admits that Epstein's attorneys negotiated with the USAO for a provision in the non-prosecution agreement that ultimately provided as follows: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure." Except as otherwise admitted above, the government denies Request No. 13(d). 14. The government admits that, when Epstein was pleading guilty to the state charges discussed in the non-prosecution agreement, the USAO and Epstein's defense attorneys sought to keep the document memorializing the non-prosecution agreement confidential, but denies that they sought at that time to keep the existence of the non- prosecution agreement confidential. Except as otherwise admitted above, the government denies Request No. 14. 8 EFTA00184450
Case 93116-ow-99735-1ICA/MI Dmmmm 2B1-131 ESlmaviathaE ESSODElciottaMMA2A1M6 Pie e lib 22 13 15. (a) The government admits that, while Bruce E. Reinhart was an Assistant U.S. Attorney, he learned confidential, non-public information about the Epstein matter. (b) The government admits that, while Bruce E. Reinhart was an Assistant U.S. Attorney, he discussed the Epstein matter with another Assistant U.S. Attorney working on the Epstein matter. (c) Denied. 16. Admitted. 17. Admitted. 18. (a) Denied. (b) Denied. 19. To the extent that Request No. 19 is directed to the business or personal relationships of the 93 U.S. Attorneys and over 5,400 Assistant U.S. Attorneys serving across this country, or the countless individuals who have formerly served as U.S. Attorneys and Assistant U.S. Attorneys throughout this nation, the government objects to Request No. 19 as overly broad and burdensome and not calculated to lead to or involve information relevant to the instant matter. The government denies possessing or having any knowledge or information about a personal or business relationship between Jeffrey Epstein and either the U.S. Attorney or any Assistant U.S. Attorney serving in the Southern District of Florida. Except as otherwise admitted above, the government denies Request No. 19. 20. Admitted. 21. Denied. 9 EFTA00184451
game930B3cauff419732E644(.4O11 Illoonumffilt333B31 EaltirmaitletrnfRISEDEMRI4e/t0C92/139111M35 FRajje 12 22. (a) Admitted. (b) Admitted. (c) Admitted. 23. The government admits that the non-prosecution agreement signed by the USAO and Jeffrey Epstein currently blocks the USAO from prosecuting sex offenses committed by Epstein against Jane Doe #1 and Jane Doe #2 in the Southern District of Florida from in or around 2001 through in or around September 2007, provided that those offenses are set out on pages I and 2 of the non-prosecution agreement, were the subject of the joint investigation by the FBI and the USAO, or arose from the federal grand jury investigation. Except as otherwise admitted above, the government denies Request No. 23. 24. Admitted; Jeffrey Epstein provided valuable consideration to the federal government through the non-prosecution agreement he entered with the USAO. 25. Denied. 26. The government objects to Request No. 26 because it seeks information protected from disclosure by the law enforcement investigative privilege. 10 EFTA00184452
oThmE9301B3awaREV73IBliggl nimunterttaEM311 ErttmmtlornFRISIDIIRmilettGYAI9JODa 13 "'Sur 'Waif Respectfully submitted, WIFREDO A. UNITED STATES ATTORNEY By: Is Dexter A. Lee Dexter A. Lee Assistant United States Attorney Florida Bar No. 0936693 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9320; Fax: (305) 530-7139 Email: A. Assistant United States Attorney Florida Bar No. 0018255 500 S. Australian Avenue, Suite 400 West Palm Beach FL 33401 Tel: Fax: Email: Eduardo I. Sanchez Assistant United States Attorney Florida Bar No. 877875 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9057; Fax: (305) 536-4676 Email: [email protected] Attorneys for United States CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing United States' Response to Petitioners' First Request for Admissions to the Government was served via CM/ECF on this 19th day of July, 2013, on the parties and counsel appearing on the attached service list. /s Dexter A. Lee Assistant United States Attorney 11 EFTA00184453
Glme 9)083 cam8320731B WiSOPI ffeanumeritt326[13311 EthlbsactlomFFILSIDUD3gaikeitIMEOM26 13 1723odf SERVICE LIST Jane Does 1 and 2i United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & 201 South Biscayne Boulevard, (305 371-6421 Fax: E-mail: Martin G. Weinberg MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 Email: [email protected] Jay P. Leflcowitz Kirkland &Ellis, LLP 601 Lexington Avenue New York NY 10022 Fax: Email: 12 EFTA00184454
Case 9:08-cv-80736-KAM Document 361-32 Entered on FLSD Docket 02/10/2016 Page 1 of 7 EXHIBIT 32 EFTA00184455
Case 9:08-cv-80736-KAM Document 361-32 Entered on FLSD Docket 02/10/2016 Page 2 of 7 JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES CASE NO: 08-80736-Civ-Marra/Johnson !i p f EXHIBIT B EFTA00184456
Case 9:08-cv-80736-KAM Document 361-32 Entered on FLSD Docket 02/10/2016 Page 3 of 7 FD-302(Rey.104.95) -1- FEDERAL BUREAU OF INVESTIGATION Date of transcription 08/14/2007 was interviewed in West Palm Beach, Florida, relfreingm agrelleral investigation involving the sexual exploitation of minors. After being advised of the identity of,the interviewing agents and the nature of the interview, igliprovided the following information: In 2003 or 2004 — was introduced to JEFFREY EPSTEIN for the purpose of providing him with personal massages. arag was approached at a party by a female she believed was named She described the female as havin r hair and taller. The female was later identified as . told alle and alb's friend, isima.moimmma that they could make money by providing massages to EPSTEIN. a told S that she could provide the massages with her clothes on or off. Aagb, who was fifteen years old, believed that she was close to turning sixteen when she first met EPSTEIN. However, during *ties first contact with EPSTEIN, she told him that she had just turned eighteen. and I ',traveled to EPSTEIN's residence in Palm Beach by taxi. was regnant at the time. Once at the residence, took W upstairs. EPSTEIN entered the room wearin only a ro e. Once EPSTEIN had removed the robe, both and .6118 provided EPSTEIN with a massage. Both and had removed their clothing and remained only in their underwear. EPSTEIN asked IMMINEMMIto leave. Once alone with EPSTEIN began to masturbate. was uncomfortable. After EPSTEIN climaxed the massage was over. m.:Mlibelieved that Nee had mentioned EPSTEIN might masturbate during the massage but she was still very surprised when he masturbated. EPSTEIN paid 11.11 $200.00. EPSTEIN did not touch during that massage. :mop departed EPSTEIN's residence with two men that worked for EPSTEIN. They drove OMMIMPto a Shell Gas Station located near Okeechobee Boulevard and the Florida Turnpike. Prior to departing the residence, Melliprovided her telephone number to one of EPSTEIN's assistants, OUNNOMMS (PHONETIC). all) described her as a very pretty Hispanic female in her early twenties, with long brown hair, and approximately 5'5" to 5 16" tall. elistated that . another of EPSTEIN'S assistants, or EPSTEIN would usually contact her. would telephone and ask if she was available or if she had any other Inyesdpoonon 08/07/2007 a, West Palm Beach, Florida Reg 31E-MM-108062 Dare dimmed 08/07/2007 by This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your army: it and its contents art not to be distributed outside !IOW agency. EFTA00184457
Case 9:08-cv-80736-KAM Document 361-32 Entered on FLSD Docket 02/10/2016 Page 4 of 7 90.302e (Rev. 10-6-95) 31E-MI4-108062 Continuation of FD-302 of I On 08/07/2007 ,Page 2 • girls she could bring. When EPSTEIN telephoned, he usually asked for=224to come over. According toig= EPSTEIN's house telephone number began with the digits 655. She would call sometimes and leave a message. MEMMDstated that when they telephoned her they would inform her of when they would be coming back to town and if she might have anyone new. did not believe that EPSTEIN ever really liked her. Otraveled to the EPSTEIN's residence during 2003 and 2004 over twenty five times mm.SIMObelieved that she provided EPSTEIN with approximately 10-15 massages. EPSTEIN initially started out touching WIENS@ breasts but gradually the massages became more sexual. EPSTEIN would instruct aeon how and what to do during the massages. He would request Willa to rub his chest and nipples. ',stated that on approximately two occasions, EPSTEIN asked that 'remove her underwear and provide the massage nude. complied. MEMOIstated that EPSTEIN would make her feel that she had the option to do what she wanted. During one massage,Ite stated that she had been.giving EPSTEIN a massage for approximately 30-40 minutes when instead of EPSTEIN turning over to masturbate, EPSTEIN brought another female into the massage area. is•WAIDIdeecribed the female as a beautiful blonde girl, a "Cameron Diaz" type, 19 years of age, bright blue eyes, and speaking with an accent. EPSTEIN hadiallstraddle the female on the massage table. EPSTEIN wanted to touch the females breast. According to WOW EPSTEIN "pleasured" the female whilemnimPwas straddled on top of the female. mallistated she could hear what she believed to be a vibrator: mmUllsaid for EPSTEIN it was all about pleasuring the female. After the female climaxed, EPSTEIN patted maon the shoulder and she removed herself from the table. The female got up from the table and went into the spa/sauna. EPSTEIN commented to REEpthat in a few minutes the female would realize what had just happened to her. received $200.00. .Apadvised the interviewing agents that EPSTEIN had used a back massager on her vagina. EPSTEIN asked her first if he could use the massager on her. mosestated that she had held her breath when EPSTEIN used the back massager on her. =m4istated that at no time during any of the massages had EPSTEIN caused her to climax. During another massage, lbelieved by this time she was seventeen, EPSTEIN placed his hand on vagina, touching EFTA00184458
Case 9:08-cv-80736-KAM Document 361-32 Entered on FLSD Docket 02/10/2016 Page 5 of 7 , ' FD-302a (Rev. 104-95) 331-MM-108062 Continuation of FD-302 of .On 08/07/2007 Pate clitoris. '?was uncomfortable and told him to stop. EPSTEIN complied. MMRAM"stated that the incident freaked her out. NIIMPstated that EPSTEIN was upset because she was upset. --"' never return to the residence. 'stated that she did not deal with EPSTEIN anymore after that incident. EPSTEIN gave both -each a book entitled "Massage for Dummies". They received the books on the same visit. EPSTEIN also commented how strong ' s hands were when it came to her providing his massages. On another occasion, 'mentioned to EPSTEIN that she was looking at a car, a Toyota Corolla. EPSTEIN provided $600.00 - $700.00. ---lstated that EPSTEIN gave her the money after the incident with the other female. According tolaill EPSTEIN would ask her to bring him other girls. a:. who started dancing at strip clubs when she was 16, brought girls from the club as well as from other sources. WILD stated she brought girls from fifteen years of age to twenty- five years of age. jappostated that EPSTEIN would get frustrated with her if she did not have new females for him. On one instance, EPSTEIN hung up on her because she could not provide him with anyone new. ais stated that EPSTEIN's preference was short, little, white girls. iaIllpstated that EPSTEIN was upset when one of the other girls brought a black girl. Ii llstated that EPSTEIN did not want black girls or girls with tatoos. IlMe stated that one of the girls she stayed with on occasion, at also started providing EPSTEIN with massages. A telephone number for VOMMIftwas WINMUMINMEOW. W said that her family resides in , Florida, possibly S --- also stayed with during this same time period. However, never went to EPSTEIN'S house or provided him with massages. has a Yacht Club address. Another girl that had taken to EPSTEIN's residence was LOMMIN0Last Name Unknown' According to EPSTEIN liked ISMOMMOLNU a lot. impsaid that she was never a favorite of EPSTEIN. EPSTEIN offeredam$300.00 to bring_ialb MEMIllwas a couple years younger than )elieveo tnat sne was either 16 or 17 when she first went to EPSTEIN's residence. ne.m...said that went 2-3 times but that she did not want any part of it after that. ---a "neves she could identify Lf she saw her photograpu. also stated that at EFTA00184459
Case 9:08-cv-80736-KAM Document 361-32 Entered on FLSD Docket 02/10/2016 Page 6 of 7 . FD-302s (Rev. 10-6-95) 31E-MM-108062 Continuation of FD-302 of 4 .on 08/07/2007 .Page one time attended HIGH SCHOOL. 'also believed that they had met through a group of friends while attending - a dropout prevention school. --,mentioned another girl by the name of Ca smille EPSTEIN distinguished the two "MS by referring to mane worked at an ice cream shop. W._ Istated that she did not likeMEMO, and that was a storyteller and a bad liar. stated thet.iiiiMMOMOnever really wanted to go to EPSTEIN's residence but she went anyway. ttttttt~ -1.1said that she had not taken a good look at EPSTEIN's penis. --Sexplained that it seemed like he would always try and hide his penis. Ilia stated that EPSTEIN never asked her for sex. HOMMOstarted dancing when she was sixteen at IMINNIII" MINIIMMOIMb The owner, SS let her dance. 'has also worked at daIMPie located 0 ' Boynton Beach, Florida. used illegal drugs during the years she provided EPSTEIN with massages. 'said that EPSTEIN tried to provide her with advice regarding controlled substances. - - stated that she met with EPSTEIN's attorneys, IIMp, a ana a unidentified female(UF), at the ALE HOUSE RESTAURANT. Willipmet with them after she contacted who confirmed that they were really working for EPSTEIN. *stated that mommmealso balked of her twin boys and stated that she was living in Manhattan. OPEREPfound out that Sand the OF are employed by illnielS. They asked a lot of questions. They specifically asked about LIMNS and a ---11reiterated her dislike for Tall mmINO0also informed the interviewing agents that she had spoken to —ishe believed before the fourth of July. told — at she had met with investigators and that they nad videoed her. numbers: pconfirmed her association to the following telephone Old cellular number - (III) Possibly an old cellular number - (III) telephone number - EFTA00184460
Case 9:08-cv-80736-KAM Document 361-32 Entered on FLSD Docket 02/10/2016 Page 7 of 7 , FD-302a (Rev. 10-640 31E-MM-108062 Cootinuation of PD-302 of • • .O0O8/O7/2OO7 JEW S fr et EFTA00184461
Case 9:08-cv-80736-KAM Document 361-33 Entered on FLSD Docket 02/10/2016 Page 1 of 4 EXHIBIT 33 EFTA00184462
Case 9:08-cv-80736-KAM Document 361-33 Entered on FLSD Docket 02/10/2016 Page 2 of 4 JANE DOE 01 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES CASE NO: 08-80736-Civ-Marra/Johnson EXHIBIT H EFTA00184463
Case 9:08-cv-80736-KAM Document 361-33 Entered on FLSD Docket 02/10/2016 Page 3 of 4 FD-302 (Rev. 10-6-95) - I - FEDERAL BUREAU OF INVESTIGATION Datconmsterioon 02/08/2008 On Thursday, January 31J- 21 128 'met with Assistant United States Attorney .= , UNITED STATES ATTORNEY'S OFFICE (USAO) and Attorney MYESHA K. BRADEN, UNITED STATES DEPARTMENT OF JUSTICE(DOJ), CRIM NAL DIVISION. Also present at the meeting were Special Agents E. and JASON R. , FEDERAL BUREAU OF INVESTIGATION. The meeting was arranged pursuant to a federal investigation regarding the sexual exploitation of minors. During the course of the meeting, provided the following additional or clarifying information not previously documented in earlier FD-302s: JEFFREY EPSTEIN and his assistants, and (identified as and allIS would contacts to set up a pointments for EPSTEIN's massages. According to—, would call and say that EPSTEIN was on a flight and inquire about scheduling work for Life was not going well for during the time she was providing EPSTEIN with massages. ..- was buying and taking drugs, i.e. Xanax, Lorcets, and Percosets. said that she stayed on pills. lexplained that she wanted to feel numb. MRWMIstopped attending school at age fifteen. Her parents were addicted to crack and cocaine. Prior to her parent's drug use, l was in the band, a cheerleader, and a straight "A" student. _ played the trumpet for the school band. When her parent's drug habits got bad, things went downhill, they lost everything. I became a dancer the day before her sixteenth birthday at IIIIIMarnalia She worked there for six months, up"until the employer found out she was underage. Later worked for which she did for 6 months. stopped seeing EPSTEIN during that time. istated that she brought up to twenty, twenty-five, or thirty different girls. E....Am said all of the girls but maybe ten of them were underage. Some of the females brought for EPSTEIN were dancers. tsaid that EPSTEIN did not care for all of the girls she brought co him _'explained that EPSTEIN did not care for some of the dancers, the older females, and the females with tattoos. ItYcetugationon 01/31/2008 et West Palm Beach, Florida Filet 31E-MN-108062 Date dated 01/31/2008 t,) SA Jason R. This document contains neither recommendetons nor conclustons of the FBI. It is the property of the FBI and is loaned to your agency. it end its contents are nor to be disvibuted outside your agency. EFTA00184464
Case 9:08-cv-80736-KAM Document 361-33 Entered on FLSD Docket 02/10/2016 Page 4 of 4 FD•302a (Rev. 104-95) 31E-MM-108062 Continuation or FD-302 of .0'101/31/2008 Mx 2 ___Isaid that during the massages EPSTEIN would push further and further regarding the sexual activity. According to i EPSTEIN never asked, "is this okay," he would just see how far one would let him go. recalled seeing sculptures of naked women and lots of pictures of kids in the library. neurologist. stated that everybody thought Epstein was a 'also stated that ♦ ar. has twin boys. • EFTA00184465
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 1 of 89 EXHIBIT 34 EFTA00184466
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 2 of 89 - - - ate: 7/19/06 ime: 15:01:37 PALM BEACH POLICE DEPARTMENT Incident Report Program: CMS30IL Page: 1 ase No PECIAL NOTES :cur To Date : ay Of Week : Dmmon/Location: ity • ,cation Type : ?..at Assignment: ?pt Class . . : Ise Status . : ipervisory Dt.: itry Date . : unes7 thicles? irrative? . : . : 1-05-000368 1/27/05 0000 Thursday 358 EL BRILLO WY PALM BEACH, FL RESIDENCE-SINGLE DETECTIVE BUREAU SEXUAL BATTERY OPEN / ACTIVE TRYLCH, JEFFREY OREGERO, LAURA .** ***** lIEHICLE Lse number . : 1-05-000368 ate Veh Type : Lke idol Name . yle dor - Bottom N sposition sured by . hicle locked to recovered reet number ty covery code : On Look Out?: : o/oo/oo ******* P E R S O N R E se Number . : 1-05-000368 reet Number : ty rth Date/Age zupation . . ne Phone No ight V*********** Female • 0 S 5e Number . : :eet Number : :y :th Date . . )loyer? . !r Lic No. . ler Phone Nbr: • limum Weight : Occur From Date: 1/27/05 0000 Report Date . : 3/14/05 1600 FAMILY Map Reference Report Officer Case Status Dt 3/14/05 4/06/05 Property? . . Offenses? . . Related Cases? 10 PAGAN, MICHELE 3/14/05 NFORMATION # 1 Category . . . : Year • 0 Model Permit Number Color - Top License # Stolen value . Insured . . . Keys in car . Lein holder . Recovery value P O USPECT/ A 1-05-000368 NCIC number . : 0 : 0 R T I N G I N F O -# 1********* Last Name Employer? . . : Oper Lic No. . Race Height Other Phone Nbr: eas White 0 RRESTEE INFORMATION- #1 ** Prompt valid in: R125320866290 FL Female 0 334121460 Maximum Age . Occupation . Home Phone No Race : 18 Minimum Height : Maximum Height : White 0 0 EFTA00184467
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 3 of 89 )ate: 7/19/06 rime: 15:01:37 PALM BEACH POLICE DEPARTMENT Incident Report Page: 2 Program: CMS3011, .ase No Laximum Weight : diases, air Color . air Style . lasses . acial Hair eeth at hirt hoes ody Marks #2 : ody Marks #4 : crest Case No.: . : . : . : ************* S ase Number . : treet Number : ity firth Date . . nployer? . . )er Lic No. :her Phone Nbr: • .nimum Weight : iximum Weight : ases' .or Color . . : tir Style . : asses . . . : cial Hair . : eth t irt oes dy Marks #2 : dy Marks #4 : rest Case No.: ************ se Number reet Number ty rth Date . ployer? . : ar Lic No. . : ler Phone Nbr: < limum Weight cimum Weight Lases' -r Color . . r Style . . : S Fema 0 0 1-05-000368 0 Misc. ID# • . MO/Crime Spec? : Hair Length . Eye Color Complexion Build Speech Coat Pants Body Marks Body Marks Status Additional #1 fl3 USPECT/ARRESTEE INFO 1-05-000368 Prompt valid in: 358 EL BRILLO WY PALM BEACH, FL 000033480 Maximum Age . : 25 Occupation . . : Home Phone No. : Race e Minimum Height 0 Maximum Height 0 Misc. ID# . . MO/Crime Spec? Hair Length Eye Color Complexion Build Speech Coat Pants Body Marks Body Marks Status Additional (Continued) • STILL SUSPECT UCR?: RMATION- # 2 ** PERSONAL ASST/EPSTEIN #1 : #3 : • STILL SUSPECT UCR? : USPECT/ARRESTEE INFORMATION - * * # 3 1-05-000368 Prompt valid in: EPSTEIN, JEFFREY 358 EL BRILLO WY PALM BEACH, FL 000033480 1/20/1953 52 Maximum Age . : 52 Occupation . . : E123425530200 FL Home Phone No. : Race • White Male Minimum Height 0 0 Maximum Height 0 0 Misc. Intl . MO/Crime Spec? Hair Length . Eye Color . . EFTA00184468
Case 9:08-cv-80736-KAM Document 361-34 89 Entered on FLSD Docket 02/10/2016 Page 4 of Date: 7/19/06 Time: 15:01:37 Incident Report PALM BEACH POLICE DEPARTMENT Page: 3 Program: CMS301L lase No. . . : ;lasses . Facia/ Hair teeth • • . . . : iat . • • : ;flirt Shoes iody Marks #2 : !cod), Marks #4 : arrest Case No.: 1-05-000368 *************.ICTIM 'ase Number . : 1-05-000368 rompt valid in: treet Number : ity irth Date/Age 14 ccupation . ome Phone No. : ex • Female eight • 0 2 On Look Out?: Lctim Type . esidency Sts an Identify . (jury Extent ijury Type 2 ad Treatment iys Last Name *.*********** ise Number . reet Number rth Date/Age cupation . . me Phone No. x • Fema e ight • 0 On Look Out?: ctim Type . sidency Sts Identify . jury Extent jury Type 2 i Treatment is Last Name r*********** ;e Number . -eet Number : ADULT VICTIM : 1-05-000368 th Date/Age : JUVENILE VICTIM : 1-05-000368 : PALM BEACH, FL : 18 I N F (Continued) Complexion . : Build Speech Coat Pants Body Marks #1 Body Marks #3 : Status STILL SUSPECT Additional UCR?: ORMATI ON - 0 1 ******************** Employer? . Oper Lic No. Race Height Misc. ID# . Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION Prompt valid 000033480 White 0 # 2 ******************** in: air Employer? . . : Oper Lic No. Race White Height • 0 Misc. ID# Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION -# 3******************** Prompt valid in: elle P EACH, FL 000033480 EACH, 16 Employer? EFTA00184469
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 5 of 89 ate! 7/19/06 ime: 15:01:37 PALM BEACH POLICE DEPARTMENT Incident Report Page: 4 Program: CMS301L ase No • 1-05-000368 ccupation . : pme Phone No. : 561/000-0000 ex • Female eight 0 On Look Out?: ictim Type . : JUVENILE esidency Sts : an Identify . : /jury Extent : /jury Type 2 : ad Treatment : lys Last Name : c************ ise Number . : 1-05-000368 .reet Number : ty • PALM BEACH, FL rth Date/Age !cupation . 'me Phone No ight On Look Out?: ctim Type . idency Sts Identify . jury Extent jury Type 2 d Treatment ys Last Name ************ se NUmber reet Number ty rth Date/Age :upation ne Phone No. IIIIIIIIIP017 M/000-0000 Female 0 : JUVENILE VICTIM : 1-05-000368 PALM BEACH, FL WIAINAIII 18 Female ight • 0 On Look Out?: Type . : ADULT ;idency Sts Identify . jury Extent jury Type 2 : I Treatment : Is Last Name : ***********VICTIM :e Number . : 1-05-Q0(1368 npt valid in: Sale Oper Lic No. Race Height Misc. ID# . . Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID : Phys First Name: (Continued) White 0 INFORMATION Prompt valid in: 000033480 4 ******************** Employer? . . : Oper Lic No. . : Race White Height 0 Misc. ID# : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION -# 5******************** Prompt valid in: as 000033480 Employer? Oper Lic No. . Race White Height 0 Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID : Phys First Name: INFORMATION - # 6******************** EFTA00184470
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 6 of 89 ate: 7/19/06 'ime: 15:01:37 PALM BEACH POLICE DEPARTMENT Page: 5 Incident Report Program: CMS301L ase No • 1-05-000368 treet Number : ity PALM BEACH, FL irth Date/Age : 16 ccupation . . ome Phone No. :M MI ex • Female eight • 0 e On Look Out?: ictim Type . : JUVENILE esidency Sts : an Identify . : ijury Extent : -ijury Type 2 : ad Treatment : -Lys Laet Name : ■************ 000033480 VICTIM /NFO Ise Number . : 1-05-000368 :reet Number : .ty .rth Date/Age : :cupation )me Phone No. 561/000-0000 Female 0 ,x :ight : On Look Out?: ctim Type . : JUVENILE sidency Sts n Identify . jury Extent jury Type 2 : d Treatment : ys Last Name : PALM BEACH, FL a 17 ************ VICTIM se Number . : 1-05-000368 reet Number : ty rth Date/Age : cupation . . : me Phone No. : Female ig• ht • 0 On Look Out?: 2tim Type . sidency Sts ▪ Identify . jury Extent jury Type 2 i Treatment is Last Name PALM BEACH, FL a 16 : JUVENILE e*********** V ICTIM Employer? Oper Lic No. Race . . Height Misc. ID# : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID : Phys First Name: • . : RMAT (Continued) White 0 I 0 N - # 7 ******************** Prompt valid in: SS 000033480 Employer? . . : Oper Lic No. . : Race Height Misc. ID# : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 Hospital ID . : Phys First Name: White 0 INFORMATION -# 8******************** Prompt valid in: es 000033480 Employer? . . : Oper Lic No. . : Race • Height Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 INFORMATION -# 9 ************ ******* * EFTA00184471
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 7 of 89 - - - )ate: 7/19/06 'ime: 15:01:37 PALM BEACH POLICE DEPARTMENT Incident Report Page: 6 Program: CMS3D1L .ase No 1-05-000368 !ase Number . : treet Number : ity irth Date/Age : ccupation . ome Phone No. : ex Female eight 0 e On Look Out?: ictim Type . : JUVENILE esidency Sts an Identify . ajury Extent : ajury Type 2 : ad Treatment : Sys Last Name : 1-************ IIICTIm tse Number . : 1-05-000368 :ompt valid in: .reet Number : ty • rth Date/Age :cupation . . wile Phone No. 1-05-000368 PALM BEACH, FL Oliglillb 17 sght On Look Out?: ctim Type . : sidency Sts : n Identify : jury Extent : jury Type 2 : d Treatment : ys Last Name : ************ V se Number . : reet Number : :y rth Date/Age :.upation . ne Phone No. fight On Look Out?: :tim Type . : ;idency Sts : t Identify . : ury Extent : ury Type 2 : Treatment : Prompt valid 000033480 Employer? Oper Lic No. Race Height Misc. ID# . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION - # PALM BEACH, FL 0000334 SIPS'S 17 Fema 0 e JUVENILE ICTIM 1-05-000368 PALM BEACH, FL VIIIIIMONM 18 Fema 0 ADULT e BO Employer? Oper Lic No. Race Height Misc. ID# Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID : Phys First Name: . : . : (Continued) in: imapas . : . : • White 0 10 ******************* White 0 INFORMATION - # 11 ******************* Prompt valid in: 000033480 Employer? Oper Lic No. . Race Height Misc. ID# . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 EFTA00184472
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 8 of 89 Date: 7/19/06 Time: 15:01:37 --- PALM BEACH POLICE DEPARTMENT Page: 7 Incident Report Program: CMS301L :else No ?hys Last Name : 1-05-000368 l************* 1I/CTIM :ase Number : 1-05-000368 ;treet Number : • firth Date/Age : tccupation : bine Phone No. : :ex 'eight .e On Look Out?: ictim Type . : esidency Sts : an Identify . njury Extent : njury Type 2 : ed Treatment hys Last Name : ************* ase Number . : treet Number : ity irth Date/Age : :cupation . . : ame Phone No. : 2x night 2 On Look Out?: ictim Type . :sidency Sts in Identify . : ijury Extent 'jury Type 2 : !d Treatment : tys Last Name : (Continued) INFORMATION Prompt valid - # in: 12 ******************* PALM BEACH, FL 18 ema ADULT VICTIM 1-05-000368 PALM BEACH, FL giOMINIMM016 Fema 0 ************ V se Number . reet Number : ty rth Date/Age : 16 cupation . . : me Phone No. : x ight On Look Out?: ctim Type . : sidency Sts : n Identify : jury Extent : e JUVENILE ICTIM 1-05-000368 PALM BEACH, FL Fema le 0 JUVENILE 000033480 Employer? Oper Lic No. Race • White Height • 0 Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION -# 13 ******************* valid in: al Prompt 000033480 Employer? . Oper Lic No. . Race • White Height 0 Misc. ID# : Other Phone Nbr: Residency Type : File Charges - : Victim Sobriety: Injury Type 1 : Hospital ID . Phys First Name: INFORMATION -# 14 ******************* Prompt valid in: f 000033480 Employer? . . Oper Lic No. . : Race White Height 0 Misc. ID# Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : EFTA00184473
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 9 of 89 Date: 7/19/06 Time: 15:01:37 PALM BEACH POLICE DEPARTMENT Incident Report Page: 8 Program: CMS301L -ase No Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number . : 1-05-000368 Street Number 2ity 3irth Date/Age : )ccupation . . Tome Phone No. ;ex • Female Jeight • 0 le On Look Out?: 'ictim Type . :esidency Sts 'an Identify . njury Extent njury Type 2 ed Treatment hys Last Name • 1-05-000368 • ************* ICTIM PALM BEACH, FL Sr 19 ADULT Hospital ID . Phys First Name: INFORMAT (Continued) I O N - # 15 ******************* Prompt valid in: 000033480 VICTIM INFO ase Number . : 1-05-000368 treet Number : ,Y PALM BEACH, FL .rth Date/Age : :cupation . : Mme Phone No. • ?ight On Look Out?: .ctim Type . : JUVENILE !sidency Sts in Identify . dury Extent : jury Type 2 : qi Treatment : ys Last Name : ************ se Number . : 1-05-000368 reet Number ty rth Date/Age : cupation . . ne Phone No. : Female ight • 0 On Look Out?: 7tim Type . : JUVENILE 3idency Sts : 17 561/000-0000 Female 0 ICTIM PALM BEACH, FL ena 16 Employer? . Oper Lic No. Race Height Misc. ID# . 1 Other Phone Nbr: Residency Type : File Charges . Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: RMATION Prompt valid 000033480 INFO Employer? Oper Lic No. Race White Height 0 Misc. ID# . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: • White 0 - # 16 ******************* in: tella RMATION -# 17 * *********** Prompt valid in: 000033480 Employer? . : Oper Lic No. . : Race • White Height • 0 Misc. ID# . . • Other Phone Nbr: I Residency Type : File Charges . : EFTA00184474
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 10 of 89 Date: 7/19/06 Time: 15:01:37 PALM BEACH POLICE DEPARTMENT Incident Report Page: 9 Program: CMS3OIL Case No Can identify . Injury Extent Injury Type 2 Ned Treatment Phys Last Name 1-05-000368 Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: (Continued) ********* OTHER P E R S 0 N INFORMATION - # 1 ********* '_ase Number . : 1-05-000368 Last Name Street Number :n os 'ity Birth Date/Age :01114,111110 14 Employer? . }ccupation . . : STUDENT Iome Phone No. : millimma :ex • Female 'eight • 0 they Phone Nbr: ******## 0 THER PERSON ase Number . : 1-05-000368 treet Number : 358 EL BRILLO WY ity • PALM BEACH, FL 00003 irth Date/Age : 2/21/1985 19 ccupation . : Dole Phone No. : ex • eight :her Phone Nbr: Female 0 v*******OTHER P E R Ise Number . : 1-05-000368 :reet Number : .ty .rth Date/Age 35 :cupation . . ,me Phone No. :x Female ight 0 her Phone Nbr: S • • Oper Lic No. • Race • White Height • 0 Person Type : OTHER PERSON kes INFORMA Last Name 3480 Employer? . Oper Lic No. Race Height 510 Person Type . : OTHER PERSON 2 ********* NADA : M625620855610 FL • White S 0 N INFORMATION -# 3 ********* Last Name . ******* OTHER P E R S O N se Number . : 1-05-000368 reet Number : ty rth Date/Age : cupation . . : PAINTER d allillia ne Phone No. : • Male ight • 0 ler Phone Nbr: Employer? . . : Oper Lic No. . Race White Height 0 Person Type . : OTHER PERSON INFORMATI ON - # 4 ********* Last Name . . Employer? . . Oper Lic No. . : Race White Height 0 Person Type : OTHER PERSON 1******OTHER PERSON ;e Number . : 1-05-000368 INFORMATION - # 5********* Last Name . . : BACK, KATHY EFTA00184475
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 11 of 89 )ate: 7/19/06 1.me: 15:01:37 PALM BEACH POLICE DEPARTMENT Incident Report Page: 10 Program: CMS301L ase No treet Number : ity irth Date/Age : ccupation : ome Phone No. : ex eight ther Phone Nbr: • ase Number . nployer Name : dress . : ity/State/Zip : lone Number . : t******* 0 T H Ise Number . : :reet Number .ty rth Date/Age :cupation . Mme Phone No. :x •ight er Phone Nbr: 1-05-000368 0/00/0000 0 FAMILY THERAPIST Fema • 0 e Employer? . Oper Lic No Race Height • 0 Person Type • • • . : • White ***EMPLOYER INFORMATION*** 1-05-000368 PBC DIVISON OF YOUTH AFFAIRS 4200 N' AUSTRALIAN AV WEST PALM BEACH, FL 33407 E R P E R 1-05-000368 WAIMMIOW 16 STUDENT 4MOMNIIIIMM Male 0 (Continued) . : OTHER PERSON S 0 N INFORMATION -# 6********* Last Name . : Employer? . . : Oper Lic No. . : Race White Height • 0 Person Type . : OTHER PERSON ***EMPLOYER INFORMATION*** se Number . : 1-05-000368 Employer Name :ilejam dress . . : ty/State/Zip : one Number . : *******OTHER PERS se Number . : 1-05-000368 reet Number • ty rth Date/Age : 0/00/0000 0 2upation . ne Phone No. : • Male ight • 0 ler Phone Nbr: 0 N INFORMATION - # 7********* Last Name . . :S Employer? . Oper Lic No Race . : White Height 0 Person Type . : OTHER PERSON l****** OTHER PERSO N INFORMATION -# 8 ********* • • : alale ;e Number . : 1-05-000368 Last Name :eet Number .y ' SIONMINS .th Date/Age : 0/00/0000 0 Employer? . . : :upation . . : Oper Lic No. . : ie Phone No. :- Race • Female Height . : 0 EFTA00184476
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 12 of pate: 7/19/06 Time; 15:01:37 PALM BEACH POLICE DEPARTMENT Page: 11 Incident Report Program: CMS301L :ase No 1-05-000368 (Continued) /eight • 0 Person Type . : OTHER PERSON )ther Phone Nbr: ******** OTHER PERSON IN - # 9 ********* 'ase Number . : 1-05-000368 Last Name . . : Ma :treet Number :ate 'Sty • 041MIS irth Date/Age : a 16 Employer? ccupation . . : Oper Li c No. :allialliabot. ome Phone No. : Race • White ex • Fema e Height • 0 eight • 0 Person Type : OTHER PERSON ther Phone Nbr: ***************************NARRATIVE # 1*************************** riginal Report LO Reported By: PAGAN, MICHELE D. 9/20/05 Entered By.: OREGERO, LAURA D. 9/20/05 On 03/14/2005, I received a call from a woman who did not wish to identify herself (later identified as 4IMMIIMMOMMOM). She stated that her fourteen year old step daughter (later identified as at S possibly may have been molested in Palm Beach by a wealthy man. According to IMMINIMM, she learned of the possible molestation by a third party. She explained that she had received a call from the mother of her stepdaughter's friend. The mother claimed to have overheard a conversation between her daughter and a male friend; they were talking about am The conversation was about how moms had met with a 45-year-old man and had sex with him and was paid for it. advised e that I would like to meet with her to obtain a more detailed statement and facts. - stated she did not know what to do and had to discuss the matter with her husband. At this point ageils did not provide me with a call back number or any other information. She stated that she would contact me once she had spoken with her husband and mother. On 03/14/2005 received a call from Mr. & Mrs. dare They stated it was all right to speak to their daughter-le via cell phone.'" Her mother eilleathad been made aware of the case. They agreed to meet me at the police department later this date. On 03/14/2005, 03/14/2005, Mr. ellgellealt accompanied by his wife AIINIMIWcame to the Palm Beach Police Department where they advised me that they believed their fourteen year old daughter may have had some type of sexual relationship with an older male who resided in Palm Beach. Neither knew the suspect's name or address. Both stated that their daughter did not talk to them about the incident, nor would she admit to it. identified his daughter asd w/f, DOB at 4/a/Sink/aWsige, iingais t 1 resides with her biological mother - Sal is a twin, EFTA00184477
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 13 of 89 )ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 12 'ime: 15:01:37 Incident Report Program: CMS301L ase No • 1-05-000368 (Continued) her sister 'OW resides with Mr. MONOONNIO Botha and a are currently attending diallassalls which is an involuntary admitted juvenile educational facility. stays at the facility during the week and comes home on the weekenlilliAccording to ImMillashe was admitted to the school because of disciplinary problems that recently escalated. The facility also coordinates with the families to provide one on one as well as family counseling. According to Mrs. IMIS she believes the incident occurred on Sunday, Feb 6, 2005. A friend of r named Haley picked her up at their house and left. They believe Ha ey initiated the relationship with the older gentleman, though they do not have any proof. Haley lives close by with her mother. Mrs. further explained that was introduced to Haley by' , a boy she was dating goes to plays baseball). Mrs. continued that on Sunday, Haley picked ups and drove to Palm Beach where they met the man. Supposedly, the man has a lot of money and often has young girls come over to his house. Haley offers these girls a way to make fast cash. The man starts with a massa e. If he likes them, he keeps them around and does more. The did not have any information on Haley other than she lives on 72nd Place North, the last house on right side (north side). Mrs. a talked of a conversation that she had with a a, the mother of filea a former friend of IMMIS She found it strange that they were no longer friends until she received the call from her mother telling her of the conversation she overheard between and a boy named S Mrs. Sellellt told me of an incident that occurred on 02/09/2005. emet got into a fight at school ( ). Mrs. dabs found over $300.00 in purse. 41.1 gave different explanations for the large sum of money. Initially the school administration thought it was drug related but then dismissed the claim. Since that day, did not return to school; she ran away Thursday, 02/10th or Friday 02/11 and returned to her mother's house later that night after midnight. It was not until after aka* received the call from Smother, INIMMORAISM) Si, that she learned VOM was the girl that got into the fight with S The fight was instigated whenlINIMOPaccusede of being a prostitute. who has legal joint custody of his daughter , signed the affidavit of prosecution indicating he wished to prosecute against the inappropriate sexual behavior with his fourteen-year-old daughter. Mr. stated that he had no objections with our agency speaking with his aughtere about the incident. Mr. S stated that motheratis aware of the allegations and also was willing to cooperate. According to Mrs. S, she does not believe her daughter had any additional contact with the suspect as she was with EFTA00184478
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 14 of 89 - - - ate: 7/19/06 PALM BEACH POLICE DEPARTMENT ime: 15:01:37 Incident Report Page: 13 Program: CMS301L ase No • 1-05-000368 her mother and then placed into I contacted the School Board Police who provided me the 'nformation for a also known as . Checking the school bOard records for laband ailllainallipg there was no disciplinary record found. I was advised if no disciplinary action was taken for a fight, such as an expulsion or detention, the incident may not have been recorded. This was at the discretion of the individual school security and principal. 03/15/2005, I called the Palm Beach County Sheriff's Office and left a message for PBSP Sgt. Chris Keen, Child Abuse Unit. On 03/25 2005, I went to where I met with white female somple Also present was Kathy Back, therapist. During an audiotaped interview, I spoke with about the allegations that were made. alalliehinitially denied anything had happened, only admitting to going with Haley (later identif ed as Haley Robson) to Palm Beach to pick up money Robson was owed. identified Haley Robson as the cousin of her former boyfriend She ultimately admitted to knowing that Robson worked for a wealthy man and possibly did sexual favors for him. She also admitted that Robson had offered her an opportunity to make money. (Continued) a identified Robson's boss as a white male named "Jeff" who lived in Palm Beach (later positively identified as Jeffrey Epstein). _explained that she was first approached by Robson to go with her to Jeff's house, when they were atiliMinithouse. According to IIIMMINNA she was not sure exactly what was going on with Robson but agreed to go with her. ANNONIMMOMMboyfriend) became angry when he heard Robson invitingSIONto accompany her. 44MINSibelieved it was to pick up money the man owed Robson. a stated Robson told her that she would pick her up at her house on Sunday. was not sure of the exact dates but knew it was a Sunday. According to ISOM Robson along with an unknownpossibly His anic female, picked her up at her father's house on told her father that they were going shopping. It was later confirmed by OMMOMOPIMONOM6that Robson picked his daughter up. According to Mr. a, Robson drove a pick up truck. Robson droveillialftralong with the unknown female to Palm Beach. Sometime on the way there, a conversation occurred between Robson and whereby Robson told a that if Jeff asked her (a) age, she should say she was eighteen. AMINOMNOrecalled that Jeff's house was on a dead end street. All three girls walked up a driveway, ast what appeared to be a small guazd/security room. In fact, B recalled a male approaching them asking what they wanted. Robson stated they were there to see Jeff. The male allowed them to continue walking up to the house. EFTA00184479
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 15 of 89 ( )ate: 7/19/06 rime: 15:01:37 PALM BEACH POLICE DEPARTMENT Page: 14 Incident Report Program: CMS3011, .ase No • 1-05-000368 (Continued) IMMINIgistated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly after, Epstein and a woman, described as white with blond hair entered the kitchen. AMONNOMPbelieved the woman was Epstein's Assistant. ANIIII0Padded that the woman did not seem friendly and kept her responses short and direct. Epstein introduced himself to a. as Jeff . Allanigot the impression that Epstein and Robson's friend knew each other. diNIMOMMidescribed Epstein as being approximately forty-five years old, a long face, and bushy eyebrows, with graying hair. Robson and Epstein left the kitchen leaving and Robson's friend alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. While speaking to me, S became upset and started to cry. Sastated the woman instructed her to follow her upstairs, which she did. According tolMOINIMMO, the woman led her to a room that had a massage table in it. The woman started to fix up the room, putting the covers on the table and taking lotions out. She then told IIIMIllithat Epstein would be up in a second. The woman left the room; and soon after, E stein walked in and teddigellIMP to take off her clothes. As was telling me what had happened, she looked away from me, and with a pointed finger, repeatedly pressed it into her thigh. stated he was stern when he told her to take off her clothes. said she did not know what to do as she was the only one there. took off her shirt leaving her bra on. Epstein, dressed in a towel told her to take off everything. delliestated she removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. Epstein laid on the table, face down. As `be an to give Epstein the massage, he told her to get on his back. stated she straddled herself on Epstein's back. SiiIirestated her exposed buttocks were touching Epstein s bare buttocks. As_ was giving Epstein the massage, he turned around, and wacked off later explained that wacking off was masturbating). stated she was disgusted by Epstein's actions but did not say anything. According tom Epstein told her that she "had a really hot body." Epstein excused himself and went to the bathroom where she believed he masturbated again. Epstein returned to the room and told that he was done and gave her three hundred dollars. They went back down stairs where they met Robson. Epstein said good-bye and they left. Robson asked- how did it go and asked what did she Sat do. When et told Robson that ' stein asked for a massage, Robson allegedly stated "I know." stated they then went shopping. s stated Robson also got paid, but that she did not know why since she was confident that Robson did not do anything. WOMOMMWdescribed Epstein's house as a two story pink house with a Cadillac Escalade parked in the driveway. re were gates leading into the property. From the kitchen, recalled walking up a flight of stairs, lined with photographs, to a room. Upon entering EFTA00184480
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 16 of ______________________________________ _________ late: 7/19/06 PALM BEACH POLICE DEPARTMENT ______ 1; rime: 15:01:37 Incident Report Program: CMS301L 7ase No • 1-05-000368 (Continued) ,,,,tbe room there was a large bathroom to the right. a recalled a hot pink and green sofa in the room. There was a door on each side of the sofa. Salip'recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. 4MOMMINbstated Epstein did not change in front of her but did take '-o''f'f his towel, exposing himself. IMMOMMOMMIrecalled Epstein being hairy especially on his chest. Epstein also had a hairline that continued to his buttocks. MOMMIIMIS admitted to seeing his penis. I asked Sif she knew what being circumcised meant and she stated no. a then said that she thought Epstein was on steroids because he was a "really built guy and his wee wee was very tiny." ould explain that when she stated "wee wee" she meant penis. 4IIIIIII stated Epstein exposed himself when he took his towel off, placing it on the floor as he laid down on the table. IS said Epstein was specific in his instruction to her on how to massage, telling her to go clockwise, etc. erecalled that Epstein got up from the table and went to the bathroom where she heard him making, what she believed to be sexual type of noises. (moaning) He then returned to the room where he again laid down on the table. Epstein then turned over and instructede, to massage his boobs. As she did this, Epstein continued to make moaning noises. a resumed massaging his chest area. awas now standing on the ground. Epstein turned to his side, and with the towel on the ground started to rub his penis in an up and down motion. INORROW stated Epstein held on to the small of her back as she massaged his chest, back and shoulder area. MOMMEMOMOrecalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. also recalled Epstein having a noticeable freckle on his chest. Epstein then left the room andS got dressed. She went back downstairs where she met Haley and the unknown white female. Ma admitted to getting paid three hundred dollars in cash from Epstein. Before they left, Epstein asked...WNW to leave her phone number. As they were leaving the house, Haley asked UMOMMa.what had happened and how much she was paid. .AS stated Haley seemed upset or jealous when she told her that she received three hundred dollars. Haley stated received only two hundred dollars that day. es stated that she believed Haley was paid two hundred dollars for bringing her. Robson told that if they do this every Saturday, they could be rich; IMMOMMIOlagreed. They then went shoppin , though she is not sure where. Possibly at TJ Maxx or Marshall's. stated she never saw Robson again as she got into a fight at school. She had not spoken with Robson either as her mother took away her cell phone. I asked if she was aware of any video equipment while she was in the room. She stated no. EFTA00184481
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 17 of 89 hate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 16 'ime: 15:01:37 Incident Report Program: CMS301L ase No 1-05-000368 (Continued) OSstated she was afraid that Robson would retaliate against her or her family if she ever went to the police regarding the incident. - stated that her father's vehicle was recently vandalized. - admitted to telling - what had happened with Epstein. According toSli,allabecame angry and upset, punching a hole in the wall.MIMMOMMOOlguessed that it wasawho told about the incident, and now there were rumors in school aboutall. and what she did with Epstein. I then talked toS about truth and lying. We talked about the color sweater she was wearing. - denied having sexual intercourse with Epstein. She denied touching his penis. SI again admitted to observing Epstein masturbate. ANINMINI agreed to cooperating with the police department phone call to Robson in a controlled settins eIiiisa htimi and advised her of the families' as well as willingness to cooperate with this investigation. Copies interview were placed into evidence. I made contact withi IiiiiIIINImother of IMINNOMMMOOMMO / advised her briefly of my investigation. She was aware of the incident and stated that she overheard a portion of a conversation that her daughter was having with a boy namedella AONMNIalbstated that it was her opinion that both girls liked Me MOMOMOOMMIK recalled hearing her daughter callingaa whore. admitted that she did not listen to the entire conversatirrurilk confront her daughter about it later. IMMOMfttold her mother that somethin to the effect thatIOMMOMIMphad slept with an older man for money. IMOMMOMistated that she would not object to me speaking with her daughter. It was belief that everyone in the school wiperailla known about this because of the fight that her daughter and had gotten into. I reminded We that this was an ongoing investigation and requested she not discuss the fact that I had contacted her. She agreed. On 03/16/2005, PBSO Sgt. Chris Keen left a message that he was returning my call. I spoke with Keen and discussed the case with him and inquired if he had any open allegations or cases where the suspect resided in Palm Beach. Keen stated he was unaware of any. Keen offered any assistance if needed. Keen stated it was his experience that due to the age of the parties involved, it would be difficult to interview them and expect the investigation to remain confidential. Because of the time delay, there was no need for the victim to be taken to a medical facility for a physical for the purpose of obtaining evidence. There was also no need to take her to CPT as she was already in a juvenile facility, with an assigned therapist, in which coordinating a day and time to obtain a statement could be made. in placing a s. Back of this On 03/17/2005, I queried Jeffery Epstein on the internet and obtained EFTA00184482
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 18 of 89 )ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 17 rime: 15:01:37 Incident Report Program: CMS301L Nase No • 1-05-000368 (Continued) a photo of Epstein to be used in a photo line up. I met with Sat which time she viewed the photo line up. She immediately recognized Epstein and pointed to him (Position #5) . 'Se signed the photo line up under Epstein's picture. This signed line up was placed into evidence. On 03/18/2005, I met with at her residence for the purpose of placing a controlled call to Haley Robson. allaS, spoke with Robson and asked if she could arrange another meeting with Jeff. Robson stated that she would have to call him and make the arrangements. A copy of this conversation was placed into evidence. 03/19/2005, I spoke withaandallealsand was advised that left the state to visit with her aunt and uncle. his scheduled to return to Florida on 03/27/2005 03/21/2005, I coordinated with PB BSF Unit and OCVAN to initiate surveillance on 358 El Brillo. 03/21/2005, Coordinated with Det. Lee regarding trash pulls from 358 El Brillo. On this same date I calledISIMMIIMMIMMkto schedule an appointment to speak wither She stated the school guidance counselor was reluctant to have police presence at the school. assured her that I would respond to the school in civilian clothes and an unmarked vehicle, S called me back and advised that I did not need to make an appointment to seelapplis I received a return phone call from ISOMMESIIIIII.Ostating thatiMMOOr would be attending the family therapy sessions with/Ill' I received messages from I conducted a computer query on Epstein. The results of this query indicated the most recent driver's license on file for Epstein was for the state of Florida, which had expired. A cross reference of Epstein s residence, 358 l revealed the following affiliated names: Nada 02/21/1985, Mark L. Epstein, w/m dob 07/14/1954, Maxwell, uk/f, dob 12/25/1961. A computer query history. On 03/23/2005, I spoke withIONNIRIMINIMIMMIcell phone wklelMOMMe I requested that she not discuss the incident with anyone including her daughterallaas I did not want the investigation compromised. I was told at this time, theta and( have not been getting along due to the fact that has decided to continue living with her father. On 03/29/2005, I placed telephone calls to both theelliliftand IIIIIIIIIIresidences requesting to speak with them regarding the Palm Beach, , w/f, dob & Ghislaine N. for both returned no EFTA00184483
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 19 of 89 )ate: 7/19/06 PALM BEACH POLICE DEPARTMENT 'ime: 15:01:37 Page: 18 Incident Report Program: CMS301L ase No • 1-05-000368 (Continued) investigation. I received return phone calls from Mrs. - and Mrs. nand advised them that I would be contacting Kathy Back, - family therapist to coordinate a time to meet wither This was at the request of both Back and Mrs.VIIIIIIIIMothat ga strict classroom and therapy schedule be disrupted as little as possible. I also updated them to the investigation thus far. Both IS and imaillestated the had no objection to my meeting with— In speaking with Ms. she identified the cell hone number of OS being the phone assigned to . Ms. shad no objections and provided consent to giving it to the police de artment for the use of placing controlled phone calls from it. stated the phone had been taken away froma as part of her punishment for not doing well in school. According to samellimmoused to be an excellent student, but in the past two mohths has edome irritable, verbally abusive to the family and has run away. illemmistated her daughter's recent behavior is the opposite of what she normally is. IMMOMMIestated they are going through family therapy sessions with the school but none of this had come up. Arrangements were made for Det. Captain Gudger to retrieve the cell phone fromiMMOOMMONoat her place of employment. I called ialla and requested to speak with Ms. Back. Upon speaking with Ms. Back she advised me that she was in the middle of therapy sessions and would call me back once the sessions were completed. Ms. Back stated the sessions should be concluded by 7:00 PM. At approximately 8:00PM I had called Ms. Back at which time I left a message on her voice mail requesting a return phone call. I spoke with Ms. and advised her that I did not meet with her daughter and that I wou d again attempt to coordinate a time with the counselor so as not to disrupt IMMIMIschool schedule. shad no objections. Shortly after speaking with Ms.iiMMUMMIlb I received a call from Ms. Back. I explained the situation and requested a time to meet within."' Back reviewed IIIIIIPschedule and advised that alftwould be available after 3:00PM. On 03 30/2005, I met with Ms. Back antate . I reminded .of her conversation with Robson. During this timeSinitiated a conversation with me in which she admitted that she was not telling me everything that had happened during the time she was alone with Epstein. According tank while she and Epstein were alone on the second loor, Epstein used a purple vibrator to massage her vaginal area. stated there was no enetration as the vibrator was on top of her underwear. I asked if Epstein ever asked her age and she stated he had. alagip stated she told him she was eighteen. When Epstein asked what school she was in,IIIIIIIMMEresponded she was in the twelfth grade at During the course of this incident,` stated Epstein told her that Haley had worked for him for years. We then continued with the controlled call to Robson. At approximately 3:35pmallaSlia from her cell phone, made a call to Robson s home, (561)333-0180. Robson was not home. gill was told EFTA00184484
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 20 of 89 )ate: 7/19/06 PALM BEACH POLICE DEPARTMENT rime: 15:01:37 Page: 19 Incident Report Program: CMS301L 7ase No • 1-05-000368 that Haley Robson was at cell phone, Olive Garden Restaurant, (Continued) working a double and could be reached on her W/F, Haley Robson is employed at The ocated on FOrest Hills Blvd in Wellington. IIIIIIIMMFcalled Robson. During the conversation between Haley Robson and — Robson askedIMMOOS, what happened, stating that she had heard rumors thauelftwas going to press charges. Robson asked if they, meaning parents, knew about Jeffery. Robson claimed to have heard that father had found out about Jeffrey, IMMIIMIONIOntold Robson that the y (her parents) did not know anything about Epstein. Robson told that Epstein needed someone to work tomorrow and asked if she was available. Robson stated she would call Epstein and then callgillaback. During the course of these conversations with , she would at times appear to be articulate and well spoken. She would then start to act in an immature manner, by looking around, not paying attention, drawing on a paper. inignillowould offer me a high five whenever she claimed to have told me the truth in the details of the afternoon at Epstein's house. would sit in the chair, with her knees propped up to her chest as she admitted that she did not tell me the all the details of her encounter with Epstein during our fir meeting. As a means of positive reinforcement I would high five 1' On 03/31/2005, subpoenaagtasts for T-Mobile Wireless - and Cingular Wireless, immignimi, (Robson and p one numbers) were drafted. On 04/01/2005, I met with members of PB BSF Unit for the purpose of conducting surveillance on 358 El Brillo. Cross-reference supplement. On 04/01/2005, I met with Det. Krauel of the Palm Beach Police Department who provided me a copy of the concealed weapons permit for Mr. Epstein. It revealed Epstein had a valid permit. There was no current photo attached to the renewal notice. On this same date I queried various different web sites for a possible identification of the purple item retrieved from the trash pull from 358 El Brillo. The item was similar in description as the one described bySand used by Epstein. I made contact with Spicygear.com and spoke with the owner John. I emailed a photograph of the item for his opinion. He identified the items as a Jelly Anal Wand of some sort. The item is easily available at sex shops in South Florida. 04/06/2005, I conducted business queries into Epstein utilizing the internet. I located articles relating to financial reports. There was no local history. On 04/01/2005 - 04/03/2005, with the assistance of BSF, there was EFTA00184485
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 21 of 89 )ate: 7/19/06 rime: 15:01:37 PALM BEACH POLICE DEPARTMENT Page: 20 Incident Report Program: CMS301L ase No • 1-05-000368 continued surveillance on the property. On 04/04/2005, I obtained a copy of voice mail messages, dated 03/31 and 04/01 from Haley Robson tosillegliaaria A female identifying herself as Haley states that she could pick — up to take her to Epstein's house for an eleven o clock appointment. A copy of this was placed into evidence. On 04/05/2005, a trash pull was conducted at 358 El Brillo by Det. Lee and me. There were several messages written on various forms of papers. There was a message from Haley, indicatingqIIII011:00. The following was additional information obtained from trash retrieved from 358 El Brillo: Jean Luc 6:20 AM; David 772-546-6952; 655-0995; 881-8116;655-0995AMIWIIIIIIIMIS Alexis, Brit; Rion lx; fuliias Friday 5:30PM;Joanna B;Wildeillit EAMOMM.; Nicole; Sherry; Haley; a message receipt dated 4/4 1:05- Joanne S. 771-0546 She is looking to speak to you .; 917-7783-4113. (Continued) On 04/06/2005, I faxed sub oena requests to SA Mighdolls office for E stein, Robson and phone records. (Phone numbers On 04/06/2005, i calle 311, and spoke with Principal He ext confirmed that they had a student by the name of He requested a written request prior to releasing any additional information. On this same date I faxed Heers a request for student and parent information one ewe / advised Heers that due to this being an open investigation he was not to discuss the matter with anyone. On 04/08/2005, I received a message fro roviding me the w m Doe Parents name: resat following information: work Sea Det. Lee provided me with trash obtained from 358 El Brillo for 04/06 04/07/05. The following information was retrieved: Jet Aviation 800-538-0724 itinerary, indicating a departure date of 04/05/2005 at 4:00 PM with an arrival in New York City of 6:15PM. Flight crew captain David Rodgers, co-captain, Larry Visoski, flight engineer Larry Morrison. Call sign N908JE; a note stating Bye J. thank you Johanna, hand written notes & messages 11-Glenn, 12:30 chicken, Melissa 4, 3 September B & J, Big Screen x8, Johanna w r Sunday @ 4pM,IIIIII Monday after school?; left message for fORa Joanna Harrison, Rhian on; Sandy works 4-9 Monday and Tuesday, leaves school 40 11:30 AM; will be here tomorrow @ 10:30 Am; Mrs. Business 654-6699 Karen;833-4533. There was no trash for 04/08/05. 04/22/05 received the results of a subpoena request from Bellsouth for The results only provided subscriber information. I contacted Alice Grant Investigative Subpoena Compliance Center who stated the request was not complete and the results would be sent to EFTA00184486
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 22 of 89 - - - )ate: 7/19/06 PALM BEACH POLICE DEPARTMENT rime: 15:01:37 Page: 21 Incident Report Program: CMS301L !ase No • 1-05-000368 me as soon as the query was finished. (Continued) Cross-referencing the names Christine Tatum and Joanna Harrison as well as phone numbers, which were obtained from message notes via trash pulls, I identified the before mentioned individuals as being acquainted with someone at 358 El Brillo. Tatum, DOB 06/07/1984, FL DL 41350115847070 and Harrison, DOB 06/12/1986 FL DL3h625432867120 are both above the legal age of consent. On 05/0g3/2005, I spoke with investiation. stated that and updated her on the was doing well in the school. Her contact with the outside is limited as they do not have access to the phones. 011acomes home on the weekends and she is not allowed to go anywhere alone. On 05/11/2005, I made arrangements to meet with andia on Thursday, 05/12/05, I spoke withOMOWNIMMOMMIregarding the case. They will be moving to GA in July 2005. They will be very busy over the next few weeks but would be available via phone. Will coordinate a date to meet to diectiss the matter further. During this week I conducted surveillance at Epstein s residence and at the airport, but there was nothing to indicate that Epstein was in town. Due to conflicting appointments, rescheduled until 06/02/2005, to meet Fit)) Os•all.. I also spoke withiallIIIIIIIMand updated her to the investigation. On 06/02/2005, I met with Sand- aft advised that she could be reached via her cell phone until she is able to `provide me with: her new contact information. , I also received a message fromieS Attempted call back but the line was busy. June 14, 2005, I received information that Epstein's plane was at Jet Aviation. I spoke with Det. Lee regarding surveillance. I called the Olive Garden and asked for Haley Robson. I was advised she was not working today. This would indicate that Robson was still employed there. On 07/07/2005, I faxed subpoena requests to SA Mighdolls office for E stein, Robson and IIIISphone records. (Phone numbers and IIIIIMMINIMMIS The original subpoena requests only provided subscriber and billing information. on 07/20/2005, conducted a trash pull arranged by Ofc. Lee. Inside there were misc. papers with phone numbers and names. There were EFTA00184487
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 23 of 89 ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 22 ime: 15:01:37 Incident Report Program: CMS301L ase No 1-05-000368 (Continued) misc. female hygiene products in the trash. Based on a prior Auto Track report done on 358 El Brill() a ossible subject residing at the residence is Nada fit the description provided by officers who ha con ucted surveillance in the area of a female seen entering and leaving the residence. On 07/21/05, I received the Duces Tecum dated 07/18/05, which was clerked by ASO On 07/26/2005, I received the results of Bell South Subpoena. On 08/04/05, I received DHL Express from T mobile with the results of the query. I spoke with who confirmed thatillewas still living out of state. It appeared that all was going well. I left a message former at On 08/08/2005, I received the results of Cingular cell phone subpoena. During the week of 09/08/2005, I checked 358 El Brillo and the Palm Beach International Airport but there was no direct indication that Epstein was in town. On 09/08/2005, I reviewed the case notes of this file, as the case will be turned over to Det. Recarey. 4 On 09/11/2005, while on patrol, I conducted a check at Epstein's residence and found that it; atilljiad the hurricane shutters on. On a drive by the Palm Beach International Airport later that afternoon, I did not observe Epstein's plane. On 09/14/2005, I conducted a check at the Palm Beach International Airport but did not see Epstein s plane. On 09/19/2005, I spoke with to keep her updated and to find out if there was any change of address or phone numbers for I was told no. I left a message for at in order to provide her with Detective Recarey s information. r************************* N A R R A T I V E 42*************************** Reported By: RECAREY, JOSEPH 9/21/05 Entered By.: ALTOMARO, NICKIE A. 9/21/05 On September 19, 2005, I met with Officer Pagan and received the information pertaining to this case. Members of the Burglary Strike Force had previously been conducting surveillance on both Epstein and Robson. Officer Munyan was assigned to monitor the Epstein home and Sgt Sorge and Officer Minot were assigned to monitor Robson. Both teams provided a surveillance log that will be placed into the EFTA00184488
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 24 of 89 )ate: 7/19/06 PALM BEACH POLICE DEPARTMENT rime: 15:01:37 Page: 23 Incident Report Program: CMS301L :ase No • 1-05-000368 attachment file. (Continued) Det. Dawson was assigned to relieve Officer Munyan at 4:00 pm; he informed me that at approximately 8;00 pm, Epstein had left for the airport and his private jet was sitting on the tarmac. Epstein's private vehicle drove to the jet and unloaded packages into the jet. It appeared that Epstein left the county at this time. Surveillance will continue to determine when Epstein will return. Inv Continues. ***************************NARRATIIE # 3 *************************** A Reported By: PARK SON, GREGORY A. 9/23/05 Entered By.: ALTOMARO, NICKIE A. 9/23/05 On Friday, September 23, 2005 at approximately 1:45 p.m., I began to copy a tape micro cassette, under case number 05-368 and property number 05-243, tape number 1. I placed the tape in the telex copy-et, series 2 machine and began to go through the copying process. Approximately 1/2 through the tape, the tape wrapped around the spindle and became locked and stretched the tape. I examined it and determined that it was in the best interest to leave it as it is as a prior copy had been made and turned over to Sergeant Frick. I immediately took the tape to Sergeant Frick and allowed him to examine it and then obtained the copy from him and Detective Recarey and brought the copy of the tape down and made a copy for him based on that. The tape was placed back in the original container and is retained in the evidence bag under the previously mentioned property number of 05-243. It is not advisable to attempt to copy this tape as further damage could result to the recorded material and there is an existing copy anyway. 4,*************************NARRATIVE # 4*************************** Reported By: PARKINSON, GREGORY A. 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/26/05 On 3-24-05 at 11:00 pm, a copy of tape 2 (case number 05-294) had been made for Det. Pagan by Evidence Specialist Annette Badger. The copy was turned over to Detective Recarey. On Friday, 09-23-05 at approimately 2:15 pm, I was in the process of reproducing audio tapes (micro and standard) to standard size when it was discovered, in the test review process, that tape number 2 was blank. I notified Sgt. Frick and Det. Recarey. I was informed that they had a prior copy and I could use it to make a master tape. I did so and when reviewing and signing the evidence sheet, I noticed/ Evidence Specialist Badger had written "42 is blank." I obtained that copy from Det. Recarey and made a new copy on a standard size tape. The new copy was placed in the evidence bag under EFTA00184489
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 25 of 89 pate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 24 rime: 15:01:37 Incident Report Program: CMS301L _ase No 1-05-000368 property number 05-294 with the blank tape. (Continued) p***************************NARRATIVE # 5*************************** Reported By: RECAREY, JOSEPH 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/28/05 Copies of the tapes that were submitted into evidence were requested. Additionally, trash pulls were started on September 21, 2005. Sgt. Szarszewski made telephone contact with Tony Higgins, Supervisor of the Sanitation Department, and requested that trash be collected at the Epstein House located at 358 El Brillo in Palm Beach. Sgt Szarszewski met with Sanitation worker, Jeff Williams and observed him enter the property at 358 El Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Sgt. Szarszewski who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected the bags where several notes and papers were found. These notes contained names of girls with times. Additionally, there was a note from MOMMiftand Laura to Jeffrey Epstein on a notepad, which stated,"For a good time call - and Laura at S." Also, there was another telephone number on the note a. Also found was a written note, which stated, as can not come at 7 p.m. tomorrow because of soccer. These items were written on notepads that contain Jeffrey Epstein on the bottom of the notes. These items were placed into evidence for future follow up. I requested subpoenas for subscriber information on the telephone numbers listed above on the note. roma...Wand Laura. The cellular telephones and are both assigned to Cingular Cellular Service. Other notes were found within the trash on Jeffrey Epstein ad, papers that contained telephone numbers. One note had with written on it. This cellular number is assigned to Cingular Cellular Service. Another sheet had written which is assigned to Bell South Telecommunications. The subpoenas were picked up and submitted to Cingular and Bell South Telecommunication for subscriber information. On September 22, 2005, I was informed by Sgt. Szarszewski that there would be no trash pick up as it was recycle pick up day. A request for copies of the micro and standard size cassettes were requested from crime scene to familiarize myself with the interviews conducted. On September 23, 2005, the tapes were received and I began to become familiar with the interviews that were conducted. Det. Krauel had met with Town of Palm Beach Sanitation worker, Jeff Williams and observed him enter the property of 358 E/ Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Det. Krauel who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected EFTA00184490
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 26 of $9 %ate: 7/19/06 'ime: 15:01:37 PALM BEACH POLICE DEPARTMENT Page: 25 Incident Report Program: CMS301L !ase No • 1-05-000368 (Continued) the bags where several notes and papers were found. The notes will be inspected for future use. The items collected were placed into evidence. It became evident that some of the recordings were recorded with background noise and some interference. The calls most affected were the control phone calls from the victim to the suspect Haley Robson. I obtained the graphic equalizer and discovered that the calls are able to be legible with the use of the equalizer by lowering the background noise and increasing voice gain. I also learned that a tape was broken during the coping of the tape. I returned the copy of the tape marked Property Number 05-243 to have it recopied to have an original in evidence and a working copy with the file. Upon researching the file, it was discovered that the suspect, Haley Robson's cellular calls wer sub oenaed incorrectly. The suspect telephone number was and the original request was for . I requeste t e information through Cingular Cellular Service from February 2005 through the present. The purpose was to have a record of Robson making calls to victim, Jeffrey Epstein and the frequency of calls. Tha"request was submitted to the State Attorney's Office. Investigation Continues.... r**************************NARRATIvE Ii 6 *************************** Reported By: KRAUEL, CURTIS D. 10/06/05 Entered By.: ALTOMARO, NICKIE A. 10/06/05 On or about September 23, 2005 at approximate/? 0915 hours, I BS responded to 35B El Brillo and met with PB Sanitation worker Jeff Williams. Williams had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 4 white in color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about September 26, 2005 at approximately 0900 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jessie Jones. Jones had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Jones enter the driveway of 358 El Brillo, where no trash was located within the receptacles. I left the area without incident EFTA00184491
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 27 of 89 Nate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 26 'ime: 15:01:37 Incident Report Program: CMS301L ase No 1-05-000368 and notified Det. Recarey to that affect. (Continued) On or about September 27, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jesse Jones. I observed Jones enter the driveway of 358 El Brillo and remove one plastic bag of trash and place it in the back of an empty sanitation truck. I then followed Jones to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 1 white in color plastic bag which contained correspondence for 358 El Brillo. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Monday October 3, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 7 white in color plastic bags with a red tie and 1 black in color bag which contained 2 white in color plastic bags with a red tie. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Inside of one of the white in color bags, I located a broken piece of a hard plastic or clear acrylic stick, which was shaped with small ridges. This device is commonly used as a sexual toy which is inserted into the vagina or anus for stimulation. This item, along with all documents of evidentiary value were removed and turned over to pet. Recarey for follow-up. On or about Tuesday October 4, 2005 at approximately 0928 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the side well of the sanitation truck. This side of the truck is separate from the rear of the truck and does not come into contact with other trash. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 2 white in color plastic bags which were tied at the top. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Wednesday October 5, 2005 at approximately 0928 hours, I EFTA00184492
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 28 of 89 }ate: 7/19/06 PALM BEACH POLICE DEPARTMENT 'ime: 15:01:37 Page: 27 Incident Report Program: CMS301L 'ase No • 1-05-000368 (Continued) responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the bed of the sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents, with the assistance of Det. Recarey. There were a total of 2 bags, one of which was white in color and tied in a knot at the top, and the other was a black in color bag, which contained two white in color trash bags along with loose debris. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. t**************************NARRATIVE # 7*************************** Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 I met with Det. Krauel and requested further assistance to maintain trash collections at Epstein's residence at 358 El Brillo Road. On October 3, 2005, at approximately 10:30 am, I was contacted by Sgt. Frick to respond to the Palm Beach Police Station. Det. Krauel had observed Jeff Epstein riding his bicycle on South County Road. Upon my arrival, I met with Sgt Frick who advised, as Epstein was currently in Town; we interview Haley Robson as to her involvement with Epstein and the girls that are brought to his house. As we were to interview Robson in the county, (outside of our jurisdiction), I contacted the State Attorney s Office Investigation Division, and made contact with Assistant Supervisor Investigator Carlos Ortiz. I requested assistance to interview Robson as the interview may occur in the county. Supervisor Ortiz assigned Investigator Mike Waites to assist us at the location and interview of Robson. Det. Dicks had responded to the address of Robson and viewed her vehicle parked in the driveway. Robson's vehicle a red Plymouth Neon baring Florida Tag of H49-PKB was parked in the driveway of 12247 72nd Court in Loxahatchee. Sgt Frick and I responded to 120th Ave and awaited the arrival of Investigator Mike Waites. Upon his arrival, he was briefed that should she wish to be interviewed within her home he would be needed. However, should Robson agree to return to the police station for further questioning, he would not be needed. Sgt. Frick and I knocked on the door and met with Haley Robson. Robson was told that we were investigating a claim involving Jeffrey Epstein of El Brillo in Palm Beach. Robson was asked if she wanted to accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. She agreed and wished to change her clothes prior to accompanying us back to the police station. At the conclusion of her changing clothes, she advised she was ready to go. I thanked Inv. Waites and advised she was going to voluntarily return to the police station. EFTA00184493
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 29 of 89 Date: 7/19/06 rime: 15:01:37 PALM BEACH POLICE DEPARTMENT Page: 28 Incident Report Program: CMS30IL _ase No. . : 1-05-000368 (Continued) Upon Robson s entry in the unmarked Detective vehicle, I placed a tape recorder within the vehicle to record any conversations within the vehicle. During the ride back to the police station, Robson advised she is attending Palm Beach Community College at the Palm Beach Gardens Campus and is majoring in journalism. Upon our arrival at the police station, Robson was brought to the interview room in the Detective Bureau. I explained to Robson that I appreciated her willingness to assist us and informed her that should she desire to leave at any time she may do so. I further explained the interview room door is only closed for privacy. Robson stated she understood. During the taped sworn interview, Robson was asked how she came in contact with Epstein. Robson stated back when she turned 17 years of age she was approached by a friend Molly in the Canopy Beach Resort in Rivera Beach. Robson was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. Robson thought about the offer and agreed to meet with Jeffrey. Molly (Unknown last name) and Tony (Unknown last name) picked her up and she was taken to Epstein's house. Upon her arrival at the house, she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as Sara. She was led upstairs to the main bedroom known to her as Jeff Epstein s bedroom. Sara arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. Sara then left the room and informed her Jeff would he in a minute. Jeff entered the bedroom wearing only a towel. Re lay on the table onto his stomach and picked massage oil for Robson to rub on him. During the massage, Robson stated, He tried to touch me and I stopped him. I asked how he tried to touch her. He grabbed her buttocks and she felt uncomfortable. Robson also stated Epstein has a vibrator, which is large and white in color. Robson told Epstein, I'll massage you but I don't want to be touched. Robson stated she performed the massage naked. At the conclusion of the massage, Epstein paid Robson $200.00 for the massage. He explained, I know you re not comfortable, but I'll pay you if you bring some girls. He told her the younger the better. Robson stated she once tried to bring a 23-year-old female and Epstein stated that the female was too old. Robson was asked how many girls she brought in total to Epstein. Robson stated six that she can re er. Robson stated she brought ilea& OM. and the victim in this case. I asked Robson which one was the youngest. Robson advised the victim was the youngest. Robson stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and some touching. I asked her if the victim was aware. She stated every girl she brought knew what to expect. She explained she knew the victim wanted to make money. She approached the victim and explained about going to work for Jeff. The EFTA00184494
Case 9:08-cv-80736-KAM Document 361-34 Entered on FLSD Docket 02/10/2016 Page 30 of 89 )ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 29 rime: 15:01:37 Incident Report Program: CMS301L :ase No • 1-05-000368 (Continued) victim agreed and arrangements were made to bring the victim to Epstein's house on a weekend. Robson stated that she and (later identified as ilealeISIN picked up the victim at the victim s house They traveled to Epstein's House and entered through the kitchen door. They met with the house chef and Epstein s assistant Sara. The victim was introduced to Epstein while they were in the kitchen area. Sara led the victim upstairs and Epstein went upstairs. When the massage was over, the victim returned to the kitchen area. Robson stated she was paid $200.00 for bring the victim to Epstein's. Robson stated the victim told her she was paid $300.00 for the massage. Back in the vehicle, Robson asked the victim what happened. The victim told her about the massage and then they went shopping. Robson stated the victim was the last person she brought to Epstein. She further stated that she had changed her cellular number to avoid being contacted by Sara. She continued that when Epstein announces to his assistant that he is traveling to Palm Beach, Sara would contact Robson to arrange girls for Epstein. IIIII, later identified as Date of Birth 05-25-1979,Hadtold Robson that Je a es o ave his fun with the girls. Robson stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. Robson further stated that Sara still tries to call the house and leaves messages. With the assistance of Robson, we were able to identify DOEIMMMONS SallaDOBalealla a DOB SIMIS, and allab DOB_ Sgt Frick entered the room and explained that based on her own statements, she had implicated herself with bringing underage girls to Epstein's house. Robson was aware of what she had stated and wished „to assist further in hopes to receive a lesser charge. Robson provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As Robson was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, Robson made the comment i m like a Heidi Fliess. (Hollywood Madam who sent girls to clients for sexual favors in California). Robson was dropped off at her house without incident. Sgt Frick and I went toSelliallnall in Slat Florida in an attem t to speak within. We met" with Mrs. a Mother) at the front door. We explained the ongoing investigation and felt that Oa may have additional information as we had information that she had worked for Jeff. Mrs. introduced us to her husband and allowed us entry into the home. We sat in t e inning room and met with Date of Birth As she was under thelTrr!!!!!!!!!Mrs. IMUMMIllbpwas advised we would be speaking with her. She expressed, if her daughter had information she wanted to assist. As we interviewed she denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff s EFTA00184495





















































