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F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 the PBPD during its investigation into Epstein 2s conduct Absent information from the USAO the state would not have been in a position to notify those additional victims of the state plea proceeding even if the State Attorney had decided to include other victims identified during the state investigation Furthermore at the time he made his decision Acosta had already been advised by Villafana that Belohlavek in November had requested that the USAO notify victims presumably those identified during the federal-investigation about the state plea hearing Acosta told OPR that it had been his understanding at the time of Epstein 2s plea that the victims would be made aware of the proceeding and would have an opportunity to speak Acosta also told OPR that he expected the state would have 223notified the victims that was an all encompassing plea that the state court sentence would also mean that the federal government was not proceeding There is no evidence however that he verified this understanding with Sloman or Villafana let alone the State Attorney OPR found no indication that Acosta ever communicated or directed Sloman or Villafana to communicate his decision to the State Attorney or to provide the State Attorney 2s Office with a complete list of victims identified during the federal investigation OPR located a draft letter to the State Attorney 2s Office that Villafana prepared and forwarded to Acosta in December which did provide such information but OPR found no evidence that the letter was ever sent and it was not among materials publicly released from the State Attorney 2s Office.424 OPR also found evidence that both Sloman and Villafana interacted with the State Attorney 2s Office in the months leading up to the June plea hearing but there is no indication that they discussed victim notification issues with that office and Villafana 2s last minute request to PBPD Chief Reiter to notify victims indicates that the USAO had not coordinated with the State Attorney 2s Office Belohlavek told OPR that no one from the USAO provided her with a list of victims or coordinated any notification of victims to appear at the hearing Krischer and Belohlavek were thus evidently unaware that Acosta had decided to leave it to them to decide whether to notify victims about the state proceeding In the absence of some discussion of which or how many victims the state intended to notify what the state intended to tell them about Epstein 2s plea and whether the state intended to let the victims speak at the plea hearing Acosta had no way to ensure that his assumption about victim notification was accurate In other words Acosta failed to plan for how all of the identified victims of Epstein 2s crimes both federal and state 223would be aware of what was happening in the state court and have an opportunity to speak up at the state court hearing OPR not find evidence that Acosta acted for the purpose of excluding victims from the plea hearing and Acosta 2s assumption that the state would handle victim notification appropriately was not unsupported State prosecutors are subject to victim notification requirements under the Florida Constitution and the state prosecution offices have victim witness personnel resources and processes to help accomplish notification However Acosta was aware 227through the prosecution memoranda the draft indictment and email communications from Villafana 227that the USAO 2s investigation had expanded beyond those victims identified in the original PBPD The text of the letter indicated that Epstein 2s attorneys asked the USAO not to inform victims of 223any rights they may have as victims of the charges filed by the State Attorney 2s Office and that the USAO was providing Ilie State Attorney 2s Office with a list of the identified federal victims case you are required to provide them with any further notification regarding their rights under Florida law i I CA/Aronberg-0738 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM the PBPD during its investigation into Epsteins conduct Absent information from the USAO the state would not have been in a position to notify those additional victims of the state plea proceeding even if the State Attorney had decided to include other victim identified during the state investigation Furthermore at the time he made his decision Acosta had already been advised by Villafana that Belohlavek in November had requested that the USAO notify victims presumably those identified during the federal-investigation about the state plea hearing Acosta told OPR that it had been his understanding at the time of Epsteins plea that the victims would be made aware of the proceeding and would have an opportunity to speak Acosta also told OPR that he expected the state would have notified the victims that that was an all encompassing plea that the state court sentence would also mean that the federal government was not proceeding There is no evidence however that he verified this understanding with Sloman or Villafana let alone the State Attorney OPR found no indication that Acosta ever communicated or directed Sloman or Villafana to communicate his decision to the State Attorney or to provide the State Attorneys Office with a complete list of victims identified during the federal investigation OPR located a draft letter to the State Attorneys Office that Villafana prepared and forwarded to Acosta in December which did provide such information but OPR found no evidence that the letter was ever sent and it was not among materials publicly released from the State Attorneys Office OPR also found evidence that both Sloman and Villafana interacted with the State Attorneys Office in the months leading up to the June plea hearing but there is no indication that they discussed victim notification issues with that office and Villafanas last minute request to PBPD Chief Reiter to notify victims indicates that the USAO had not coordinated with the State Attorneys Office Belohlavek told OPR that no one from the USAO provided her with a list of victims or coordinated any notification of victims to appear at the hearing Krischer and Belohlavek were thus evidently unaware that Acosta had decided to leave it to them to decide whether to notify victims about the state proceeding In the absence of some discussion of which or how many victims the state intended to notify what the state intended to tell them about Epsteins plea and whether the state intended to let the victims speak at the plea hearing Acosta had no way to ensure that his assumption about victim notification was accurate In other words Acosta failed to plan for how all of the identified victims of Epsteins crimes both federal and state would be aware of what was happening in the state court and have an opportunity to speak up at the state court hearing OPR did not find evidence that Acosta acted for the purpose of excluding victims from the plea hearing and Acostas assumption that the state would handle victim notification appropriately was not unsupported State prosecutors are subject to victim notification requirements under the Florida Constitution and the state prosecution offices have victim witness personnel resources and processes to help accomplish notification However Acosta was aware-through the prosecution memoranda the draft indictment and email communications frdm Villafana-that the USAOs investigation had expanded beyond those victims identified in the original PBPD The te of the letter indicated that Epsteins attorneys asked the USAO not to infonn victims of"any rights they may have as victims of the charges filed by the State Attorneys Office and that the;usAO was providing U1e State Attorneys Office wiU1 a list of the identified federal victims in case you are required to provide U1em wiU1 any further notification regarding their rights under Florida law I CA/Aronberg-0738 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM investigation Because the state indictment and information appeared to pertain to far fewer than the total victims identified in either the state or the federal investigation and no one at the USAO was certain which victims were covered by the state charges it should have been apparent to Acosta that without advance planning between the USAO and the State Attorney 2s Office there was a substantial risk that most of the victims identified in the federal investigation would not receive notice of the hearing.425 Notification to the broadest possible number of identified victims could only have been successful if there was appropriate communication between the USAO and the state prosecutors communication that had previously been lacking regarding other significant issues relating to Epstein Villafana and Sloman 2s hastily arranged effort to enlist in the notification process PBPD Chief Reiter who likely played little role in complying with the state 2s victim notification obligations in a typical case was not an adequate substitute for careful planning and coordination with the State Attorney 2s Office.426 Even if the State Attorney 2s Office had notified all of the identified victims of the upcoming plea hearing there was no guarantee that such notification would have included information that the state plea was resolving not just the state 2s investigation of Epstein but the federal investigation as well The State Attorney was not obligated by state statutes to inform the victims of the status of the federal investigation and there was little reason to assume Krischer or one of his staff would voluntarily do so thereby putting the State Attorney 2s Office in the position of fielding victim questions and concerns about the outcome Furthermore as both the USAO and the defense had differing views as to who could lawfully participate in state plea hearing there is no indication that Acosta Sloman or Villafana took steps to confirm that if victims appeared they could actually participate in the state court proceeding when they were not victims of the charged crimes Through counsel Acosta asserted to OPR that because Villafana and Sloman both told OPR that they believed that state officials would notify the victims 223OPR identified no reason why Secretary Acosta should have distrusted his team on these points Acosta 2s counsel further Krischer told OPR that the state 2s notification obligation extended to all victims identified in tire state investigation Nonetheless which victims were encompassed in the state 2s investigation was unclear The PBPD 2s probable cause affidavit included crimes against only victims not the identified in the state investigation According to state records made public the state subpoenaed to the grand jury only victims After Epstein 2s guilty plea the state sent notification letters to only victims Belohlavek told OPR that because of the nature of the charges she did not know whether 223technically under the law the girls were 223victims she was required to notify of the plea hearing The State Attorney 2s Office liad its own procedures and employees who handled victim notification and Belohlavek told OPR that the Chief of the Police Department would not regularly play a role in the state victim notification process Although Villafaiia 2s notes indicate that she researched Florida Statutes and when she drafted unsent letters to victims in November and December inviting them to participate in the state plea hearing pursuant to those statues the caselaw was not clear that all federal victims would liavc been allowed to participate in state plea hearing In Lefkowitz 2s November letter to Acosta he argued tliat Ilie statutes afforded a right to speak at a defendant 2s sentencing or to submit a statement only to the victims of the crime for which the defendant was being sentenced In April a Florida District Court of Appeal ruled against a defendant who argued that Florida Statute not allow the testimony of the victim 2s relatives at the sentencing hearing The court ruled that 223should not be read as limiting the testimony Rule allows trial courts to consider at sentencing hearings Smith State So 2d Fla Dist Ct App I CA/Aronberg-0739 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I investigation Because the state indictment and information appeared to pehain to far fewer than I the total victims identified in either the state or the federal investigation and no one at the USAO was certain which victims were covered by the state charges it should ve been apparent to Acosta that without advance planning between the USAO and the State Attorneys Office there was a substantial risk that most of the victims identified in the federal in estigation would not receive notice of the hearing Notification to the broadest possible number of identified victims could only have been successful if there was appropriate communication between the USAO and the state prosecutors communication that had previously been lacking regarding other significant issues relating to Epstein Villafana and Slomans hastily arranged effort to enlist in the notification process PBPD Chief Reiter who likely played little role in complying with the states victim notification obligations in a typical case was not an adequate substitute for careful planning and coordination with the State Attorneys Office Even if the State Attorneys Office had notified all of the identified victims of the upcoming plea hearing there was no guarantee that such notification would have included information that the state plea was resolving not just the states investigation of Epstein but the federal investigation as well The State Attorney was not obligated by state statutes to inform the victims of the status of the federal investigation and there was little reason to assume Krischer or one of his staff would voluntarily do so thereby putting the State Attorneys Office in the position of fielding victim questions and concerns about the outcome Furthermore as both the USAO and the defense had differing views as to who could lawfully participate in the state plea hearing there is no indication that Acosta Sloman or Villafana took steps to confirm that if victims appeared they could actually participate in the state court proceeding when they were not victims of the charged crimes Through counsel Acosta asserted to OPR that because Villafana and Sloman both told OPR that they believed that state officials would notify the victims OPR identified no reason why Secretary Acosta should have distrusted his team on these points Acostas counsel further Krischer told OPR that the states notification obligation iended to all victims identified in the state im,estigation Nonetheless which victims were encompassed in the states investigation was unclear The PBPDs probable cause affidavit included crimes against only victims not the identified in the state investigation According to state records made public the state subpoenaed to the grand jury only victims After Epsteins guilty plea the state sent notification letters to only victims Belohlavek told OPR that because of the nature of the charges she did not know whether technically under the law the girls were victims she was required to notify of the plea hearing The State Attorneys Office had its own procedures and employees who handled victim notification and Belohlavek told OPR that the Chief of the Police Department would not regularly play a role in the state victim notification process Although Villafafias notes indicate that she researched Florida Statutes and when she drafted unsent lcllcrs to victims in November and December inviting them to participate in the state pica hearing pursuant to t11osc statues t11c casclaw was not clear tliat all federal victims would liavc been allowed to participate in the state plea hearing In Lefkowitzs November leller to Acosta he argued that t11e statutes afforded a right to speak at a defendants sentencing or to submit a statement only to the victims of the cri1ne for which t11e defendant was being sentenced In April a Florida District Court of Appeal ruled against a defendant who argued that Florida Statute did not allow t11e testimony of the victims relatives at t11e sentencing hearing The court ruled t11at should not be read as limiting the testimony Rule allows trial courts to consider at sentencing hearings Smith State So 2d Fla Dist Ct App CNAronberg-0739 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM argued that Acosta should been able to rely on his staff to accomplish the victim notification task and thus had no responsibility to personally confirm that Chief Reiter would notify the victims of the hearing.428 Acosta is correct that under usual circumstances USAO management played no role in the victim notification process however in this case the issue of victim notification had been elevated from a rote administrative task to a major area of dispute with the defense Acosta personally involved himself by resolving the notification dispute with defense counsel in his December letter Villafafia provided Acosta with a draft letter to state officials that would have opened a dialogue concerning the notification of all the victims identified in the federal investigation OPR found no evidence however that Acosta sent the letter or any similar communication to the State Attorney 2s Office or that he provided Villafafia and Sloman with instructions concerning victim notification other than those contained in his December letter Having inserted himself into the notification process Acosta had a responsibility to ensure that his expectation that the victims would be notified could be accomplished through the state process Many victims only learned of Epstein 2s state court pleas when they later received a letter from the USAO informing that those pleas had resolved the federal investigation and some victims only learned of the state court pleas and sentencing from the news media In the end although Villafafia and Sloman hastily attempted to ensure victim notification through Chief Reiter their effort was too little and too late to ensure that victims had the opportunity to attend the plea hearing or were given sufficient information about its significance to their own cases.429 Although Acosta may have conferred with others about the decision to defer the responsibility for notifying victims to the State Attorney Acosta was responsible for choosing this course of action OPR concludes that under these unique circumstances its criticisms are warranted because Acosta personally decided to change the process initiated by his staff and although he expected that the federal victims would be notified he did not take the necessary steps to ensure that they would be Acosta could have authorized disclosure of the plea hearing to victims even if he did not believe the CVRA required it to ensure that the victims identified in the federal investigation were aware of the state court proceeding Because the state pleas ended the federal investigation into Epstein 2s conduct ensuring that the victims were notified of the state plea hearing would have been consistent with the Department 2s overarching commitment to treat victims with fairness dignity and sensitivity Acosta 2s failure to prioritize notification and coordinate communication about the As noted in his comments on OPR 2s draft report Acosta 2s counsel strongly objected to OPR 2s finding of poor judgment with respect to victim notification arguing that OPR 223unwarranted applies a standard never before expected of any US Attorney and inappropriately criticizes Acosta for 223not personally confirming that the State Attorney had the information needed to notify the victims and for 223not personally confirming that Chief Reiter liad actually notified the victims For the reasons discussed the issue is not whether Acosta 223personally took certain specific steps but that he stopped Iris staff from implementing a notification plan they had devised and instead shifted responsibility for notification to another entity while failing to consider how or even whether that entity would be able to accomplish the notification that Acosta expected to happen OPR notes that Villafafia contacted Reiter soon after the state plea hearing was scheduled and the resulting window of time for Reiter to make any notifications was short Had the USAO coordinated with the State Attorney at some point in time closer to Acosta 2s December letter and decision the USAO could have ensured that the State Attorney had an appropriate notification process in place to act quickly when the hearing was scheduled and tliat issues concerning the victims appearance at the hearing were appropriately considered by state authorities Similarly if the USAO believed that Reiter should make the notifications it could have coordinated with Reiter in the months tliat the matter was under review by the Department CA/Aronberg-0740 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM argued that Acosta should have been able to rely on his staff to accomplish the victim notification task and thus had no responsibility to personally confirm that Chief Reher would notify the victims of the hearing Acosta is correct that under usual circumstances USAO management played no role in the victim notification process however in this case the issue of victim notification had been elevated from a rote administrative task to a major area of dispute with the defense Acosta personally involved himself by resolving the notification dispute with defense counsel in his December letter Villafana provided Acosta with a draft letter to state officials that would have opened a dialogue concerning the notification of all the victims identified in the federal investigation OPR found no evidence however that Acosta sent the letter or any similar communication to the State Attorneys Office or that he provided Villafana and Sloman with instructions concerning victim notification other than those contained in his December letter Having inserted himself into the notification process Acosta had a responsibility to ensure that his expectation that the victims would be notified could be accomplished through the state process Many victims only learned of Epsteins state court pleas when they later received a letter from the USAO informing them that those pleas had resolved the federal investigation and some victims only learned of the state court pleas and sentencing from the news media In the end although Villafana and Sloman hastily attempted to ensure victim notification through Chief Reiter their effort was too little and too late to ensure that victims had the opportunity to attend the plea hearing or were given sufficient information about its significance to their own cases Although Acosta may have conferred with others about the decision to defer the responsibility for notifying victims to the State Attorney Acosta was responsible for choosing this course of action OPR concludes that under these unique circumstances its criticisms are warranted because Acosta personally decided to change the process initiated by his staff and although he expected that the federal victims would be notified he did not take the necessary steps to ensure that they would be Acosta could have authorized disclosure of the plea hearing to victims even if he did not believe the CVRA required it to ensure that the victims identified in the federal investigation were aware of the state court proceeding Because the state pleas ended the federal investigation into Epsteins conduct ensuring that the victims were notified of the state plea hearing would have been consistent with the Departments overarching commitment to treat victims with fairness dignity and sensitivity Acostas failure to prioritize notification and coordinate communication about the As noted in his conunents on OPRs draft report Acostas counsel strongly objected to OPRs finding of poor judgment with respect to victim notification arguing that OPR unwarrantedly applies a standard never before expected of any US Attorney and inappropriately criticizes Acosta for not personally confirming that the State Attorney had the information needed to notify the victims and for not personally confirming that Chief Reiter had actually notified the victims For the reasons discussed the issue is not whether Acosta personally took certain specific steps but that he stopped his staff from implementing a notification plan they had devised and instead shifted responsibility for notification to another entity while failing to consider how or even whether that entity would be able to accomplish the notification that Acosta ex-peeled to happen OPR notes that Villafana contacted Reiter soon after the stale pica hearing was scheduled and the resulting window of time for Reiter to make any notifications was short Had the USAO coordinated with the State Attorney at some point in time closer to Acostas December letter and decision the USA9 could have ensured that the State Attorney had an appropriate notification process in place to act quickly when the hearing was scheduled and that issues concerning the victims appearance at the hearing were appropriately considered by slate authorities Similarly if the USAO believed that Reiter should make the notifications it could have cocirdinated with Reiter in the months tl the matter was under review by the Department CA/Aronberg-0740 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I resolution of the case to ensure Epstein 2s victims were given an opportunity to attend the plea hearing and to possibly speak about the impact of Epstein 2s crimes presented a glaring contrast with Acosta 2s responsiveness to the demands of Epstein 2s attorneys which included the unusual courtesy of allowing them to preview and respond to the USAO 2s draft victim notifications This contrast added to the victims perception that they had been treated unfairly a view shared by the public Nothing in the documentary record suggests that Acosta thought through the issue of determining which victims would be notified by the state or that he took any steps to ensure that all of the known federal victims received information about state plea hearing Instead as with his decision to resolve the federal investigation through a state-based resolution Acosta exercised poor judgment when he made critical decisions affecting the federal investigation and the victims but also failed to consider the full consequences of those decisions or what was needed to implement them Acosta 2s failure to consider these issues before simply leaving the responsibility for making notifications entirely to the State Attorney 2s discretion reflected poorly on the USAO and the Department as a whole It left victims in the dark about an important proceeding that resolved the federal investigation an investigation about which the USAO had communicated with victims for months It also ultimately created the misimpression that the Department intentionally sought to silence the victims by keeping them uninformed about the NPA and the resulting state proceeding Acosta failed to ensure that victims were afforded an opportunity to attend a hearing that was related to their own cases and thus failed to ensure that victims were treated with forthrightness and dignity VILLAFANA DID NOT COMMIT PROFESSIONAL MISCONDUCT IN HER ORAL COMMUNICATIONS TO VICTIMS AND VICTIMS ATTORNEYS IN WHICH SHE DESCRIBED THE CASE AS 223UNDER INVESTIGATION BUT DID NOT DISCLOSE THE EXISTENCE OF THE NPA TO SOME VICTIMS From September when the NPA was signed until after Epstein 2s June state court plea the case agents acting under Villafana 2s direction directly informed only three victims-that the government had signed an NPA and that if Epstein complied with its terms the federal investigation would be closed During this time period Villafana and the case agents interacted with several victims and their attorneys and Villafana contacted victims attorney Bradley Edwards to encourage him to attend state court plea hearing but she did not inform victims or Edwards of the NPA or the resolution of the federal investigation As described in Part One of this chapter after the NPA was signed the FBI case agent and co-case agent began notifying victims about the After speaking to three victims however the FBI case agent became concerned that informing the victims about the NPA and the monetary damages provision would create potential impeachment material for the victims and the agent should Epstein breach the NPA and the case proceed to indictment and trial As the case agent told OPR would have to testify that I told every one of these girls that they could sue Mr Epstein for money and I was not comfortable with that I didn 2t think it was right The case Although Wild disputed that she was informed of the resolution of the federal case the case agent 2s email to Villafana from this time period reflects tliat at least one victim understood dial the federal case was resolved and tliat she was unhappy with the resolution i I CA/Aronberg-0741 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM resolution of the case to ensure Epsteins victims were given an opportunity to attend the plea hearing and to possibly speak about the impact of Epsteins crimes prese ted a glaring contrast with Acostas responsiveness to the demands of Epsteins attorneys whichlincluded the unusual courtesy of allowing them to preview and respond to the USAO draft victim notifications This contrast added to the victims perception that they had been treated unfairly a view shared by the public Nothing in the documentary record suggests that Acosta thought through the issue of determining which victims would be notified by the state or that he took any steps to ensure that all of the known federal victims received information about the state plea hearing Instead as with his decision to resolve the federal investigation through a state-based resolution Acosta exercised poor judgment when he made critical decisions affecting the federal investigation and the victims but also failed to consider the full consequences of those decisions or what was needed to implement them Acostas failure to consider these issues before simply leaving the responsibility for making notifications entirely to the State Attorneys discretion reflected poorly on the USAO and the Department as a whole It left victims in the dark about an important proceeding that resolved the federal investigation an investigation about which the USAO had communicated with victims for months It also ultimately created the misimpression that the Department intentionally sought to silence the victims by keeping them uninformed about the NP A and the resulting state proceeding Acosta failed to ensure that victims were afforded an opportunity to attend a hearing that was related to their own cases and thus failed to ensure that victims were treated with forthrightness and dignity VILLAFANA DID NOT COMMIT PROFESSIONAL MISCONDUCT IN HER ORAL COMMUNICATIONS TO VICTThfS AND VICTThfS ATTORNEYS IN WHICH SHE DESCRIBED THE CASE AS UNDER INVESTIGATION BUT DID NOT DISCLOSE THE EXISTENCE OF THE NPA TO SOME VICTThfS From September when the NPA was signed until after Epsteins June state court plea the case agents acting under Villafanas direction directly informed only three victims-that the government had signed an NPA and that if Epstein complied with its terms the federal investigation would be closed During this time period Villafana and the case agents interacted with several victims and their attorneys and Villafana contacted victims attorney Bradley Edwards to encourage him to attend the state court plea hearing but she did not inform victims or Edwards of the NPA or the resolution of the federal investigation I As described in Part One of this chapter after the NP A was signed the FBI case agent and co-case agent began notifying victims about the NP A After speaking to three victims however the FBI case agent became concerned that informing the victims about the NP A and the monetary damages provision would create potential impeachment material for the victims and the agent should Epstein breach the NP A and the case proceed to indictment and trial As the case agent told OPR I would have to testify that I told every one of these girls that they could sue Mr Epstein for money and I was not comfortable with that I didnt think it was right The case Although Wild disputed that she was infonned of the resolution of the federal case the case agents email to Villafana from this time period reflects that at least one victim understood that the federal base was resolved and that she was unhappy wit11 the resolution I I I CA/Aronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM agent and Villafana consulted with the USAO 2s Professional Responsibility Officer about the matter and thereafter stopped notifying the victims about the NPA and their ability to pursue monetary damages according to its terms Villafana advised Sloman by email of her concerns regarding the potential impeachment evidence telling him 223One thing I am concerned about is that if we file charges now cross examination will consist of 221and the government told you that if Mr Epstein is convicted you are entitled to a large amount of damages right Explaining the decision in her later CVRA declaration Villafana said that after Epstein 2s attorneys 223complained that the victims were receiving an incentive to overstate their involvement with Mr Epstein in order to increase their damages claims she 223concluded that informing additional victims could compromise the witnesses credibility at trial if Epstein reneged on the agreement Acosta was aware of these concerns as he referred to them in an August email also believed that contacting the victims would compromise them as potential witnesses Epstein argued very forcefully that they were doing this for the money and we did not want to discuss liability with them which was a key part of the agreement The case agents interviewed victims in October and November but did not inform them about the On January the FBI agents Villafana and the CEOS Trial Attorney interviewed three victims including Courtney Wild and they interviewed at least one more victim the next Wild and two others had been contacted by the FBI in the fall of and may have been informed about the resolution of the federal investigation Villafana told OPR that during the January interviews she did not specifically tell the victims that 223there was a signed non-prosecution agreement that had these terms She stated that she would not use 223terminology such as 223NPA because 223most people don 2t understand what that means Instead with respect to the three victims who according to Villafana had been informed by the FBI about the resolution she stated that agreement had been reached where Epstein was going to be entering a guilty plea but it doesn 2t look like he intends to actually perform and now it looks like this may have to be charged and may have to go to trial Villafana recalled telling some victims that Epstein 223was supposed to enter a plea in state court that would end the investigation but she did not recall distinguishing between the 223federal investigation versus a state investigation Villafana told OPR she explained 223the case was under investigation she and the agents 223were preparing again to file charges and they hoped 223that charges would be brought An email from Villafana to Sloman and Acosta during this time period reflects that she had such discussions with at least one victim interviewed on this date 223The second girl was very upset about the month deal she had read about in the paper She would rather not get any money and have Epstein spend a significant time in jail Villafana however did not recall telling all of the victims interviewed at this time of the state plea rather she likely only told those who knew about the resolution from the FBI In her own CVRA case declaration Wild stated that she 223was not told about any NPA or any potential resolution of FBI agents also interviewed victims in March and May of without prosecutors and did not inform the victims of the NPA Two additional victims were scheduled to be interviewed on February but the evidence is unclear as to whether the interviews occurred CA/Aronberg-0742 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I agent and Villafana consulted with the USAOs Professional Responsibility Officer about the matter and thereafter stopped notifying the victims about the NP A and eir ability to pursue monetary damages according to its terms Villafana advised Sloman by email of her concerns regarding the potential impeachment evidence telling him One thing I am concerned about is that if we file charges now cross examination will consist of and the government told you that if Mr Epstein is convicted you are entitled to a large amount of damages right Explaining the decision in her later CVRA declaration Villafana said that after Epsteins attorneys complained that the victims were receiving an incentive to overstate their involvement with Mr Epstein in order to increase their damages claims she concluded that informing additional victims could compromise the witnesses credibility at trial if Epstein reneged on the agreement Acosta was aware of these concerns as he referred to them in an August email We also believed that contacting the victims would compromise them as potential witnesses Epstein argued very forcefully that they were doing this for the money and we did not want to discuss liability with them which was a key part of the agreement The case agents interviewed victims in October and November but did not inform them about the NPA On January the FBI agents Villafana and the CEOS Trial Attorney interviewed three victims including Courtney Wild and they interviewed at least one more victim the next day Wild and two others had been contacted by the FBI in the fall of and may have been informed about the resolution of the federal investigation Villafana told OPR that during the January interviews she did not specifically tell the victims that there was a signed non-prosecution agreement that had these terms She stated that she would not use terminology such as NP A because most people dont understand what that means Instead with respect to the three victims who according to Villafana had been informed by the FBI about the resolution she stated that an agreement had been reached where Epstein was going to be entering a guilty plea but it doesnt look like he intends to actually perform and now it looks like this may have to be charged and may have to go to trial Villafana recalled telling some victims that Epstein was supposed to enter a plea in state court that would end the investigation but she did not recall distinguishing between the federal investigation versus a state investigation Villafana told OPR she explained the case was under investigation she and the agents were preparing again to file charges and they hoped that charges would be brought An email from Villafana to Sloman and Acosta during this time period reflects that she had such discussions with at least one victim interviewed on this date The second girl was very upset about the month deal she had read about in the paper She would rather not get any money and have Epstein spend a significant time in jail Villafana however did not recall telling all of the victims interviewed at this time of the state plea rather she likely only told those who knew about the resolution from the FBI In her own CVRA case declaration Wild stated that she was not told about any NP A or any potential resolution of FBI agents also interviewed victims in March and May of without prosecutors and did not inform the victims of the NP A I Two additional victims were scheduled to be interviewed on February but the evidence is unclear as I to whether the interviews occurred CA/Aronberg-0742 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM the federal investigation I was cooperating in If I had been told of an NPA I would have objected Wild further stated in her declaration that 223Based on what the FBI had been telling me I thought they were still investigating my case Neither the CEOS Trial Attorney nor the FBI case agent recalled the specifics of the victim interviews The FBI reports memorializing each interview primarily addressed the facts elicited from the victim regarding Epstein 2s abuse and not describe any discussion about the status of the case or the victim 2s view about the prosecution of Epstein.433 When asked whether she was concerned that failing to tell victims about the NPA when she was interviewing them would mislead victims as previously noted Villafana told OPR that she believed she and the agents were conducting an investigation because they continued 223interviewing witnesses and 223doing all these things to file charges and prepare for a federal trial As Villafana stated to me saying to a victim the case is now back under investigation is perfectly accurate Villafana was also aware that some victims were represented by counsel in connection with civil lawsuits against Epstein but did not proactively inform the victims attorneys about the NPA In a affidavit filed in the CVRA litigation victims attorney Bradley Edwards alleged that during telephone calls with Villafana he 223asked very specific questions about what stage the investigation was in and Villafana replied that she could not answer his questions because the matter 223was an on-going active investigation Edwards stated that Villafana gave him 223the impression that the Federal investigation was on-going very expansive and continuously growing both in the number of identified victims and complexity Edwards also stated fair characterization of each call was that I provided information and asked questions and Villafana listened and expressed that she was unable to say much or answer the questions I was asking In her written response to OPR Villafana stated that she 223listened more than she spoke during her interactions with Edwards and that due to the 223uncertainty of the situation and the possibility of a trial she 223did not feel comfortable sharing any information about the case Villafana also told OPR that because of 223all of these concerns and instructions that I had been given by Alex Acosta and Jeff Sloman not to disclose things further and not to have any involvement in victim notification felt 223prohibited from providing additional information to Edwards Sloman told OPR that although neither the NPA terms nor the CVRA prevented the USAO from exercising its discretion to notify the victims was of concern that this was going to break down and result in us prosecuting Epstein and that the victims were going to be witnesses and if we provided a victim notification indicating hey you 2re going to get that 2s going to be instant impeachment for the defense Acosta told OPR that because Epstein did As noted above the FBI agent 2s notes for one victim 2s interview reported that she wanted another victim to be prosecuted When asked why the USAO did not simply notify the victims of the change of plea hearing Sloman responded that he 223was more focused on the restitution provisions I didn 2t get the sense that Ilie victims were overly interested in showing up at the change of plea CA/Aronberg-0743 I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I the federal investigation I was cooperating in If I had been told of an INPA I would have objected Wild further stated in her declaration that Based on what the FBI had been telling me I thought they were still investigating my case I Neither the CEOS Trial Attorney nor the FBI case agent recalled the specifics of the victim interviews The FBI reports memorializing each interview primarily addressed the facts elicited from the victim regarding Epsteins abuse and did not describe any discussion about the status of the case or the victims view about the prosecution of Epstein When asked whether she was concerned that failing to tell victims about the NP A when she was interviewing them would mislead victims as previously noted Villafana told OPR that she believed she and the agents were conducting an investigation because they continued interviewing witnesses and doing all these things to file charges and prepare for a federal trial As Villafana stated So to me saying to a victim the case is now back under investigation is perfectly accurate Villafana was also aware that some victims were represented by coun,sel in connection with civil lawsuits against Epstein but did not proactively inform the victims attorneys about the NP A In a affidavit filed in the CVRA litigation victims attorney Bradley Edwards alleged that during telephone calls with Villafana he asked very specific questions about what stage the investigation was in and Villafana replied that she could not answer his questions because the matter was an on-going active investigation Edwards stated that Villafana gave him the impression that the Federal investigation was on-going very expansive and continuously growing both in the number of identified victims and complexity Edwards also stated A fair characterization of each call was that I provided information and asked questions and Villafana listened and expressed that she was unable to say much or answer the questions I was asking In her written response to OPR Villafana stated that she listened more than she spoke during her interactions with Edwards and that due to the uncertainty of the situation and the possibility of a trial she did not feel comfortable sharing any information about the case Villafana also told OPR that because of all of these concerns and instructions that I had been given by Alex Acosta and Jeff Sloman not to disclose things further:and not to have any involvement in victim notification she felt prohibited from providing additional information I to Edwards Sloman told OPR that although neither the NP A terms nor the CVRA prevented the USAO from exercising its discretion to notify the victims It was of concern that this was going to break down and result in us prosecuting Epstein and that the victims were going to be witnesses and ifwe provided a victim notification indicating hey youre going to get thats going to be instant impeachment for the defense Acosta told OPR that because Epstein did As noted above the FBI agents notes for one victims interview reported that she wanted another victim to be prosecuted When asked why the USAO did not simply notify the victims of the change of plea hearing Sloman responded that he was more focused on the restitution provisions I didnt gel the sense that the victims were overly interested in showing up at the change of plea I I I CN Aronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM not plead guilty in October as the USAO expected it was a 223very open question whether the case would go to trial and Acosta thought that 223where there is no legal requirement there has to be discretion to judge how much you can tell the victims and when Epstein 2s attorneys conduct during the period between the signing of the NPA and Epstein 2s entry of his state guilty pleas illustrated the risk that Acosta Sloman and Villafana all identified As Epstein 2s counsel deposed victims related to state court criminal charges and civil cases against Epstein counsel suggested that the victims were motivated to testify against Epstein by the government 2s promises of financial gain For example during a February state deposition of a victim defense counsel asked her whether the federal prosecutors or FBI agents told her that she was entitled to receive money from Epstein.435 In her declaration in the CVRA litigation Villafana identified that line of questioning as a motivating factor in the government 2s decision to stop notifying the victims about the potential for U.S.C recovery On June the Friday before Epstein 2s Monday June state court guilty plea hearing Villafana contacted Edwards to inform him about that upcoming hearing Villafana told OPR she 223was not given authorization to contact any victim 2s attorney other than Edwards about the scheduled state plea hearing.436 In his affidavit prepared for the CVRA litigation Edwards stated that Villafana 223gave the impression that she was caught off-guard herself that Epstein was pleading guilty or that this event was happening at all Edwards said in a court filing that Villafana told him only that 223Epstein was pleading guilty to state solicitation of prostitution charges involving other victims 227not Mr Edward 2s clients nor any of the victims Villafana stated in her declaration that she 223never told Attorney Edwards that state charges involved 221other victims and neither the state court charging instrument nor the factual proffer limited the procurement of prostitution charge to a specific victim Villafana told OPR she 223strongly encouraged Edwards and his clients to attend the plea hearing but 223could not be more explicit because she was not 223authorized by the Office to disclose the terms of the NPA In his affidavit Edwards acknowledged that 223Villafana did express that this hearing was important but never told me why she felt that way Edwards claimed that Villafana 2s failure to inform him that the 223guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement resulted in his clients not attending the hearing Edwards himself was out of town and not able to As previously noted the defense used Florida criminal procedure to depose potential federal victims to learn information concerning the federal investigation even though those individuals were not involved in the state prosecution For example in a March email Villafana informed her managers tliat she spoke to a victim who had received a subpoena 223issued in connection with the state criminal case which as you know doesn 2t involve most of the victims in our case including the girl who was subpoenaed Villafana further observed that because Epstein is 223going to plead to the solicitation of adults for prostitution charge in state court the act of subpoenaing the victim seems to be a clear effort to find out about our case through state case Villafana 2s June handwritten notes reflect tliat at the time of Epstein 2s state court guilty plea Villafana was aware of the identities of a least five oilier attorneys representing EpsteinS victims In her written response to OPR Villafana stated requested permission to make oral notifications tojthe victims regarding the upcoming change of plea but the Office decided dial victim notification could only come from a state investigator and Jeff Sloman asked PBPD Cliief Reiter to assist On Saturday June Villafanajemailed Sloman to inform him tliat PBPD Cliief Reiter going to notify victims about the plea Sloman replied 223Good CA/Aronberg-0744 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM not plead guilty in October as the USAO expected it was a very open question whether the case would go to trial and Acosta thought that where there is no legal equirement there has to be discretion to judge how much you can tell the victims and when I Epsteins attorneys conduct during the period between the signing of the NPA and Epsteins entry of his state guilty pleas illustrated the risk that Acosta Sloman and Villafana all identified As Epsteins counsel deposed victims related to the state court criminal charges and civil cases against Epstein counsel suggested that the victims were motivated to testify against Epstein by the governments promises of financial gain For example during a February state deposition of a victim defense counsel asked her whether the federal prosecutors or FBI agents told her that she was entitled to receive money from Epstein In her declaration in the CVRA litigation Villafana identified that line of questioning as a motivating factor in the governments decision to stop notifying the victims about the potential for U.S.C recovery On June the Friday before Epsteins Monday June state court guilty plea hearing Villafana contacted Edwards to inform him about that upcoming hearing Villafana told OPR she was not given authorization to contact any victims attorney other than Edwards about the scheduled state plea hearing In his affidavit prepared for the CVRA litigation Edwards stated that Villafana gave the impression that she was caught off-guard herself that Epstein was pleading guilty or that this event was happening at all Edwards said in a court filing that Villafana told him only that Epstein was pleading guilty to state solicitation of prostitution charges involving other victims-not Mr Edwards clients nor any of the federally-identified victims Villafana stated in her declaration that she never told Attorney Edwards that the state charges involved other victims and neither the state court charging instrument nor the factual proffer limited the procurement of prostitution charge to a specific victim Villafana told OPR she strongly encouraged Edwards and his clients to attend the plea hearing but could not be more explicit because she was not authorized by the Office to disclose the terms of the NP A In his affidavit Edwards acknowledged that Villafana did express that this hearing was important but never told me why she felt that way Edwards claimed that Villafanas failure to inforn1 him that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement resulted in his clients not attending the hearing Edwards himself was out of town and not able to As previously noted the defense used Florida criminal procedure to depose potent,ial federal victims to learn information concerning the federal investigation even though those individuals were not involved in the state prosecution For example in a March email Villafafia infonned her managers that she spoke to a victim who had received a subpoena issued in connection wit11 the state criminal case which as you ki-10w doesnt involve most of the victims in our case including the girl who was subpoenaed Villafafia further observed that because Epstein is going to plead to t11e solicitation of adults for prostitution charge in state court the act of subpoenaing the victim seems to be a clear effort to find out about our case through t11e state case Villafafias June handwrilten notes reflect that at t11e time of Epsteins state court guilty plea Villafana was aware of the identities of a least five ot11er altorne representing Epstein;s victims In her writte response to OPR Villafana stated I requested pennission to make oral notifications toj t11e victims regarding the upcoming change of plea but Ute Office decided t11c1t victim notification could only come from a state investigator and JeJI Sloman asked PBPD Chief Reiter to assist On Saturday June Villafafia emailed Sloman to infonn him that PBPD Chief Reiter is going to notify victims about the plea Siornan.replied ood CA Aronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM attend the hearing In his affidavit Edwards asserted 223There was no possible way I could have believed that this state plea could affect the federal investigation or the rights of my clients in that federal investigation I In Wild the Eleventh Circuit panel stated that the government 223seemingly deferred to Epstein 2s attorneys requests not to notify the victims about the NPA and that in sending the January and May FBI letters the government 2s efforts 223seem to have graduated from passive nondisclosure to or at least close to active misrepresentation Although both the appellate court and district court focused on the FBI 2s letters for which OPR concludes that neither Villafana Sloman nor Acosta was responsible OPR considered the courts analyses in evaluating whether similar representations Villafana made to the victims whom she interviewed on January and February and to Edwards were misleading Therefore OPR considered whether Villafana 2s statements that the matter was 223under investigation and her failure to inform all of the victims whom she interviewed or Edwards about the NPA violated FRPC a or FRPC a prohibits an attorney from 223knowingly makfing a false statement of material fact or law to a third person during the representation of a client The FRPC defines 223knowingly as 223denoting actual knowledge of the fact in question and states that such knowledge may be 223inferred from circumstances The comment to FRPC states that 223misrepresentations can also occur by partially true but misleading statements or omissions that are the equivalent of affirmative false statements The comment references FRPC 223for dishonest conduct that does not amount to a false statement Like FRPC a Rule requires evidence that the attorney knew the statement in question wasfalse Under FRPC the intent requirement can be satisfied 223merely by showing that the conduct was deliberate or knowing and the 223motive underlying the lawyer 2s conductis not determinative instead the issue is whether he or she purposefully acted In Feinberg the court concluded that the prosecutor violated FRPC and and by deliberately making untruthful statements to a defense attorney despite evidence that the prosecutor intended to help the defendant by making the statements.440 In this case Villafana was fully aware of the signed NPA when she interviewed the victims on January and February arid when she spoke to Edwards on the telephone but she did not inform them specifically of the signed NPA The question is whether this omission amounted to a knowing false statement of misrepresentation One difficulty is determining what Villafana actually said duririg conversations that participants were asked to recall many years later With respect to three of the victims whom she interviewed in January and February Villafana contended that she discussed the agreement with them even if she did not specifically refer to it as the NPA or discuss all of its terms and as Wild F.3d at See Regulating Fla Bar 4-Preamble A Lawyers Responsibilities 223Terminology Florida Bar Schwartz So 3d Fla citing Florida Bar Berthiaume So 3d Fla Florida Bar Riggs So 2d Fla Florida Bar Smith So 2d Fla Florida Bar Feinberg So 2d Fla CA/Aronberg-0745 I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I attend the hearing In his affidavit Edwards asserted There was no possible way I could have believed that this state plea could affect the federal investigation or the right of my clients in that federal investigation In Wild the Eleventh Circuit panel stated that the government sJemingly deferred to Epsteins attorneys requests not to notify the victims about the NPA and that in sending the January and May FBI letters the governments efforts seem to have graduated from passive nondisclosure to or at least close to active misrepresentation Although both the appellate court and district court focused on the FBI letters for which OPR concludes that neither Villafana Sloman nor Acosta was responsible OPR considered the courts analyses in evaluating whether similar representations Villafana made to the victims whom she interviewed on January and February and to Edwards were misleading Therefore OPR considered whether Villafanas statements that the matter was under investigation and her failure to inform all of the victims whom she interviewed or Edwards about the NPA violated FRPC a or FRPC a prohibits an attorney from knowingly making a false statement of material fact or law to a third person during the representation of a client The FRPC defines knowingly as denoting actual knowledge of the fact in question and states that such knowledge may be inferred from circumstances The comment to FR.PC states that misrepresentations can also occur by partially true but misleading statements or omissions that are the equivalent of affirmative false statements The comment references FRPC for dishonest conduct that does not amount to a false statement Like FRPC a Rule requires evidence that the attorney knew the statement in question was false Under FRPC the intent requirement can be satisfied merely by showing that the conduct was deliberate or knowing and the motive underlying the lawyers conductis not determinative instead the issue is whether he or she purposefully acted In Feinberg the court concluded that the prosecutor violated FRPC and and by deliberately making untruthful statements to a defense attorney despite evidence that the prosecutor intended to help the defendant by making the statements In this case Villafana was fully aware of the signed NPA when she interviewed the victims on January and February arid when she spoke to Edwards on the telephone but she did not inform them specifically of the signed NPA The question is whether this omission amounted to a knowing false statement or misrepresentation One difficulty is determining what Villafana actually said duririg conversations that participants were asked to recall many years later With respect to three of the victims whom she interviewed in January and February Villafana contended that she di cussed the agreement with them even if she did not specifically refer to it as the NP A or discuss all of its terms and as Wild F.3d at See Regulating Fla Bar 4-Preamble A Lawyers Responsibilities Tenninology Florida Bar Schwartz So 3d citing Florida Bar IJerthiaume So 3d Fla Florida Bar Riggs So 2d Fla Florida Bar Smith So 2d Fla Florida Bar Feinberg So 2d Fla CA/Aronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM previously noted there is some contemporaneous evidence supporting her assertion Villafana 2s mention of the agreement even if not described in specific terms would have been sufficient to apprise those victims of the status of the federal investigation Nevertheless Villafana not recall discussing the NPA specifically or in general terms with other victims interviewed at that time nor did she do so with Edwards or any other victim 2s attorney OPR therefore considered whether the omission of information about the existence of the NPA during these interactions rose to the level of professional misconduct in violation of FRPC or OPR evaluated Villafana 2s conduct in light of the comment to FRPC A lawyer is required to be truthful when dealing with others on a client 2s behalf but generally has no affirmative duty to inform an opposing party of relevant facts A misrepresentation can occur if the lawyer incorporates or affirms a statement of another person that the lawyer knows is false Misrepresentations can also occur by partially true but misleading statements or omissions that are the equivalent of affirmative false statements The victims and their attorneys were certainly not 223opposing parties to the USAO but the comment indicates that the rule recognizes that omissions made during discussions with third parties even of relevant facts are not always treated as false statements Here the evidence does not show that Villafana knowingly made an affirmative false statement to the victims or Edwards or that her omissions were 223the equivalent of affirmative false statements about material facts First Villafana told OPR that she believed the investigation was ongoing and her statement to that effect truthful and as discussed earlier in this Chapter the evidence shows that Villafana and the agents did continue to investigate the case until Epstein entered his guilty plea in state court in June Villafana 2s email correspondence with her supervisors reflects her strong advocacy during that timeframe to declare Epstein in breach and to charge him The evidence similarly does not show that Villafana knowingly made any affirmative false statement to Edwards when she informed him of state court plea although she declined to provide additional information in response to his questions.442 Second in reaching its conclusion OPR considered the full context in which Villafana interacted with the victims and Edwards Prosecutors routinely make decisions about what information will be disclosed to witnesses including victims for a variety of strategic reasons In many cases prosecutors must make difficult decisions about providing information to witnesses In Florida Bar Joy the court affirmed a referee 2s conclusion that Joy violated FRPCs a and 223for making false statements by omission of material facts in his representations to counsel Florida Bar Joy So 2d Fla See also Florida Bar re Webster So 2d Fla petition for reinstatement denied due to 223misrepresentation by omission In Feinberg So 2d at the court found that an Assistant State Attorney lacked candor and violated ethics rules when after meeting with a defendant outside liis attorney 2s presence the prosecutor falsely slated to the defense attorney that he the prosecutor had not met with the defendant I i CA/Aronberg-0746 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM previously noted there is some contemporaneous evidence supporting her Lsertion Villafanas mention of the agreement even if not described in specific terms would hhve been sufficient to apprise those victims of the status of the federal investigation Nevertheless Villafana did not recall discussing the NP A specifically or in general terms with other victims interviewed at that time nor did she do so with Edwards or any other victims attorney OPR therefore considered whether the omission of information about the existence of the NP A during these interactions rose to the level of professional misconduct in violation ofFRPC OPR evaluated Villafanas conduct in light of the comment to FRPC A lawyer is required to be truthful when dealing with others on a clients behalf but generally has no affirmative duty to inform an opposing party of relevant facts A misrepresentation can occur if the lawyer incorporates or affirms a statement of another person that the lawyer knows is false Misrepresentations can also occur by partially true but misleading statements or omissions that are the equivalent of affirmative false statements The victims and their attorneys were certainly not opposing parties to the USAO but the comment indicates that the rule recognizes that omissions made during discussions with third parties even of relevant facts are not always treated as false statements Here the evidence does not show that Villafana knowingly made an affirmative false statement to the victims or Edwards or that her omissions were the equivalent of affirmative false statements about material facts First Villafana told OPR that she believed the investigation was ongoing and her statement to that effect truthful and as discussed earlier in this Chapter the evidence shows that Villafana and the agents did continue to investigate the case until Epstein entered his guilty plea in state court in June Villafanas email correspondence with her supervisors reflects her strong advocacy during that timeframe to declare Epstein in breach and to charge him The evidence similarly does not show that Villafana knowingly made any affirmative false statement to Edwards when she informed him of the state court plea although she declined to provide additional information in response to his questions Second in reaching its conclusion OPR considered the full context in which Villafana interacted with the victims and Edwards Prosecutors routinely make decisions about what information will be disclosed to witnesses including victims for a variety of strategic reasons In many cases prosecutors must make difficult decisions about providing information to witnesses In Florida Bar Joy lhe court affinned a referees conclusion lhal Joy violated FRPCs a and for making false statemenls by omission of material facts in his representations lo col1Il5el Florida Bar Joy So 2d Fla See also Florida Bar re Webster So 2d Fla petition for reinslatement denied due to misrepresentation by omission I In Feinberg So 2d at the court found that an Assistant State Attorney lacked candor and violated ethics rules when afler meeting wiU1 a defendant outside his altorneys presence U1e prosbculor falsely slated lo the defense attorney that he the prosecutor had not met with the defendant I I CA/Aronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM and they often cannot fully reveal either the facts or the status of an investigation even with victims The Guidelines advise that in consulting with a victim prosecutors may be limited in their disclosures 223Because victims are not clients may become adverse to the Government and may disclose whatever they have learned from consulting with prosecutors such consultations may be limited to gathering information from victims and conveying only nonsensitive data and public information Villafaha 2s concern about generating potential impeachment evidence by informing victims of their potential to recover monetary damages from Epstein was not unreasonable Indeed the case agents initially raised the impeachment issue and after considering the problem Villafana agreed with the agents concerns Villafana raised those concerns with the USAO 2s Professional Responsibility Officer in October after the agents brought the issue to her attention and she ultimately raised the issue with Sloman and Acosta as well neither of whom advised her that those concerns were improper or unsound OPR also considered that although Villafana had sought to notify the victims in writing of the NPA soon after it was signed her supervisor the U.S Attorney had decided otherwise When authorized to inform Edwards of the scheduled change of plea hearing she did so Although she not inform Edwards that the plea was part of a global resolution that would end the federal investigation the evidence does not show that Villafana acted for the purpose of deceiving Edwards or preventing him from attending the hearing Had she sought to exclude him from state proceedings she could have elected not to inform Edwards at all or she could have discouraged him from attending state proceedings Rather as Edwards confirmed Villafana told him the hearing was 223important Villafana sought to strike a difficult balance of securing Edwards 2s and his clients attendance at the state court plea while obeying her management 2s directive that informing victims of the resolution of the federal investigation should not be done until completion of the state plea Therefore after carefully considering all of the circumstances OPR concludes that the evidence does not establish that Villafana violated her obligations under FRPC or or Nonetheless as discussed below Villafaha 2s interactions with victims and victims attorneys without informing them of the NPA and the potential conclusion of the federal investigation contributed to the likelihood that the victims would feel that the government was Guidelines Art IV I As noted some victims continued to express favorable views of Epstein during interviews with the government and they or their attorneys could have provided information to Epstein about the government 2s communications For example within a day of Villafana contacting a victim 2s attorney about a potential victim notification letter Starr complained to Acosta that the government had recently inappropriately provided 223oral notification of tire victim notification letter to one girl 2s attorney even though it was clear from the girl 2s recorded FBI interview that she 223did not in any manner view herself as a victim m4 The case most directly on point is Smith A.3d in which the Man kind Court of Appeals affirmed a violation of Maryland Rule of Professional Conduct based on a prosecutor 2s failure to notify the victim of the resolution of a sex abuse case However as noted previously in Smith the criminal defendant had been arrested and charged before entering a plea and various specific statutes afforded victims the right to receive notices and an opportunity to be heard concerning case originating by indictment or information in a circuit court In tliis case for lie reasons previously discussed Villafana did not have a clear and unambiguous obligation to inform the victims or Edwards of the NPA i CA/Aronberg-0747 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM and they often cannot fully reveal either the facts or the status of an investigation even with victims The Guidelines advise that in consulting with a victim prosetutors may be limited in their disclosures Because victims are not clients may become adversb to the Government and may disclose whatever they have learned from consulting with prosecutdrs such consultations may be limited to gathering information from victims and conveying only honsensitive data and public information Villafanas concern about generating potential impeachment evidence by informing victims of their potential to recover monetary damages from Epstein was not unreasonable Indeed the case agents initially raised the impeachment issue and after considering the problem Villafana agreed with the agents concerns Villafana raised those concerns with the USAOs Professional Responsibility Officer in Oct9ber after the agents brought the issue to her attention and she ultimately raised the issue with Sloman and Acosta as well neither of whom advised her that those concerns were improper or unsound OPR also considered that although Villafana had sought to notify the victims in writing of the NPA soon after it was signed her supervisor the U.S Attorney had decided otherwise When authorized to inform Edwards of the scheduled change of plea hearing she did so Although she did not inform Edwards that the plea was part of a global resolution that would end the federal investigation the evidence does not show that Villafana acted for the purpose of deceiving Edwards or preventing him from attending the hearing Had she sought to exclude him from the state proceedings she could have elected not to inform Edwards at all or she could have discouraged him from attending the state proceedings Rather as Edwards confirmed Villafana told him the hearing was important Villafana sought to strike a difficult balance of securing Edwardss and his clients attendance at the state court plea while obeying her managements directive that informing victims of the resolution of the federal investigation should not be done until completion of the state plea Therefore after carefully considering all of the circumstances OPR concludes that the evidence does not establish that Villafana violated her obligations under FRPC or or Nonetheless as discussed below Villafanas interactions with victims and victims attorneys without informing them of the NPA and the potential conclusion of the federal investigation contributed to the likelihood that the victims would feel that the government was Guidelines Art IV i I As noted some victims continued to express favorable views of Epstein during interviews with the government and they or their attorneys could have provided infonnation to Epstein about the govenunents conununications For example within a day of Villafafia contacting a ictims attorney about a potential victim notification letter Starr complained to Acosta that the govenunent had recently inappropriately provided orn.l notification of tl1e victim notification letter to one girls attorney even though it was clear from the girls recorded FBI interview that she did not in any manner view herself as a victim The case most directly on point is Smilh A.3d in which the Maryland Court of Appeals aflinncd a violation of Maryland Rule of Professional Conduct based on a prosecutors failure to notify the victim of the resolution of a sex abuse case However as noted previously in Smilh the criminal defen4ant had been arrested and charged before entering a plea and various specific statutes afforded victims tl1e right lo receive notices and an opportunity lo be heard concerning a case originating by indictment or infonnalion in a circuit court In tlris case for tl1e reasons previously discussed Villafafia did not have a clear and unambiguous oblig tion to infonn the victi1ns or Edwards of the NP A CNAronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM intentionally concealing information from them and was part of a series of interactions with victims that led to condemnation of the government 2s treatment of victims.445 VI THE GOVERNMENT FAILED TO TREAT VICTIMS FORTHRIGHTLY AND WITH SENSITIVITY WHEN IT FAILED TO TIMELY PROVIDE VICTIMS WITH IMPORTANT INFORMATION ABOUT THE RESOLUTION OF THE FEDERAL INVESTIGATION Although OPR does not conclude that any of the subjects committed professional misconduct either by failing to consult with the victims before the NPA was signed or in interactions afterwards OPR 2s findings are not an endorsement of the government 2s course of action The government 2s interactions with victims confused and frustrated many of the victims particularly the two CVRA petitioners and the two victims who had unsuccessfully attempted to join in the CVRA litigation As a result the victims and the public 2s perception of the matter is that the prosecutors worked with Epstein 2s attorneys to disenfranchise and silence the victims It is unfortunate and appears fundamentally unfair to the victims that Acosta and Sloman after Menchel and Lourie departed took the unusual step of deciding to the USAO victim notification letters with the defense after the NPA was signed but failed to go beyond the requirements of the CVRA or the Guidelines to consult with the victims before the NPA was signed This result is contrary to the Department 2s intent as set forth in the Guidelines that Department employees work to 223minimize the frustration and confusion that victims of crime endure in its wake When considering the entirety of the government 2s interactions with victims OPR concludes that victims were not treated with the forthrightness and sensitivity expected by the Department Wild 2s criticisms of the government 2s conduct were based on interactions that are similar to and generally representative of the government 2s interactions with other Epstein victims and that demonstrate an overall lack of sensitivity to the victims by the government Wild experienced a series of confusing and inconsistent communications in her interactions with Villafana and the case agents Wild received Villafana 2s letter in June stating inaccurately that she was a federal victim entitled to CVRA rights She was interviewed by the FBI in August but was not told that a potential outcome was a state plea Shortly after the September signing of the NPA the FBI contacted her to inform her of the resolution of the federal case Nonetheless on January the FBI sent her a victims rights letter indicating that the case was under investigation and that some of her CVRA rights may not apply until after the defendant was charged On January Villafana re-interviewed Wild along with a CEOS attorney and the FBI agents and told Wild that the case was under investigation but did not specifically mention the NPA although she may have mentioned a possible resolution In mid-June when Edwards contacted Villafana on Wild 2s behalf Villafana informed him that the case was under investigation but did not mention the NPA Just before Epstein 2s June state court plea OPR notes tliat similar to Villafana Sloman interacted with a victim 2s attorney during the time period between the signing of the NPA and Epstein 2s state guilty plea In January Sloman received a telephone call from liis former law partner who represented one of the victims and who asked Sloman whether the federal government could bring cliarges against Epstein Sloman concerned about the potential for conflict of interest allegations due to his prior business relations with the attorney refused to answer any questions regarding Epstein Because Sloman refused to provide any information OPR found no basis for finding that Sloman misled the attorney I CA/Aronberg-0748 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM intentionally concealing information from them and was part of a series of interactions with victims that led to condemnation of the governments treatment of victims I I I VI THE GOVERNMENT FAILED TO TREAT VICTIMS FORTHRIGHTLY AND WITH SENSITIVITY WHEN IT FAILED TO TIMELY PROVJDE VICTIMS WITH IMPORTANT INFORMATION ABOUT THE RESOLUTION OF THE FEDERAL INVESTIGATION Although OPR does not conclude that any of the subjects committed professional misconduct either by failing to consult with the victims before the NPA was signed or in interactions afterwards OPRs findings are not an endorsement of the governments course of action The governments interactions with victims confused and frustrated many of the victims particularly the two CVRA petitioners and the two victims who had unsuccessfully attempted to join in the CVRA litigation As a result the victims and the publics perception of the matter is that the prosecutors worked with Epsteins attorneys to disenfranchise and silence the victims It is unfortunate and appears fundamentally unfair to the victims that Acosta and Sloman after Menchel and Lourie departed took the unusual step of deciding to vet the USAO victim notification letters with the defense after the NP A was signed but failed to go beyond the requirements of the CYRA or the Guidelines to consult with the victims before the NPA was signed This result is contrary to the Departments intent as set forth in the Guidelines that Department employees work to minimize the frustration and confusion that victims of crime endure in its wake When considering the entirety of the governments interactions with victims OPR concludes that victims were not treated with the forthrightness and sensitivity expected by the Department Wilds criticisms of the governments conduct were based on interactions that are similar to and generally representative of the governments interactions with other Epstein victims and that demonstrate an overall lack of sensitivity to the victims by the governm nt Wild experienced a series of confusing and inconsistent communications in her interactions with Villafana and the case agents Wild received Villafanas letter in June stating inaccurately that she was a federal victim entitled to CVRA rights She was interviewed by the FBI in August but was not told that a potential outcome was a state plea Shortly after the September signing of the NPA the FBI contacted her to inform her of the resolution of the feder.al case Nonetheless on January the FBI sent her a victims rights letter indicating th11t the case was under investigation and that some of her CVRA rights may not apply until after the defendant was charged On January Villafana re-interviewed Wild along with a CEOS attorney and the FBI agents and told Wild that the case was under investigation but did n6t specifically mention the NP A although she may have mentioned a possible resolution In mid-June when Edwards contacted Villafana on Wilds behalf Villafana informed him that the case was under investi ation but did not mention the NPA Just before Epsteins June state court plea OPR notes that similar to Villafafia Sloman interacted wit11 a victims attorney during the time period between the signing of the NPA and Epsteins state guilty plea In January Sloma11 received a telephone call from his former law partner who represented one of t11e victims and who asked SlomaI1 whether the federal govenunent could bring charges against Epstein SlomaI1 concerned about the potential for conflict of interest allegations due to his prior business relations with t11e attorney refused to a11Swer qu stions regarding Epstein Because Sloman refused to provide any infonnation OPR found no basis for finding that S!oman misled the attorney CNAronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Villafana informed Edwards about the state plea but did not mention the NPA or the fact that the state pleas would resolve the federal investigation Edwards then filed the CVRA petition and learned about the NPA signed months earlier and that the federal investigation of Epstein had concluded with Epstein 2s state guilty pleas Wild only received access to the NPA when a judge permitted it in August pursuant to a protective order After considering this series of interactions it is not surprising that Wild came away from the experience.feeling confused and believing she had been misled OPR did not find evidence supporting a conclusion that Villafana Acosta Sloman Menchel or Lourie opted not to consult with the victims in order to protect Epstein or shield the NPA from public scrutiny Although neither Sloman nor Acosta could recall a specific discussion of CVRA obligations before the NPA was signed both recalled knowing that victim consultation was not required and Menchel also told OPR that consultation was not required at least not up to the point when he left the USAO The evidence is clear that Villafana sought at various points to consult with and to notify victims about the details of the NPA but was constrained before the NPA was signed by managers who either made a decision to not consult victims or did not address the issue after it was raised and after the signing by her own concern about creating possible impeachment evidence that would damage the victims credibility at a possible trial Nonetheless a more open and straightforward approach with the victims both before and after the signing of the NPA would have been the better practice Before the NPA was signed victims could been asked for their views about the general terms the USAO was contemplating offering including that a plea to state charges was one of the options being considered asked for their views in general about a guilty plea or at a minimum asked to share their views of how the case should be resolved Even if the USAO ultimately determined to proceed with the NPA the government would have had the benefit of the victims thoughts and concerns particularly on the issue of punishment and victims would have felt included in the process OPR found no evidence that the benefits of victim consultation were discussed or considered before the NPA was signed After the NPA was signed no one from the government explained the agreement to the majority of the victims until months later and only after the entry of Epstein 2s guilty plea Although the evidence supports Villafafia 2s assertion that she acted from a good faith belief that Epstein might breach the NPA and a potential trial would be harmed if information about the NPA was divulged to the victims and their counsel she Sloman and Acosta failed to consider how the desire to shield the victims from that potential impeachment might impact the victims sense of the openness and fairness of the process As Wild stated during the CVRA litigation she believed she had been 223mistreated in the process When deciding not to inform the victims of the NPA to avoid creating impeachment evidence Villafana Sloman and Acosta do not appear to have carefully considered possible alternatives to or all of the ramifications of that decision nor did they revisit the decision before Villafana met the victims in person to discuss a potential trial or spoke to Edwards or other attorneys representing victims.446 Furthermore more attention needed It is not at all clear whether a court would have permitted impeachment of tlie victims concerning one provision in a plea agreement that otherwise could not be used as evidence See Fed Crim 223The admissibility or inadmissibility of a plea a plea discussion and any related statement is governed by Federal Rule of Evidence In any case the victims could have been impeached regarding the possibility of their obtaining monetary damages through either a civil suit or through U.S.C if Epstein we:re convicted after a trial CA/Aronberg-0749 i FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Villafana informed Edwards about the state plea but did not mention the NPA or the fact that the state pleas would resolve the federal investigation Edwards then filed th CVRA petition and learned about the NP A signed months earlier and that the federal investigation of Epstein had concluded with Epsteins state guilty pleas Wild only received access to the NPA when a judge permitted it in August pursuant to a protective order After considering this series of interactions it is not surprising that Wild came away from the experience feeling confused and believing she had been misled OPR did not find evidence supporting a conclusion that Villafana Acosta Sloman Menchel or Lourie opted not to consult with the victims in order to protect Epstein or shield the NPA from public scrutiny Although neither Sloman nor Acosta could recall a specific discussion of CVRA obligations before the NP A was signed both recalled knowing that victim consultation was not required and Menchel also told OPR that consultation was not required at least not up to the point when he left the USAO The evidence is clear that Villafana sought at various points to consult with and to notify victims about the details of the NPA but was constrained before the NP A was signed by managers who either made a decision to not consult victims or did not address the issue after it was raised and after the signing by her own concern about creating possible impeachment evidence that would damage the victims credibility at a possible trial Nonetheless a more open and straightforward approach with the victims both before and after the signing of the NP A would have been the better practice Before the NP A was signed victims could have been asked for their views about the general terms the USAO was contemplating offering including that a plea to state charges was one of the options being considered asked for their views in general about a guilty plea or at a mif imum asked to share their views of how the case should be resolved Even if the USAO ultimately determined to proceed with the NP A the government would have had the benefit of the victims thoughts and concerns particularly on the issue of punishment and victims would have felt included in the process OPR found no evidence that the benefits of victim consultation were discussed or considered before the NP A was signed After the NP A was signed no one from the government explained the agreement to the majority of the victims until months later and only after the entry of Epsteins guilty plea Although the evidence supports Villafanas assertion that she acted from a 267good faith belief that Epstein might breach the NPA and a potential trial would be harmed if information about the NPA was divulged to the victims and their counsel she Sloman and Acosta failed to consider how the desire to shield the victims from that potential impeachment might impact the victims sense of the openness and fairness of the process As Wild stated during the CVRA litigation she believed she had been mistreated in the process When deciding not to inform the victims of the NPA to avoid creating impeachment evidence Villafana Sloman and Acosta do not appear to have carefully considered possible alternatives to or all of the ramifications of that decision nor did they revisit the decision before Villafana met the victims in person to discuss a potential trial or spoke to Edwards or other attorneys representing victims Furthermore more attention needed It is not at all clear whether a court would have permitted impeaclunent of the victims concerning one provision in a pica agreement Uiat otherwise could not be used as evidence See Fed Crim The admissibility or inadmissibility of a plea a plea discussion and any related statement is govemed by Federal Rule of Evidence In any case U1e victims could have been impeached regarding the po sibility of their obtaining monetary damages through either a civil suit or through U.S.C if Epstein re convicted after a trial CN Aronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM to be paid to the FBI 2s communications to ensure that the victims were receiving accurate and timely information that was consistent with the status of the case and with the US AO 2s communications with victims.447 The decision not to inform victims and their attorneys about the existence of the NPA gave victims and the public the misimpression that the government had colluded with Epstein 2s counsel to keep the agreement secret from the victims Moreover the lack of openness about the NPA gave the impression that the USAO lacked sensitivity for the victims in resolving the matter and undercut public confidence in the legitimacy of the resulting plea agreement The overall result of the subjects anomalous handling of this case left at least some of the victims feeling ignored and frustrated failed to promote their healing process and resulted in extensive public criticism Although OPR credits Villafana 2s statements that she wanted to go beyond her obligations in dealing with victims the end result nonetheless was that communications with victims were not prioritized by the USAO In part this was due to the fact that interactions with victims are generally handled by staff in the USAO and the FBI who are trained and have expertise in dealing with victims and other witnesses However decisions made by Acosta Sloman and Villafana also contributed to the problems The government as it ultimately acknowledged in the CVRA litigation could have and should have engaged with the victims in a more transparent and unified fashion OPR recognizes that the Epstein investigation occurred soon after the passage of the CVRA In the years since the Department 2s prosecutors and personnel have become more familiar with itsprovisions OPR encourages the Department as a whole to take the issues discussed above into account when providing training and direction to its employees regarding victims rights to ensure that in the future Department attorneys actions promote victim inclusion whenever possible.448 For example although the division of responsibility between the FBI and the USAO for communicating with victims works efficiently and appropriately in the average case the USAO failed to consider that in a case involving a pre-charge disposition the victims were receiving inconsistent and confusing communications from the separate entities In certain cases such as the Epstein case prosecutors may need to provide more oversight when imultiple Department components are communicating with victims to avoid providing confusing and contradictory messages independent of the NPA provision OPR also notes that impeachment regarding the NPA provision may have permitted the government to rehabilitate the victims through their prior statements to law enforcement In other words while the USAO 2s view concerning potential impeachment was not unreasonable more extensive consideration of the case agent 2s concerns might have led the prosecutors to conclude that the risk of tire information being used to significantly damage the credibility of the victims was low In addition to the FBI letters previously discussed another example of the inconsistent conununication can be seen in letters tliat were to be sent after Epstein entered Iris guilty plea to two victims residing in foreign countries Although OPR was unable to confirm that the two victims actually received the letters it appears from the records OPR reviewed that the government intended to provide them with a standard FBI letter stating that the case was under investigation while also providing them with a USAO letter stating tliat the case had been resolved through Epstein 2s state guilty plea OPR understands tliat the Department is in the process of revising the Guidelines CA/Aronberg-0750 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM to be paid to the FBIs communications to ensure that the victims were receiving accurate and timely information that was consistent with the status of the case add with the USAO communications with victims I The decision not to inform victims and their attorneys about the existence of the NP A gave victims and the public the misimpression that the government had colluded with Epsteins counsel to keep the agreement secret from the victims Moreover the lack of openness about the NP A gave the impression that the USAO lacked sensitivity for the victims in resolving the matter and undercut public confidence in the legitimacy of the resulting plea agreement The overall result of the subjects anomalous handling of this case left at least some of the victims feeling ignored and frustrated failed to promote their healing process and resulted in extensive public criticism Although OPR credits Villafafias statements that she wanted to go beyond her obligations in dealing with victims the end result nonetheless was that communications with victims were not prioritized by the USAO In part this was due to the fact that interactions with victims are generally handled by staff in the USAO and the FBI who are trained and have expertise in dealing with victims and other witnesses However decisions made by Acosta Sloman and Villafana also contributed to the problems The government as it ultimately acknowledged in the CVRA litigation could have and should have engaged with the victims in a more transparent and unified fashion OPR recognizes that the Epstein investigation occurred soon after the passage of the CVRA In the years since the Departments prosecutors and personnel have become more familiar with its 267provisions OPR encourages the Department as a whole to take the issues discussed above into account when providing training and direction to its employees regarding victims rights to ensure that in the future Department attorneys actions promote victim inclusion whenever possible For example although the division of responsibility between the FBI and the USAO for communicating with victims works efficiently and appropriately in the average case the USAO failed to consider that in a case involving a pre-charge disposition the victims were receiving inconsistent and confusing communications from the separate entities In certain cases such as the Epstein case prosecutors may need to provide more oversight when imultiple Department components are communicating with victims to avoid providing confusing and contradictory messages independent of the NPA provisio11 OPR also notes that impeaclunent regarding the 1JPA provision may have pennitted the govenunent to rehabilitate the victims through their prior statements to law enforcement In other words while the USAOs view concerning potential impeachment was not unreasonable more extensive consideration of the case agents concerns might have led the prosecutors to conclude that the risk of the information being used to significantly damage the credibility of the victims was low In addition to tl1e FBI letters previously discussed another example of the inconsistent conununication can be seen in letters that were to be sent after Epstein entered his guilty plea to two victims residing in foreign countries Although OPR was unable to confinn that the two victims actually received the letters it appears from the records OPR reviewed that t11e govenunent intended to provide them with a standard FBI letter stating that the case was under im,estigation while also providing them with a USAO letter stating that the case had been ksolved through Epsteins state guilty plea I OPR understands that the Department is in the process of revising the Guidelines CNAronberg-0750 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CONCLUSION In November the Miami Herald published an extensive investigative report about state and federal criminal investigations initiated more than years earlier into allegations that Jeffrey Epstein a wealthy financier with residences in Florida New York and other United States and foreign locations had coerced girls into engaging in sexual activity with him at his Palm Beach Florida estate The Miami Herald reported that in the U.S Attorney for the Southern District of Florida Alexander Acosta entered into an 223extraordinary deal with Epstein that permitted Epstein to avoid federal prosecution and a potentially lengthy prison sentence by pleading guilty in state court to 223two prostitution charges immunized from prosecution Epstein 2s co-conspirators and concealed from Epstein 2s victims the terms of the NPA Following the Miami Herald 2s report and after receiving a Congressional request to investigate OPR initiated an investigation into the allegations that prosecutors in the USAO improperly resolved the federal investigation into the criminal conduct of Jeffrey Epstein by negotiating and executing the NPA OPR subsequently included in its investigation allegations stemming from judicial criticism of the government 2s conduct relating to federal prosecutors and law enforcement agents interactions with Epstein 2s victims In July a victim later joined by a second victim filed in federal court in the Southern District of Florida an emergency petition for enforcement of her rights under the CVRA In February the district court found that the government violated the CVRA by failing to advise victims about its intention to enter into the NPA The court also found that letters the government sent to victims after the NPA was signed describing the investigation as ongoing were misleading During the course of its investigation OPR obtained and reviewed hundreds of thousands of records from the USAO the FBI and other Department of Justice components The records included emails letters memoranda and investigative materials OPR also collected and reviewed materials relating to the state investigation and prosecution of Epstein including sealed pleadings grand jury transcripts and grand jury audio recordings examined extensive publicly available information including depositions pleadings orders and other court records and reviewed media reports and interviews articles podcasts and books relating to the Epstein case OPR conducted more than interviews of witnesses including the FBI case agents their supervisors and FBI administrative personnel current and former USAO staff and attorneys current and former Department attorneys and senior managers and the former State Attorney and Assistant State Attorney in charge of the state investigation of Epstein OPR also interviewed or received written information from several victims and attorneys representing victims concerning victim contacts with the USAO and federal law enforcement OPR identified the following five former USAO attorneys as subjects of its investigation based on information indicating that each of them was involved in the decision to resolve the case through the NPA or in the negotiations leading to the agreement former U.S Attorney Alexander Acosta and former AUSAs Jeffrey Sloman Matthew I Menchel Andrew Lourie and Ann Marie Villafana Each subject submitted written responses detailing their involvement in the federal investigation of Epstein the drafting and execution of the NPA and decisions relating to victim notification and consultation OPR conducted extensive interviews of all five subjects The subjects also submitted comments on OPR 2s draft report CA/Aronberg-0751 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CONCLUSION I In November the Miami Herald published an extensive invebtigative report about state and federal criminal investigations initiated more than years earlier into allegations that Jeffrey Epstein a wealthy financier with residences in Florida New York and other United States and foreign locations had coerced girls into engaging in sexual activity ith him at his Palm Beach Florida estate The Miami Herald reported that in the U.S Attorney for the Southern District of Florida Alexander Acosta entered into an extraordinary deal with Epstein that permitted Epstein to avoid federal prosecution and a potentially lengthy prison sentence by pleading guilty in state court to two prostitution charges immunized from prosecution Epsteins co-conspirators and concealed from Epsteins victims the terms of the NPA Following the Miami Heralds report and after receiving a Congressional request to investigate OPR initiated an investigation into the allegations that prosecutors in the USAO improperly resolved the federal investigation into the criminal conduct of Jeffrey Epstein by negotiating and executing the NP A OPR subsequently included in its investigation allegations stemming from judicial criticism of the governments conduct relating to federal prosecutors and law enforcement agents interactions with Epsteins victims In July a victim later joined by a second victim filed in federal court in the Southern District of Florida an emergency petition for enforcement of her rights under the CVRA In February the district court found that the government violated the CYRA by failing to advise victims about its intention to enter into the NPA The court also found that letters the government sent to victims after the NPA was signed describing the investigation as ongoing were misleading During the course of its investigation OPR obtained and reviewed hundreds of thousands of records from the USAO the FBI and other Department of Justice components The records included emails letters memoranda and investigative materials OPR also collected and reviewed materials relating to the state investigation and prosecution of Epstein including sealed pleadings grand jury transcripts and grand jury audio recordings examined extensive publicly available information including depositions pleadings orders and other court records and reviewed media reports and interviews articles podcasts and books relating to the Epstein case OPR conducted more than interviews of witnesses including the FBI case agents their supervisors and FBI administrative personnel current and former USAO staff and attorneys current and former Department attorneys and senior managers and the former State Attorney and Assistant State Attorney in charge of the state investigation of Epstein OPR also interviewed or received written information from several victims and attorneys representing victims concerning victim contacts with the USAO and federal law enforcement OPR identified the following five former USAO attorneys as subjects of its investigation based on information indicating that each of them was involved in the decision to resolve the case through the NPA or in the negotiations leading to the agreement former U.S Attorney Alexander Acosta and forn1er AUSAs Jeffrey Sloman Matthew I Menchel Andrew Lourie and Ann Marie Villafana Each subject submitted written responses detailing their involvement in the federal investigation of Epstein the drafting and execution of the NP A and decisions relating to victim notification and consultation OPR conducted extensive interviews of all five subjects The subjects also submitted comments on OPRs draft reJort i CA/Aronberg-0751 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM OPR evaluated the conduct of each subject based on his or her individual role in various decisions and events and assessed that conduct pursuant to OPR 2s analytical framework OPR found that Acosta made the pivotal decision to resolve the federal investigation of Epstein through a state-based plea and either developed or approved the terms of the initial offer to the defense that set the beginning point for the subsequent negotiations that led to the NPA Although Acosta did not sign the NPA he participated in its drafting and approved it with knowledge of its terms Therefore OPR considers Acosta to be responsible for the NPA and for the actions of the other subjects who implemented his decisions Based on its extensive investigation OPR concludes that the subjects did not commit professional misconduct with respect to the development negotiation and approval of the NPA Under OPR 2s framework professional misconduct requires a finding that a subject attorney intentionally or recklessly violated a clear and unambiguous standard governing the conduct at issue OPR found no clear and unambiguous standard that required Acosta to indict Epstein on federal charges or that prohibited his decision to defer prosecution to the state Furthermore none of the individual terms of the NPA violated Department or other applicable standards As the U.S Attorney Acosta had the 223plenary authority under established federal law and Department policy to resolve the case as he deemed necessary and appropriate as long as his decision was not motivated or influenced by improper factors Acosta 2s decision to decline to initiate a federal prosecution of Epstein was within the scope of his authority and OPR did not find evidence that his decision was based on corruption or other impermissible considerations such as Epstein 2s wealth status or associations Evidence shows that Acosta resisted defense efforts to have the matter returned to the state for whatever result state authorities deemed appropriate and he refused to eliminate the incarceration and sexual offender registration requirements OPR did not find evidence establishing that Acosta 2s 223breakfast meeting with one of Epstein 2s defense counsel in October led to the NPA which had been signed weeks earlier or to any other significant decision that benefited Epstein The contemporaneous records show that USAO managers concerns about legal issues witness credibility and the impact of a trial on the victims led them to prefer a pre-charge resolution and that Acosta 2s concerns about the proper role of the federal government in prosecuting solicitation crimes resulted in his preference for a state-based resolution Accordingly OPR does not find that Acosta engaged in professional misconduct by resolving the federal investigation of Epstein in the way he did or that the other subjects committed professional misconduct through their implementation of Acosta 2s decisions Nevertheless OPR concludes that Acosta 2s decision to resolve the federal investigation through the NPA constitutes poor judgment Although this decision was within the scope of Acosta 2s broad discretion and OPR does not find that it resulted from improper factors the NPA was a flawed mechanism for satisfying the federal interest that caused the government to open its investigation of Epstein In Acosta 2s view the federal government 2s role in prosecuting Epstein was limited by principles of federalism under which the independent authority of the state should be recognized and the federal responsibility in this situation was to serve as a 223backstop to state authorities by encouraging them to do more However Acosta failed to consider the difficulties inherent in a resolution that relied heavily on action by numerous state officials over whom he had no authority he resolved the federal investigation before significant investigative steps were completed and he agreed to several unusual and problematic terms in the NPA without the consideration required under the circumstances In sum Acosta 2s application of federalism CA/Aronberg-0752 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I OPR evaluated the conduct of each subject based on his or her indiridual role in various decisions and events and assessed that conduct pursuant to OPRs analytical framework OPR found that Acosta made the pivotal decision to resolve the federal investigati;on of Epstein through a state-based plea and either developed or approved the terms of the initial offer to the defense that set the beginning point for the subsequent negotiations that led to the NP A Although Acosta did not sign the NPA he participated in its drafting and approved it with knowledge of its terms Therefore OPR considers Acosta to be responsible for the NP A and for the actions of the other subjects who implemented his decisions Based on its extensive investigation OPR concludes that the subjects did not commit professional misconduct with respect to the development negotiation and approval of the NP A Under OPRs framework professional misconduct requires a finding that a subject attorney intentionally or recklessly violated a clear and unambiguous standard governing the conduct at issue OPR found no clear and unambiguous standard that required Acosta to indict Epstein on federal charges or that prohibited his decision to defer prosecution to the state Furthermore none of the individual terms of the NPA violated Department or other applicable standards As the U.S Attorney Acosta had the plenary authority under established federal law and Department policy to resolve the case as he deemed necessary and appropriate as long as his decision was not motivated or influenced by improper factors Acostas decision to decline to initiate a federal prosecution of Epstein was within the scope of his authority and OPR did not find evidence that his decision was based on corruption or other impermissible considerations such as Epsteins wealth status or associations Evidence shows that Acosta resisted defense efforts to have the matter returned to the state for whatever result state authorities deemed appropriate and he refused to eliminate the incarceration and sexual offender registration requirements OPR did not find evidence establishing that Acostas breakfast meeting with one of Epsteins defense counsel in October led to the NPA which had been signed weeks earlier or to any other significant decision that benefited Epstein The contemporaneous records show that USAO managers concerns about legal issues witness credibility and the impact of a trial on the victims led them to prefer a pre-charge resolution and that Acostas concerns about the proper role of the federal government in prosecuting solicitation crimes resulted in his preference for a state-based resolution Accordingly OPR does not find that Acosta engaged in professional misconduct by resolving the federal investigation of Epstein in the way he did or that the other subjects committed professional misconduct through their implementation of Acostas decisions Nevertheless OPR concludes that Acostas decision to resolve the federal investigation through the NPA constitutes poor judgment Although this decision was within the scope of Acostas broad discretion and OPR does not find that it resulted from improper factors the NPA was a flawed mechanism for satisfying the federal interest that caused the government to open its investigation of Epstein ln Acostas view the federal governments role in prosecuting Epstein was limited by principles offederalism under which the independent authority of the state should be recognized and the federal responsibility in this situation was to serve as a backstop to state authorities by encouraging them to do more However Acosta failed to consider the difficulties inherent in a resolution that relied heavily on action by numerous state officials over whom he had no authority he resolved the federal investigation before significant investigative steps were completed and he agreed to several unusual and problematic terms in the NPA without the consideration required under the circumstances In sum Acostas application of federalism CA/Aronberg-0752 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM principles was too expansive his view of the federal interest in prosecuting Epstein was too narrow and his understanding of the state system was too imperfect to justify the decision to use the NPA Furthermore because Acosta assumed a significant role in reviewing and drafting the NPA and the other three subjects who were supervisors left the USAO were transitioning to other jobs or were absent at critical junctures Acosta should have ensured more effective coordination and communication during the negotiations and before approving the final NPA The NPA was a unique resolution and one that required greater oversight and supervision than Acosta provided OPR further concludes that none of the subject attorneys committed professional misconduct with respect to the government 2s interactions with victims The subjects did not intentionally or recklessly violate a clear and unambiguous duty under the CVRA by entering into the NPA without consulting with victims because the USAO resolved the Epstein investigation without a federal criminal charge Significantly at the time the NPA was signed the Department did not interpret CVRA rights to attach unless and until federal charges had been filed and the federal courts had not established a clear and unambiguous standard applying the CVRA before criminal charges were brought In addition OPR did not find evidence that the lack of consultation was for the purpose of silencing victims Nonetheless the lack of consultation was part of a series of government interactions with victims that ultimately led to public and court condemnation of the government 2s treatment of the victims reflected poorly on the Department as a whole and is contradictory to the Department 2s mission to minimize the frustration and confusion that victims of a crime endure OPR determined that none of the subjects was responsible for communications sent to certain victims after the NPA was signed that described the case as 223under investigation and that failed to inform them of the NPA The letters were sent by an FBI administrative employee who was not directly involved in the investigation incorporated standard form language used by the FBI when communicating with victims and were not drafted or reviewed by the subjects Moreover the statement that the matter was 223under investigation was not false because the government in fact continued to investigate the case in anticipation that Epstein would not fulfill the terms of the NPA However letters risked misleading the victims and contributed to victim frustration and confusion by failing to provide important information about the status of the investigation The letters also demonstrated a lack of coordination between the federal agencies responsible for communicating with Epstein 2s victims and showed a lack of attention to and oversight regarding communication with victims After the NPA was signed Acosta elected to defer to the State Attorney the decision whether to notify victims about the state 2s plea hearing pursuant to the state 2s own victim 2s rights requirements Although Acosta 2s decision was within his authority and did not constitute professional misconduct OPR concludes that Acosta exercised poor judgment when he failed to make certain that the state intended to and would notify victims identified through the federal investigation about the state plea hearing His decision left victims uninformed about an important proceeding that resolved the federal investigation an investigation about which the USAO had communicated with victims for months It also ultimately created the misimpression that the Department intentionally sought to silence the victims Acosta failed to ensure that victims were made aware of a court proceeding that was related to their own cases and thus he failed to ensure that victims were treated with forthrightness and dignity I i i i CA/Aronberg-0753 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM principles was too expansive his view of the federal interest in prosecuting Epstein was too I narrow and his understanding of the state system was too imperfect to justify the decision to use the NP A Furthermore because Acosta assumed a significant role in revie ing and drafting the NPA and the other three subjects who were supervisors left the USAO were transitioning to other jobs or were absent at critical junctures Acosta should have ensured more effective coordination and communication during the negotiations and before approving the final NP A The NP A was a unique resolution and one that required greater oversight and supervision than Acosta provided OPR further concludes that none of the subject attorneys committed professional misconduct with respect to the governments interactions with victims The subjects did not intentionally or recklessly violate a clear and unambiguous duty under the CVRA by entering into the NP A without consulting with victims because the USAO resolved the Epstein investigation without a federal criminal charge Significantly at the time the NPA was signed the Department did not interpret CVRA rights to attach unless and until federal charges had been filed and the federal courts had not established a clear and unambiguous standard applying the CVRA before criminal charges were brought In addition OPR did not find evidence that the lack of consultation was for the purpose of silencing victims Nonetheless the lack of consultation was part of a series of government interactions with victims that ultimately led to public and court condemnation of the governments treatment of the victims reflected poorly on the Department as a whole and is contradictory to the Departments mission to minimize the frustration and confusion that victims of a crime endure OPR determined that none of the subjects was responsible for communications sent to certain victims after the NP A was signed that described the case as under i 265vestigation and that failed to inform them of the NPA The letters were sent by an FBI administrative employee who was not directly involved in the investigation incorporated standard form language used by the FBI when communicating with victims and were not drafted or reviewed by the subjects Moreover the statement that the matter was under investigation was not false because the government in fact continued to investigate the case in anticipation that Epstein would not fulfill the terms of the NP A However the letters risked misleading the victims and contributed to victim frustration and confusion by failing to provide important information about the status of the investigation The letters also demonstrated a lack of coordination between the federal agencies responsible for communicating with Epsteins victims and showed a lack of attention to and oversight regarding communication with victims After the NP A was signed Acosta elected to defer to the State Attorney the decision whether to notify victims about the states plea hearing pursuant to the state.s own victims rights requirements Although Acostas decision was within his authority and did not constitute professional misconduct OPR concludes that Acosta exercised poor judgment when he failed to make certain that the state intended to and would notify victims identified through the federal investigation about the state plea hearing His decision left victims uninformed about an important proceeding that resolved the federal investigation an investigation about which the USAO had communicated with victims for months It also ultimately created the rriisimpression that the I Department intentionally sought to silence the victims Acosta failed to ensure that victims were made aware of a court proceeding that was related to their own cases and thus he failed to ensure I that victims were treated with forthrightness and dignity I I i i CA/Aronberg-0753 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM OPR concludes that the decision to postpone notifying victims about the terms of the NPA after it was signed and the omission of information about the NPA during victim interviews and conversations with victims attorneys in do not constitute professional misconduct Contemporaneous records show that these actions were based on strategic concerns about creating impeachment evidence that Epstein 2s victims had financial motives to make claims against him evidence that could be used against victims at a trial and were not for the purpose of silencing victims Nonetheless the failure to reevaluate the strategy prior to interviews of victims and discussions with victims attorneys occurring in led to interactions that contributed to victims feelings that the government was intentionally concealing information from them After examining the full scope and context of the government 2s interactions with victims OPR concludes that the government 2s lack of transparency and its inconsistent messages led to victims feeling confused and ill-treated by the government gave victims and the public the misimpression that the government had colluded with Epstein 2s counsel to keep the NPA secret from the victims and undercut public confidence in the legitimacy of the resulting agreement The overall result of the subjects anomalous handling of this case understandably left many victims feeling ignored and frustrated and resulted in extensive public criticism In sum OPR concludes that the victims were not treated with the forthrightness and sensitiyity expected by the Department CA/Aronberg-0754 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM OPR concludes that the decision to postpone notifying victims about the terms of the NP A after it was signed and the omission of information about the NP A during yictim interviews and conversations with victims attorneys in do not constitute professional misconduct Contemporaneous records show that these actions were based on strategic ccincerns about creating impeachment evidence that Epsteins victims had financial motives to ma claims against him evidence that could be used against victims at a trial and were not for th purpose of silencing victims Nonetheless the failure to reevaluate the strategy prior to inter liews of victims and discussions with victims attorneys occurring in led to interactions that contributed to victims feelings that the government was intentionally concealing information from them After examining the full scope and context of the governments interactions with victims OPR concludes that the governments lack of transparency and its inconsistent messages led to victims feeling confused and ill-treated by the government gave victims and the public the misimpression that the government had colluded with Epsteins counsel to keep the NPA secret from the victims and undercut public confidence in the legitimacy of the res9lting agreement The overall result of the subjects anomalous handling of this case understandably left many victims feeling ignored and frustrated and resulted in extensive public criticism In sum OPR concludes that the victims were not treated with the forthrightness and sensiti ity expected by the Department CA/Aronberg-0754 i FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Attorney 2s Offices was migrated to EOUSA 2s centralized system to be maintained The USAO 2s data was migrated between March and June EOUSA and OPR separately confirmed with the USAO that it was unable to locate any additional emails OPR questioned Acosta as well as numerous administrative staff about the email gap Acosta and the witnesses denied having any knowledge of the problem or that they or to their knowledge anyone else made any efforts to intentionally delete the emails In addition at OPR 2s request EOUSA conducted an analysis of records migrated from four other U.S Attorney 2s Offices and found that each office provided data that also contained significant gaps in their U.S Attorney email records although the time periods varied for each office OPR found no evidence indicating that the gap in Acosta 2s emails was caused by any intentional act or for the purpose of concealing evidence relating to the Epstein investigation and concludes that it was most likely the result of a technological error Although a gap in Acosta 2s email inbox from May through April remained OPR was nonetheless able to examine a significant number of Acosta 2s emails from this time due to the extensive case files kept by the USAO the availability of Acosta 2s sent email which did not contain a similar gap and the availability of emails of other USAO subjects and witnesses who were included on emails with Acosta Federal Bureau of Investigation Records OPR worked with the FBI 2s Palm Beach Office including with two case agents and the Victim Witness Specialist who worked on the Epstein matter to obtain relevant FBI documents In addition the FBI searched its Automated Case Support system and also provided documentation concerning its victim notification system Criminal Division Records The Office of the Assistant Attorney General for the Criminal Division provided OPR with Outlook data for the four individuals from that Office who examined issues connected to the USAO 2s Epstein investigation The data included the individuals inbox outbox sent deleted and saved emails and calendar entries CEOS also provided OPR with Outlook data for the four individuals from that office who worked on or examined issues connected to the USAO 2s Epstein investigation The data included the individuals inbox outbox sent deleted and saved emails CEOS also conducted a check of its shared hard drive and provided documents that were potentially relevant to OPR 2s investigation Office of the Deputy Attorney General Records OPR obtained Outlook data for the three individuals from the Office of the Deputy Attorney who examined issues connected to the USAO 2s Epstein investigation including the former Deputy Attorney General The data included the individuals inbox outbox sent deleted and saved emails and calendar entries CA/Aronberg-0756 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Attorneys Offices was migrated to EOUSAs centralized system to be maintained The USAOs I data was migrated between March and June I EOUSA and OPR separately confirmed with the USAO that it was unable to locate any additional emails OPR questioned Acosta as well as numerous administrative staff about the email gap Acosta and the witnesses denied having any knowledge of the problem or that they or to their knowledge anyone else made any efforts to intentionally delete the emails In addition at OPR request EOUSA conducted an analysis of records migrated from four other U.S Attorneys Offices and found that each office provided data that also contained significant gaps in their U.S Attorney email records although the time periods varied for each office OPR found no evidence indicating that the gap in Acostas emails was caused by any intentional act or for the purpose of concealing evidence relating to the Epstein investigation and concludes that it was most likely the result of a technological error Although a gap in Acostas email inbox from May through April remained OPR was nonetheless able to examine a significant number of Acostas emails from this time due to the extensive case files kept by the USAO the availability of Acostas sent email which did not contain a similar gap and the availability of emails of other USAO subjects and witnesses who were included on emails with Acosta Federal Bureau of Investigation Records OPR worked with the FBIs Palm Beach Office including with two case agents and the Victim Witness Specialist who worked on the Epstein matter to obtain relevant FBI documents In addition the FBI searched its Automated Case Support system and also provided documentation concerning its victim notification system Criminal Division Records The Office of the Assistant Attorney General for the Criminal Division provided OPR with Outlook data for the four individuals from that Office who examined issues connected to the USAOs Epstein investigation The data included the individuals inbox outbox sent deleted and saved emails and calendar entries CEOS also provided OPR with Outlook data for the four individuals from that office who worked on or examined issues connected to the USA Os Epstein investigation The data included the individuals inbox outbox sent deleted and saved emails CEOS also conducted a check of its shared hard drive and provided documents that were potentially relevant to OPRs investigation Office of the Deputy Attorney General Records OPR obtained Outlook data for the three individuals from the Office of the Deputy Attorney who examined issues connected to the USAOs Epstein investigation including the former Deputy Attorney General The data included the individuals inbox outbox sent deleted and saved emails and calendar entries i I I CA/Aronberg-0756 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM U.S Attorney 2s Office for the Middle District of orida Records The U.S Attorney 2s Office for the Middle District of Florida provided OPR with records related to its review of evidence against Epstein after he concluded his Florida state sentence when the Department recused the USAO in August from 223all matters to include the investigation and potential prosecution relating to Jeffrey Epstein 2s alleged sexual activities with minor females and assigned the matter to the Middle District of Florida U.S Attorney 2s Office for further consideration The records included a declination of the matter due to the NPA U.S Attorney 2s Office for the Northern District of Georgia Records The U.S Attorney 2s Office for the Northern District of Georgia provided OPR with records related to its work on the CVRA litigation after the recusal of the USAO Public Records OPR obtained and reviewed a variety of public records including publicly released records of the Palm Beach Police Department the State Attorney 2s Office for the 15th Judicial Circuit and the Palm Beach Sheriffs Office documents pertaining to the CVRA litigation and other court proceedings involving Epstein and related individuals and books and media reports Information from Subjects Witnesses and Victims Subjects OPR requested that all five subjects provide written responses detailing their involvement in the federal investigation of Epstein the drafting and execution of the NPA and decisions relating to victim notification and consultation In addition OPR conducted extensive interviews of each subject under oath and before a court reporter Each subject was represented by counsel and had access to relevant contemporaneous documents before the subject 2s OPR interview The subjects reviewed and provided comments on their interview transcripts and on OPR 2s draft report Witnesses OPR conducted more than interviews of witnesses including the FBI case agents their supervisors and FBI administrative personnel OPR interviewed current and former USAO staff and attorneys and current and former Department attorneys and senior managers including former Deputy Attorney General Mark Filip and former Assistant Attorney General for the Criminal Division Alice Fisher OPR also interviewed former State Attorney Barry Krischer and former Assistant State Attorney Lanna Behlolovick Communications with Victims and Victims Attorneys OPR contacted attorneys known to represent victims among the surviving individuals who were identified in the USAO 2s July listing of victims the USAO was prepared to include in federal charges against Epstein and who accordingly were entitled to the benefits of the U.S.C monetary damages provision of the NPA OPR contacted Ithe attorneys to invite CA/Aronberg-0757 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM U.S Attorneys Office for the Middle District of Florida Records I The U.S Attorneys Office for the Middle District of Florida provided OPR with records I related to its review of evidence against Epstein after he concluded his Florida state sentence when the Department recused the USAO in August from all matters to include the investigation and potential prosecution relating to Jeffrey Epsteins alleged:sexual activities with minor females and assigned the matter to the Middle District of Florida U.S Attorneys Office for further consideration The records included a declination of tlie matter due to the NP A U.S Attorneys Office for the Northern District of;Georgia Records The U.S Attorneys Office for the Northern District of Georgia provided OPR with records related to its work on the CVRA litigation after the recusal of the USAO Public Records OPR obtained and reviewed a variety of public records including publicly released records of the Palm Beach Police Department the State Attorneys Office for the 15th Judicial Circuit and the Palm Beach Sheriffs Office documents pertaining to the CVRA litigation and other court proceedings involving Epstein and related individuals and books and media reports Information from Subjects Witnesses and Victims Subjects OPR requested that all five subjects provide written responses detailing their involvement in the federal investigation of Epstein the drafting and execution of the NPA and decisions relating to victim notification and consultation In addition OPR conducted extensive interviews of each subject under oath and before a court reporter Each subject was represented by counsel and had access to relevant contemporaneous documents before the subjects OPR interview The subjects reviewed and provided comments on their interview transcripts and on OPRs draft report Witnesses OPR conducted more than interviews of witnesses including the FBI case agents their supervisors and FBI administrative personnel OPR interviewed current aqd former USAO staff and attorneys and current and former Department attorneys and senior managers including former Deputy Attorney General Mark Filip and former Assistant Attorney Gen:eral for the Criminal Division Alice Fisher OPR also interviewed former State Attorney Barry Krischer and former Assistant State Attorney Lanna Behlolovick Communications with Victims and Victims Attorneys OPR contacted attorneys known to represent victims among the surviving individuals who were identified in the USAOs July listing of victims the USAO was prepared to I include in federal charges against Epstein and who accordingly were entitled to the benefits of the U.S.C monetary damages provision of the NPA OPR contacted the attorneys to invite CA/Aronberg-0757 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM the victims to provide OPR with information regarding their contacts yith and notification received from the FBI and USAO during the period before the NPA was signed or before Epstein 2s state plea hearing about the status of the federal investigation about Epstein 2s state plea or about the NPA OPR received information from or pertaining to victims CA/Aronberg-0758 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM the victims to provide OPR with information regarding their contacts and notification received from the FBI and USAO during the period before the NPA was signed or before Epsteins state plea hearing about the status of the federal investigation abo Epsteins state plea or about the NPA OPR received information from or pertaining to victihls CA/Aronberg-0758 I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I EXHIBIT State Indictment CA/Aronberg-0759 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT State Indictment CA/Aronberg-0759 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0760 Page Intentionally Left Blank FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i Page Intentionally Left Blank CNAronberg-0760 i FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I INDICTMENT A TRUE BILL rn IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLdRjD 2A r.-J-CD CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA no cn For Palm Beach County at the Spring Term thereof in the-year of our Lord Two ThouSg IWd Six to-wit The Grand Jurors of the State of-Florida inquiring Beach upon their oaths do present that JEFFREYX EPSTEIN in the County of Palm Beach aforesaid inthe Circuit and State aforesaid COUNT ONE 225FELONY SOLICITATION OF PROSTITUTION On or about or betweemthe st day of August in the year.of our Lord Two Thousand and Four and October did solicit induce entice or procure another to commit prostitution lewdness or assignation contrary to Florida Statute796.07 on three or more occasions between August:0i contrary to Florida Statute and DEGFEL LEVEL1 against the form of the statute to the evil example of all others and against therpeace and dignity of the State of Florida I hereby certify that I recortf in!my Wice Y-Ci wt MUgutW ssiwant-State Attorney Fifteenth Judicial Circit of the State Florida prosecuting for the said o0 utYCiWK 221State GRAND JURY FOREPERSON Jeffrey Epstein Race:White Sexi Male DOB SS Issue Warrant CA/Aronberg-0761 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM INDICTMENT A TRUE Bit.,L t_ JCt Jr 1N rHe AND av 267THe 267ALJTHOR i-v of:tH1 267stAte 1ffigA IN tHE CIRCUiT 267coURt OF THE FIFTEENTH JUDICIAL 267c1RCUll.QF."J.HE STATE.OF:flORtOA For Palm ou ty th_e Spring ern tt er of in 267the Br Qf our Lora 267TYJo Thq Sl wib Th Gra,nc:i Jurors the State of,f:iorjda;inquiririg.in ria:for the 225pody said nty Palm:Be ch upon heir 267oaths do J?,resent that Jl;FFREY EPSTEIN in Courity of lm sea ch afor S?ld ir1 Circuit and Stat af resaid_ COUNT ONE LONY 267souciTATION OF,RF osr1tut10.N on ab ut_orbetwe.en,tt HS!.day Augustin the._y ar.of our t;.or Tw9Thousanda_nr:J Four rid 225Qct t3r qlicJt;Jriquc ent!c prqcure.af!6therto commit P9 1tution,1ewd19 s,,or ass!gn.atioli coritr ry 267-F.lorid on ree or,_ more occasio.ns.between ust n.d 267.October3l OO;i contrary to Florida Stc!tUte796:07 and _3 FEt EVEL against the_ fomi_ ofthe sta_tuie to tt:ie evil exc1mple of all ot_hers 267and against the:peace and:digr,,ity the State I of Floriga I hereby f.i WYetUrn,ing this indictment as.au,ttiorfzed.and,required byiaw l!l e.trr 1tyAn a 18iegoing nrue copy n!co1 iti.inY:ii EL 225JE,!ffrey _Epstein Rae White i Mc1le,DOB SS Issue Warrant CA Aronberg-0761 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0762 Page Intentionally Left Blank FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Intentionally Left Blank CNAronberg-0762 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT I September Draft Non-Prosecution Agreement CA/Aronberg-0763 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0763 EXHIBIT September Draft Non-Prosecution Agreement FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Page Intentionally Left Blank I CA/Aronberg-0764 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Intentionally Left Blank CA/Aronberg-0764 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM IN RE INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that Jeffrey Epstein hereinafter 223Epstein is reported to have committed offenses against the United States from in or around through in or around October including knowingly and willfully conspiring with others known and unknown to commit an offense against the United States that is to use a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Section all in violation of Title United States Code Section knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females in violation of Title United States Code Section all in violation of Title United States Code Section using a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Sections and traveling in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females in violation of Title United States Code Section and knowingly in and affecting interstate and foreign commerce recruiting enticing and obtaining by any means a person knowing that the person had not attained the age of years and would be caused to engage in a commercial sex act as defined in U.S.C in violation of Title United States Code Sections a and and IT APPEARING that Epstein has accepted responsibility for his behavior by his flays CA/Aronberg-0765 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM INRE INVESTIGATION OF JEFFREY EPSTEIN I NON-PROSECUTION AGREEMENT IT APPEARING that Jeffrey Epstein hereinafter Epstein is reported to have committed offenses against the United States from in or around through in or around October including knowingly and willfully conspiring with others known and unknown to commit an offense against the United States that is to use a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Section all in violation of Title United States Code Section knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illidt sexual conduct as defined in U.S.C with minor females in violation of Title United States Code Section all in violation of Title United States Code Section using a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Sections and traveling in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females in violation of Title United States Code Section and knowingly in and affecting interstate and foreign commerce recruiting enticing and obtaining by any means a person knowing that the person had not attained the age of years and would be caused to engage in a commercial sex act as defined in U.S.C in violation of Title United States Code Sections a and and IT APPEARING that Epstein has accepted responsibility for ihis behavior by his I Tiay6 i CNAronberg-0765 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM signature on this Agreement and i IT APPEARING after an investigation of the offenses and Epstein 2s background that the interest of the United States and Epstein 2s own interest and the interest of justice will be served by the following procedure THEREFORE on the authority of Alexander Acosta United States Attorney for the Southern District of Florida prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida provided that Epstein abides by the following conditions and the requirements of this Agreement set out below Should Epstein violate any of the conditions of this Agreement the United States Attorney may at any time initiate prosecution against Epstein for any offense In this case the United States Attorney will furnish Epstein with notice specifying the conditions of the Agreement which he has violated After timely fulfilling all the terms and conditions of the Agreement no prosecution for the offenses set out on page of this Agreement will be instituted in this District and the charges against Epstein if any will be dismissed Neither this Agreement nor any other document filed with the United States Attorney as part of this Agreement will be used against Epstein except for impeachment purposes in connection with any prosecution for the above-described offenses Terms of the Agreement Epstein shall plead guilty not nolo contendere to an Information filed by the State Attorney 2s Office for the 15th Judicial Circuit in and for Palm Beach County hereinafter the 223State Attorney 2s Office charging violations of the following Florida Statutes a lewd and lascivious battery on a child in violation of Fl Stat solicitation of minors to engage in prostitution in violation of Fl Stat and engaging in sexual activity with minors at least sixteen years of age in violation of Fl Stat Epstein and the State Attorney 2s Office shall make a joint binding recommendation that Epstein serve at least two years in prison without any opportunity for withholding adjudication or sentencing and without probation or community control in lieu of imprisonment Haye CA/Aronberg-0766 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM signature on this Agreement and I IT APPEARING after an investigation of the offenses and Epsteins background that the interest of the United States and Epsteins own interest and the inter st of justice will be served by the following procedure THEREFORE on the authority of Alexander Acosta United States Attorney for the Southern District of Florida prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida provided that Epstein abides by the following conditions and the requirements of this Agreement set out below Should Epstein violate any of the conditions of this Agreement the United States Attorney may at any time initiate prosecution against Epstein for any offense In this case the United States Attorney will furnish Epstein with notice specifying the conditions of the Agreement which he has violated After timely fulfilling all the terms and conditions of the Agreement no prosecution for the offenses set out on page of this Agreement will be instituted in this District and the charges against Epstein if any will be dismissed Neither this Agreement nor any other document filed with the United States Attorney as part this Agreement will be used against Epstein except for impeachment purposes connection with any prosecution for the above-described offenses Terms of the Agreement CA/Aronberg-0766 Epstein shall plead guilty not nolo contendere to an Information filed by the State Attorneys Office for the 15th Judicial Circuit in and for Palm Beach County hereinafter the State Attorneys Office charging violations of the following Florida Statutes a lewd and lascivious battery on a child in violation of Fl Stat solicitation of minors to engage in prostitution in violation of Fl Stat and engaging in sexual activity with minors at least sixteen years of age in violation of Fl Stat Epstein and the State Attorneys Office shall make a joint binding recommendation that Epstein serve at least two years in prison without any opportunity for withholding adjudication or se tencing and without probation or community control in lieu of imprisonm ent I IlayE ocp FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Epstein shall waive all challenges to the Information filed by the State Attorney 2s Office and shall waive the right to appeal his conviction and sentence Epstein agrees that if any of the victims identified in the federal investigation file suit pursuant to U.S.C Epstein will not contest the jurisdiction of the U.S District Court for the Southern District of Florida over his person and/or the subject matter and Epstein will not contest that the identified victims are persons who while minors were victims of violations of Title United States Code Sections and/or The United States shall provide Epstein 2s attorneys with a list of the identified victims which will not exceed forty after Epstein has signed this agreement and entered his guilty plea The United States shall make a motion with the United States District Court for the Southern District of Florida for the appointment of a guardian ad litem for the identified victims and Epstein 2s counsel may contact the identified victims through that counsel Epstein shall enter his guilty plea and be sentenced not later than September and shall begin service of his sentence not later than October By signing this agreement Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein for any and all federal offenses By signing this agreement Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial Epstein further is aware that Rule of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment information or complaint for unnecessary delay in presenting a charge to the Grand Jury filing an information or in bringing a defendant to trial Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution as provided for in the terms expressed herein shall be deemed to be a necessary delay at his own request and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreemenVand the breach of this Uaye CA/Aronberg-0767 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Epstein shall waive all challenges to the Information filed by the State Attorneys Office and shall waive the right to appekl his conviction and sentence Epstein agrees that if any of the victims identified in the federal investigation file suit pursuant to U.S.C Epstein will not contest the jurisdiction of the U.S District Court for the Southern District of Florida over his person and/or the subject matter and Epstein will not contest that the identified victims are persons who while minors were victims of violations of Title United States Code Sections and/or The United States shall provide Epsteins attorneys with a list of the identified victims which will not exceed forty after Epstein has signed this agreement and entered his guilty plea The United States shall make a motion with the United States District Court for the Southern District of Florida for the appointment of a guardian ad item for the identified victims and Epsteins counsel may contact the identified victims through that counsel Epstein shall enter his guilty plea and be sentenced not later than September and shall begin service of his sentence not later than October By signing this agreement Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein for any and all federal offenses By signing this agreement Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial Epstein further is aware that Rule of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment information or complaint for unnecessary delay in presenting a charge to the Grand Jury filing an information or in bringing a defendant to trial Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution as provided for in the terms expressed herein shall be deemed to be a necessary delay at his own request and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statJte of limitations for a period of months equal to the period between the signing of this agreement:and the breach of this Daye ocp CA/Aronberg-0767 I I I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM agreement Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule a of the Federal Rules of Civil Procedure provide that all felonies must be charged in an indictment presented to a grand jury Epstein hereby agrees and consents that if a prosecution against him is instituted it may be by way of an Information signed and filed by the United States Attorney and hereby waives his right to be indicted by a grand jury By signing this agreement Epstein asserts and certifies that the above has been read and explained to him Epstein hereby states that he understands the conditions of this non-Prosecution Agreement and agrees to comply with them Dated:_ Jeffrey Epstein Dated:_ Roy Black Esq Counsel to Jeffrey Epstein ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated:_ By A Marie Villafana Assistant United States Attorney Hays CA/Aronberg-0768 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM agreement Epstein further asserts and certifies.that he understands that the Fifth Amendment and Rule a of the Federal Rules of Civil Procedure provide that all felo nies must be charged in an indictment presented to a grand jury Epstein hereby agrees ana consents that if a I prosecution against him is instituted it may be by way of an Information signed and filed by the United States Attorney and hereby waives his right to be indicted by a gran:d jury By signing this agreement Epstein asserts and certifies that the above has been read and explained to him Epstein hereby states that he understands the conditions of this non-Prosecution Agreement and agrees to comply with them Dated Dated Dated CA/Aronberg-0768 Jeffrey Epstein Roy Black Esq Counsel to Jeffrey Epstein ALEXANDER ACOSTA UNITED ST A TES ATTORNEY By A Marie Villafana Assistant United States Attorney Ilaye FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT September Non-Prosecution Agreement CA/Aronberg-0769 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0769 EXHIBIT September Non-Prosecution Agreement FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Intentionally Left Blank CA/Aronberg-0770 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Intentionally Left Blank CA/Aronberg-0770 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I IN RE INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney 2s Office for the 15th Judicial Circuit in and for Palm Beach County hereinafter the 223State Attorney 2s Office have conducted an investigation into the conduct of Jeffrey Epstein hereinafter 223Epstein IT APPEARING that the State Attorney 2s Office has charged Epstein by indictment with solicitation of prostitution in violation of Florida Statutes Section IT APPEARING that the United States Attorney 2s Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein 2s background and any offenses that may been committed by Epstein against the United States from in or around through in or around September including knowingly and willfully conspiring with others known and unknown to commit an offense against the United States that is to use a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Section all in violation of Title United States Code Section knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females in violation of Title United States Code Section all in violation of Title United States Code Section using a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Sections and traveling in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females in violation i Page of i CA/Aronberg-0771 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM INRE INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorneys Office for the 15th Judicial Circuit in and for Palm Beach County hereinafter the State Attorneys Office have conducted an investigation into the conduct of Jeffrey Epstein hereinafter Epstein IT APPEARING that the State Attorneys Office has charged Epstein by indictment with solicitation of prostitution in violation of Florida Statutes Section IT APPEARING that the United States Attorneys Office and the Federal Bureau of Investigation have conducted their own investigation into Epsteins background and any offenses that may have been committed by Epstein against the United States from in or around through in or around September including CA Aronberg-0771 knowingly and willfully conspiring with others known and unknown to commit an offense against the United States that is to use a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Section all in violation of Title United States Code Section knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females in violation of Title United States Code Section all in violation of Title United States Code Section using a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Sections and traveling in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor fe ales in violation i Page of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM of Title United States Code Section and knowingly in and affecting interstate and foreign commerce recruiting enticing and obtaining by any means a person knowing that the person had not attained the age of years and would be caused to engage in a commercial sex act as defined in U.S.C in violation of Title United States Code Sections a and and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that in exchange for the benefits provided by this agreement he agrees to comply with its terms including undertaking certain actions with the State Attorney 2s Office IT APPEARING after an investigation of the offenses and Epsteins background by both State and Federal law enforcement agencies and after due consultation with the State Attorneys Office that the interests of the United States the State of Florida and the Defendant will be served by the following procedure THEREFORE on the authority of Alexander Acosta United States Attorney for the Southern District of Florida prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below If the United States Attorney should determine based on reliable evidence that during the period of the Agreement Epstein willfully violated any of the conditions of this Agreement then the United States Attorney may within ninety days following the expiration of the term of home confinement discussed below provide Epstein with timely notice specifying the condition of the Agreement that he has violated and shall initiate its prosecution on any offense within sixty days of giving notice of the violation Any notice provided to Epstein pursuant to this paragraph shall be provided within days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement After timely fulfilling all the terms and conditions of the Agreement no prosecution for the offenses set out on pages and of this Agreement nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney 2s Office nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District and the charges against Epstein if any will be dismissed Page of CA/Aronberg-0772 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I of Title United States Code Section and I kn f:C dfi owrng rn an a 1ectmg mterstate an ore1gn commerce recnntrng enticing and obtaining by any means a person,_knowing th the person had not attained the age of years and would be caused to engage in a commercial sex act as defrned in U.S.C in violation of Title United States Code Sections a and and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that in exchange for the benefits provided by this agreement he agrees to comply with its terms including undertaking certain actions with the State Attorneys Office IT APPEARING after an investigation of the offenses and Epsteins background by both State and Federal law enforcement agencies and after due consultation with the State Attorneys Office that the interests of the United States the State of Florida and the Defendant will be served by the following procedure TIIEREFORE on the authority of Alexander Acosta United States Attorney for the Southern District of Florida prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below If the United States Attorney should determine based on reliable evidence that during the period of the Agreement Epstein willfully violated any of the conditions of this Agreement then the United States Attorney may within ninety days following the expiration of the term of home confinement discussed below provide Epstein with timely notice specifying the condition of the Agreement that he has violated and shall initiate its prosecution on any offense within sixty days of giving notice of the violation Any notice provided to Epstein pursuant to this paragraph shall be provided within days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement After timely fulfilling all the terms and conditions of the Agreemerit no prosecution for the offenses set out on pages and of this Agreement nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorneys Office nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District and the charges against Epstein if any will be dismissed Page of CNAronberg-0772 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Terms of the Agreement Epstein shall plead guilty not nolo contendere to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County Case No charging one count of solicitation of prostitution in violation of Fl Stat In addition Epstein shall plead guilty to an Information filed by the State Attorney 2s Office charging Epstein with an offense that requires him to register as a sex offender that is the solicitation of minors to engage in prostitution in violation of Florida Statutes Section Epstein shall make a binding recommendation that the Court impose a thirty month sentence to be divided as follows a Epstein shall be sentenced to consecutive terms of twelve months and six months in county jail for all charges without any opportunity for withholding adjudication or sentencing and without probation or community control in lieu of imprisonment and Epstein shall be sentenced to a term of twelve months of community control consecutive to his two terms in county jail as described in Term a supra This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney 2s Office and Epstein the details of which are set forth in this agreement The terms contained in paragraphs and supra do not foreclose Epstein and the State Attorney 2s Office from agreeing to recommend any additional charge or any additional term of probation and/or incarceration Epstein shall waive all challenges to the Information filed by the State Attorney 2s Office and shall waive the right to appeal his conviction and sentence except a sentence that exceeds what is set forth in paragraph supra Epstein shall provide to the U.S Attorney 2s Office copies of all Page of CA/Aronberg-0773 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Tenns of the Agreement CA/Aronberg-0773 Epstein shall plead guilty not nolo contendere to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County Case No charging one count of solicitation of prostitution in violation of FL Stat In addition Epstein shall plead guilty to an Infonnation filed by the State Attorneys Office charging Epstein with an offense that requires him to register as a sex offender that is the solicitation of minors to engage in prostitution in violation of Florida Statutes Section Epstein shall make a binding recommendation that the Court impose a thirty month sentence to be divided as follows a Epstein shall be sentenced to consecutive terms of twelve months and six months in county jail for all charges without any opportunity for withholding adjudication or sentencing and without probation or community control in lieu of imprisonment and Epstein shall be sentenced to a term of twelve months of community control consecutive to his two terms in county jail as described in Term a supra This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorneys Office and Epstein the details of which ate set forth in this agreement The terms contained in paragraphs and supra do not foreclose Epstein and the State Attorneys Office from agreeing to recommend any additional charge or any additional term of probation and/or incarceration Epstein shall waive all challenges to the Information filed by the State Attorneys Office and shall waive the right to appeal his conviction and sentence except a sentence that exceeds what is set forth in paragraph supra Epstein shall provide to the U.S Page of Attorneys Office copies of all I I I I I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM proposed agreements with the State Attorney 2s Office prior to entering into those agreements The United States shall provide Epstein 2s attorneys with a list of individuals whom it has identified as victims as defined in U.S.C after Epstein has signed this agreement and been sentenced Upon the execution of this agreement the United States in consultation with and subject to the good faith approval of Epstein 2s counsel shall select an attorney representative for these persons who shall be paid for by Epstein Epstein 2s counsel may contact the identified individuals through that representative If any of the individuals referred to in paragraph supra elects to file suit pursuant to U.S.C Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein so long as the identified individual elects to proceed exclusively under U.S.C and agrees to waive any other claim for damages whether pursuant to state federal or common law Notwithstanding this waiver as to those individuals whose names appear on the list provided by the United States Epstein 2s signature on this agreement his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability Epstein 2s signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States Except as to those individuals who elect to proceed exclusively under U.S.C as set forth in paragraph supra neither Epstein 2s signature on this agreement nor its terms nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whether or not her name appears on the list provided by the United States Epstein shall use his best efforts to enter his guilty plea and be i Page of I i i CA/Aronberg-0774 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0774 proposed agreements with the State Attorneys Office prior to entering into those agreements I I I The United States shall provide Epsteins attorneys with a list of individuals whom it has identified as victims as defined in U.S.C after Epstein has signed this agreement and been sentenced Upon the execution of this agreement the United States in consultation with and subject to the good faith approval of Epsteins counsel shall select an attorney representative for these persons who shall be paid for by Epstein Epsteins counsel may contact the identified individuals through that representative If any of the individuals referred to in paragraph supra elects to file suit pursuant to U.S.C Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein so long as the identified individual elects to proceed exclusively under U.S.C and agrees to waive any other claim for damages whether pursuant to state federal or common law Notwithstanding this waiver as to those individuals whose names appear on the list provided by the United States Epsteins signature on this agreement his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability Epsteins signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States Except as to those individuals who elect to proceed exclusively under U.S.C as set forth in paragraph supra neither Epsteins signature on this agreement nor its terms nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whether or not her name appears on the list provided by the United States Epstein shall use his best efforts to enter his guilty plea and be Page of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM sentenced not later than October The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January Epstein agrees that he will not be afforded any benefits with respect to gain time other than the fights opportunities arid benefits as tiny other inmate including but not limited to eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida At the United States request Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration The parties anticipate that this agreement will not be made part of any public record If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement it will provide notice to Epstein before making that disclosure Epstein understands that the United States Attorney has no authority to require the State Attorney 2s Office to abide by any terms of this agreement Epstein understands that it is his obligation to undertake discussions with the State Attorney 2s Office and to use his best efforts to ensure compliance with these procedures which compliance will be necessary to satisfy the United States interest Epstein also understands that it is his obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein 2s binding recommendation regarding the sentence to be imposed and understands that the failure to do so will be a breach of the agreement In consideration of Epstein 2s agreement to plead guilty and to provide compensation inthe manner described above if Epstein successfully fulfills all of the terms and conditions of this agreement the United States also agrees that it will not institute any crimina hames against any potential co-conspirators of Epstein including but not limited to Further execution agreement and a plea agreement with the State Attorney 2s Office the federal Grand Jury investigation will be suspended and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas Both parties agree to maintain their evidence specifically evidence requested by or directly related to the grand jury subpoenas that have beeri issued and including certain computer equipment inviolate until all of the terms of this agreement have been satisfied Upon the successful completion of the terms of this agreement all outstanding grand jury subpoenas shall be deemed withdrawn Page of CA/Aronberg-0775 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM sentenced not later than October26 The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January Epstein agrees that he will not be afforded any benefits with respect to gairi time other than the tights opportunities and benefits as any other inmate including but not limited to eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida At the United States request Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration The parties anticipate that tlus agreement will not be macie part of any public record If the United States receives a Freedom oflnformation Act request or any compulsory process commanding the disclosure of the agreement it will provide notice to Epstein before making that disclosure Epstein understands that the United States Attorney has no authority to require the State Attorneys Office to abide by any terms of this agreement Epstein understands that it is his obligation to undertake discussions with the State Attorneys Office and to use his best efforts to ensure compliance with these procedures which compliance will be necessary to satisfy the United States interest Epstein also under tands that it is his obligationtouse his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epsteins binding ommendation regarding the sentence to be imposed and understands that the failure to do so will be a breach of the agreement In consideration of Epsteins agreement to plead guilty and to provide coml nsation inthe manner described above if Epstein successfully fulfills all of the terms and conditions of this agreement the United States also agrees that it will not institute any criminal char es against any potential cerconspirators of Epstein lncluding but not limited to Further upon execution of this agreement and a plea agreement with the State Attomcys Office the fed ral Grand Jury investigation will be suspended and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas Both parties agree to maintain their evidence specifically evidence rcqu tcd by or dit:ectly related to the grand jury subpoenas that have beert issued and including certain computer equipment inviolate until all of the terms of this agreement have been satisfied Upon the successful completion of the terms of this agreement all outstanding grand jury subpoenas shall be deemed withdrawn Page of CA/Aronberg-0775 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM By signing this agreement Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses By signing this agreement Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial Epstein further is aware that Rule of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment information or complaint for unnecessary delay in presenting a charge to the Grand Jury filing an information or in bringing a defendant to trial Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution as provided for in the terms expressed herein shall be deemed to be a necessary delay at his own request and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury 2s investigation Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule a of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury Epstein hereby agrees and consents that if a prosecution against him is instituted for any offense that was the subject of the grand jury 2s investigation it may be by way of an Information signed and filed by the United States Attorney and hereby waives his right to be indicted by a grand jury as to any such offense Ill I I Page of CA/Aronberg-0776 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM By signing this agreement Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses By signing this agreement Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial Epstein further is aware that Rule of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment information or complaint for unnecessary delay in presenting a charge to the Grand Jury filing an information or in bringing a defendant to trial Epstein hereby requests that the United States Attorney for the Southern District ofFlorida defer such prosecution Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution as provided for in the terms expressed herein shall be deemed to be a necessary delay at his own request and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jurys investigation Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule a of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury Epstein hereby agrees and consents that if a prosecution against him is instituted for any offense that was the subject of the grand jurys investigation it may be by way of an Information signed and filed by the United States Attorney and hereby waives his right to be indicted by a grand jury as to any such offense II I II I Ill CNAronberg-0776 Page of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM By signing lliisagreement Epstein asserts aiici certifies that the above has been read and explained to him Epstein hereby states that he understands the conditions of this Non Prosecution Agreement and agrees to comply with them ALEX ANDER ACOSTA UNITED ST ATES ATTORN EY A MARIE VILLAFANA ASSISTANT U.S ATTORNEY Dated JEFFREY Dated GERALD LEFCOURT ESQ COUNSEL TO JEFFREY EPSTEIN Dated LILLY ANN SANCHEZ ESQ ATTORNEY FOR JEFFREY EPSTEIN Page 7of7 CA/Aronberg-07 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Lliis agrcerpe11t;.Ep teii1,asserts aiid tljftes that:thc ibove has,bee1i 1e ai1d expla ned to Epstein Hei 267cby states t11at he undcrst pds the cond i tions qf is on roscclilion_.Agrccmcnt and agrees to somrly with thcrp By CA Aronberg-07 AtEXANDERACOSTA UNITED A MARIE VILLAFANA AssfsTANT fos ATTQ N-tY 267OERALi L13FCbUJ t;:ESQ C0VNSELTQ JEFFREY EJJ,SJEJN LiLLY ANNSANCIJ isQ NFTORNEY FQR 275FFREY EPSTEIN FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM tBytsignmg-tblsrt rccmfenUJ THe above has been read and explained to him.J Epstein:hereby stales that he understands the.conditions of this Non Prosecution Agreement and agrees to comply with them ALEX AND EK ACOSTA UNITEDSTATESATTORNEY By ASSISTANT U.S ATTORNEY Dated JEFFREY EPSTEIN Dated Dated RAED liR ES COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ ESQ ATTORNEY FOR JEFFREY EPS TEIN Page of CA/Aronberg-0778 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ig11ing thi aglccm9nt,E tcincasscrls Lccitifics that Hlc above h4s en rcaci anti cxplainc:d lo him Epstcin:hcreby:slalc:rllmt he understands the concliti61 ofthisNori i ros,ec ticrn A recmci1t md,agrne to,co1nply 225v;ith 267thcm By Dated CA Aronberg-0778 A1:i:xANDEll Atos A UNJT STA2S A1TOR,Nl ASSISFANTU.S Al TDRNEY ULLYANN SANCHEZ ESQ ATI0RNEY 267oii 11::irni ElSr lN FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM By sighing;this agreement Epstein asserts and certifies;that the abovchas.becn read and explained to him Epstein herebystates that hc understands the conditions of this Non Prosecution Agreement and agrees to comply with them ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated By A MARIE VJLLAFANA ASSISTANT U.S ATTORNEY Dated Dated JEFFREY EPSTEIN GERALD LEFCOURT ESQ COUNSEL TO JEFFREY EPSTEIN Dated cA TILLY ANN AN TlZ ESQ ATTORNEY FOR JEFFREY EPSTEIN Page of CA/Aronberg-0779 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM l3y sigiJi,i1g this agreement stein_ serts and ccrtifies;that he abovc becn ryaci and 267cxplaincd.foniin Epstcin 267hercby 267slales,that:hc.undcrstands the 267cohditions ofthisNoiic rosecution Agr.e1::1ent,and 1.gr c_s to comply_ vith 1hem I atcd CA Aronberg-0779 ALEX:ANDERACOS UNTTED STATES ATTORJffiY A;tviARJE-VJLLA;FANA ASSISTA.i 1T_;lJ;S A.TTORNEY A JEPEREY EP TEIN GBRALD,LEfCO_Uitf S,Q COUNS LTOJEFFRE EPS:TEIN AlTORNJ?Yf.QRJEFFREYEPS::TN gc7of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0780 Page Intentionally Left Blank FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Intentionally Left Blank CA/Aronberg-0780 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT Addendum to the Non-Prosecution Agreement CA/Aronberg-0781 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT Addendum to the Non-Prosecution Agreement CA/Aronberg-0781 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0782 Page Intentionally Left Blank FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Intentionally Left Blank CA/Aronberg-0782 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM IN RE INVESTIGATION OF JEFFREY EPSTEIN _t ADDENDUM TO THE NON-PROSECUTION AGREEMENT IT APPEARING that the parties seek to clarify certain provisions of page paragraph of the Non-Prosecution Agreement hereinafter 223paragraph that agreement is modified as follows 7A the United States has the rightto assign to an independent third-party the responsibility for consulting with and subject to the good faith approval of Epsteins counsel selecting the attorney representative for the individuals identified under the Agreement If the United States elects to assign this responsibility to an independent third-party both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative 7B The parties will jointly prepare a short written submission to the,independent third-party regarding the role of the attorney representative and regarding Epstein 2s Agreement to pay such attorney representative his or her regular customary hourly rate,for representing such victims subject to the provisions of paragraph infra 7C Pursuant to additional paragraph 7A Epstein has agreed to pay the fees of the attorney representative selected by the independent third party This provision however shall not obligate Epstein to pay the fees and costs of contested litigation filed against him Thus if after consideration.Of potentialsettlements an attorney representative elects to file a contested lawsuit pursuant to U.S.C or elects to pursue any other contested remedy the paragraph obligation of the Agreement to pay the costs of the attorney representative as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those containedin to bear the costs of the attorney representative shall cease CA/Aronberg-0783 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM INRE JNVESUGATIONOF JEFFREY EPSTEIN ADDENDUM TOT ON-PROSECUTION AGI_IBEMENT IT APPEARING that the parties seektoclaritycertajn provisions of page paragraph of the Non-Prosecution Agreement hereinafter paragraph that agreement is modifi as follows A The United States has the right to assign to an independent thirdsparty the responsibility for co11 u!ting with and ubject to the 267goc;id Jaith approv_al ofEpst.tim co nsel lecting the attorney representative for the individuals identified under the Agreement If the United States elects to assign thisresponsibilifyto lili independentthird party both the United States and Epstein retain the right to make good faith objectiol to the attorney representative suggested by the independent third-party prior to the finai designation of the.attorney representative 7B The parties will jointly prepare a short written submission to the,independent third-party regarding the r_ole of.the attorney representative and regarding Epstein s:Agreemert to pay such,attorney representative his:or her regularcustomary hourly rate.for representing such 267victims subjcctto the provisions of paragraph infra 7C Pursuant:to additional paragraph 7A Epsteirthas agreed to pay the fees of the attorney representative selected by the independent.third party This provision however shall not obligate Epstein to pay:the fees and costs of contested litigation.filed-against hiin Thus if after consi,deration.ofpotentiatsettlements an attorney 267representative electno file a contested lawsuit pursuantto u:s.c oi"elects to pursue an other-contested remedy the paragraph obligation of the Agreement to pay the costs of the attorney representative as opposed to any statutory-or other obligations:to pay reasonable attorneys Jees and costs such as those contained in to bear the costs of the attorney representativt shall cease CA Aronberg-00O783 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM iBysignin 2gthis Addendum Epsrein erts and has been read and explained him Epstein hereby states that he understands the-clarifications to the.Non Pjosecution Agreement and agrees tocomplywith them iR ALE NbER ACOSTA rUNITED-STATES ATTORNEY fe WfAUMAME VlLLAFANA ASSIST U.SJ-ATTORNEY Dated Dated __ GERALD LEFCOURT ESQ COWSEL.TOIEFFREyE Dated sErcuy mSANCHEZ ATTORNEY FOR JEFFREY EPSTEIN CA/Aronberg-0784 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM By:signirlgtlifs na Epstein.asserts ancli iitifi.efttilit tb.eJ11 crvi:h cen cb ro iji te n:f,hlf!Br tJ BAds f:he fef fj uti nt.y,d grees to co P,ly tlj th CA/Aronberg-0784 A CEXANOERACOSTA If Tf et flHli zY!:f fflWlf mfA MA.RlB Vl A A1 AsststANT:u.s::A n:oRi-lEt If FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM By-Signing this-Addendum Epstein asserts certifieslffiat ai explained to-hinv.;Epstein:thereby states;that hejunderstands the.clarifications-to iheiNdn 221Prosecution Agreement and agrees to comply with them Rd ALEXANDER ACOSTA UNITED STATES ATTORNEY1 Dated Dated By A MARIE VILLAFARA assistantu JEFFREY EPSTEIN Dated QEj DmEFeoMES.QF Dated L1EEY ANNSANCHEZ ESQ AT RfeYFOK CA/Aronberg-0785 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aronberg-0785 JEFFREY.EPSTEIN sE iTEINn im1;v ANRSANCHEZ Nrm tF QR Jj3FF E.P TEhf FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM By signing this Addendum Epstein asserts and certifies that the above hw been read and explained to him Epstein hereby 221stales that he understands the clarifications the Non Prosecution Agreement and agrees tb 2comply with them Dated ALEXANDERACOSTA UNnw/s jg MARIEVlEEAFANA ASSISTANT U.S 221ATTORNEY Datedt Dated TEFFREY EPSTEIN GERALD LEFCOURT ESQ COUNSEL TO JEFFREY-EPSTEIN ULLY ANN ANCHEZ ESQ ATTORNEYFORJEFFREYEPSTEIN I CA/Aronberg-0786 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM __ i;,si tliis,,A ti e5le it ifi a,i-ili 225J!JlJ fl;!P li ti he I ta,m!s tb 243l!l:f1fiyi1 1e l,S Qn iit ii,!h i ii CA Aronberg-0786 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT State Information CA/Aronberg-0787 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT State Information CNAronberg-0787 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0788 Page Intentionally Left Blank FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Intentionally Left Blank CA/Aronberg-0788 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AN FORT ALM BEACH COUNTY STATE OFFLORIDA CRIMINAL.DIVISION LB STATE OF FLORIDA ARISES FROM BOOKING NO vs JEFFREY EPSTEIN W/M co INFORMATION FOR I PROCURING PERSON UNDER FORPROST1TU1ON FT Ihthe.Nameandiby Authority pfthe State ofFlorid BARRY KR1SCHER State Attorney for the FifteenthJudicial 221Circuit Palm by and through His undersigned Assistant State Attorney charges that JEFFREY EEPSTEIN on or about or between the August in the year of purarid Four and October knowingl and urilawfully procure for prdstitu causedto be under theage of yerirs contrary to Florida Statute DEG FEE TANNABELuITLAyEI FL AR NO Assistant State Attorney STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me LANNA BELOHLAVEK Assistant State Attorney for Palm Beach County Florida personally kndwritome who being first duly 2sworn,says.thatthe allegations;as set forth in the fpregbihg iriformatipn are basediupoh facts that have been swdnf tpas/true.and which i true would constitute the offense therein chargedLthat this.prosecutidn isTnstitutaj in good faith and certifies that testimony under path hasbeenreceived/froiri thematerial witness or witness for the offensj Assistant State Attorney Sworn to and subscribed to before me thi ay of June NOTARY PUBLIC te of Florida STATE pf FLORIDA PALM BEACH COUMY DamaAPta MTCOMMSSKW rws L0/dp FC1C REFERENCE/NUMBERS FELONY SOLICITATION OF PROSTITUTION hereby cw lily tNai the RI toreooing iss a true copy fl tt J?c 2n office SHARON 80CK COmROLLGR fHM 2OA aS CA/Aronberg-0789 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM wniE c1RcuJouR.:i OF THE f1FIEENTII illoic tlc1Rtorr nt:ANo i oifrAi:rvt.aEAtH couN:rv st ATE oF:Fl;;oRmA CRIMIN/2L,DIVISI6N l;BJ it_f STA;fE:OF FLOf IDA ARISES FR6tvtB00KING STATEOF 267FLORlDA 267cOtJNTY,oF 225rALM 267BEACH 267lNfORMATION,f,OR Appe elbefo me ANNA LOHLAVEK Assistant State Attorney sf or Palm:Be.acl Couill Florida Of.lailtknownfo me who being-first duly 225SWOI1 says.lhat,t 3!legat1ons,a se_t fo in the foregoing-information 267a.te:basedupon facts;that,have:been swoirf as;We,.and which iftiue would constitute offcns;thcrei charge ii that ihis.p os utidn fs,fostinited in-goti faith,:1m.d 242et:t1fies 1hat tiinony Wlder oatn has,bee:n,rece!ved,Jrom:the.material witness-or wi ssistan,t tatc:A of!lC?Y Sworfrto 225tlild subscribed to bt!fore me,thi C1 ofJ Ule LB ip FCICREFEREN NUMBERS fE!,;o Qt 225ciTATl QF:P osr r10N CA/Aronberg-0789 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM A3 Mʃ I ԢV??J hR I DtP??B ڝ?f rX0 z??I?E f?4B I 5?49?MCGeԱ I LF SY a a K?I ӰB,x?Ј?pLm0M1I0??m j??D i5s p?i??F Y7?ZDn?m H?Y I?Dx 4?In J?ww?mރ AÇc??ݨop mW O??Z ӺM??Tی 龯?P?8k ү??k A6g??ڏ?J?cX lj Uw u?a ݵ?j?n Z?:v M4 DA m?Z i ꎨ?K?z?p P?δ I s8 I Bһ?m hDw TG r?Q ʵRs?-e?P?-b pT i iomnf 1h i b?M fJ?ʾ?XM xR!ڝ h?DS?TB A K0?j CQ S?b II 4Ө rj Mf t?W v?p?W f?t hCV?nLw DI?H?d Xn8 A?B S?T W?鯀LA oxQ lF?B H??e?V e"l?i x??ޑ Y?!rvja DD Ր?u?M T?A L?r Fi?L E?v??t?v 7h Q?F;k??R?t 84Iݠ m??O??D?WO ol na??B e89r A8?L Oy ïW??M?T B?I A ڧm??Uv?CJ Ct?0 Q?i5l?v?zm?fv?j?k?Of y7Oڴ?0M?ݤ?V?A Z?C??C Һ?8B 8o?M?t V?C Zxm?H8 p_ AwA:ޓ F?fr?k??i n?V?ƾ?뽇W?a?9O vO:J V??i Un I n?zv ޛw t?i?k??ŧ dn??k I 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ڊ?M h?ˆH5 I3 p??x?V hCe??I w0 x5 I T?D w;?s?x)P Z?d6 BAR Ki rR B??t?Ҁ K?A GE?hiҪVҀ-?8 J?素 I M?T?lV TȞG A?r P?KҀ A?D??im CA/Aronberg-0790 Page Intentionally Left Blank FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Intentionally Left Blank CA/Aronberg-0790 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CA/Aronberg-0791 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CA/Aronberg-0791 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page IN THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO MB AB B.B Plaintiff vs JEFFREY EPSTEIN Defendant VOLUME I VIDEO-TAPED DEPOSITION OF MICHAEL REITER A WITNESS TAKEN BY THE PLAINTIFF DATE November TIME a.m p.m Page i The deposition of MICHAEL REITER a witness the above-entitled and numbered cause was taken before me Vanessa Archer CourtRepprter NotaryTublic.fqr.the State of Florida at Large at PGA Boulevard Palm Beach Gardens Florida on the 23rd day of November pursuant to Notice in said cause for theitaking of said deposilion.on behalf of the Plaintiff OF PLAINTIFF B.B.r SPENCER KUVIN ESQ LEOPOLiKKUVIN,P.A PGA Boulevard Suite Palm Beach Gardens Florida APPEARING ONBEHAEEOF PLAINTIFFSJANE DOES ADAM HOROWITZ ESQ MERMH-STEIN HOROWITZ P:A 18205iBiscayne Boulevard Suite Miami Fldrida:33160 APPEARING ON BEHALF OF PLAINTIFF C.A JACK.HILU.ESQ SEARCY DENNEY SCAROLA BARNHART SHIPLEY RA Palm Beach Lakes Boulevard West Palm Beach Florida APPEARING ON BEHALF OF PLAINTIFF ISIDRO GARCIA Esq GARCIA LAW FIRM RA The/Harvey Building Datura Street Suite West Palm Beach Florida Page l-N-D-E-X November MICHAEL REITER DIRECT CROSS REDIRECT RECROSS By Mr Kuvin By Mr Garcia By Mr Crittoh IO EXHIBITS Marked Plaintiffs ExhibitNo Palm.Beach PD Intelligence.Report Plaintiffs Exhibit No/2 Incident.Reports Plaintiffs Exhibit No LettertoBarry Krischer Plaintiffs Exhibit Noj4 Photographs of.El Brilip Way 225Plaintiff 2s Exhibit No Photo of El Brillo Way Defendant 2s ExhibitNo Subpeona Duces Tecum Plaintiffs Exhibit No Money Transfers Plaintiffs Exhibit No Flight Summary Certified Question Page Line Letter to John Randolph,.Esq Errata-Shects to be forwarded upon completion Page APPEARING ON BEHALF OF DEFENDANT ROBERT CRITTON ESQ BURMAN CRITTON,EUTT1ER COLEMAN LLP 515North 221Flagler Drive Suite VVest Palm Beach Florida JACK GOLDBERGER,:ESQ ATTENBURY GOLDBERGER RICHARDSON WEISS P:A South Australian Avenue Suite West Palm Beach Florida APPEARING ON BEHALF OF WITNESS JOANNE OCONNOR ESQ JOHN RANDOLPH ESQ JONES FOSTER JOHNSTON STUBBS R:A South Flagler Drive Suite West Palm Beach Florida ALSO PRESENT JEFFREY EPSTEIN VIDEOGRAPHERS MICHAEL DO EY EDDIE GUERRERO VISUALEVIDENCE North pixie Highway Suite A West PalmBeacb Tlorida Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0792 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM VS Page TN IE Fl HEE NTH JUDiCiAL cf RCQiT co-Urn IN AND FOR PALMBEACH COUNTY FLORIDA CASE NO MB AB Plaintif JEFFREY EPSTEIN Defendant V.OLUfyl.E I i VIDEO-TAPED DEPOSITIONOFMlCHAELREITER A WITNESS TAKEN BYTHE PLAINTIFF DATE November23 TIME a.m MICi-ili.Et REITER DIRECT CROSS REDIRECT RECROSS By Mr Kuvin By-Mr Garcia ByMr Crittoi1 I EXHIBITS Marked Plaintifls Exhibit No I 1ch PDhitclligcilcc Rcportli/28/04 Plaintifls fahibit No.2 incident.Reports Plainiifls Exhibit No Letter;to Barry krischer Plaintiffs Exhibit No.A Photographs of.El Brill Way Plaihtitls Exhibit No Phcito El BriHo Y,ay Defendiinis F.xhibit:No is Subpeona Duces Tecum Plaintiffs Exliibi No i MoneyTransfers Plaintitls ExliibifNo Flight Sumiliary Certified Qt1csiion Pagel60 fine Letterto John Randolrli Esq ErrataShecis to be forwarded uoon comoletfori Page A Page The deposition of MICHAEL REITER a witness in the abov eniitled and_numbered c;iuse was iaken lfore.me Vanessa Archer.,Court 267Reporter No ary:PublicJor.the siit offi Jrid:l Llge.at GX Iloule Beach Gardens Florida on the 23rd day ofNovember,2009 pursuant to Notice Ill said cause 267foi ihe;taking of.said deposition.on belialfciftiie Piaintiff APPEARNG 267ON,DEHALF PI.:AINTIFl.13.8 SPENGER KUYIN ESQ LEOPOLIFKUVIN P,A Bo lcvard Suitc.200 Palm Beach Gardens Flon la i APP,EARJNG Ol./.1:3.EHALE OF PL INl;IFFS JANE I QF AQAM 1:10Jl9WJTZ,.E MERMELSTEIN HOROWITZ P:A 18205.Discayne Boulevard Suit i-.1iami Florida i AP.PEARINGON BEHALFOFPLAINTIEF CA JACKJTTLL,,ESQ SEARCY DENNEY SCAROLA BARNHART SHIPLEY P,A Pcil I3e Lak Bo iev West Palin Deacli Jiiorida APPEARING ON BEHALF OF PI:AINTIFF ISIDRO GAR:CIA Esq GARC:JAL,AW FIRlyl P:A lhe.Harvey Building 2240:ituia Street Suite West Palm Beach Florida33401 APPEARING ON BEIIALFOF DEFENDANT ROBERT CRITTON ESQ Pa.ge BUfuviAi"I CRITTON LUTTIER COLEMAN LLP 515Norih.Flagler Drive Suite Vest Palm Bea.ch Florida I JACK GOLDl3ERGER,:ESQ ATTENBURY GOLDBERGER RICIIARDSON WEISS P:A South A nstralian A venue Suite West P.ahn B.each Florida Af,.PE J.UNG BEI-IALF OF VITNE JQANNE QCONNQR,ESQ JOHN RANOOLPH,:ESQ JONES FOSTER JOHNSTON STUBBS P.:A 505.South 267Fiagler Drive Suite Wesi Palm BeachiFlorida ALSO PRESENT JEFFREY EPSTEIN VIDEOGilAPHERS MiCl-iAEL DOWNEY EDDIE GUERRERO VISUAL EVIDENCE I l;,lorthDixie Highway Suije A West Pain Beacl Floiicla Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0792 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page And at what point did you learn that Mr Epstein in fact did become aware of the investigation A I think the point that I actually knew that it was it was reported to meby one of the detectives that one of the victims had been contacted by a private investigator that the department believed was employed by a lawyer of employed by Mr Epstein On that topic at some point did you become aware that Mr Epstein was actually investigating you MR CRITTON Form THE WITNESS Yes BY MR KU VIN Tell me about that A Well I heard through various individuals that one of his lawyers Mr Dershowitz had been contacting private investigators in the area to perform background investigations on me I know that there was a public records law demand filed by several private investigators on the Town of Palm Beach for my personnel records And Tactually ran into one of the private investigators very early on you asked me when I first became aware I Page A No I First time ever MR CRITTON Form BY MR KU VIN First time you can recall it going to this extent A The only time,lever recall.anyone ever going to this extent How long were you aware there was 1Q surveillance on you personally A Well you know I justtook the approach that I have nothing to hide and I just lived my life so I tried not to look around every corner I fe like it was around three months At any time during the investigation did you become aware that investigators were also sUrveilling and investigating potential victims A That had been reported to us by victims And the lead investigator in the case also felt like he was being surveilled people were picking up his trash and so on Is that Detective Recarcy A Yes So there was a time that your officers became aware it was being investigated on Page i Yeah A that basically-toldI me that I also I mean I Saw surveillances number of times I didnt know precisely who had hired those persons but mean had surveillance for a fair long period of time There was surveil lance you noticed on you A Yes Do you know why A No no I dont It would be an assumption In general sense you know theres an attack on the case and if that doesnt work theres an attack on the investigators I dont know I dont know Shouldnt,say that MR CRITTON Form move to strike BY MR KU VIN You were working as a police officer for twenty-eight years and then as a chief well A And two years prior to that actually Right During your entire history as a police officer can you ever recall someone going to that length In other words a suspect conducting an investigation oh you such as the lengths that occurred in this case which include surveillance on you Page MR CRITTON Form THE WITNESS One officer one detective BY MR KUVTN To the extent they were picking up his trash A Yes Were-you awareof that ever occurring in your career to officers working under you A I didnt say it never occurred to this degree Got you A think if youre asking the question do I know of any other law enforcement officers who know as part of their job somebody investigated them and picked up their.trash not that I can specifically recall Okay A Other than the police department itself we 2ve had private investigators take trash at the police department itself weve caught-282 people doing that Obviously at some point Mr Epstein was tipped off as to the investigation because of the investigators that you becameaware of Did you ultimately know how he became tipped off Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0793 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page And atwhat point did you learn that Mr Epstein irt fact did be.come a.ware of the investigation A I think the point thflt I a;ctually knew that it was iHvas reported to me by one of the detectives that on of the victims had bc contacted by a priyatc investigator tha:tthe dcpartmentbelieved was employed by a lawyer of ernployeci byMc Epstein On that topic at some poiritdid you io come a 1/are that Mr Epstein vas actiJally investigating you MR CRJTibN Form HE WITNESS Yes l3YMR.kUVIN is Tell me about that A Well I heatd through various ii1dividuals that.one of his lawyers Mr Dershowitz had 267becn contacting priyate investigators in the area to perform background investigations on me I know thatthyre Vas a public recprcii la ciemand filed by several private investigators on the town of Palm Beach for my personnehecords And I actually ran into one of the priyatc invc tigators very early on you asked me when I first became aware Page Yeah A that basicaliy 267told me that laiso I mean I saw slirveillance,a number of times didnt know precisely who had hired those persons but lmeanJ had st1rvi;:illance fgr c1 fairly lot;g period of time There was surveillance yo noticed on yot1 A Yes Do you know why A No np I do11t It wo be;an li ass 265mption In generalsense you know theres an attack on the case ancl if that cloesnt work theres art attack on the investigators I dont know I l3 dont know Shouldn;tsay that MR CRITTON form rnove to strike BY MR KUVIN You were working as a police officer for twerity-eigtit years and then as a chief well A And two years p1ior to that actually Right lring your entire histmy as a police officer can you ever recall someone guirtg to that length In qther words a suspect conclucting ah investigation on you such as the lengths that occUITed in this case which.include surveiliance on vou I i Page A N.o First time eve MR dRJTTON Form BYMRKlJYJN Ffrsttimc you;can recall it going to this extynt A The only timeJ ever re 267call anyone ever going to this extent I How long wereyouawaretherewas surveillance on you personally A Well you know I just.took the approach that I have nothing to hide and I jUst lived my lifc:so I tried not to look around every corner I I felt hke it was around three months At any time dming the investigation did you become aware that ilvestigc1tors were also sutveilling and investigating potential victims A Thathad been reported to us by victims And th ad investigaJor:inthe case al ofelt like he was ben1g surve11led people were p1ckmg up his I trash 1nq so on is that Detective Rec 267arey A Yes So there was a time that your officers became aware it was being investigated on Page MR CRITTON Forrn THE WITNESS One officer one detective BY MR KUVIN To the extent they were picking up his trash A Yes Were 267yuu aware of that ever occurring in yo career to 9fficers working under ycm A didnt say it never occurred to this degree iutyot A Ttfunk 1fyoure asking the question do I I kn_ow of anyotherJawen orcefilent officers who know as part oftheir job somebody investigated them and i picked up their.trash not thatf can specifically r.ecall Okay A Qther thart jhe pqljc:e clepartment itselt weve had.private investigators take trash atthe police department itself eve caught people doing Th Obviously at some point Mr Epstein was tipped Q.ff as tQ inyestigc1tion beca_use Qfthe investigators:that you became,aware of Did you ultimately know how he became tipped.off Pages to Pieasantoh G:te.ehhill Meek arid Associa.tes CA Aronberg-0793 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page How did you keep that information when you were there A It was a letter that received from the U.S Attorney Hang on back up you misunderstood my question Im talking about the state your investigation In other words what did you match the forty some odd victims in the U.S Attorneys letter with in your 1ist Im looking for your list A The incident reports Okay How many incident reports did you all generate A I dont recall if the latter victim or victims generated a new case number or if theyre included in this It seems like it probably generated a new case number but cant say for sure But Detective Recarey would know Okay All right Would all of the potential victims,that wcrc being investigated by your department prior to lets say July of have been listed in this incident report weve marked as Exhibit Were,there any additional incident reports MR GRITTON Form Page THE WITNESS For the time period that that covers BYMR KU VIN Yeah For the time period of January of through the last page of this Exhibit 2;is July 12of A I think.there was only one report Okay A When you mention victims and thats sort of a subjective word there were individuals that we felt their activity had constituted a crime but,they were not cooperative Right A You know theyre not.victims but-theyre in here and the numbers change if you want to add all them in Okay And what Im just trying to find is is in this particular report weve marked as Exhibit it has if I recall seventeen victims listed and it goes through the date of July of Do you know how many girls approached the department later on total number A Definitely one and possibly more Im not sure exactly But once I realized that they had been considered by the federal investigation knew Page we had no further involvement So-it wasnt something that I would be completely informed about Okay At any point did someone anyone come to you and either formally or informally ask you to back off the investigation stop the investigation or alter your investigation in any way A I had individuals suggest that the departments approach to the investigation and my referral of the investigation to the FBI was more horse power than the investigation deserved And I had other individuals suggest that yeah the term back off probably fits yes Who A I think that Barry Krischer would be included in that description Who else A had people in the community in Palm Beach that either made comments directly to me or to others who relayed them to me that.I didnt need to take the tact in the investigation that we did which is completely investigate it arid then refer it to the FBI after the state case was.resolved Dp you remember any of those people that mentioned iteither-to you directly or through your Page department A Wefl.it wouldnt be I think appropriate for me to list individuals.that I dont know first-hand said that I had many people relate conversations of anotheron the cocktail party circuit that suggested that we approach this in a way that wasnt necessary I had one individual who actually came to see me a couple of times about this Who was that A Jerry GdldSmith Okay What did he say A He said that this wasnt necessary this was a case that really was very minor The victims had.lifestyles that dont make them shouldnt make them-believable to the police department And he said that shouldnt haveireferred.it to the EBI and Palm Beach solves its own problems why did I do that why am I after.Jeffrey Epstein A couple of occasions that was the general topic of the discussion Did you know who Mr Goldsmith was A Yes know them all Lives on the island A As far as I know yes Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0794 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 2ll Page How did you keep that infonnation when you Wer there A It was a letter that I received from the U.S Atto_rney Hang on backup youniisunderstood my question Im talk:ing:about the state your in i stigaiion In oihcr Word Whal did you match the forty some odd victims in the U.S Attorneys letter with in yourlist l.mloolcing fiJr-your list id A The incident reports Okay How many ihcident reports did you all,generate A do.nt recall if the latter victim or victims generated a new case humbcr,or if theyre inch,1de,d in this It seems like probably generated a new case number b_ut can!t say for sure But Detective:Recarey would know Okay All right Would all of the potential victims thatwcre bdng investigated by you.r departme,nt pri9r to le,ts say July of have beeo listed in lis jocident reportWe marked as Exhibit Were there any additional incide11t rcpor MR GRITTON Form Page THE W-ITN_ES_S Iptthe:tiip_e period that i that covers BY MR KUVTN Yeah for,the,time p_eriod oOanuary of05 through the lastpage of this Exhibit2js July of A I think.there was only-one report Okay A When you mention vic_tims and thats s.ort of a subjective word there were.individuals that:we it elt their activity had constituted a crime buttlfr were no.t cooperative Right l3 A You mow theyrenot.victims,but-theyre inhere and the numbers.change 267if.youwanUo add i _aU them in Okay And WhatTm just trying to find is is iil this partiq1lar report Veve:marked a Exhibit it has if I recall seventeen victims listed and it goes through the date ofJuly of06 Do you know how many girls approached ihe dcpartmel1 later on totalnumber A Dc;finitt:ly one and possibly more Im not sure exactly But once I alized that they.had been considered by the federal investigation I knew Page we had no further involvement So-1t wasnt sorneti:tjl thatr wqulcj be corriplete informeq i;tbout Okay At any point did someone anyone come:to yo and e.ithel formally or 225infcmnally ask 267yoif to back off the investigation stop the investigation or alter_your investigation in any w_ay A I had individuals suggest thatthe gepartments approac;h to the investigation and my referral of the investigation to the,FBI was more horse power than the investigation.deserved And had other individuals suggest that a 267yeah the term back off probably fits yes Who A I thinkthat Barry Krischer would.be included in that description Who else A had people in the community in Palm Beach that either_ made cqrmnenh 267dire,ctly fo me or to others who relayed them tome:thad didnt need to take the tact in the investigation that we did which is coinpletely investigate it artd theh re er i to the FBI after the state case was:resolved I ycmre1eniber any oftli.CJ peopl tbat mentioned iteither you directly or through your Page rtinent A Welbt wouldnt be I think appropriate for me to list individuals:that I dorifknow first hand said that I had many:people relate conversations of an:other:on the cocktail party cir 242uit that suggested that we approach this fo a way that wasnt necessary had one:ind1vidual who actually came to see me a couple of times about this Who-was that A Jerry GoldSmith 267Okay What dici he say A He sajq:that this wa nt.nece.ssary this was a case that really was very minor The victims hadJife tyles that tiontmake them hq Jnt make them:believabl_e to the police dep rtrrtent And he said thatT shouldnt have eforred.it to the EBI and Palm Bea,cn solves its own ptoblenis wny did I do that why am I after.Jeffrey Epstein A couple of occasions thatwa the,generar topic of the oiscussion 267oid you know who Mr Goldsmith was A Ye lknqwtliemaH Lives on the 1sland A As far asIknow yes Pages to Pieasanton Greenhi11 Meek and Associates CA/Aronberg-0794 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page MR CR1TTON Form THE WITNESS Thats not my role as Police Ghief BY MR KU VIN Bow did you ultimately learn what was going to happen with respect to the federal investigation who told you that for the first time A Well it changed so many different times The final outcome when it had been agreed upon Assistant US Attorney Marie Villafana shared with me in a general sense that there was a nonrprosecution agreement and told me what Mr Epstein would plea to in state court and just in a very general sense Whatwere your thoughts about what oceurred with respeefto thefederal investigation MR CR1TTON Form BY MR KU VIN In other words did you respond to her and tell her what you were thinking MR CRITTON Form THE WITNESS had been telling her what my thoughts were about the investigation and the prosecution all along I dont think when she told me what was going to happen did Page that you should not answer that question BY MR KU VIN I certainly dont think once your investigation is closed that theres any problem with havinglhc discussion if its.a closed investigation which it is now Well let me ask that Is your investigation closed with respect to Mr Epstein A Im retired So as far as I know when I left it was a closed investigation yes Okay So when you left the investigation with respect to Mr Epstein was closed A Yes Ldonf know if the federal investigation is closed Fair enough You didnt though learn of any new investigation with respeetto the Town of Palm Beachs duties after you left did you A No So as far as you know as you sit here today the Town of Palm Beachs investigation is over as far as you know A Yes MR KU VIN Then atthat point once the investigations c!osed Tcertainly dont see Page make a comment about it BY MR KU VIN Yes A If thats what your question is yes All along my concern was that he would be classified as a sexual offender and all of the provisions that travel along with that so there wouldnt be opportunity or be far less opportunity for additional victims to fake place And I think shared with her some sense of relief that-325 that was a part of the plea Beyond that there really wasnt a need to say anything else Did you discuss with het the fact that the feds were not going to prosecute in other words the federal government werent going to prosecute the case A You know I guess I have to sort of pose this question that this is part of the I suppose the work product of the U.S Attorneys Office Is this the kind of thing that should be talking about I mean is this privileged from the federal end forme to talk about the conversations Lhad with the United States Attorney MR RANDOLPH I think if you have any discomfort at all in regard to whether it is Page that theres any privilege with respect to those communications that he may have had on a closed investigation MR RANDOLPH Hes not stating a concern in regard to the closed investigation of the town hes stating his concern in regard to a federal investigation and stated he does not know whethertheresany ongoing investigation in that regard I believe and he has concerns revealing that BY MR KU VIN Well with respect to your communications with the Attorneys Office regarding your now closed Investigation do you recall discussing with them the non-prosecut ion agreement lets juststart there Generally did.you discuss that with.them A Yes I discussed that with them And its different iterations as it went along Theyshared some portion of the information I still today have not seen the non-prosecution agreement but they shared some of the provisions with me Okay Based upon what was shared with you did you at any point discuss your dissatisfaction with that.agreement;in any regard A Yes Pages to Pleasanton Greenhill Meek arid Associates CA/Aronberg-0795 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page MR CRITTON Form THE WITNESS That.s notirty role as Police Ghicf BY MR KUVJN How did you ultimately learn what was gQing to happen with respect to th fe Jeral investigation who told you that for tlie first tirne A Well it changed so many different times The finc1l outcome when it.had been c1greed upon Hi Assistant u:s AttomeyMarie Villafana shared with me in a general nse that tht,:re was a non,prosecution agreement:and told me what l3 Mr Epstein would plea to state.court and just in a very general sense What.were your thoughts about what occ 265ned with nespecfto the ff ieral investigation MR CRITTON Form BYMR KUVIN In other wor:ds dig you respond to her and tell her what you were thinking MR CRITTQN For:nt THEWITNESS I had been telhiig hei wliat my thoughts were about the investigation and prosl!cution allalqng I ciontthirikwh_cn she told mc,what was going to happen dtd I 2i Page n1akc a comine1it aboutit i BY MR KUVIN Yes A If thats what-your qucstion..is yes All lqng my c.:oncern Wq thafh,e would be classified.as a sexua offendet and all of-the provisions that travel along with that so there lclnt be qpportuhity or fat less oppofhirtjty for additional victims to fake place And thinkJ sh red with hcrsqme sense of relief that thiitw a part of the pica Beyond that there really wasn;t i a need to say anything else Did:you discuss with her the facnhanhe feds were not going to prosecute in other words the federal goyernment werent going to pros.ecute A You know guess I have to sort 9f:pose this question that this is part of the suppose the work product of the U:S.Attomeys 267Office Is this the ki,nc!.ofthingthat I should bda1king about I mcanis this privileged from the fcdcrnl i end for to talk abo1 the c9nversati9ns Ihacl with the United States Attorney MR RANDOLPH lthink 1.fyou have any discomfort at all in regard to whether it is Page that you should not answer that 265estfon BYMltKUVlN I certainly dont think once your irty_cstigafion is clo_scd ha.tthc:tcls any proljlcm 267with having:thc discussion it;s a closed investigation which it is now Well let me ask that Is your 267invcstigafron closed with respect to Mr Epstein A Im retired So as far as I know when I left it was a closed investigation yes Okay So whe_l1 yo_u left tl!ei11ve tig3-tion witlircSpcct to Mr Epstein was.closed A Yes Ldon.t know if the federal investigation is closed Fair enough You didn.t though learn of any new investigation with respect to the Town of Palm Beachs duties after yo left did 267you A No So as far as you know as you sit here toc:lay the T9wn ofT?l.in Bf;achs investigation is ovei::as far as you ki10.w A Yes MR KUVJN 1en;at tliat point once the invcstlgation;s closed I certainly dont sec Page that theres any priviiegewith respect to those communications thatbe may have bad on a closed investigation MR RANDOLPH Hes not statinga 267concern in regiinj to he closecl _in.Y stig on of th_ town hes stating his cbnc.erri in regard to a federal investigation and stated he does not know 267w,hcthcr theres tiny ongoing invcstigalioil in that regard believe and he has conc rns revealing th BY MR KWIN Well.with rcspcct:io your communications with the U.S Attome i!s Office regarding your now ciosed:investigation do you recall discussing with them the 267nqnapr,osecutio.n grce1cnt lets Ju.sf sta_rt there Gcncrally did you-discuss that with them A Yes I d,isc 265sscc;lthat vith.thcm And its different iterations as ihvertr along They-shared some portion of:tbe information I still today have n.ot 5een t:ie ripn-prosecution agreement buJ th shared.some of the provisions with me Okay Based UP.On what was sharecj Vith you did you at any point discuss your dissatisfaction with 267thatagreemenbn any regard A Yes Pages to P1ea.santoh Greenhill Meek and Associates CA Aronberg-0795 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Why A Weil had been told by the U.S Attorneys.Office that typically these kinds of cases with one victim would end rip in a ten-year sentence And they told me early on that they had I guess in earlier iterations of agreement tried to get some sort of a fund set up which I understand there are provisions for in federal law to compensafethc victims And i thinkil,remember asking that when they told me that the agreement had been signed and I think it was changed a time or two and they told me that that was not a part of it Because I always felt that this casc it was all about the.victim thats reason to do this And I did I think they told me that this fund had not been a part of the final version and I told them that I was disappointed in that But they didnt really give me the details of it they gave me an ovcrallcxplanationand they said it was going to be sealed And i understand its been unsealed but havent I havent read it Along the Way gave general comment;when they would inform me abou parts of if ecause they asked for my input I would give them general Comment about the parts of Page it that were important to me And the part that was important to me is the classification as a sexual offender Okay Did.you at any time learn why they entered into a non-prosecution agreement as opposed to prosecuting the forty some odd cases MR CRITTON Form THE WITNESS No BY MR KU VIN Never gave you anexplanation on that A No You know the name Ken Starr A Yes Did you learn.that.name with respect to th is i vest igat ion at all A From the news media Arid I think maybe the U.S Attorneys Office:mentioned to me that he either represents or did represent Ejpsteih Do you know what discussions were had with Ken Starr regarding the federal investigation at all did you ever become aware of that A No Do you know what influence Mr Stam may have exerted on the U.S Attorneys;Office and the DC Office at all regarding this investigation if Page any A No i At some point you sent a letter to State Attorney Barry Krischer Let me show you what well mark as Exhibit Let me give you a chance to just read through this letter again toTelp refresh your recollection A Ive read it At this point in May of Im assuming based on what you told us before that you had had some conversations with Barry Krischer directly at this point by phone correct prior to this letter A I had conversations in person and by phone Okay But nonetheless in May May you felt the need to write this letter is that correct A Yes Can you tell us why A Well I felt the handling and just continued to feel that the way the State Attorneys Office handled this case was;extremely unusual I felt that Mr Krischers I knew that Mr Krischer was making decisions about this case felt that Page his objactivitywas lacking and I felt that the appropriate way after reading the statute that governed the assignment of cases to other circuits I felt;that his action met-the standard used some of the words from the statute in here Andi attempted to call him and he wouldnt return my phone calls The detective attempted to contact his contact in the State Attorneys Office Lanna Belohlavek however you pronounce that I apologize if I have it wrong and she wouldnt return his calls Sol wrote the letter in hope that he would think about his situation and realize that his objectivity was insufficient to prosecute the case and ask the governor to appoint someone else And I felt like that was necessary for a fair prosecution of our case that we submitted to him Could you tell us explain to us Why you felt that his objectivity may be lacking in regards to this prosecution MR CRITTON Form BY MR KU VIN In other words what evidence did you see here uncover that you felt made.it potentially non-objective Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0796 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Why A WellThad 267been told by the U.S Attomeys:Qffice that:typicallythese kinds of 267cases with one victim would end upin a ten year sentence And they-told me early.on thi.it they had I guess in earlier iterations of:agrccmcnt tried to get some ort ofa fund setupwhich I understancl there an provisions for in federa_l law to compensafo 267thcvictims Andi think.l.remcmbcr i aski that vb:cnthcy tole me that the agrccmcnrhad been signed and I think ihvas changed a time or vo and.they told me that that as not a part of it Because always folt-thatthis,c;ise it was all.about the.victim thats reason to do Cs this And did tilik they told me thaftljis I fund had not been a.part of the final version and I told them i:hat I was clisappointe,d in that they didnt really give me the details of it they gave_ me an ovcralLcxplanation and they said ii was going tobe sealed And Lunderstand its been unsealed hut I havent I hayeilt read.it Along the vay I gave general commcnt 267whcn _they would inform me abou parts of it Because they asked for my input I would give them gehetal comment about the parts of Page it that eteimpotta:nTfome And.the_parrthatwas i important to me is the classification as a:sexual offender Okay Did.you at any time,learn why they entered into anon-prqsec 265tion agreement as opposed to prosecuting _the orty some odd cases MR CRITTON Form THE WITNESS No BY MR KUVIN Never,gavt you an 267explanation on.th.at 1i A No You know thc-nfile Ken Starr A Yes Did you fearnthatname with respect to thts jnv stigatio11,at alJ A From the hews media Atid lthink maybe the U;S Attorneys Office,mentioned tome thathe 1s either represents or did represent.Mr Epstein Db you know what discussions were bad with Ken Starr rega.rding the federal investigati.on a.t all didyou.evefbecome aware-ofthat A No Do you kriciw whatinfluence Mrc Starr may 267have exerted on the U:S Attorneys Office and the DC Office at all regarding this investigation if Page I any A No i At some point you sent letter to State Att9rneyBan-y Krisch Let me show yo whatw ll I mark as Exhibit Let 1rte give xou a chance to just read through this letter again to,help refresh your teciJllection A tve read it Atthis point in.May assli1rting based on wharyoli told us beforei that you had had some conversations with Barry Krischer directly at this point by phone correct prior tO I this letter A I had conyersations in person and by phone Okay But nonetheless in May May i you feltthe need to write this letter is that correct I A Yes Can you:tell us why A Well I felt the handling 267andjust 267con:tin clto feel th nlie way the State Attorneys Office handled this case was extremely unusual I lt that Mr Krischers kl that Mr Kli 9_her was making dedsions abouMhis case I felt that Page his objectivitywas lackihg,,arid I feltthaHhe appropriate way afterreading the 267statute that goVem:ed ti1e assigrunent of cases to 0th.er circuits I feltthat his action meHhe standard I used 267some of the YQrds from the stat ih here And.I atteinpted to caJ hint and he wouldnt.return my phone calls The detective atterhj:Jted to contact his contact in the State Attorneys Office Lanna Belohlavek however you pronounce,that I apologize ifrhave itwrohg and she wouldnt.return hii calls So I wrote the lefter in hope that he would thipk c1boiit hii situation and realize that his objectivity was insufficient to prosecute the case and askthe governor to appoint someone els And I felt like that was 267necessary for fair prosecution of our.case that we submitted to him Could you tell us explain tp us why you felt that his objectivity may be lacking in regards _i to this prosec_ution MR CRITTON Form BYMR.KUVIN lh oth:etwords what evidehct clicl you see here uncover that you felt made It potentiaHy non-objective I Pages to P1easanton G:teenhill,c Meek and Associates CA Aronberg-0796 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page P.age MR GRITTON Form THE WITNESS Well early on I had When I first told him about the case and I realized that it was a serious case there were multiple victims that,the suspect was very well known I told him about if And we were it was in person I talked to him after a meeting that he and I were both involved in And I had known him to be a victim advocate and to protect the rights of children Well I know that he even wrote a portion of the statute that addresses those issues And when I told him about it originally he said lef go for it this is an adult male in his fifties whos had sexual contact with children of the ages of the victims He said this is somebody who we have to stop And whatever we need he said in the State Attorneys Office we have a unit thats equipped to investigate and prosecute these kinds of cases I think,he probably mentioned Lannas name to me and anything that you need and you know this is basically a case that needs to be prosecuted Andi didnt have too many facts early on when talked with him but I knew that there Page Were multiple victims and to our detectives they were believable So when time went on and Mr Epstein became aware of the investigation and his lawyers contacted the State:Attorneys Office they told me that And from that point on and believe it was Mr Dershowitz initially the tone and tenor of the discussions of this case With Mr Krischer changed completely One point he suggested that we write him a notice to appear which would be for a misdemeanor He just completely changed from not only our first conversation about this and he didnt know the name Jeffrey Epstein till when he had been informed on Mr Epsteins reputation and his wealth and I just thought that very unusual I feel like I know him or knew him very well the State Attorney and I just felt like he:could not objectively make decisions about this case that is why wrote it BY MR KU VIN Was there anything that you learned through discussions with him that led you to believe maybe his objectivity had been altered in some regards in other words anything he told you 225directly MR CRITTON Form THE 223WITNESS He told me that he had conversations with Mr Dershowitz I know Roy Black At least the news media reporter was involved in this and I thirikthat he said that he had a conversation with him I think Roy Black,had another case with that circuit around the same time and maybe even other lawyers that represented Mr Epstein and they were obviously discussing the case And he basically told me that he looked at Facebook pages of some of the victims and that he fell like they were incredible And I have never felt like prosecutions evidence should be weighed outside of the judicial process I just dont we wouldnt cover our ears and eyes when a person under investigations lawyer would bring forward exculpatoiy evidence but on the other hand were not the weigher of fact in these things We reach the standard of probable cause and beyond and thats when a judge or inthis particular case a State Attorney should,make those decisions Page Arid he had been meeting with them without the presence of.our investigators Fdont mean he personally but at least probably he personally butdefinitely members of his office and he hadnt been sharing that information with us He hadnt you know he characterized it with me but he didnt show us the things at leastnot exhaustively that had been given to him by Mr Epsteins attorneys I just felt like that was wrong Those are the reasons BY MR KU VIN Have we exhausted the reasons why you felt that this case at least you put in your letter was the handling of this case was highly unusual Was there anything else that you felt was highly unusual.regarding the investigation A Well the Dahlia Weiss being involved in this case with her husband as a lawyer for Im not saying that anything happened there but theres certainly an appearance of impropriety I felt.like that alone should been reason enough First of all for her to be disqualified as soon as she became aware that a law firm,that not disqualified but removed from the case as soOn as she became aware Pages to Pleasanton Greenhill Meek arid Associates CA/Aronberg-0797 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM lb _3 i6 l8 Page MR CRITTON Form THE WITNE Well early onrhad when firsMoid him aboutthe case arid I realized that it wa i rim1s case th re were rn 265Hiple victims that the suspect was Vefy well kno:Wn I told him about if Anci Ve were it was in person I talked to him after a meeting that he andlwere both involved in And I had known him to be a victim advocate and to protect tl:te rights of children Well I know that he even i wrote a portion of the stah te that addresi?eS thoseissues And when I told him about it originally he said lets go for this is an adult,male in his fifties whos ha.d 1:,exual contact with children otthe ages of the i victims He said this is somebociy who y.,e have to stop And whatever we need J-ie said iri the State Attorneys Office we have a unitthats equipped fo inyei?tigate and prosecute these kinds of cases I think,he probably mentioned Lannas name to me and anything that y9u need and you know this is basically a case that needs to be prosecuted ADd I dicint hav.c too many facts early on whenJ talked with him but I knew that there Page were rimltiple victims and to our detectives i they were believabie So whentimewent on and Mr Epstein became aware of the investigation and his lawyers contacted the State 267Attorneys Offic;e they told me that Andfrom 267that point on andlbelieveit was Mr Dershowitz initially the tone and tenor ohbc discussions of this case with Mr Krischer changed completely One point he suggested that we write hi.ma notice to appear which would be for a misdemeanor He just completely changed fromnotorily ourfirs,t convetsatioh abciut this and he didnt kno,v the name 267Jeffrey Epstein till when he had been informed on.Mr Epsteins reputation a1d his wealth and just thought that very unusual i6 I feel I ike Tknow him or knew him very well the State A ttomey and I just felt like rs he could not objectively make decisions about this case thafis why I wrote it BY MR KUVIN Was there anything 267thatyou learned throligh discussions with him that led you to believe maybe his objectivity had been aitered in some regards in other words anything hdold you I el I directly MR..CRJTTON forth Page THE vITNE.SS He toldme that he had c9nyern 265tio witn Mr Dersh?witz l,kpow Roy Blade At.least thenews:media tepoi1erwas involved in this an1 I thi atht id that I he hadaconvetsahon w1tb him thnikRoy I Black,had_another case with that_ circuit around the sa.me time and.maybe even othe1Jawyers that represented Mr Epstein andtheywere opvio 265sly liscu.ssing the case And he basically 267told me that he looked at Facebook pages of some of the victims and that he felt lik,ethey were incredible Andl.have never folt like prosecutions evidence should be weighed outside of the judicial process JjustdonJ we wouldnt cover our ears and eyes when a person under 225investigations laYJer would bring forward exculpatory evidence but on the other hand we.re not the weighic.:r 9f fa in these things We reach the standaid of probable cause.arid beyond and thats when ajudg or in.this pmiicular case a State Attorney shoulc,tmai those decfaions Page And he had been meeting with them without the presence of.our investigators I dont mean.he personally but at least probably he pcrsonalfy butdefinitely members of his information with office a11d he rndnt bic.:en sharing that He hadnt you know he characterized it with me but he didnt show us the things at least 267not exhaustively that had been givento him by lvk Epstein.s attorneys jusJ felt likethatwas wrong Those arc the reasons BYMR.KlJVIN Have we exhausted the 225reasons why you felt thatthis case a ti east you put in your letter was t.h handling ofth,is cas,ewas higi1Jy unusua.l Was there anything else that:you 267feltwashighly 265nusuaLregarciing the investigation A Well the Dahlia Weiss being involved in this case with her husband as a lawyer for Im not saying that anything lrnppcned there buf ther.es i certainly an appearance of impropriety I fcltJike that alone sh91.1ld have been.reas9n enough First of all rofherto b.e disqualified as soon as slie became aware that a:law firm.that not disquallfied but removed from the case as soon as she became aware Pages to Pleasanton Greenhill Meek and Associates CA Aronberg-0797 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page that her husbands law firm had represented Mr Epstein And maybe even done damage to the point that because that happened it should be handled by another circuit This was a case that I felt absolutely needed the attention of the State Attorneys Office that needed to be prosecuted in state court Its not generally something thats prosecuted in a federal court And knew that it didnt really matter what the facts were in this case it was pretty clear to me that Mr Krischer did hot want to prosecute this case Did he in fact make that clear to you at some point verbally A Not in those exact words But the suggestion that multiple victims and some of the crimes felonies that heshould writea notice to appear for a misdemeanor and the scheduling of a grand jury on an issue like this is extremely rare The fact that he and had an excellent relationship I was the speaker at his swearing in ceremony And that he wouldnt return my phone calls I mean it was clear to me by his actions that he could not objectively look at this case Page At some point did you feel or did you becomeaware that maybe he had been.threatened.in some regard either regarding hisjob or personally in any regard A No MR CRITTON Form BYMR.KUVIN Youre aware that obviously his position is an elected position A am aware Did you know whether or not he had had any discussions with anyone about his political career if this case did not go a certain way did you ever become aware of that in any regard MR CRITTON Form THE WITNESS No He had already publicly announced he wasnt running for re-election MR KUVIN All right This is.actually a good,stopping point tor a quick lunch if you want to take a quickone I just have to eat Im hopefully not far from concluding THE VIDEOGRAPHER Were off the record al This is the end of tape Recess THE VIDEOGRAPHER Were back on the Page record at This is thebeginning of tape BYMR.KUVIN Okay When we left off we were talking about Barry Krischers office And before I move on Trom that subject I just have one other question Are you aware of any contact that Was made with Mr Krischerls office from anyone in the democratic party or the DNC at all MR CRITTON Form THE WITNESS Relative to this case BY MR KUVIN Yes relative to the Epstein case A No Are al of the officers that were involved in the investigation listed or contained within the incident report that weve marked as Exhibit and were there any additional officers that were involved that may not be listed in there A Typically and generally when you say involved I mean that could encompass all sorts of different people It might be dont even know that this was the case but it might ask the patrol officer in the area to collect license tags from a street or something like that Lmeanif they Page arent writing a report and they arent doing somethingthats probably important later on.as a witness they might not appear in there But the detectives who conducted the investigation arc listed in there from what Frecall the last time I read it and its been a while but as far as I know At any point did you have to remove for any reason anyone in.your department from the investigafion for any reason A No It took place over a fairly long period of time so people were transferred and so on but I didnt personally remove someone for any reason And it may not have-323 been you personally but just to make sure that it encompasses all potential iterations of that question was anyone removed for any reason other than just someone transferring out A Dp you mean for I think you have to explainthat Were any of the investigating police officers removed for any potential conflicts refusal to follow direction any reason other than just a transfer out of the department for some Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0798 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM l3 Page thather hl!sbands law firm had represent ci Mr Epstein And IQaybe eveh done damage to fhe point thatbecausc that happened it shoulcfbc handled by in9tl er circuit This was a case thatT felt absolutely neec;led the attention of the State Amwney!s Offic:e th it needed to be prosecuted in state court Its not:generaily something:thats pros_ecutc;d in a_ federal court And lknewtJiat it didn;t really matter what the facts were in this ca it Va pretty clear to me that Mr Krischer did hot want to prosecute this case Did he fact make that clear to you at some point verbally A Not inthose exactwords Butthe suggesti9n tharmultiple victims and some ofthe climes felonies that he,should write notice to appear for a misdemeanor and the scheduling of a grandjury on an issue _like this is extremely rare The ract that.he and I had an i::xi::ellent laJib11 hip I W?.s-the spea er at h_is swearing in cererribni And that he wouldnt retuni my phone calls I mean it was clear to me by his actions that c:oulci 11ot objectively look a thjs case Page Atsorne point clid you feel,.cir die you become.aware that maybe he had been.threatened.in some regard either regarding his job or personally in any regard A No MR CRITTON fcmn BYMR KUVIN to Youre aware thatobyiously:his positio_n is an elected:position A Tam aware Did you kl whether or not:he had any i discussions with anyone about his politicai career if tbis ca_se djd not go a cert:iin way did_ you ever become aware of that any regard MR CRITTON form THE WITNESS No He had alreac.ly publicly i6 announced he wasn.t running for re-eiection MR KUVlN AH right lhis is actually:a good stopping point for a quick lunch if you want to take a quick:one ust have t9 eat hopefully not far from tondudihg THE VIDEOGRAPHER Were off the record a This is:the nd oftape2 Recess THE VIDEOGRAP-HER Were back on the Page record at I This js the,beginning of pe BY MR KUVIN Okay Wh Ve off we w,erc:talking aboutBarfy krischcrs office And beforeT mbve oh 267from that subject I Just have one other question Arc you aware of any contact iha:t Was made with Mr Kriscner.s o!iice from anyone-in the 267democratic party or Ihe DNC a_t all MR CRITTON Form THE WITNESS Relative to this case BY MR KUVIN Yes relative to the Epstein.case A No Arc all ofthe officers that were involved in thecinvestigation listt::d 9r contained withiinhe incident report that weve marked as Exhibit and were there any additional officers that were invoJved thafmay not be list!!d in tbf:re A Typically and generally when you say inyolved I mean that could ncomp all sons of different people It rtiigh be dont even kno,v that this was the case but it might ask the patrol officer in ih arc.:c1 t_o collccJ lic:cnsc tags from a street or something like that Lmean:irthey Page aient writing a report and they arent doing something thats probably important later on.as a witness they might not appear in there But the detectives who conducted the 267investigation arc listt;!d in the_re from 267what Ireca tlre l_ast tiqi I read it and its beeii a while buta:s Jar as I know Ata.nypoitit didyouhavc to remoVdor any reason anyone 267in:your dt;partment from the investigation for any reason A No It took place over a fairly long periqd oftim peoplt Vere transferrecl and so on but I didnt petsonaHy renioVe-someone 225for any reason And it maynofhav been you personally but just to make sure that it encompasses aH potential iterations of that question was anyone removed for anyr,eason other than just someone transferring.out A Do you mean for I think you have io cxplainthat Were any of the investigating police officers removed for any-poteiltial conflicts refusal to follow direction anyreason other than just a transfer out of the-department for sotne Pages to Pleasanton Greehhi11 Meek arid Associates CA Aronberg-0798 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Ifwe lookat thcbottom of page second paragraph down sorry second paragraph from the bottom excuse me it says here letter to Mr Dershowitz sent advised.he was looking into the allegation that one of the-private investigators used by the private attorneys of Epstein attempted to impersonate or state that they were police officers.from Palm Beach Do yourecall hearing about that A didnt rccall not till read this Okay Apparently there was a package sent to both ASA Lanna Belohlayek and ASA Dahlia Weiss at the State Attorneys Office Do you see that A I sec that sentence yes Did you see that package that was sent A dont;remember that I did I wouldnt normally Ifweturn to page 73,topof the page it lias the name of a Dr Perry Bard Do you see that in the first paragraph A Ido Did you ever Come to learn who Dr Perry Bard was other than what might.be stated in here A read this at one time so I was informed of it but had not recalled the name until I read Page A No If you turn to page it appears that on the dale of.February theres a meeting that takes place between the investigator Joseph Recafey and two women Joanna Harrison and.a Victoria Bean Do you see that MR CRITTON Are we at MR KU VIN Yeah THE WITNESS Yes BY MR KU VIN Okay Did you learn any additional information regarding those two women other than what might be in here in the report A No not personally This may go along with what you discussed at the beginning with.respect to not really prosecuting what technically would be a criminal act for prostitution in.a home But it appears from this information here that these two girls were paid for-sexual contact with Mr:,Epstein at least according to what Detective Recarey investigated Were there any additional investigations ongoing regarding allegations of prostitution at the home MR GRITTON Form Page it again here No additionalinformation regarding Dr Bard A No And with respect to the next paragraph it mentions a woman by the name of Johanna Sjoberg spelled S-J-O-B-E-R-G Do you see that A I see it yes Do you recall anything in particular with respect to Ms Sjoberg A No If we turn to page for a moment there are at the bottom of the page last paragraph four separate telephone numbers listed for a Cingular wireless one of which is listed to a Janusz J-A-N-U-S-Z Banasiak Do you know who Janusz Banasiak is A No Only from what it says here No additional information though A No Christina Venero at the bottom of the page do you see that name A I See it Any additional information that youre aware of regarding her Page THE WITNESS The only way I can answer that question is dont consider fifteen-year-olds sixteeh-year-oldS who are paid money to engage in sexual contact prostitution by the legal definition of the law for purposes of prosecuting them I really dont know what youre getting at beyond that I mean thats dont know how else to answer that BY MR KU VIN Maybe Ephrased it wrong But these girls Ms Bean and Ms Harrison were apparently over the age of eighteen These were girls that were over the age of maj ority that were apparently paid for sexual contact with Mr Epstein Were there any ongoing investigations regarding solicitation for prostitution against Mr Epstein regarding girls over the age of eighteen A No These kinds of situations arc not prosecutable The State Attorneys Office some years earlier even suggested that we no longer do sting operations for prostitution because they didnt want to prosecute them This is a case where you have willing participants after the facVand no Pages to Pleasanton Greenhill Meek and Associat.es CA/Aronberg-0799 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Jfwe iookat the bottom ofpage second paragraph down sorry second paragraph frbin the bottom etcuse fne,jtsl!ys 267here letter to Mr Dershowitz sent advised.he was lookinginto the 267a:11ega:tion thatorte ofthe:private:investigatots used by the private attorneys of Epstein attempted to impersonate or state that theywere police officers.from Palm Beach Do 267yourecall hearing about that A I didnt-recall not till I rc,ad.th_i tci Okay Apparentiytherewas a 267package sent_ to.both A.SA Lanna Belohlavekand ASA Dahlia Weis at the State:Attorneys Qff!ce Po you see tha A I sec that sentence yes Pid yo see that piic,k_a:ge that ias sent A I dont remember that I did I wouldn.t nonnally Tfwe tum to page top of the page it liasthe name ofa Dr Perry Bard Doyou see.that ifrtbc fi.rst paragrllph A I.do Did you ever rrte to learn tvho Dr Perry Bard as other than what might be stated in here A I read this at one time so Iwas informed ofo but lnad not recailecJ the hl!irie uritii I i:ead Page it again heie i No additional 1nformat1on regarding Dr Bard A No A An.d wj_th re pec:t to lle 11ext par?"gn1ph i_t mei1tions a Woman by the name of Johaima Sjoberg spelled S-J-O-B-E-R Do yo see that A I sec it yes Do you recall anything in paiticular with respect to Ms Sjoperg A No il If we tumto page for a m9ment then are the bottom of the page last paragraph foul separate telephone,nun:ibers listed for a Cingular wireless one ofwhich listed to a Janusz i6 A N-U S-Z Banasiak bo you know who Janusz Banasiak is A No Only from what irsays here No additionalinformation though A No Christina Vcncro at the bottom of the i page do you see that name A I see it Any additJonai information that 267youre aware of regarding her Page A No ff you tum to 267page it appears j_hat ort the date of.February theres a meeting that lakes place behve the investj_gat_o:r J9_seph 1tecarey and two women Joanna Harrison and.a Victoria Bean Do you see that MR CRITTON Ar MR KUVIN Yeah THE WITNES Yes BY MR KUVIN Okay Did you learn any 225additional information regarding those two women other tha.n what might be in here in the report A No potpersonaHy This.may go alongwith wha.t you discussed at the beginning with respect to not really Prosecuting what technically would be acrii.nihaLact for prostitution in:a home But it appears from this inforrna_tion here that these i vo girls were paid for sexual contact with Mr Epstein at least accorging to what Detectiye Recarey investigated Were there any additional investigations ongoing regarding allegations of 267prosGti,ition at thf home MR CRITTON Form Page THE WITNESS The only wayl Cati ai1swer that question i I clont consider fifteen-year-olds sixteen year-olds who are paid money to engage in sexual contact pr9stitution by t_hi lr;:gal ddi11itiQll oftll faw for purposes of prosecuting them really ciont know what your getting at eyoncl thaL I mean thats I dont:know how else to answer that BY MR KUVIN Maybe I phrased itwrong But these girl Ms Bean and Ms Harrison were apparently over theatfe of eighteen These were girls that were over the age of majority that were apparently paid for sexual contact with M.r E:pstein Were there any ongoing investigations regarding solicitation for prosfit 265tion against Mi Epstein regarding girls over the,age of eighteen A No These kinds of sit 265ations arq not prosc1.;utablc The State Attorneys Office some years earli revr;:n 265gge_st th.at we no 2671cmgercio sting operations for prostitution because they didnt want to prosecute them This is a case where 267you have willing participants after thc 267fact,and no Pages to Pleasanton Greehhi11 Meek and Associates CA Aronberg-0799 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page physical evidence No the resources of the department are nofdedicatedfor these kind of semi-victimless crimes in private residences unless it presents some other problem Okay If we turn to page bottom of the page dated April of Second to last paragraph.it references MR CRITTON Im sorry Spencer what page MR KU VIN BY MR KU VIN Additional subpoenasfrom the State Attorneys Office requesting information from Dollar Rent a Car and Jet Aviation Do you see that A Yes Do you recall seeing any of the records that were produced in response to this subpoena to Dollar Rent a Car or Jet Aviation A No Turn to page if you would Top of page theres discussion and this goes back to the initial note as begun on April and actually begins on page regarding grand jury subpoenas and discussions with the State Attorneys Office Page If we go to page though it talks about the quote unquote deal being offered to Mr Epstein And if you look at paragraph one here in the middle of the paragraph it says however I expressed that was only my opinion and that the final approval would come from the Chief of Police She explained to have Chief Reiter call Barry Kriseher about the deal Do you see that A I do Did Officer Recarey talk to you about the deal A There were so many potential deals deals being the plea agreement that had been suggested I dont know which one theyre talking about here Bottom of page if you read the last paragraph itll explain it might help refresh your recollection A Well after reading this it refreshed my recollection on one of the different proposed agreements which Okay A I guess some of which they asked for our input And what;this reflects is that in this particular case with all of its unusual twists and turns I told Detective Recarey that he should not Page offer an opinion on behalf of the departmentof whether we think any deal is appropriate that I would want to reserve that for myself So thats what happened here Okay All.right Do you recall having direct conversation with Barry Kriseher about this particular deal thats discussed here on pages and In other words it looks here on page to be a deal where the offer is one count of aggravated assault with intent to commit a fel ony five years probation with adjudication withheld which was conveyed to Mr Epsteins attorneys at the time Guy Fronstin and Mr Dershowitz A I always told Barry Kriseher when we had conversations about how this would resolve itself that my biggest concern really my main concern was that Mr Epstein be classified as a sexual offender to reduce the likelihood,that this would continue in the future I never formed an opinion or communicated-it to him about how many years of this or how many years of that so on other than to tell him that feIt like a Notice to Appear was not the appropriate way to resolve this Page Okay All.right Bottom of page theres a documented call with Officer Recarey Detectiye Recarey Says here on May 3rd at approximately p.m I meaning Detective Recarey received a telephone call from ASA.Dahlia Weiss on my cellular telephone ASA Weiss advised has been taken:off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger Do you see that A Yes MR CRITTON Is there a date there Spencer of reference MR KUVIN Yes May 3rd MR CRITTON Thank you BY MR KUVIN Is that the first time that or shortly after that call that you became aware of the relationship between ASA Weiss and Mr Goldbergers office A Like I said earlier I became aware of the relationship prior to learning of her being taken off the case so I would have known about the relationship before this day It appears and I dont want you to guess so all want to know is whether you had a Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0800 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page physical evidence N_o the,re_so,urces ofth clepartme_nt are not dedicated for-these kind of semi-victimless ri.mtc:s in privare r_c:sisltc:nc hl,ess i_t pte ents on1e othcq:iroblein Ok If we turn to page bottom of the page dtHcd April JO of Second Jo fast paragraph it references MR CRITTON Im sorry Spencer wha page iO MR KUVTN BY MR KUVIN Additional subpoenas.from the State Attorneys Office requ_esting information from Pollar Rent a Car andJct Aviation Do you sec that is A Yes Do you recall seeing any of the records that;were produced in response to this subpoena to Dollar Rent a Car or Jet Aviation A Turnto page 84ifyou would Top ofpage 267theres discussion and this goes back to tile initial note.as begun on April and actually 267begins on page regarding grand jury subpoenas and discussions with the State Attorneys Office 267age Ifwe go to page though it talks aboutthe quote 267unquote deal being offered to Mr Epstein And if you look at paragraph one here in the middle of the paragraph it says however I tc:xpress that was ol ly JlY 9pini9_n and Jll.1 t,he final:apptoval would come from i:he Chiefoflolice he c:xplained to have-Chief Reiter call Barry Krischct about the dcaL Doyou sec that A I do Did Officc:r Recarey talk tq you _about the deal A There were so many:p9tential deals deals being the plea agre_ement thtit had bec::n suggested I don;t know which one 267theyi talking about here ottom of page if yo read Jhe last para.graph itll explain it might help refresh your rc:collcction A Well after readingthis it refreshed my recollection on one oftlie differentproposed agreements which Okay A I gues some of"".hich they asked for our irij:itit Andwhatthis teflectsis that in this particular case with all of its unusual twists and turns told,Dctcdivc Recatcy that he should not Page offer an opinion on behaif ofthe department of whethetwethirtk any-deal is-_apptopi:iate,that I would want to,reserve that for myseif So that;s what happened here Okay AILright Do you recall having direct conversation with Baiiy,KJis lier abouqhis particular cieaLthats-discusseci here on pages and84 other words it looks here on page to be a deal where the offer is one count of aggravat assault With int nt to commit a felony five years probation with 267adjudication withheld which wa:s conveyec_l to Mr Epsteins attorneys at the time Guy Fronstfo and Mr Dershowitz A I always told Barry Krischer when we had convetsations,about h9-w this w,oi.Jld resolve itself tha my biggest concern reafly main concern was that Mr Epstein be classified as a sexual offender to_ reduce the likelihood that this would continue in the future I never formed an opinion or comrriuriicatecl to hitn about hoW ma11y years of this or how many years ofthat so on other than to teli him that lfel_t like a Notice to Appear was not the appropriate way,to resolve this Page Qkay A.ILrigbt Bottom page theres a documented ca II with Officer Recarex Dete tive Recarey Says here on May 3nl at approximately p.m meaning Detective Recarey received a telephone call from ASADahlia Weis_S ih rrty cellul;_ir teleph9ne A.SA Wejss advise,d she has been taken:othe Jeffrey Epstein case because her husbancl"is er,nployed witll.Attorn_ey Jack Goldberger Do you see that A Yes MR CRITTON Is there a date there Spencer of reference MR 15.UVIN Yes May-3rd MR CRiTTON Thank you BY MR.KUVfN Is that the first time that or shortly after thatcall that you became aware of the rel 1tions_hip bet:wet;h ASA Wei and Mr Goldbergers oftJCe A Liker said earlier I became aware of the relationship pricfrto lea.ming ofher being taken off the case so Lwould,have known abotitthe rel:,itionship bef9re thi dlly It appears andI dont want youto guess so-all Lwant to know is whether you had a Pages to Plea.santon Greenhill M:eek and Associates CA Aronberg-0800 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page conversationwith Detective Recarey about this whether he said anything directly to you that she was removed as opposed to removing herself voluntarily from the case MR CRITTON Form Youre asking him to speculate MR KUVIN No Im not Im asking for any conversation he had with Detective Recarey THE WITNESS I dont remember BY MR KUVIN Okay Page again going down to the date of May theres a reference to a contractor by the name of David Norr N-O-R-R and apparently he was surveilled for a short period of time A Let me find that Sure Middle of the page A Okay Do you recall whether your department obtained any records regarding the renovations that were going on at Mr Epsteins 2home blue prints construction diagrams anything like that documents from the contractor A No No you didnt or no Page i i with Mr Indyke A No There appear to be a number of corporations El Zorro Ranch Corporation New York Strategy Group Ghislaine G-HT-S-L-ArEN-E Corporation Epstein and Company and the Financial Strategy Group Do you see those A Ido Do you recall anything seeing any documents.or information regarding those companies A Ive read this report before And if its in the report read it previously but dont have anything independent of the report nor do I recall any more than what youve shown me here Im just looking to see whether or.not you saw any corporate printouts or corporate documents or anything like that that might have been obtained online or through other sources A I not get involved in this investigation at that level Okay Last entry here of July T2 it says here Belohlavek and spelled for the benefit of the court reporter weve used.it before but ust for her sake its B-E L-O-H-L-A-V-E4C stated State Attorney Barry Krischer made the Page A No dont recall It would have been easily available to us from the building department Right building and zoning A I have nd idea if wedid Turn to page Top of the page on May 22nd received several phone calls throughout the day from Mr and then its blacked out who stated he had been followed aggressively by a private investigator Who was that A I dont know It appears if you.go further down that the vehicle that was following this person was traced by Florida tag I35-XGA tp a Mr Zachary Bechard of Candor Investigations Do you see that A Yes Did you come to learn anything about that particular investigative agency Independent of what might be in the report A No not that I can recall Page last page Middle of the page references Epsteins corporation attorney a gentleman by the name of Darren Indyke/I-N-D-Y-K-E Dp you see that A Not yet Okay yes Do you recall having any conversations Page determination to go to the Grand Jury to hear the case Did you or do you recall discussing directly-with him why he was taking this to a Grand Jury as opposed to just charging Mr Epstein his office doing it themselves A No You agree with rhe that that would be out of the ordinary based on the charges that were brought MR CRITTON Form THE WITNESS My experience yes BY MR KUVIN Do you agree:with me that you.learned that it was Mr Krischer that made that decision himself MR CRITTON Form THE WITNESS Thats my understanding BY MR KUVIN Did,you.ever get any explanation from anyone not just him but anyone as to why they did that MR CRITTON Form THE WITNES Sometime after the fact the Grand Jury maybe evcn possibly long after the fact he told me that it was a political not Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0801 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM is Page conversationwith Detective Recarey about this vhether he s.iid inything directly to you that she was removed as opposed to removing 267herseif volunfarily from tb cas MR CRITTON FOnn Youre asking him to speculate MR KUVJN No,Jm noti lmaskingfor any conversation he had-with Detective Recarey THJ2 WIJNE.SS I dont remember BY MR Rt:.J ITN Okay Page again going down to the date or May theres a reference to a contractor by the name:or David Norr O-R-R and apparently he-was surveilled fqr a sl;lort period of time A Let me find that Sure Middle of the page A Okay Do ycmrecaH whether-yourdepari:ment obtained any records rcgard!ng the renovationsJhat were going 9n at Mr Epsteinshome blue prints construction diagrams anything like that docurnents_ from the contractor A Nb No you didnt orno is Page A I dont"recall I_t woul,Jhave been easily avaiiable to us from the buiiding department Righi building and zon1ng A have no idea if:we did Tum to page Top of the page on May I received s_everal phone calls throughout the day from Mr 267and;then its biaeked out who siated he had been followecl aggressively by a private ii1vestigator Who was that A I dotit know It appears if you.go further do vh tlfat.the vehicle that was following this.person was traced by Floricla tag to-a Mr Zachary chard.of Candor 267investigations Do you see _tl1at A Yes Diel you come to lea.m anything apoutihat particular investigative agency Independent of What might iil tl1etepqt A No noMhrit I can recall Page last page Middle ofthe page refotences Epsteills corporation attoniey,_,a 267gentleman bythename:ofDarrenIndyke l-NcD Y-K-E D9 you ee thai A Not yet Okay yes Do you recall having any conversations P.age with.Mr lndyke A r-lq There appearto be a number of corporations El Zorro Ranch Corporation York Strategy Grm1p Ghislaine S-L-A,I N-E Corporation J.Epstdn anci Company and the Financial Str tegy Group Do you see tho A Ido Do you call anything eeing any 267documents or infonilation regatding those companies A Ive read this report before And if its in the report read it previously butI dont have anything independent of the report nor do I recall any more than what youve shown me here Itn just looki"ng to s_ee whether or not you saw any corporate printouts or corporate documents or nything like thattqat might have bee11 obtained online orthrough other sources A I did-not inyolved in this investigation at_ that level Okay Last entry here of July it says here"Belohlavek Spelle_dfor the benefit of the court-reporter weve used.it before butjust fm h_er sake iti _B E,L-O-H L-AN sE stated State Attorney Barry Krischer made the Page 267detem1ination:t6 go to the Gnif1dJury to:hear the case Did you or do yourecall discussi dircctly with him whYhe was taking this a Grand as opposed to j_ust chc1rging Mr Epstei11 his office doing:it themselves A No agree with rhc thatthatwould be out of the ordinary based on the charges that 267were brought MR CRITTON Form THE WITNESS My experienc yes BYMR KUVIN Do you agree:with methatyouleamed that it wa_s Kris 242her that made that decision himsef1 MR CRJTTON Form THE WITNESS Thats my understanding BYMR KUVIN Did.you.ever get any explanation from anyone 267otjllst him _l:iut anyone as fo why t_hey did that MR CRlTTON Form THE WITNESS Sometu:ne aftetthefact the Grand Jury maybe even:possibly long after the fact hdold me thatit was a t,olitkal not Pages to Pleasanton G:te.erthi11 Meek and Associates CA Aronberg-0801 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page a political but it was a noteworthy investigation a noteworthy prosecution And in these kind of controversial situations an independent body of the Grand Jury it was appropriate to have them exam him Recalled other grand juries for things I cant say similar but a homicide that-had racial overtones and so on and he made reference to that that that was his choice to deal with these kinds of things That could have been as recent as you know within the last year and a half or so BY MR KU VIN Do you recall your department being involved in any other high profile type of investigations for example the investigation that involved a radio personality that lives in Palm Beach and the investigation of a potential boater fraud as a result of another author or radio personality on.Palm Beach or.was this the only high profile investigation you can recall working on in your history in the city of the town A Involved in the.department,and personally been involved in many high profileinvestigations Many being more than ten fm justifying Page perspectives but not necessarily the news media coverage BY MR KU VIN Was it handled any differently than you handled other high profile cases that you may have handled in the past MR CRITTON Form BY MR KUV1N From your perspective A I dont think it was handled any differently by the PalmBeach Police Department than from any of the other high profile cases Okay I appreciate it Thats all the questions have.at this point Urn going to turn it oyer tothe otherplaintiffattorneys who may have a few for you MR HILL I dont have any Thank you sir THE WITNESS Youre welcome MR GARCIA I just have a couple here GROSS-EXAMINATION BY MR GARCIA Chief my name is Sid Garcia I represent one of the plaintiffs in,the case think we met before in another case another deposition years Page to get an idea A The standard rules dontreally help me We used to joke about how very small things in Palm Beach would become jnoleworlhy in the news media that they would be meaningless everywhere else Right A If you mean national political interest at that level profile yes at least ten probably more than ten In your experience in dealing with even those high profile investigations was this one different MR CRITTON Form THE WITNESS It wasn.t different in the amount of you know at the level of profile of had we been involved in that before where it gets international news media coverageand all of the things that come with that It was different in the respect that probably what should have remained a state case had to become a federal case which they ended it and it all ended in an agreed plea in the state case It was different for me in that asked the State Attorney to remove himself from the case you know It was different from many different Page ago Just want to ask you a few questions beginning with the asking basically your opinion as to why Mr Krischer did not pursue the case with the diligence that you thought he should have pursued itwith MR CRITTON Form THE WITNESS Im not sure I understand the question BY MR GARCIA In other words you talked about that,you sent a letter to Mf Krischer asking him 2to disqualify his office from the case Why do you believe that.he did not pursue the case with the zeal that you thought he should pursue it with A I dont-.know MR CRITTON Form BY MR GARCIA What is your opinion of why he didnt pursue it that way MR CRITTON Form THE WITNESS Thats not my role I havent formed an opinion oh that I dont know why Pages to Pleasanton Greenhill Meek arid Associates CA/Aronberg-0802 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM li Page a 267political but 1t was a noteworthy investigation a notewor:thy prosecution And in these kind ofeontroversialsituations an i11dept;m9ent boqy ofthG Or;mdJury itwas appropriate to have them exam hinf He called other granq juries for things I cant say similar but a homicide that-had.racial overtones and so on and.he made reference to that that that wa.s h:is choice to d.eal with these kinds of things That could have been as r1;:eent as,eyo know vi thin the last year and a halforso BY MR KUVIN iO Do you recall yo.ur department being involved in any other.high profile type of investigations forexample the investigation that i11volved a radio personality that lives in Palm Beach anci the investigation of a potentialboater fraud as a res_ult ofanother author or radio personality on.Palm Beach or was this the only high profile investigation yoll can rec:all working on in 267your history in the city orthe town A Involved inthe:department.and personaiJy been inyolvc;d in many high.profile investigatioris Many being more than ten imjusttrying is Page get an idea A The standard rules dont:reallyhelp me We used to joke about how very small things in Palm Beach wouldbecome:noteworthyin the news medfa thatthey wo1,1ld be 267meaningh;ss everywhere else Right A If you meall national political interest at that level pro i yes lcaSt:tcil probably more than ten Ip yolclr 267experi_ence in dealing 225with even those high profile investigations was this one i different l2 MR CRITTON form THE WITNESS Itwasn.t different inthe amount of yo know at the evelq profiJe had w.cbccn involved in tha beforewherc it gets international news media coverage and all ofthe things that C:oine with that It vas different in the respect tbatprobablywhat sboulg bave _n:rn iT ed a state qse had to tiecome a;federal case which they ehded it.and it all ended in an agreeq plea in the tate case It Was differentfor:me irtthatlasked th1 State Attorney to remove himself from the cas you know lt was different from many differeni Page perspectives but notnecessanly the news media coveragi BYMR KUVIN Was it handl any differently than yo handled other high profile cases that you may nave handled in the pasti MR CRITTON Forni BYMR.,KUVIN Frqm yot1r perspec:tive A I dont think it was handled any differently by the Patm:Beach Police Departmentthan from aIJy i the other high profile cases Okay I appreciate 1t Thats a:llthe questionsThave at this point Jim going to tum it o;ver to 267the other plaintiff attorneys who may have a feWforyou MR HlL have 1!ny Thank you SIL THE WITNESS Youre wi;:lcome MR GARCIA I just have a couple here CROSS-EXAMINATION BY MR GARCIA Chief my name is Sid Garcia I represent on of the plaiJ1tifs jn:the case Ithi we rnet before in another case 267another deposition years Page ago Just want to ask you a few questions beginning with the Sa asking basically your opinion as why Mr Krise her did not pursue the 225casc with the qilig nce tha,t.you thought he shouldh 1ve pursued it with MR CRITTON Form WITNESS Itn not sure I understand the question BY MR GARQA In other words you talked about that you sent a letterto Mr Krischer asking him to disqualify his office from the case Why dcryou believe that.he did not pursuethe case with the zeal tha,t you thought he sho.uld-purs it with A dont:know MR CRITTON Form BY MR GARCIA Whatis your opinion.ofwhy he didn.t pursue that way MR CR1TTON Form THE WJT:NES_S Thatsnotmyrole I have11t foiinea an opinion oh that I do11t know why Pages to P1easantoh Greenhiil Meek and Associates CA Aronberg-0802 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page BY MR GARCIA Did you think that were you aware or did you become aware at some point that Mr Epstein was a contributor to the democratic party A Yes Are you aware that 2Mr Krischer has ties to the democratic party MR GRITTON Form THE WITNESS Yes BY MR GARCIA Did you suspect at any point in,time that there was a connection between Epsteins political connections with the democratic:party and Mr Krischcrs refusal or neglect to prosecute in this case with the zeal he should have pursued it with MR CRITTON Form THE WITNESS didnt allow myself to explore that BY MR GARCIA Did you have any discussions with Mr Krischer about that issue whether or not Mr Epstein was receiving favorable treatment from the State A ttorneys Office because of Mr Epsteins politicalconnections Page criminal charges.against Mr Epstein correct MR CRITTON Form THE WITNESS Yes BY MR GARCIA This is hot a situation where there was maybe a situation an age difference and the victim was not cooperating in the investigation is that correct MR CRITTON Form THE WITNESS Thats correct BY MR,GARCIA ID id you challenge him oil that issue A Yes And what was his response A He continued to reiterate that the case that it was.his.ethical obligation And he had told me this before about other cases that we had discussed Palm Beach Police:Department cases and other cases that he has an ethical responsibility to feel to be reasonably certain that the case is winnable before he prosecutes it And he said,that because of all of those reasons and others involving some of the reputation and Facebook pages and so on of certain victims that he couldn 2t feel that he could be successful in the prosecution Page MR CRITTON Form THE WITNESS asked him why he was treating the case in the way that he did BY MR GARCIA And what was his response A His response was that the victims werent credible in his mind I dont know I dont mean all the victims werent credible but some of the victims werent credible He didnt believe that sixteen and seventeen-year-old victims he told me Were he said it Was the policy of the State Attorneys Office not to charge molestation type cases of even a sex type battery case when it was consensual His answer to that question was about the merits of the case i So he told you it was the policy of the State Attorneys Office not to charge victims of lewd and lasci vious who were sixteen and seventeen years old A Well when it was a consensual I know its kind of a misnomer because they cant legally consent to it but he said when it was practically a consensual situation it.Was their general policy not to prosecute those kinds of cases yes But these victims were willing to press Page Did he show you any of the Facebook pages that he had considered A He did not You said when he presented this case to the Grand Jury he gave you sonic explanation as to why he presented it that way Did your detectives and investigators were they subpoenaed to appear before the Grand Jury A At least one detective was You know who that was A I have to ask my lawyer the question of whether or not I can answer that because Grand Jury material I know always remains sealed I dont know ifl do something;improper by identifying that person alone without I dont know what they said I wasnt in the Grand Jury I thinkthe tcstimony would remain privileged of confidential but the Grand Jury did return an indictment is that correct A Thats my understanding,yes So Im not asking you to you dont have access to the testimony Im assuming A Thals correct Im just asking you for the identity of the person who was subpoenaed to appear before the Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0803 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page BY MR GARCJA Did ycm think that Were you aware oi did you become aware at some poinl that Mr Epstein Was a cq 265tributor lo the l_llqc,ratic party A Are you aware thatMr Krischer has ties tlw democratic pa:rtyJ MR GRJTION Form THE VrTNE_SS Yes BY MR GARCIA to Did you suspect at any point in time that there wa:s,a connection.betWeeriMr Epsteins political connectionswitb the democratic.party and Jlr Krischers refusal or neglect to prosecute in tfiis case with the zeal he should have pursued it is with MR CRJTTON Form THE WITNESS didnt allow myselfto explore that BYMR.GARCIA Did you bay any.discus:;ions With Mr Krischetabout tha_t issue whether ornot Mr Epstein was receiving fa Orable treatment from the Statc 267,Ai:torncy!s Office because of Mr Epst 242ins politicalconnections i Page MR CR1TtON form THE WITNESS asked him why he was treating the case in the way that he did BY MR GARCIA _ffi1d Yl1a_t was his re po.n A His response wa thaflhe victims werei1t credible in his mind I dont know dontmean i allthc victims werent credible butsorrie of the victims werent credible He didnt believe that sixtee11 and seventeen-year oJd ictims he told ITit were be said itwas the policy of the state t1 Attorneys Office not to charge molestation type cases ore:ven a sex typebattecy case when it was consensua"L His answer tothat question was about the meri_ts of the cc1se So he told you it was the policy of the i E;i State Attorneys Office not to charge 267victims of lewd and lasci_vious Who were sixteen ano seventeen years old A whcn itwas a co11scns,1.1al know its.kind of a misnomer because they cant legally 2i consentto it bllt he said when it was pra9tically a co1tsensua:l situation it was their genera polii::y not to prosecute those kinds of cases yes But these victiinswerc willing to press I Page criminal charges against Mr Epstein correct MR CRJTIONi fonn THE WITNESS Yes BY MR GARCIA This is nota.siti.1ation where there Was maybe a boyfriend/girlfriend situation an age difference and th:e icti1 wa rjqJ 242liopetatingin the investigation;h that correct MR CRITTON Form THE WrtNESS Thats correct BY;MR.GARCJA Pid yo cbaHen_ge hirr1 on that issue A Yes At1d what wa.s his response A He continued to,reiterate that the case that itwas.his.ethical obligation And he hadtold me thi_s fore about other Ci!Ses that we discussed Palm Beach Police,Department,cases and other cases th;it.he has an_ ethical:responsibility to feel to be reasonably certain that the case is winnable before he prosecutes it And he said.that because of,all ofthos reasoris.and others ihVolvi11g some of the reputation and Facebook pages and so on of c:_ert in vicj:ims tha he c:ouldntfeel that he c.ould be 267successiul in:the prosecution Page Did he show you any of the Face book pages that he had considered A He did not You said when.he presented this case to the Grand Jury _be ga_ yo_ son1e explanatiop as to why he presented It that way Did your detectives and investigators,.were they subpoenaed to appear before the Gn1nd Jury A Atleast one:detect1ve was You kne wh:o that a A lhave to ask my lawyer the question of whether or not I can answer thatbecause Grand Jury material I knoW always remains sealed I dont know ifl,do something:improperby identifying that person alon.e without I d_gnt know what tiley said wasnt in the-Grand Jury think the tcstimonywould remain privileged or eonffdeniial butthe Grand Jury did return an i 267ndictment is that correct A tats Ill ders,ta11ding,_yes So I.m not asking you to you dont have ac to th testimony Im ass ling A Thats correct Im just asking_you:for the identity of 267the person who was subpoenacd to appear before the Pages to Pleasanton GreehhiIl Meek and Associates CA Aronberg-0803 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page IN THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY FLORIDA CASEN0 X:MB AB B.B Plaintiff vs JEFFREY EPSTEIN Defendant _1 VOLUME II VIDEO-TAPED DEPOSITION MICHAEL REITER A WITNESS TAKEN BY THE PLAINTIFF DATE November,23 TIME a.m p.m i Page Page D-ErX November MICHAEL REITER DIRECT CROSS REDIRECT RECROSS By Mr Kuvin By Mn Garcia By Mr Crittoii EXHIBITS Marked Plaintiff Exhibit No Palm.Beach PD Intelligence Rcpdrtli/28/04 Plaintiffs Exhibit No.2 incident.Reports Plaintiffs Exhibit No Letter to Baiiy Krischer Plaintiffs Exhibit No/4 Photographs of.El Brillp Way Plaintiffs Exhibit Nd Photo El Brillo Way Defendants Exibit.No Subpeona Duces Tecum Plaintiffs Exhibit No Money Transfers Plaintiffs Exhibit No Flight Summary Certified Question Page Line Lettef to John Randolph,.Esq ErrataSheets to be forwarded upon completion Page The:dep6siti6n of MICHAEL REITER a withess:ih 2the above-entitled arid numbered cause wastriken before/me Vanessa Archer Court Reporter Notary.Public forthc Staie ofFlorida at Large at PGA Boulevard Palm Beach Gardens Florida on the rd day of November pursuant to Notice in said causeifor the taking said deposition oh.behalf of the Plaintiff a i APPEARING ON BEHALF OF PLAINTIFF B;B SPENCER KUVIN ESQ EEOPOLD-KUVIN.P.A PGA Boulevard,Suite Palm Beach.Gardens,Florida APPEARING ON BEHALF OF PLAINTIFFS JANE DOES ADAM HOROWITZ ESQ MERMELSTEIN HOROWITZ P.A Biscayne Boulevard Suite APPEARING ON BEHALF OF PLAINTIFF C.A JACK HILL,ESQ SEARCY DENNEY SGAROLA BARNHART SHIPLEY P.A Palm Beach Lakes Boulevard West Palm Beach Florida APPEARING ON BEHALF OE PLAINTIFF ISIDRO GARCIA,.Esq GARCIA LAW EIRM P.A The Harvey Building Datura Street Suite West Palm Beach Florida Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0804 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 5_ i VS Page TN IE FIF:TEENl.i-l JODiCIAL CfRCUiT COURT IN ANDFORP,ALMBEACH COUNTY FLORIDA CASE NO X,MB AB Plaintiff JEFFREY EPSTEIN Defendant VOLUME II VIDEO-TAPED DEPOSITION OEMlCHAELRElTER A WITNESS TAKEN BYTHE PLAINTifF DATE November TIME a.m p.m E,X MICH EL RE_ITER DIRECT CROSS REDIRECT RECROSS By Kuvin By-Mr Garcia ByMr Criltori I EXHIRITS _Marked Plainiifls Exhibit No I I hn ch PDb1tcUigcncc Rcportiit28/04 Plaintifls Exhibit No.2 I Incident Reports Plainiifls Exhibit No i:etter,to Harry krischer Plaintiffs Exliibit NoA Ph tographs of.El Brillo Way Plaintiffs Exhibit No Photo El_ Brillo yay Dcfei1diints Exhibil.No Subpeona Duces Tecum Plaintitis Exliibit-No Money 267Transfers Plaintifls Exliibi!No Flight Sun1iliary Ccnificd Q,,csiion Page I Line I Letter to John Randolph Esq Errata-Sheets to be fmwarded uoon comoletiori Page iB7 lL Page Pa9e Hj9 Jhe:deposition of MICHAEL REITER iiwililess iilthe above-c1itiilcd arid nwnbcred cause wastaKcn bcfore:me Vanessa Archer Court Reporter Notary:Public for,the Staie of.Florida at Large at Boulevard Palm Beach Garden Florida tjle clay ofN_ovenil;ier _pursuant to.Notice in said cause 225for.the taking of said deposition on.behalf of the Plaihtiff API AIUNG.0N BEHALF OF PLAINTIFFRB SPENCER KU llN ESQ l.EOPOLD-KUVlNYA 292S:PGA Boulevard Suite lni Behch Garden iorida APPEARING ON BEHALF OF PLAJNTiFFS JANE DOES ADAM HOROWITZ ESQ MERMELSTEIN HOROWITZ tA ay!_le Boulc-:ard Miami,-Floiida APPEARING ONBEHALF OF.PLAINTIFF CA JACK HILL,.ESQ SEARcY DENNEY SCAROLA BARNHART SHJPLEY P.A Palm Beach Lakes Boulevard Vest Pal Beach Fiorida33409 APPEARINGDN irnHALF OF PLAINTIFF ISIDRO GARCIA,.Esq GARCIA LAW EIRJvl P.A The Harvey Building Daiura Street Suiie900 West Palni ri ach Florid Pag,es to Pleasanton Greenhill Meek and Associates CA/Aronberg-0804 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Youre talking about alittie over a year a dozen or so communications between at least calls to or from Ms Villafana to you A Right What are we talking about A Do you want me to guess about thenumber No I asked for your best estimate and you said approximately.a dozen calls A The best estimate is a guess in this case So what did you do did you call up arid say whats going on with regard to the Epstein matter A Sometimes when.we hadnt.heard from them for months or when.Detectiye Recarey would call the EBI and the EBI would say I 2m not Oh Em sorry he has to change the tape THE VIDEOGRAPHER Were off the record al This is the end of tape Off the record THE VIDEOGRAPHER Were back on the record at Thisds the beginning of tape BY MR CRITTON Mr Reiter has there ever been an occasion another occasion when youve been the Page with.them that,you were disappointed with the manner in which the State Attorney had prosecuted or had handled the Epstein matter MR HILL Objection asked and answered MR KU VIN Twice join THE WITNESS Yeah I dont know that I used that exact word I didnt feel as though justice had.been sufficiently served BY MR,CRITTON Had there ever-been another instance where the State Attorney had either filed charges had gone to a Grand Jury as they did in the Epstein case and then you subsequently contacted either the EBI or the U.S Attorneys.Office and/or they contacted you A Ill try to stay with you better this time Could you In this particular instance Mr Krischer took the Epsteimcharges or the allegations to a Grand Jury the Grand Jury came back with an indictment and he subsequently was arrested You subsequently had contact with the EBI and the FBI and the US AO did their own independent investigation correct A Yes Page Chief when you were Chief of Police where you went to the EBI and/or the EBI called you about pursuing a prosecution because you felt what the state 2had done was not adequate or not acceptable to you A No This was the first and only occasion correct A Well that was kind of a complicated set of situation circumstances But what you described this is the first time that I was not didnt think that justice was sufficiently served and that the EBI contacted me to initiate an investigation That unusual thing yes thats true And in fact you were in large part relying on the report thathad been done in the investigation thathad beemdone by the Palm Beach Police Department A Yes Had there ever been an.occasion where let me strike that At any time did you tell the EBI not to discuss the case with the State Attorneys Office A No Did you tell the FBI when you first met Page Had you ever had another circumstance like that during the time that you had been the Chief or the Assistant Chief or a police officer for the Town of Palm Beach that is where the State Attorney had filed either charges that you didnt agree with,or had taken it to a Grand Jury Grand Jury had come back and had returned an Indictment and then you went to the FBI or the FBI contacted you or was this the firstand only occasion A This was the first.occasion in which I ever had a case go to a State Grand Jury that washt a homicide There have been-other instances that the case bogged down in the state prosecution and.it was clear that the most appropriate place to be would be a federal prosecution And the case was eventually investigated by the FBI or the DEA or the Secret Service or somebody being prosecuted by the US Attorney In that particular situation though did the state-work the State Attorneys Office work with the FBI or the U.S AOs office to bring the federal charges because it got bogged down in the state investigation and/or process A Yes typically thats how it would go So the state was then actively involved Pages to Pleasanton Greenhill Meek and Associates CA/Aronberg-0805 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Page Youre,talking abouta:Httle over a year a doz or so com1J1nic;atioI1s bet yt:e_n at Jeast calls to or from Ms Villafana to you A Right What are we talking about A Do you want me to.guess aboutthe 267number _No I ask fgr your best estimate and yo 267said approximately-a dozen calls A The.best estimate is a guess in this case So what did you-do did you tall up artd i say whats going onw!th regard to the Epstein matter A Sometimes when:we hadnifheard from them for.months or whenDt:tective Rec:arey wo call the EBI _artd the EBL voi.lld say imnot Oh Im,son-y he has to change the tape THE VIJ E0G.lu HE_R Were o,ffthe rec:ord a This is the end of tape 0ffthe record THE VOEQGRAPHEit Weje back.on the record at This1s 267the beginning of tape t2 BY MR CRITTON Mr Reiter has th re evefbt:en an occasion another occasion when youYe been the is I Hi Page Chief when yoi.1 were Chief of Police where you went to the FBI and/orthe FBI called you bout pursuing a prosecution because youfelt 1/hat tl:ie state.had done,was not adequate or not acceptable to you A No This was the first and only occasion fr correct A Well thatwaskind of a cpmplicated set of 267situation circumstances But whatyou described this is the first time that I was not clic:lnt think that justice was sufficiently served andthat i the,,EBicontacted me to.initiate an investigation Thgt 11n11sual tl;Ling 1_ that_s true And in fact you were in large part relying qn the report thathad been done in the investigation that-had been;dorie by the Ialm Beac:h Hi Pofice.Department A Yes Had there ever been an occasion where me strike that At any time did youteH the FBI not to discuss the case with the State Attorneys 267Office A No Did you tell the FBI when you first met Page with them that you were disappointed with the manner YQich tti.e SJ13te Aitorpey had pro;,ecuted or hacl handied the Epstein matter MR HILL Objection asked and answered MR KU VIN Twice Join THE WITNESS Yeah I dontknow than used thatcexact vor__cL I didtit et as th9tigh justice had.been sufliciently,served BY MR CRITTON Had there ev.er bt:eii another inStance,where the State:Attomey had either filed charges had gone to a Grand Jury as they diclin the Epstein case and then you:subsequently contacted either the FBI or.the U,S Attorneys.Office and/or they contacted you A Ill try to stay with you better this tile Cplild ygu ln this particularinstance Mr Krischer tookth Epstein:ch13rges or t!w allt!gation to a 267ornnd Jury the Grand Jury came back with an indictment an:d he subsequently was arrested You subseqiJent!yha contact With the EBi ancf the FBl 225and the USAO did thdr own independent inves_tigation correc;t A Yes Page Had you ever had another circumstance like 267that during the time that you bad been the Chief or 267the Assistant Chief or a police officer for the Town ofPalm Beach that is where the State Attorney had filed either charge that yoll didnt agree with.or had taken it to a Grand Jury Grand Jury had come back and had returned an indictment and then you to the FBI cir the FBI contacted you or-wa:s this the 1irstand only occasion A This w.;is the _first.occasionjn whigh ever.had a case go to a State Grand Jury that 267wasi1 a homicide There have other instances that the case 1,ogged down in the state prosecutipn and.it was dear that the most appropriate piace to be 267would.beg fed_eral_prqsec:ution Alld th.le cast wa,s eventually investigated by the FBI or theDEA or the Secret Service or somebody 267being:prosecuted by the US Attorney In that particular situation though did the stat 225wor;k-s th StaJ Attomey!s Office york with the FBI ot the U.S Abs office to bring the fed.era charges because it gqt b9gg dmyn in the stat investigation and/ot proe ss A Yes typically thats hoW it woufd go So the stale wa:s 267then actively involved Pages to Pleasanton G:te.enhiIl Meek and Associates CA Aronberg-0805 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CA/Aronberg-0806 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CA/Aronberg-0806 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM TOWN PALM BEACH POLICE DEPARTMENT A NATIONAL AND STATE ACCREDITED LAW ENFORCEMENT AGENCY May PERSONAL AND CONFIDENTIAL Mr Barry Krischer State Attorney Office of the State Attorney Fifteenth Judicial Circuit North Dixie Highway West Palm Beach FL Dear Mr Krischer Please find enclosed the probable cause affidavits and case filing packages thus far resulting from the Palm Beach Police Department 2s investigation of Jeffrey Epstein Sarah Kellen and Haley Robson The submission of these documents are both in response to Assistant State Attorney Lanna Belohlaveks request for them and to serve as the Palm Beach Police Departments presentation for prosecution I know that you agree that it is our shared responsibility to seek justice and to serve the public interest by discharging our duties with fairness and accountability I must renew my prior observation to you that I continue to find your offices treatment of these cases highly unusual It is regrettable that I am forced to communicate in this manner but my most recent telephone calls to you and those of the lead detective to your assigned attorneys have been unanswered and messages remain unreturned After giving this much thought and consideration I must urge you to examine the unusual course that your office 2s handling of this matter has taken and consider if good and sufficient reason exists to require your disqualification from the prosecution of these cases Sincerely Michael Reiter Chief of Police MSR:nt Small County Road Palm Beach Florida Fax w.parmbeachpolicexoin Page of Public Records Request No CA/Aronberg-0807 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM A NATIONAL A.ND STA TE ACCREDITED LAW ENFORCEMENT AGENCY May PERSONAL AND CONFIDENTIAL Mr Barry Krischer Stat1:1 Attorney Office of the StatE3 Atto_rney Fifteenth Judicial Circuit North Dixie Highway WestPalm.Beach FL Dea..r Mr Krischer Please find enclos the prc l::lcJble c-ause affidc1_vits ar1d case fing packages thus far resulting from the Palm Beach Police Dep rtmehfs i,nve tig tion ofJeffr E:p te.in Sarah Kellen and Haley Robson Th submission ofthese documf;ints are bottfi!I re ponse to Assistant State Attorney Lanna Belohlaveks requestfar themand to serve as the Palm Beach Police Departments presentation for prosecution I know that you agree that it is our shared respcm_sibility to seekjtJstice and to serve 267the public interest by discharging our duties with fairness and c!Ccoun.tabillty.J mu.st renew rny prior observation to you that I continueto 267find your office.s treatment ofthese cases,highly ur:,us It i regrettable that I am 267forced to communicate in this manner but my most recent teiephone call_s to you and those ofthe lead detective to your assigned attorneys have oeen unanswered ari.d messages remain unreturned After giving this much thought and consideratio11 I must urge you to amine the unusual course that your offices handling of this matter ha taken ari9 cor:15.ider if good arid sufficient reason exists to require your disqualification from the prosecution of these cases MSR:nt Sincer:ely Michaels Reiter Chief of Police Sm,rh County Road Palm Bca f;l11riua F:n 5h OH ww palm cachpolice,com Page 5:of Public Records Request No CA/Aronberg-0807 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM OBTS Number ARREST NOTICE TO APPEAR juvenile Referral Report AumiTmiS tHAiivt AgencyORl Number aoi Agency Name PALM BEACH POLICE-DEPARTMENT Cha Type felony Misdemeanor Ordinance 2ap Foiony Traffic Mkt meano Other Lqcatonol Anest lnciuding Name Business DaieoJ Hame Usi,-F 253Mie Arrest 3/Request ior?Warrani NTA 4.;Reqwsl tor Cap a i ncy,Report Number N.TA Juvenile Weapon Seized?5 Enter type i Multiple CleerariceK Indicalor cationo Offenses Business Name/Address YY i 2F e.c Timeo Aries i Booking Date Boohing Time Jail Date JaifTtme1 Location dtvenicir Alias Name/D Race wu 2WMa i Amencan indanp BiacX OrieintaVAsian pate di Birth He pl Weight i cyA.Cdlor Y_ Lp!C Complexion lion Marital Status Religion ScarshMa Tattoos Unique Physical Feaiufes Indication ok Alcohol Influence OfUQlnfluence 2Cr Local Motas SlrMi.-Aot NumbarK i CM slSinoir Zio Residence/type i City 3?Fiorida County a Out of Stale PermaneniAMress Slre I.Nvmt CitX aja zar phone i Address Source yS M1 ZtuM Phone Occupation INS Number Place pKBirth City State iz nshij D/UNumber,.State7 Y4 tvvWb p0eiWftf Name.fCasi 2Ft Race Sew Daleol Birth Oy Arrested Ai Large iO Misdemeanor SrUtiveW ca-Defertani Ha ae laslfn i Race Sev Oai Bnh Arrested 03.Felony A Misde rite a no Juvenile Parent Name Last 5-Logai Custodian Other FKSlU Middle Residence Phone WCrass Street Apt Number CCyl Stale Business Phone i TOT.JAC Date Time The above aittess was provided by defendant and ZorDdelendanrs-parenu Thexhi and/orpireni was told to keepme Juvenile CourtClerks Office fhb-ne Tntdrmed of any change cl address CTYesi byi Name Ney Reason Property Crime DYes No Description 6l Property SchbbiAnerided Grade Value of Property WA Buy Defiver Distribute 2PfOOy P/Pcssess T./Tianic Cultivate Charge tescriptiprtj DfugActiviY Oryg-Typp Amount-/Unit Kjj Offense Counts Domestic XT iO ihai Descripiipn Counts Domestic Violence DrugAcliv.ty DrugTyjpe Jryg Activity Drug Type 225harge Description Vug Activity1 OfugTypo ArnbunlZUfiib Amount ZUnii Amount Tnsfruaioh Mandatory Appearance in Mnstnjcibri No Ycu,noeO not appMHn.Couri but comply with inslructions on-Reverse do Offense Counts Domestic Violence ON Offense Counts Domestic Violence GLY Offense OfugType Barbiturate H.Halluanogen Paraphernalia UcUnkn6wh n;wA Cocaine M?Marijuana Equipment 243Other A Kmghelamin Emtero Stetirte fiafatioa Number Warrant Capias.Numbef 243ruio.y lai Nu Warrani Capas Number Statute yoiatigriNumbbr WanantZCapiasNumber O/Opium/Deriv Synthetic I in A i i i Vkrtatign.btpRp-a Bonar StatuteViolation Number _L_I i KI 225Warrant ZCa aSNumber TyjdaiioaoTpRDjr Bono Vrpiaiton of ORQ Bondi i i violation ORO Bond Location Court Room Number Address Court Date-arid me Month 221Day Year Time a:m P.M iGREE TO APPEARAT-THEJIME ANDPLACEiDESiGMATED TO ANSWER THE OFFENSE CHARGED.OR TO PAYTHE FinE SUBSCRIBED I UNOERSTAnO ThaT SHOULDJWILLFUUIYTAII.TO REAR BEFORE-THE COURT AS REQUIRED BY THIS TlCE TO APPEAR,THATTMAY BE HELD IN CONTEMPTOF.COyRT A A WARRANT fOR MY ARREST SHA Sigrialwebf Defendant or/Juveifclea aren UDforptner Agency fme Signature 6l Ariesi dhicffr A Dangerous D;Rosisled Arrest ItSuicidai diher Nameiof Arresiing Officer CPrint LD jo He 2Oeputy Pouch Transporting Officer Agency PRINT Witness here if subject sigriec.wilh an 2X DateSigned Name 2Verifi iGri Rri PAGE jOE DfSlRI TlONt WHITE COURT-COPY GREEN 221STATEAHORNEY YELLOW AGENCY PJNK 227JAK GOLD-1 DEE ENDANT EA ON LVj CA/Aronberg-0808 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM BTS Number ARREST NOJ ICE/f fiRPEAR I i I i I JlivenilfReifoalR po_rt Nam Property.Crim O_es p.1lo ii 1pperty_ CJYis O!io __ Utpo-n No om ltje_r Adg!!Ssf a fa16,Y arenc flfC_ou!l 1nstructirill No _2 i:A.u0 i _CMO_I Anended I I 30rqu95t O!.,Wairan1 ll I io,i;:aJlia AIT8SIOO O2..-Alla i I Res_iger.ce PfM?ne s-Ptibne_ i Violation ol ORO Violation ol ORD 267,YtU_noe-:t.nOJ"apperi,,ir _Coun:bu riitisl Coury Qau fr.e oo_ 225wllh-in t1 orf S.oo MO,fol_ YO"a Time P,M 1GREE TOA.PPEAT 225THE.TIME ANO.PI.ACEDESIGtiATEO TO ANSWER THE OFrENSE CHARGED ORTOPAY,THE 267FltiE SUBSCRIBED UN0Ef1STANO 267THAT 225SHOULD IWILLFU lY.FAil TQ PEA BEFOR_E THE URT RE lUlflEI lY THIS NOTICE AP R,:THAf,A 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counts Lewd and Lascivious Molestation From March through February the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein Sarah Kellen and Haley Robson Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein El Brillo Way Palm Beach Several of the victims were recruited by and brought to the residence by Haley Robson to perform massages for Epstein for which Robson received monetary compensation During the visit they would be introduced to Sarah Kellen Epstein 2s assistant who in turn would record their telephone numbers and name The victims would be brought to Epstein 2s bedroom to provide the massage Epstein would enter the room and order the victims to remove their clothing to provide the massage As the victims complied and provided the massages Epstein would rub his fingers on their vaginas On occasion Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage On three separate occasions Epstein had intercourse and inserted his penis/fingers in the victims vaginas At the conclusion of the massages the victims were paid sums of money ranging from The facts as reported are as follows On A fourteen year old white female hereinafter referred to asM dobtf mi hnd her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach reported that a subject known to her as 223Jeff had touched her vaginal area with a vibrator/massager while within his residence 223Jeff was later identified as Jeffrey Epstein through a photo line up During a sworn taped interview ltated that Haley Robson dob a cousin boyfriend and classmate at worked for a wealthy man and did sexual favors for him She also admitted that Robson had offered her an opportunity to make money During the beginning of the montl 2February fexplained that she was first approached by Robson to go with her to Epstein 2s house Ftated that Robson along with a Hispanic female later identified at iickher up at her father 2s house on a Sunday as not sure of the exact dates but knew it was a Sunday 243lold her father that they were going shopping but in reality Robson drove them to Palm Beach During the drive a The foregoing instrument was sworn to or affirmed before me this lsl day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County of Palm Beach Signature/A sting Officer Date I CA/Aronberg-0809 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Defendant Race/Sex DOB Charges Probable Cause Affidavit Palm Beach Police Department Jeffrey Epstein White Male Agency ORI FLO Police Case I Unlawful Sexual Activity with a Minor counts Lewd and Lascivious Molestation From March through February the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein Sarah Kellen and Haley Robson Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the sidence of Jeffrey Epstein El Brillo Way Palm Beach Several of the victims were rec ited by and brought to the residence by Haley Robson to perform massages for Epstein for which Robson received monetary compensation During the visit they would be introduced to Sarah Kellen Epsteins assistant who in turn would record their telephone numbers and name The victims would be brought to Epsteins bedroom to provide the massage Epstein would enter the room and order the victims to remove their clothing to provide the massage As the victims complied and provided the massages Epstein would rub his fingers on their vaginas On occasion Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage On three separate occasions Epstein had intercourse and inserted his penis/fingers in the victims vaginas At the conclusion of the massages the victims were paid sums of money ranging from The facts as reported are as follows On A fourteen year old white female hereinafter referred to as 225dob her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach reported that a subject known to her as Jeff had touched her vaginal area with a vibrator/massager while within his residence Jeff was later identified as Jeffrey Epstein through a photo line up During a sworn taped interview,atated that Haley Robson dob a cousin boyfriend and classmate for a wealthy man and did sexual favors for him She also admitted that Robson had offered her an opportunity to make money During the beginning of the month of February xplained that she was first approached by Robson to go with her-to Epsteins ho11se tated that Robson along with a Hispanic female later identi ed at ick her up at her fathers house on a Sunday atvas not sure of the exact dates but knew it was a Sunday ltold her father that they were going shopping but in reality Robson drove them to Palm Beach During the drive a The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me ignature of Police Officer F.S.S CA/Aronberg-0809 Beach sting Officer FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO conversation occurred between Robson and whereas Robson reportedly told bthat if Jeff asked her age she should say she was eighteen It was later confirmed by theOBB father that Robson picked his daughter up on February According tc fefather Robson drove a pick up truck Bescribed Epsteins house as a two-story pink house with a Cadillac Escalade parked in the driveway She recalled that Jeffs house was on a dead end street Upon arriving at the houseOBstated that they walked up a driveway past what appeared to be a small guard/security room A male approaching them asking what they wanted Robson stated they were there to see Epstein The male allowed them to continue walking up to the house tated the man told them that Epstein was not there but was expected back He allowed them to enter the house the kitchen He offered them something to drink while they waited inside Shortly thereafter Epstein and his assistant described as white female with blond hair and later identified as Sarah Kellen entered the kitchen Epstein introduced himself to MB OBdescribed Epstein as being approximately forty-five years old having a long face and bushy eyebrows with graying hair Robson and Epstein left the kitchen leaving lone in the kitchen They returned a short time later They all spoke briefly in the kitchen vas instructed to follow Kellen upstairs I Becalled walking up a flight of stairs lined with photographs to a room that had a massage table in it Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room There was a door on each side of the sofa there being a mural of a naked woman in the room as well as several photographs of naked women on a shelf Kellen told the victim that Epstein would be up in a second Epstein entered the room wearing only a towel and toldflMo take off her clothes MMstated Epstein was stem when he told her to take off her clothes Kaid she did not know what to do as she was the only one there in the room so she took off her shirt leaving her bra on Epstein had removed his towel and told the Bto take off everything MBstated Epstein was nude when he took his towel off placing it on the floor as he laid down on the table I tated she then 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 AsBBbegan to give Epstein the massage he told her to get on his back 256Bstated she straddled herself on Epstein 2s back whereby her exposed buttocks were touching Epstein 2s bare buttocks BBcaid Epstein was specific in his instruction to her on how to massage him telling her to go clockwise or counter clockwise Epstein then turned over and instructedOMto massage his chest lvas now standing on the ground and resumed massaging Epstein 2s chest area htated Epstein held onto the small of her back as she massaged his chest and shoulder area Epstein then turned to his side and started to rub his penis in an up and down motion Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County oTPalm Beach SignatJr 243Wrrelsting Officer Date Pape7of CA/Aronberg-0810 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO conversation occurred between Robson andililwhereas Robson reportedly tol hat if Jeff asked her age she should say she was eighteen It was later confirmed by the41 225father that Robson picked his daughter up on February According ther Robson drove a pick up truck iescribed Epsteins house as a two-story pink house with a Cadillac Escalade parked in the driveway She recalled that Jeffs house was on a dead end street Upon arriving at the house tated that they walked up a driveway past what appeared to be a small guard/security room A male approaching them asking what they wanted Robson stated they were there to see Epstein The male allowed them to continue walking up to the house tated the man told them that Epstein was not there but was expected back He allowed them to enter the house via the kitcheri He offered them something to drink while they waited inside Shortly thereafter Epstein and his assistant described as white female with blond hair and later identified as Sarah Kellen entered the kitchen Epstein introduced himself to_ a:Iescribed Epstein as being approximately forty-five years old having a long face and bushy eyebrows with graying hair Robson and Epstein left the kitchen leavin lone in the lcjtchen They returned a short time later They all spoke briefly in the kitchen a.vas instructed to follow Kellen upstairs taecalled walking up a flight of stairs lined with photographs to a room that had a massage table in it Upon entering the room there was a large bathroom to the r_ight and a hot pink and green sofa in the room There was a door on each side of the sofa ltecalled there being a mural of a naked woman in the room as well as several photographs of naked women on a shelf Kellen told the victim that Epstein would be _up in a second Epstein entered the room wearing only a towel and told-..0 take off her clothes.9stated Epstein was stern when he told her to take off her clothes aid she did not know what to do as she 267was the only one there in the room so she took off her shirt leaving her bra on Epstein had removed his towel and told the-to take off everything 9stated Epstein was nude when he took his towel off placing it on the floor as he laid down on the table tated she then 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 Asallabegan to give Epstein the massage he told her to get on his back tated she straddled herself on Epsteins back whereby her exposed buttocks were touching Epsteins bare buttocks 225aid Epstein was specific in his instruction to her on how to massage him telling her to go clockwise or counter clockwise Ep tein then turned over and instructed massage his chest as now standing on the ground and resumed massaging Epsteins chest area lated Epstein held onto the small of her back as she massaged his chest and shoulder area Epstein then turned to his side and started to rub his penis in an up and down motion Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S Paee2of22 CNAronberg-0810 State of Florida FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO massage vaginal area stated there was no penetration as the vibrator was on top of her underwear 14recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table Epstein then left the room andH ot dressed She went back downstairs where she met with Robson aid she was paid three hundred dollars in cash from Epstein Before she left Epstein askedO4to leave her phone number As Robson and 4were leaving the house Robson told 4b she received two hundred dollars that day for bringing her During the course of the investigation parental consent was granted for4Bto assist with the investigation At our direction 14conducted controlled taped phone calls to Robson 2s cellular telephone spoke with Robson in an attempt to arrange another meeting with Epstein 2564sked Robson what did she need to do to make more money Robson stated 223the more you do the more you get paid Robson had subsequently called back left a voice ma message for her indicating that she had set up an appointment for to go to Epstein 2s house at am on April This message was recorded from voice mail Based on the above trash pulls were established at Epstein 2s residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach The trash pull from April revealed a telephone message for Epstein which stated Haley and name at am This was the time frame Robson had informed to be ready to go work at Epstein 2s house On October Sgt Frick and I went to Robson 2s residence and viewed her vehicle parked in the driveway a red Dodge Neon 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 Way in Palm Beach Robson was asked if she would 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 Robson voluntarily came with us back to the Palm Beach Police Department Upon our arrival at the police station Robson was brought to the interview room in the Detective Bureau where I obtained a taped sworn statement I began the interview by asking Robson how she became acquainted with Epstein Robson stated that approximately two years ago just after she turned years of age she was approached by a friend named Molly at 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 Robson thought about the offer and agreed to meet with Jeffrey The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County of Palm Beach Signaiur A/rr sting Officer Date Page3of CA/Aronberg-0811 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO massage vagina area stated there was no penetration as the vibrator was on top of her underwear 225recal1ed Epstein ejaculating because he had to use the towel to wipe himself as he got off the table Epstein then left the room andll9got dressed She went back downstairs where she met with Robson 4Psaid she was paid three hundred dollars in cash from Epstein Before she left Epstein askedlato leave her phone number As 267Robson and were leaving the house Robson told-she received two hundred dollars that day for bringing her During the course of the investigation parental consent was granted for-to assist with the investigation At our direction-conducted controlled taped phone calls to Robsons cellular telephone spoke with Robson in an attempt to arrange another meeting with Epstein a.sked Robson what did she need to do to make more money Robson stated the more you do the more you get paid Robson had subsequenty called backemd left a voice mail message for her indicating that she had set up an appointment foI9to go to Epsteins house at am on April This.message was recorded from voice mail Based on the above trash pulls were established at Epsteins residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach The trash pull from April revealed a telephone message for Epstein which stated Haley and name at am This was the time frame Robson had informedlto be ready to go work at Epsteins house On October 267Sgt Frick and I went to Robsons residence and viewed her vehicle parked in the driveway a red Dodge Neon 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 Way in Palm Beach Robson was asked if she woud 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 Robson voluntarily came with us back to the Palm Beach Police Department Upon our arrival at the police station Robson was brought to the interview room in the Detective Bureau wbere I obtained a taped sworn statement I began the interview by asking Robson how she became acq.uai.Qted with Epstein Robson stated that approximately two years ago just after she turned years of age she was approached by a friend named Molly at 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 Robson thought about the offer and agreed to meet with Jeffrey The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S Page.:3of CA/Aronberg-0811 State of Florida County of Palm Beach FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Molly Unknown last name and Tony Unknown last name picked Robson up and she was taken to Epstein 2s house Upon her arrival to the house she was introduced to Epstein in the kitchen of the house She was also introduced to a white female known to her as Sarah She was led upstairs to the main bedroom known to her as Jeff Epstein 2s bedroom Sarah 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 Sarah then left the room and informed Robson Jeff would be in in a minute Jeff entered the bedroom wearing only a towel He removed the towel and laid nude on the massage table He laid on the table onto his stomach and picked a massage oil for Robson to rub on him During the massage Robson stated tried to touch me and I stopped him I asked how he tried to touch her Robson stated that Epstein grabbed her buttocks and felt uncomfortable Robson told Epstein I 2ll massage you but I don 2t want to be touched Robson stated she performed the massage naked At the conclusion of the massage Epstein paid Robson After the massage Epstein stated to Robson that he understood she was not comfortable but he would pay her if she brought over some girls He told her the younger the better Robson stated she once tried to bring a year old female and Epstein stated that the female was too old Robson stated that in total she only remembers six girls that she brought to see Epstein each time she was paid Robson stated she had brought the following girls a year old female a year old female and Robson said thal at time she brought Sirls t0 Epstein 2s house they were all through years of age I asked Robson which one was the youngest Robson advised the youngest as she was fourteen when the massage occurred Robson stated every girl she brought knew what to expect when they arrived They were told they would provide a massage possibly naked and allow some touching I asked her if was aware She stated every girl she brought knew what to expect She explained she knew that wanted to make money She approached and explained about going to work for Jeff agreed an arrangements were made to bring her to Epstein 2s house on a weekend Robson stated that she and Later identified asflHKflHMH picked up flfeat her house Robson stated that at that time she was driving a red pickup truck They traveled to Epstein 2s house and entered through the kitchen door They met with the house chef and Epstein 2s assistant Sarah fl vas introduced to Epstein while they were in the kitchen area Sarah iedfeflupstairs and Epstein went upstairs When the massage was overfefceturnedto the kitchen area Robson stated she was paid for bringingflfeto Epstein 2s house Robson stated 225told her she was paid for the massage Robson stated that vas the last person she brought to Epstein 2s house She had changed her cellular number to avoid being contacted by Sarah She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this ls day of May by Det Joe Recarey who is personally known to me Signature of Police fficerfi.S.S State of Florida County of Jm Beach SignaturpAXKMting Officer Date Ql OOb Fagen of CA/Aronberg-0812 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Molly Unknown last name and Tony Unknown last name picked 267Robson up and she was taken to Epsteins house Upon her arrival to the house she was introduced to Epstein in the kitchen of the house She was also introduced to a white female known to her as Sarah She was led upstairs to the main bedroom known to her as Jeff Epsteins bedroom Sarah 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 Sarah then left the room and informed Robson Jeff would be in in a minute Jeff entered the bedroom wearing only a towel He removed the towel and laid nude on the massage table He laid on the table onto his stomach and picked a 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 Robson stated that Epstein grabbed her buttocks and she felt uncomfortable Robson told Epstein Ill massage you but I dont want to be touched Robson stated she performed the massage naked At the conclusion of the massage Epstein paid Robson After the massage Epstein stated to Robson that he understood she was not comfortable but he would pay her if she brought over some girls He told her the younger the better Robson stated she once tried to bring a year old female and Epstein stated that the female was too old Robson stated that in total she only remembers six girls that she brought to see Epstein each time she was paid Robson stated she had brought the following girls al6 year old female _a year old female and Robson said that at the time she brought these girls to Epsteins house they were all14 through years of age I asked Robson which one was the youngest Robson advised as the youngest as she was fourteen when the massage occurred Robson stated every girl she brought knew what to expect when they arrived They were told they would provide a massage possibly naked and allow some touching I asked her if as aware She stated every girl she brought knew what to expect She explained she knew that wanted to make money She approached-and explained about going to work for Jeff agreed and arrangements were made to bring her to Epsteins house on a weekend Robson stated that she and Later identified picked up 9lt her house Robson stated that at that time she was driving a red pickup truck They traveled to Epsteins house and entered through the kitchen door They met with the house chef and Epsteins assistant Sarah 119was introduced to Epstein while they were in the kitchen area Sarah led-,Upstairs and Epstein went upstairs When the massage was overa9returned to the kitchen area Robson stated she was paid for bringing9to Epsteins house Robson stated9told her she was paid for the massage Robson stated tha as the last person she brought to Epsteins house She had changed her cellular number to avoid being contacted by Sarah She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this I day of May by Det Joe Recarey who is personally known to me PageL of CA/Aronberg-0812 ing Officer Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO when he was going to travel to Palm Beach Robson said when Epstein announces to his assistant Sarah that he is traveling to Palm Beach Sarah would then contact Robson to arrange girls to 223work for Epstein 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 Sarah still tries to call Robson 2s house and leaves messages Sgt Frick entered the room and explained to Robson that based on her own statements she had implicated herself by bringing underage girls to Epstein 2s house 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 2m like a Heidi Fleiss Hollywood Madam who sent girls to clients for sexual favors in California Robson was dropped off at her house without incident On October Sgt Frick and I went to speak with a sixteen year-old female who was brought to Epstein 2s residence by Haley Robson We met with fl mother at their front door We explained the ongoing investigation and asked to speak withl as we had information that she had 223worked for Jeff Mrs.introduced us to her husband and allowed us entry into the home We sat in the dining room and met with Date of BirthAs she was under the age of eighteen Mrsivas advised we would be speaking with her She expressed if her daughter had information she wanted to assist We interviewed who denied having any inappropriate encounters with Jeff Epstein She stated she had gone to Jeff house with Haley Robson approximately eight months ago and sat in the kitchen with the house chef but nothing happened As the parents were present during the interview we felt that was withholding information from us She made several comments as to putting the entire incident behind her I left my telephone number and advised should she wish to speak with me again to telephone me Sgt Frick and I thanked Mrs 225for her time and left the area She stated she would ask hgain after we left as to what happened at Epstein 2s house I informed her that had my telephone number and hopefully she would call On October Det Dawson and I drove to theOBB home and met with and BB dobflHMI During a sworn taped statement approximately a year ago when she was seventeen years old she was taken to a house by Haley Robson MBK stated she knows Robson because they both attend She was told she could make money working The foregoing instrument was sworn to or affirmed State of Florida before me this Is day of May by County of Palm Beach Det Joe Recarey who is personally known to me Signature of Police-Officer F.S.S Signature A ting Officer Date Page of CA/Aronberg-0813 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Ag,mcy ORI FLO when he was going to travel to Palm Beach Robson said when Epstein announces to his assistant Sarah that he is traveling to Palm Beach Sarah would then contact Robson to arrange girls to work for Epstein 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 Sarah still tries to call Robsons house and leaves messages Sgt Frick entered the room and explained to Robson that based on her own statements she had implicated herself by bringing underage girls to Epsteins house Robson provided cellular telephone numbers for the girls she had mentioned previously Additiona11y she also provided possible addresses and areas in which they Jived 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 Im like a Heidi Fleiss Hollywood Madam who sent girls to clients for sexual favors in California Robson was dropped off at her house without incident On October Sgt Frick and I went to speak with a sixteen year-old female who was brought to Epsteins residence by Haley Robson We met with mother at their front door We explained the ongoing investigation and asked to speak with we had information that she had worked for Jeff Mrs ntroduced us to her husband and allowed us entry into the home We sat in the dining room and met with Date of Birth As she was under th age of eighteen advised we would be speaking with her She expressed if her daughter had information she wanted to assist We interviewed ewho denied having any inappropriate encounters with Jeff Epstein She stated she had gone to Jeffs house with Haley Robson approximately eight months ago and sat in the kitchen with the house chef but nothing happened As the parents were present during the interview we felt tha.was withholding infonnation from us She made several comments as to putting the entire incident behind her I left my telephone number and advised should she wish to speak with me again to telephone me Sgt Frick and I thanked Mrs.tlfor her time and left the area She stated she would ask ain after we left as to what happened at Epsteins house I informed her that.had my telephone number and hopefully she would call On October Det Dawson and.I drove to the home and met with I During a sworn taped statement 225tated approximately a-year ago when she was seventeen years old she was taken to a house by Haley Robson stated she knows Robson because they both She was told she could make money working The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Page5of22 CA/Aronberg-0813 State of Florida FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORB FLO for Jeff She was told she would have to provide a massage to Jeff tstated upon her arrival to the house she was brought to the kitchen area by Robson They met with the house chef who was already in the kitchen area stated Haley Robson would wait for her in the kitchen was introduced to Sarah Jeff 2s assistant who brought her upstairs to the master bedroom Sarah prepared the room and massage table for a massage Epstein entered the room wearing only a towel and she provided a massage stated she kept her clothes on during the massage She advised sometime during the massage Epstein grabbed her buttocks and pulled her close to him said she was uncomfortable by the incident involving Jeff At the conclusion of the massage she was paid for the massage I asked if she has any formal training in massages to which she replied no I asked her if Robson received any monies for taking her to perform the massage stated Robson had received money for taking her there but was unsure in the amount BB stated she returned to Epstein 2s house on another occasion with Robson and another girl MB stated she waited in the kitchen with Robson while was taken upstairs by Sarah stated she only did the massage once as she was uncomfortable with the whole experience At the conclusion of the interview the tape was stopped I was informed that Sarah had attempted to reachMBB via cell phone A voice mail message on October at am revealed a female voice who identified herself as Sarah who requested to call her back reference the police questioning provided the incoming telephone number asl BB stated she inadvertently told about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein 256Bhad called her to tell her that she was given a rental car a Silver Nissan Sentra to utilize to visit family and visit Epstein 256asked her what was going on at the house that the police would be asking questions stated then called Jeff and Sarah and asked what was going on reference the ongoing police investigation According to BB Sarah has since then been trying to contact her to ask about the police questions I instructed 256not to contact Sarah and do not provide any more information to she would notify Jeff Epstein and Sarah what was transpiring On October4 made telephone contact with vho had left several messages for me to contact her During the message she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened She further advised she did not want to speak of this incident in front of her mother At approximately pm I made telephone contact with During a taped recorded statement 2566tated the following approximately a year ago when she was sixteen years of age Robson took her to Epstein 2s house twice She knows Robson because they both attend The first time she went Haley Robson drove to the house They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed before me this Is day of May by Det Joe Recarey who is personally known to me Signature of Police Officer S.S State of Florida County of Palm Beach Signature/Arrestlng Officer Date Pagekof CA/Aronberg-0814 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO for Jeff She was told she would have to provide a massage to Jeff stated upon her arrival to the house she was brought to the kitchen area by R9bson They met with the house chef who was already in the kitchen area stated Haley Robson would wait for her in the kitchen was introduced to Sarah Jeffs assistant who brought her upstairs to the master bedroom Sarah prepared the room and massage table for a massage Epstein entered the room wearing only a towel and she provided a massage I stated she kept her clothes on during the massage She advised sometime during the massage Epstein grabbed her buttocks and pulled her close to him said she was uncomfortable by the incident involving Jeff At the conclusion of the massage she was paid for the massage I asked if she has any formal training in massages to which_she replied no I asked her if Robson received any monies for taking her to perform the massage stated Robson had received money for taking her there but was unsure in the amount 225tstated she returned to Ep teins house on another occasion with Robson and another girl stated she waited in the kitchen with Robson while was taken upstairs by Sarah stated she only did the massage once as she was uncomfortable with the whole experience At the conclusion of the interview the tape was stopped I was informed that Sarah had attempted to reach via cell phone A voice mail message on October at am revealed a female voice who identified her 267self as Sarah who requested to call her back reference the police questioning provided the incoming telephon number asa stated she inadvertently to about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein 225tiad called her to tell her that she was given a rental car a Silver Nissan Sentra to utilize to visit family and visit Epstein asked her what was going on at the house that the police would be asking questions stated then called Jeff and Sarah and asked what was going on reference the ongoing police investigation According to Sarah has since then been trying to contact her to ask about the police questions I instructed not to contact Sarah and do not provide any more information she would notify Jeff Epstein and Sarah what was transpiring On October4 I made telephone contact wi ho had left several messages for me to contact her During the message she advised she was not completely truthful when we met in person but would like to speak with me fo advise what had happened She further advised she did not want to speak of this incident in front of her mother At approximately pm I made telephone contact with During a taped recorded statement.tated the following approximately a year ago when she was sixteen years of age Robson took her to Epsteins house twice She knows Robson because they both attend The first time she went Haley Robson drove to the house They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed _before me this st day of May by Det Joe Recarey who is personally known to me Signature of Policeficer S.S Pagek of22 CA/Aronberg-0814 State of Florida County of Palm Beach Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO introduced to Sarah and Epstein She was taken upstairs to a bedroom by Sarah who set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel He laid on the table and picked out a lotion for to rub on him At one point during the massage he tried to remove her shirt at which point she became very upset and discontinued the massage BothW and Epstein had a verbal disagreement at which time she left without being paid She got with Haley Robson who was sitting in the kitchen and told her 223let 2s go Bhdvised she received no money for that day BBalso said that Haley Robson had told her if she was uncomfortable with what was going on to let him know and he 2ll stop She knew that the more you do the more you get paid BB dvised that several weeks later she agreed to be taken a second time by Haley Robson Once they arrived at the residence Haley Robson sat in the kitchen and Sarah took her upstairs to the master bedroom again Sarah set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel He laid on the table andpicked out a lotion for rub on him At one point during the massage he tried to touch her buttocks As vas wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks Epstein then rolled onto his back during the massage and then attempted to touch her breastsflBhen became upset again and told Epstein she didn 2t want to be touched discontinued the massage and was paid then went downstairs where Haley Robson was waiting for her She told Robson she wanted to leave aid she never returned to the house stated she is aware that her also at the house and had a problem with Epstein Hater researched met with her at her residence During a sworn taped statement MBstated the following on or about November he was approached at fl Haley Robson a fellow student Robson asked HBif she wanted to make money She agreed and was told she would provide a massage to wealthy man in Palm Beach Robson picked her up and drove her to a house in Palm Beach She was brought into the kitchen area of the house She further stated that fellow BB HHI0Bstudents OB and 4BB came withthem They were brought into the kitchen where she was introduced to Epstein and other females tated she was introduced to a female helper of Epstein the female was described as white female unknown name with blond hair She stated that the assistant was familiar with Robson The assistant brought her upstair a master bedroom area The assistant set up the massage table and put out lotions to be used She toldB Epstein would be available in a minute Epstein entered the room wearing only a towel Epsteu emoved his towel and laid naked on the massage table and picked a lotion to rub on his thighs and back further stated during the massage Epstein asked her to remove her clothes She complied and removed her pants and blouse Bfc didn 2t remember if she had removed her bra but feels that she did OB Bwas certain that she stayed in her thong underwear OB continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer S-S State of Florida County of Palm Beaph Signature/Ar emn Officer Date OS/Ol/Wb Page of CA/Aronberg-0815 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palni Beach Police Department Agency ORI FLO introduced to Sarah and Epstein She was taken upstairs to a bedroom by Sarah who set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel He laid on the table and picked out a lotion for.to rub on him At one point during the massage he tried to remove her shirt at which point she became very upset and discontinued the massage Bothe and Epstein had a verbal disagreement at which time she left without being paid She got with Haley Robson who was sitting in the kitchen and told her lets go Advised she received no money for that day ea.Isa said that Haley Robson had told her if she was uncomfortable with what was going on to let him know and hel1 stop She knew that the more you do the qiore you get paid 9lidvised that several weeks later she agreed to be taken a second time by Haley Robson Once they arrived at the residence Haley Robson sat in the kitchen and Sarah took her upstairs to the master bedroom again Sarah set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel He laid on the table and picked out a lotion foreo rub on him At one point during the massage he tried to touch her buttocks A as wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks Epstein then rolled onto his back during the massage and then attempted to touch her breastsathen became upset again and told Epstein she didnt want to be touched tll9discontinued the massage and was paid ihen went downstairs where Haley Robson was waiting for her She told Robson she wanted to leave aid she never returned to the house 4II stated she is aware that her friend I as also at the house and had a problem with Epstein I later researchec I glob and met with her at her residence During a sworn taped statement stated the following on or about November she was approached at Haley Robson a fellow student Robson asked if she wanted to make money She agreed and was told she would provide a massage to wealthy man in Palm Beach Robson picked her up and drove her to a house in Palm Beach She was brought into the kitchen area of the house She further stated that fellow and with them They were brought into the kitchen where she was introduced to Epstein and other she was introduced to a female helper of Epstein the female was described as white female unknown name with blond hair She stated that the assistant was familiar with Robson The assistant brought her upstairs into a master bedroom area The assistant set up the massage table and put out lotions to be used She told Epstein would be available in a minute Epstein entered the room wearing only a towel Epstein removed his towel and laid naked on the massage table and picked a lotion to rub on his thighs and back further stated 267d.uring the massage Epstein asked her to remove her clothes She complied and removed her pants and dido remember if she had removed her bra but feels that she did 225awas certain that she stayed in her thong underwear ontinued the massage artd at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this it day of May by Det Joe Recarey who is personally known to me Page of CA/Aronberg-0815 State of Florida County of Palm Bea Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM PiobableCauseAffiduvil Palm Beach Police Department Agcnc/ORlS FIX table/straddling EpSteihW XVhile doihgThiMief buttp yw return io-the,groundjatvvhich-tinie Ep5te ntuied.tQ!h she was-surLhe was riiasturbatihg/bas pn hiyhand hipv ts noi want to look at his penis;areaWa uncomfortable Epst,ein,remov wasmextlodheintissage/tablc 2andturped-ir underwear on her vaginal-area Shortly thereafter Epstein ejaculated and rembveihjmself He Shbwaited-a he was taking a shower di 2i-ectwiefv Vhenl asked Bhbw old 2she was when this occuired she-st sheEad ieemALthecbhdusirf wasnt sure hit knows-it was close,to 273.stated she never returned to provide a niassage for Epstein At approximately Det Dawson and I mi?tAvith:fl 2dpb;flH residence has only seventeen years of age had notifiedher mother that she would be intervievyed reference an ongoing investigation in Palm Beach ihssuiedW that-her daughter was not a.suspect i explained the possibility of her bdiheeilhbr jtfrsjfedyBed consented to-the interview puring a sworn tdped;statemeht iSHfctated the fbllp wing at the age of Sixteen,-during thc-mpnth of associates of RobsphTnd-knew did sanie pebp told by Jier ehds from MM Robson called 3:iperspn knowing Sarah and scheduled the appointment Dobson picked dp imd.droveherWRalm fbhstreet cdW Brtll They drove to the end of the street and-entered a large driveway Tliey entered the kitchen area of the houseanc 225.-rietwithEps Ppbson led upstairs-to thgmam bedroom area apd sefupdhofobmAvith,a massage table and set-out tfe dils 273stated that uhil ing bedroom she observed numerous photographs of naked young gu Is Robson dimmed the hghts and turned on sb If music Robson exitcddhd-rdom.arid Epstein.entefeddhe-room wearing onlya towel ihstcuctedTcr to mb hiklegs underKiybutto area EPsicimaskedW;tb getoonrfortablg advised she didnot remo henclbthesv She was weafmg jeans and apropp nkH exg During the massage Epstein rehiovi the massagedablemh Epstein 2s-Chest area he-htteimpted-tdhci buttocl areadiowever due so due to the tightness oi the leans and a tight bell 256adc ised Epstein begairto masturbate as she mbbed his chest Epstein moaned.as shc rubbed his chest She observed he was continuing to masturbate and The foregoing instrument was swvrn to dr affirmed before methis 1sl day of May by Det Jpe Recarey who is personally known to me Signaiurefof Police OTficer E.S,S State ol jofida Co tyoPR alm Beat li Sngnatuni Date O3Q1 Rage pf CA/Aronberg-0816 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM P,tql/a Lil cGt1us,e,;_1JJi m,.f d1 PJlice pattJfi ent gcn.cxb_Rl/1 ab Ji s.t add ing E:pit 200irlt ss ck hili dojJ.lgtl1i lj 265ttp kp vere to_t;thing 6pstein i1s,i 1sfrl c"fo io tetuni to-ih:c grq411 wqrcl1-tirne:,Epsteinl rj1ecl 267have njs cl i:nfbb_e ad lisecf she sure.he_ ias m:a ttu.bflti!ig ase_q his ncl fiYoV nYe ts,g9lgg 267ljp ai ci gown on,hi 267-peni_s r,ea wrlid 3ill fo look tJiis 242a:bfc shi 225nvas U:r1t:Cll"ifrbrt?hi fpstein 19ved,;aJa:rge yl vibfator ich _cwas xt to tN.iu sstg tabl i lf le oh,_ CT tgiteg Ep teir biegafr ubbing tJie j9r11tq_r ve he hp1 _llr1def iiear J1et aginalitr Shci.r:tlY-ffjer fter pst,ein 267cjac_ur ied re1n0 iin1_sett ir9hi 225tnetibie He ed 9yer,t,:o i!1ere U1 shO et 267was-:apd 267ope cl th,e;;gl 1st _doq1 sh_ ited as:Jie s;ttiRiJ f:l b9v-;t ii i1:el i_i ctVie Whei S_ke_g a I qlqs_he Vas vh 242rftl-iis tate shs:,hfi,d.1usLttirned Ci1 At th t,l.5nc:J us ion Jhe st10 ver vas 267.paid either 0Q of OQi.OQ sh ated,s_M wasnt i,ire i:iu _hows:ii JQ 267.stai cl he:never,r turn_eq:9,pro,Vicfe lge 267for _Epst At aj pt x.irnately 2:lO pm Q.etb 245ws0ri ai1Wl inet vith-cioB 1tihl3r res,i_d9flc,e A 3s bii_ly e11lee11 i:tracf n:qtified 10ther;,that wt uldbe i11tiryj fet an o,hgojhgi ip siigati9 Palm Beas:h assuredifrer thc1 i daught nofa uspec.t ff exj a_ihed tlie,ii?OS;SJ l_i fy,9fh beii1g eftpi::r a Yitiless:or v1di1 _Mrs.dvis d_she,wanJt!,d-tb toope te atii;t pii te.dJcrtlie lntet n!:lf Ah,g a Ili tajj stc teJil_eflt ll:.tj the Io I lo fog Jlt ti ge si te.e1J;6 ri r,,g the-mop i Slijtem bcr she as i i"l2lOat:11e l:qy lal Robsoit or c:h;mcte mak ri1oiief yas.frie1td_s wit __ assQdat 9f Rolf1cihJ1d KJ1 ih same-r,eOj?le.,a aa bee1,:rteYfriusl told,by erfrieilds lYbi11 lt.i vha_t:Ro 265_son.d.id;fc riEpstefo Rob on lfe.c person kn"o.wirto Sarah 1edule,d th appointment Rohs:Oii pi dtlt1Jp nd,,drove herto Bea:ch 267fo,a."?treet Q,tilled,.B iJJo fzif lihey,drnve,;to the end ihe.stteeJan9:ent red large driyyway iex nte ed iheiki ghc:n ar a,6f the hous_e 1i:F ni wi ti Epst in V1Si1ftrQdUced,to.:Teif Eps_teiil Cib ort upsJai1 to the:;rnai il be _rd0in ar acllJ i SCJtiffthetoom 267With,a massagctaiil set 9_ut the citls stateptlizit,:whilegping:,up th stai_ts a ii1J9:_tlje qroo1i1;:h obscrved.ni,in1efo4 ph9i9gt!-P 11ake 267t1rig gid Jf9bso1i ihliijed:,ii gl ts ancl tutjled oil saft-1usic bso1rexJwd ihii 267l;:psteifl 11teit;d-i1 vea:tii1g l,tpiv.tr Ep tei11 pic.k d-.Qii and_ isti:uc.tecr her to riih ti:i:s t_md1;.r Iii l1ut1ock_s an ch ctr _a ps njisk:ecfh rJo gefco1n o_rta:bl ac ise_d she,di f,n,ot r"eniov,ehcr iihes She,,V af.1i igl t:j_emi!!Jand a ropp ik iqp po ing e_rbellY Jte DJ!fihgJhc qa sagc pstsin 11iOi,ed l1is I an la on,tbf ss.1ge-t hle lkeft A.s-rlW:iecf pste,ihs c:f1e fgya ie atl in ed i ayh do herptji1tsito tou 242frh rb1J to ks,t1rea 267.llbs,iiv i aql Jo ir so di.ifk tn_e Ugh tiei the and a,tigli d:yise Ep te,in,!J garitciri1astt1r tfte 225asj ll r_li6B h1 267.9h.es1,.:J;psre,in.Ihoa ed:as,shetl bedhis chest 1e oJjse.n,e.cf he as ti:inti11 hig to 225mt1sturoatrand Tl e--fbrcgoi instrum was sjt:ti:i;i1 to affih bc or,e lC tbk1st;;_diiy of lay I Jp 267.Recatcy 1s.per 6nalb kn _nie CA/Aronberg-0816 State ofiFioi-iti 225CountVof:.Palm Beach FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO attempted to reach up her tank top and touch her breasts pulled back and Epstein stopped however he kept masturbating until he climaxed He cleaned himself with the towel he was previously wearing was paid for the massage and left the area She met with Robson who was waiting in the kitchen area and left the house explained she never provided another massage for Epstein She did however go to the house lobson and 256Bas they took another friend of Robson 2s 256advised she was present when wait for while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went When finished with the massage they left the area I asked if Robson ever told her what would be expected when she provided a massage stated yes Robson told her that a massage would be expected possibly naked and possibly some touching involved 256has no formal training in providing massages poke about a thirdand last time she went to that drove another girl sixteen years of age who is friend to Epstein house ted 273had made money massaging Epstein and wanted to make money herself Robson took them in the kitchen area of the house and introduced Sarah Robson and Sarah took upstairs to the main bedroom advised she doesn 2t know what happened as id not speak about what happened in the room Received from Robson for going with her to Epstein 2s house and recommend ing On October at am I met with 253WBB dob explained to her why we there to interview her She advised she was aware of the ongoing investigation MB had previously spoken wid told her she-s interviewe by sworn taped statement 225stated she knew that Haley Robson worked for Jeff Epstein in Palm Beach BM advised she originally had been taken to the Epstein house by Haley Robson whom she met when they bo She began going t0 the house when she was years stated she had been there a lot of times to provide massages over the pasttwo years I asked her if she had formal training in providing massages whichB 256tated she had not advised she was told what was expected of her by providing massages and she would have to remove clothing but if she to say so and Epstein would stop pushing the issue Mbegan providing massages and ad he clothes on She considered Epstein a pervert and he kept pushing to go further and further xplamed he would keep telling him she had a boyfriend and would not be right to her boyfriend Itwasn 225began removing her clothes and staying in her thong underwear to provide a massage The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County of Palm ach SignaturelAri in Officer Date Page of CA/Aronberg-0817 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO attempted to reach up her tank top and touch her breasts pulled back and Epstein stopped however he kept masturbating until he climaxed He cleaned himself with the towel he was previously wearing was paid for the massage and left the area She met with Robson who was waiting in the kitchen area and left the house then explained she never provided another massage for Epstein She did however go to the house with Robson and they took another friend of Robsons advised she was present when ent to work for Epstein She advised she rode over and sat in the kitchen area with Robson to wait for eidvised while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went When 225atwas finished with the massage they left the area I asked if Robson ever told her what would be expected when she provided a massage a stated yes Robson told her that a massage would be expected possibly naked and possibly some touching involved 9has no formal training in providing massages 9,poke about a third and last time she went to Epsteins house Robson drove another girl sixteen years of age who is friend to Epsteins house that 9had made money massaging Epstein and wanted to make money herself Robson took them in the kitchen area of the house and introduced to Sarah Robson and Sarah took upstairs to the main bedroom advised she doesnt know what happened aslaiid not speak about what happened in the room aeceived from Robson for going with her to Epsteins house and recommending a On October at am I met with jiob nd explained to her why we there to interview her She advised she was aware of the ongoing investigation stated she had previously spoken told her she was interviewed by detectives During a sworn taped statement stated she knew that Haley Robson worked for Jeff Epstein in Palm Beach advised she originally had been taken to the Epstein house by Haley Robson whom she met when they both attende She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years I asked her if she had formal training _in providing massages which 225-tated she had not advised she was told what was expected.of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue began providing massages and advised she kept her clothes on She considered Epstein a pervert and he kept pushing to go further and further xplained she would keep telling him she had a boyfriend and would not be right to her boyfriend It wasnt until recently that gan removing her clothes and staying in her thong underwear to provide a massage explained The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Sigoa.ture of Police Page of CA/Aronberg-0817 Officer Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ProbableCause Affidavit Palin Beaeli PohceDepa rtment Agency OR IM ELO Epstein wanted to be rubbed on his back and recently he began turning ovei and have her rub his chest as he masturbated HCWpuld try icfbdcUhbr 273:statW 221JeffA try tgrgebawgy vvRh mdre and moreen eabh he attempted to use a rhassager/vibrator on-hen Rbbsoiidrw houseTbrthe original massage left Sarah herxeikphone iwniber and every timeEpsteih pukr appointment to Work Each time she went Sarah wouldmeet her at the kitchen door area She would bririg Epstein would asUfeW QP5 about herself Epstein knew-she wasja soccer player and wouldlie attendihg iB 2568iMrt knew her real agefl Wed Mpstein;didiajtddidmt care the most recent massage she provider was pn October During the massage:-she asked Epstein if she cpuldibpmow.one of his vehicles tQwisii jhef family and boyfriend in iOrlan.W Epstein JiadfoldJiCr 2shecw of.his vehicles:,buiJatppstateiLh her a ear She continuedAvith the massage as 243psteimgrabbed;,herbu A Mfeitshe waX tvearmir uiidergannehtsitp whicirshe replied herdhong tifidefweam keified tQ tpuch Her breasts.-she wbiild puE axvay fr.dm hinfandrhe yvould.s aMbifat jSj vas/aWare-.of 2.the-vibraterbut.adyised.shey She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator She stated he kept the vibfatoi in a closet near the massage table stated that on October wafECphiacted fe 243psteinJs.-as that Jeff Epstein had rented her a new Nissan Sentra-and she should conic by the.house to pick it up Sarah infoimedii she would hate the cai for a month taicd Epstein knew her car was not working properly and that she missed appointments currenth parked nextmO Held asked her if she ever jb61e.anYfoe explained she.jookWHB a..triendiof.hers who:attended MM Who-has relocated Orlando to attend college laskedif she ever allowed another femalein the fppm,;O 273advis one brbughl.into tliMppmW At the conclusion of the interview Det Dawson and 1went to the gym area and located the Silver.Nissan Sentfa bearing EJorida tag X9S-APM The vehicle is registered to Dollar Rent a Oaf out of the Palin BeachInternational Airpoi The velucjewyas by Janusz Banasiac later learned to be Epsteinis lioiis.pnian and paid with Epstem 2sBfedi On September 5j jW/f R4ob MH was arrested by the PalmBeachBbli The foregoing instrument as sworn to or affirmed State of Florida before me this day of May by County of Palm Beach Det Joe Recarey ho is personally known to me ign afii re fl 2o I icebiffice F.S.S CA/Aronberg-0818 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ftob.t1 Jjf edJtu,se Jffitjdvii alw.I.Jea,d1-P,olice Qepartnierit Ag nc ORill E:pst_efo yanted to be i:i bbccfo ri bis ba anqrece11iiy:l1e byg 11:tt1thing nd;li her/ruhhis bhe a a_stuibate iHc:ioul try w.fo 265t,h,frer.b asfs ipe.,rubb hi"s-qhe.s tiited Jeffwgt1ld tty t,9,geta-,Y Vith hlo.re 9re OJ ch f!l?S ge liillistat dE1:istei yb 265lcl,-try t9 267heq:ii0re and,9n _ohe ci 9asi6n be atte,npted 1jlass.ag 225ibra tor.on.J1t;L Robso;il 267ardve lhe hoU Jor 267the;_;rigi_nal ge left afr ei,cei1.-pl;ione,ntill1_beirantj ery ie"Eps_1ei_i-t v.oUUi cqi 1e,into to _vi Sar_ah 267-i.Votjic!;c ll herJo art appoihtpientlO";";_,:qrk EuJi tirne she Went _ar;al1 IQ Jd her at tl kitt ef door:area,:Sh ldbririg qei u.pstairs 267and.:Pr9pare 225tlt dT1aSsage taJ5I i JSed Ep O,Ul _kfrer;q 1e_s io.rfs abqHt-hersei Ep tei kne v,she_wci.s;a r1 Jcfrer ai1di io ge attendii J.g p:tHliilillf inlqie agi!-st teg_Ep teij1;did ajid di_cl Car The I recc1ii mis_Sag p;tj ja Mis b1HQ.cto!5 zpp Dudng:_tht 1s agi;-she,asked?Epst ih i slft f0 1lg b9rro v.opeT1fhis,V 242!lii-ies fo iisit;n f-fa1iiy:;and.1J0Yfirtffih orra 1i:lo1 fl r,ida FPS1 had co.,ui:d-.b r6 ofie j5 ehiil bu laJ f:stated ivo 267renr hefa car he onfinue l:Witii-!he inassag as J::pst.ei_.,grabbe her bi.ltt_oC:ks fess t.he tJoc liek i;y i riqgilil dergarq1e 1t t9 Ybich-she replielhyi;thOT UJ t,fet,i;,;;ea Qiji;:eihe triecl tq;tcil 9h lie breasis dhe would pun a ay.fi:orn-hi1ii:a1idihe ii6Uld stop ias asked1iLh ier used,a 267vihtatdr.,ori 1er re f.Ji1 vll;iral6r b,VLacl 1sed he.I CWC i W6t,1ld Vltim si tn iit,r Jor WJ;i et sh;:_d j_b:;d th_e,fibt,:Hcir s:theJa1cgewllite vibr.1.i9C i a:huge head o:n rhe _lp qfth i jr itor 225,stat clhe 225ke,pr,me bjator in a e,l_os _t:i"!ear the:n1assa Jable tat t_h?t on October 2pos,,sh ia _,cbi1facted l:jy;Epsfeiil _assis arah1.:Wh6:iijforrpe Ll1eY rhatJeff:Epftein;hadt a new N1s Se!1in1,and 267she hciuid cot1i lW,tpe hot 225stTP pjcKft tip Sa aJ1 fqnne shei io:Lilq h4ve thc:.ca for.o n1o_qlly tfrief_Epste loie V;hi;r Vas Tk!ng propetlY a.ricl fsheli;drri1sse9 appoiriti11e11 t.bc au tof ier-91r i11g illOJ rqhl __ xplafhed c:urreJit p_arl edne:xttothef llt Gyitt fielcL lSkGcldJyf i.fsh eVedcYok OI th ll_ou pla1n c1;ifi:e..:todkL a i n.d.ofh.ers,who al deq who hc,is lo ilt d-ii Oi ai1_d_o att nd c6ll cl if h_e allb d,artoibir.f errfril 225iff Hie ip __ advised_:bCi vc1s ightin_to tl1Moorn Yitli.1fer AtJl_1e 225co.nclusf9n:dLtfei fery:jei ii,et Pa VSp,it andf e1ii;to he fir a and Jo ecf the"S i ve:r i Sei1 tra 225!Jear hgf fo iqf tat AP Iv TliG veh ii;le gjs L.t fo.Dollar Re,,nt c1 oufofth_e.f i!m,B 267eac.l lnt maJiopah itport The 267,veli_ic e,5aS,ryrire l;hy:JAn_y.s Baq siac rerl arned w.be 267Epstein:s rflJan agcf-p i1 245ith pSt i!.ifS::cre ifcNcf g9.in 267irstrtim iji:n:to:_01 225iafftfti1:e before 267-thish av by CA Aronberg-0818 State Ffor;icfo Cbu tv of neacli FILED PA BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO for misdemeanor possession of marijuana During the arrest 225told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein Additionally during the ongoing trash pulls from Epstein 2s residence discarded papers were found which contained name and cell phone number On October Det Dawson and I met with nd obtained a sworn taped statement explained she had been going to Epstein 2s house since when she was sixteen years of age Since then she has gone to the house hundreds of times 225stated she became his 223number one girl She explame haton her first visit she was brought to the house by fellov II BIMMii BB classmate 225said she was brought through the kitchen area where she met Sarah Kellen for the first time led the master bedroom Epstein room 225explained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house explained that she was brought into the bedroom where Sarah prepared the room by setting up the massage table and provided the oils for her to rub on Epstein 225explained she remembered the steam room area which contained two large showers Epstein entered the room from the steam room area and introduced himself Epstein lay on the and told her to get comfortable 225removed her skirt and kept her shirt on Epstein then instructed her to remove her shirt 225removed her shirt and remembered she was not wearing a bra 225Stated she ded the massage wearing only her panties She continued rubbing his legs thighs and feet he turned over onto his back Epstein touched her breasts and began to masturbate Epstein ejaculated which meant the ZsagTwi over At the conclusion of the massage 225vas paid They walked together downstairs Ze Sarah Kellen and I were waiting 225stated 225received an unknown amountof money for taking her to Epstein Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town 225slated that during her many visits a routine was established between her and Epstein She would enter the house and get naked in the bedroom She would then start with a back massage Epstein would roll on to hs back and allow her to massage his chest area 225slated Epstein would then began to mariurbate the same time would insert his fingers in her vagina and masturbate her with his finger would continue this process until he ejaculated He would then utilize a vibrator/massager orthe.-vagina climaxed 225advised that during her Sequent visits Epstein asked for her real Epstein advised her not to tell anyone her real age 225advised that things escalated thin the home as.Epst would instruct and pay to have intercourse with his female friend Nada Marcmkova 225explained the intercourse included using strap on dildos large rubber penis and other devices that Epstein had at his dispos Fp in would watch them have intercourse and masturbate himself Occasionally Epstein would then join in The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Officer State of Florida CouwtystfPaimyBeach Signature/Arrksimg Officer Date Page of CA/Aronberg-0819 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO for misdemeanor possession of marijuana During the arrest 9told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey 267Epstein Additionally during the ongoing trash pulls from Epsteins residence discarded papers were found which contained name and cell phone number On October Det Dawson and I met withli9md obtained a sworn taped statement explained she had been going to Epsteins house since when she was sixteen years of age Since then she has gone to the house hundreds oftimes she became his number one girl She explained that on her first visit she was brought to the house by fello classmate aid she was brought through the kitchen area where she met Sarah Kellen for the first time as led to the master bedroom Epstein room explained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house further explained that she was brought into the bedroom where Sarah prepared the room by setting up the massage table arid provided the oils for her to rub on Epstein lltexplained she remembered the steam room area which contained two large showers Epstein entered the room from the steam room area and introduced himself Epstein lay on the table and told her to get comfortable em6ved her skirt and kept her shirt on Epstein then instructed her to remove her shirt removed her shirt and remembered she was not wearing a bra all6tated she provided the massage wearing only her panties She continued rubbing his legs thighs and feet tll9idvised he turned over onto his back Epstein touched her breasts and began to masturbate Epstein ejaculated which meant the massage was over At the conclusion of the massage,lla paid They walked together downstairs where Sarah Kellen and 225itwere waiting stated 225.-1eceived an unknown amount of money for taking her to Epstein Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town stated that during her many visits a routine was established between her and Epstein She would enter the house and get naked in the bedroom She would then start with a back massage Epstein would roll on to his back and allow her to massage his chest area allstated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers xplained Epstein would continue this process until he ejaculated He would then utilize a vibrator/massager on her vagina climaxed advised that during her frequent visits Epstein asked for her real age 9stated she was sixteen Epstein advised her not to tell anyone her real age.-advised that things escalated within the home as Epstein would instruct and pay to have intercourse with his female friend Nada Marcinkova explained the intercourse included using strap on dildos large rubber penis and other devices that Epstein had at his Qisposal Epstein would watch them have intercourse and masturbate himself Occasionally Epstein would then join in The foregoing instrument was sworn to or affirmed before me this st day of May by Det Joe Recarey who is personally known to me Signature of Police Pagel of CA/Aronberg-0819 State of Florida Cou Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Agency ORI FLO on female intercourse and provide oral sek;tO;b0ili 253Aand:Ma This occurred during the-time a vasosixieen.years of age fil dydsedThisxohtirit The routine became fanriliaH assistant Sarah would telephone her even time Epstein was in the own of Palm Beach nd would place appointments forher to visit and work for Epstein Each time something new was introduced additional monies were produced and offcied for allow he acts to happen consented to peiform all these acts but as adamant that there was an understanding with Epstein that no aginal penetration would 0CCU Ilh his Pcn1 thatEpsteins pcnis-was deformed explained that his penis xxas oval shaped claimed when Epsteins perns waserect.it was thick toward the bottom but was thin and small toward the head portion calledEpsteiir 2spenisttipgg-Shape stated Epstein would 2photogiaph Marcinkova and her naked and hayihgse and proudlyidispiay We photographs the home gpstatefdurihgbnWsm in wlijch-.fe Epstein WisTei friend Nada Maicinkpya was also,present provided the massage im which Marcinkova and her would.fondle each others breasts and kiss for Epstein to eniov Towards the:erid:oWlta lier ow onto her stomach onih.c manage table and fored inserted his.penis-into her vagina Wstated Epstein beganWumpWt became-upset oven this SheYaitW held against-the table to pump inside her Shescreamed 223NqU and Epstein stopped She told him that she did.npt want to have ns penis inside of her Epstein did not ejaculate inside of her and apologized for his actions and subsequent pan hiMNhGu3tari displays her photographs tliropghrout the houses DiiOcwber ImietywiW a sworn taped-statement that nothing happened between her and Epstein disappeared nervous during ae interview TassureddieLthW have spoken xvithqtherpe letxvho adv ischd occasions she prox ided a massage to Epstein She staled she was brought to the Epstein house in March of classmate at flMMaMBIM approached her and asked her it she ivanted diB rnddStfie hg assistant who has no formal Wi.ih.jM clothed for As sensed hesitancy fro,n EPsle,n organizations hpug 273siated she was interviewed already by a pnvate investigator for Epstein He identified himself as aul Tndinquired about the police investigate and left hrs telephone number foi additional contact no-aijdiMWlfa were almost scripted The foregoing instrument was sworn to or affirmed before me this davofMav by Det Joe Recarey Signature of 1h liceX ficef I frt-.lOj State of Florida County of Palm Oichi Signature/A esfi ig 3ffietr Date Page.l2of CA/Aronberg-0820 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probahfe,CrtiJse--.Affi,daVit a1tn Bea _IJC 267a-rtml;nt A c.iifiQ.B:ili FLP soCJ _Q:o duri:ngJi fe1pa.l onf irilile iht c;ui:se and prQyidc 6rALs bi;i:th _a_nd Ki i oxr Thi pc tJrr fdt1"r:G1 foe-time as,six eeh-Y a.ts of cjv/sed this:conliriue t6,fsc I.ati:q_1,1fjngj V9;ye:al"s Tlie roi.itine.bec irtie"fatnili rto,_ Epstiins ass,staiit 267Efa:ral _wqtild tel_ephone eyir5,:1inie asj11 ejp Vnp-ttaJn2Jka:ecp,anc1 itJld pfo i ii rt trJ1e:i1 tsf orc 267hefi to vi.sit?.n,d:,work:.Tf E:ps te:in Ea6l titp 1rn::ne as froqti ce.cl a:adi ori;il fC:pr dtic a11d ciff cl:f6r wtJ1e:acts Jo tppeh Qh Iit lOJ E!tforfl lliti s.e:a tsibu1 was 1da!1Jcll1t tbaUJ-i V3S I i.friderit 11Q,ihg vitli.EpsteirlJh tr10 Vctgihal penefrat iqit YOU.IQ OC-CUr;_ itll,his periis CXRl?Ji1 cJ Q1at Epsteifrs pe/1is as defor-hie 8explc1in eci Q1at,b his.was oval s"haJ1eq cl?imed e1 Epsteihsipeilis as,efe t;,i twasthiclqoy;rard bOJlc;iil JJ.ut thfll a d;siall Jp yar 1-Uw Jj_eacl p:qrt,orf i c:al_l 4J,p ieii1 _P.eni lrnp te EpBtc i woutH::phqtqgraph tvl rci nk Va artd he_r na ed and l:iayi1-1g se a_n,ct,proll9Jf:displ?Y 267the.J ji_q1tigraphs hih ih h61e:c faiE.g during_cfr e,visfl l_O Epsteitrs;house ifr:wbjc,h,sM-p"ro icl ige o:.Ep i1i sf e1 t!-;riync di far,q11 kQY 267aJso Stnt prov_ided he 267,rriass ge 267iir yhi9lrK1arcfnkova ri_dh i,wiul9,fondJ1 267eathqiherstir a.s1s d,k_iss or teji1 iq 11j.oy TowafC::1 q:n 267ctofthis 1il:i age Epstein 267gral,h 242d:land ur!J 267cl.her 267ov_er qnt6 her sJomatli:ort m;s ole aT1d for iJ2lf,ins rt l"h1 p_en s,inJo li vagi_ria 267-,,ag_ina;-bepai;i1e 267_Lips ovc;:u Shr said het ii11g freld a,gaihst-the,JrJ,DIC fofoibl as_;he lp putnp insi:d er She Cre,cl ls Nq andt;P,Stein_,stopp sne 267tolcl hi tha:r?h dicl not ha e-Hi pei1i;shwicJeofli ppst indicl,fi:o:rfjac fin id dfl eiindapoi 267ctgizfd:fot,1 i a cti lli_s.a Lili eq S:pii.d h,er Uhol sanq Jgl ars ro hcii vi,si lpted slje ni y.rl e-sfi 11:displ_ays her pfo;go iph,s thr0Ugj119uf he h9,use 0n.O.smhei wson _find 1:me,t.vi i ho stateiJ dtirjng il 267Hip_eq statement tff aiilolliing:happeriecfl:iet,ye_e11 rand Ei itei app:eaiecl 11ervous i:lurjhitth inter.Vi 225rass,medJ1ei 1t ha:ve pciken ith 9thetp 9pJ vho i:h.isr J.:differentlj srnt bn,se eraC asio11s she 267cj:fro i d:,p1nass ge to lpsteiri 267She?statGd she as r9 265ght lq the-Epitiin fa l,jse in M?i _La c:lassfn:ale ar __ app r,o,ac.f J,efc n.?r _dih c-ifil1e antc.d lO iClr flD1adet e:aqa gemc11ts vith r.s_t in;S sis irit_:4 wJig sn fo 1L irai11ing ii1 providinJ a,g.es/sia,ted she::p_roVideo amassage;,ftJl clo;hed fof Q:O.O As nseci hyS!tc ncr i iskec I _i sh been,-c ed by 260;inYone.f1.:c 1pEpsiein q_i-g?h1zations oF;llis Jouse a,icd she yc1s iC e,d;alfo?s!Y by-a rh.:vat ijl e.stigc1.t9rfo psteiJ.1 Ij idpnJi:fi d:,llimself as P;auli hd;:i11g jred fl?cil;if ili pbl sfrg g9q ft ni telephone.11ll1J:ier foJ:-aclclitiorial corit,ac j:ifCJyid no a6,qitiQl1a,Vi,rif0rination as:it._app ycl 11c:i::1espon were n1QSfS Tipted i:t1.efor ing frunien rai to or 225frfi-im beforcme thisJ da ofi:t 1av by et-.Joc Reta l,:lrn i pctseina,I_J rn 1n CA Aronberg-0820 State ofFJo idh i unty P.fiiv ch FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Gj ɃS s?,lBj?U m띃 C?7J rqF??ԧ F?y T?ҡ kW?艖IǕ??5?-z P??yċ?xx Ig i-V??L 8a ϠA i aP?t??pU ccKn U?J?xJ??XP Uz??g??V R9 GхZ T??ZP U?KCb j?W Uj W??R M-l?f5?Da?Z GDz A KZ??V?F?T W??n??ZUZs4?F ZU 0?rg B?ڈU UV-1I ciP X.??dS?Ʌ Ɋ?v ӄ?v?j QR cԄ 1g FV NI?a 2O P?F ql ej I J-a4w D?T6?ik4 DPl Ɩ?-k Ӄc?Q?D)Y i?l?D i9c??Z m?H F?,Т Ⱥ?鹞 pn?d RcY gD PLö qgDu a??C gb LB c?gZ ё??D M4Gm?A fp h1T?A?v c?Wn?â?"l f?E D?7VLpR Bh?Zq m?c?Ӭ9 C-?gqr?Rǩ?A l6f4?Q?pU??c?P?EG?k qq L"V Ҥ??l ո?i??XO?F M?r?C?t a yc??g?Ϙ p?ږ;rXl u??u?u c?I?U VոO?I pǦ?_V c?i z?Le?A-?ҹc?a w??Q Yc 㥭Z?dEq??d!P b?k,t uśL??ΜZ gٵ B??jY?l X?X j?qk,t(j?S nB A ǎ??cU Y?_SȢ t3 م?c?L W?I 1G j?c?n??Y G?оۋHj A3 Ue he d?5pԱ t?L8iH8 h?H B5 J??e Va Iz?X dA R?G Ťݤ??B 5x i hFM X?c??S Ҩl g?z AK?B SLL aDS"A?8 S?NX?䂜 H?pK t??U fEє ˊŝ p?G a Y??b?a QMR A N7 4?;Ddg PD r4 3?VK qRSgc h??zb ja a tFE aHZ dE2 tt?1 Ϲ?fv Eh Dmc L??BҀ-u??C d?2n?vv??-EyS RΑW UiC?R FaH i M?J OAF t?p 4h WT?a?gƐo L??oO?QM s?l?_h?I ia iSZ FҮ?C?F 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ʴM?F5 E_Sk??Ua S??F?Y?B B??C P2 yW m2U I Ʊn??A?jE xb?s a?O Ӱ?ҫ C??d?E??Fd?E O?Q hh G?Jd BЈ 2Z y?z ʒT LU?2 _:pŋ A g?l x?h vg i gL?ĒH?E?Ŭ E??nA?ԝ DA QAJ N?g NG EpUe E?I eu?vP I A?r ߊ?v QN r??q ƷݨH?M X??Whh i E?W i HP2o EB:?Q GѴG i d??pE A v!?M?ӫC N?H Fg?F??X??P ˌד?y?O I v?Z a D?ODK?fKvv C.e q)?O gM3 L?t Ϗ?p ڮ)?Q A gg?I4_ ڊES i j?Y ӧ_?C?y aA I?I A?q W?o??hw a CB?ohC??"?y?a ED?d S?xכr Z?u A rl2 w_ E?B ܭ??:EIgj Y?.K 0Y vBʌ?QC iZ jo?_ KJ0 S?t 4?fP fˈ??L?R ƩTxɱb?1 X??k RF?A?ŋ z?I E?r ɄmE XDJ I Wkt?ۮ W??š?V?AuVO ܟһv?a?s?on TD??I Hˢ Mڰ?!п F?V 4K Ӹjox3 ƨ?B"6v DXdx??G?s xOO??hW z??m eƻ DF aQ?w J??C rC?y K?I?G ݍ?ﾶ ݘI?Jm1 O?s mT i ӄ?q7T Yǰ?a?쑯 x?H?T j??b h4t?b;J?4a Vߣ?0K dp??DBL?iy?6?4E?j??L?G PGt C"?B??uy mi Q?X??r pň ϦC S0 x?M a c?V s?QV?Y?U??ɾ C?N Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO P7nBe 223oep XXinXXiV house one time approximately two months ago She was approached by a girl.OI roommate for an opportunity to make some quick money advisedshe neededtomakesome Thckcash to make the rent that month She agreed to go to the house She had been told by the have to be done in her underwear She advised with her and brought her into the house They walked into the kitchen area and took the stairs upstairs stated she was broug into a master bedroom area She advised she recalled seeing portraits of naked women throughout the room A massage table was already out near the sauna/shower area in the master bedroon pstem enteredthe roo wearing only a towel and introduced himself as 223Jeff At Epstein 2s direction,and removed th clothing doL to their punties Bpstem laid on his stomach area and they provided a shewas area I asked if she had any formal massage training and she replied no she wore were the boy shorts lace panties She an 227coined fee massage uiml.be last ten minutes of the massage Epstein told leave the room so ha towd 227gotdressed and eftdx short panties and he produced a large white vibrator on her vaginal area stated she was very uncomfortable during the himself with the towel he had on previously and went into the shower area inin thp tc.hen and DrovidedOB ZUU.UU ror oringiug paid to providing the massage told to leave her telephone number with Sarah for future contact ner cenunu che reDiied she was called but it was contacted about this investigation by anyone from the Epstein organt stated 223work is for work She stated she was called by Sarah for her to remm to the term used by Sarah to provide the massages and other thugs advtsed she comfortable in providing that type of work sworn tX Epsteinlhirough Haley wh ey were still The foregoing instrument was sworn to or affirmed before me this Is day of May by Det Joe Recarey who is personally known to me State of Florida County of Palm Begch Signature/AYre tip Officer Signature of Police Officer F.S.S Date CA/Aronberg-0821 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO On November at approximately pm I met with dob at the Palm Beach Police Department identified as a potential witness/victim through information obtained during the trash pulls During the sworn taped statement advised she was at Jeffrey Epsteins house one time approximately two months ago She was approached by a girl who was dating oommate for an opportunity to make some quick money 225advised she nee_ded to make some quick cash to make the rent that month She agreed to go to the house She had been told by 225that the massage would have to be done in her underwear She advised dlove with her and brought her into the house They walked into the kitchen area and took the stairs upstairs 225further stated she was brought into a master-bedroom area She advised she recalled seeing portraits of naked women throughout the room A massage table was already out near the sauna/shower area in the master bedroom Epstein entered:the room wearing only a towel and introduced himself as Jeff At Epsteins direction andll removed their clothing down to their panties Epstein laid on his stomach area and they provided a massage on his legs and feet area I asked if she had any formal massage training and she replied no advised she was topless and the panties she wore were the boy shorts lace panties She an I continued the massage until the last ten minutes of the massage Epstein told leave the room so that ould finish the massage got dressed and left the room as Epstein turned over onto his back Epstein then removed the towel and laid naked Epstein requested that 225rub his chest area 225stated as she did this Epstein began masturbating stated Epstein pulled down her boy short panties and he produced a large white vibrator with a large head She stated it was within his reach in a drawer in his master bathroom He rubbed the vibrator on her vaginal area 225advised he never penetrated her vagina with the vibrator He continued to rub her vagina with the vibrator as he continued to masturbate stated she was very uncomfortable during the incident but knew it was almost over Epstein climaxed and started to remove himself from the table He wiped himself with the towel he had on previously and went into the shower area gnt dressed and met with the kitchen area Epstein came into the kitchen and provided for bringing and paid to fur providing the massage 225awas told to leave her telephone nwnber with Sarah for future contact p1ovided her cellular telephone number 225was asked if she was recently contacted about this investigation by anyone from the Epstein orgapization She replied she was called but it was for work She stated she was called by Sarah for her to return to work for Epstein 225stated work is the term used by Sarah to provide the massages and other things advised she declined as she was not comfortable in provid1.ng that type of work On November Det Sandman and I met with 225dob During a sworn taped statement stated she met Jeffrey Epstein through Haley Robson when they were still The foregoing instrument was sworn to or affirmed before me this st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S Pagel CN Aron State of Florida Officer FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Agency ORIP FLO 225tilidinekbbsbhiwbu females who wished WB mexrfain Usages She wakasked about any formalltraining.in providing massages which she said no WPM ih adcompanWRpbsomahdoth further stated sheYiad been to the house appfoxiihately or timesin the past year She accompanied Robson over thcy were previously told they vvould have to provide a massage possiblynaked They-were also told that dwuld Epstei require them to do a 221hey weic not comfortable just to tell him and he would 20Wfor each girl sheibrp.ugMioye Vheh basked which girl appeared to be theyoungest she repiied hb was reallyyoun fifteen years old at aheanpsWfiiBtefufthCT the house she sat.in the kitchen.and waited with Robson nhtil Hidhiassiage She ftrfthersiated thatThe cook woplfriaiRe waited I asked her inhere was anything that caught he atlent.on wtthin the Im Stated there Wereal iotiYfinakedVgSsfinjphd Uuirig/a sworn taped statement tate approximately first approached by Haley Robsqnya Qla.s Ro for Epstein and proyiding;a:mass for WP was unable to takelier the:day the amangenignts were made RPbsonMifilBMiBfrtakeWM she was brought there and entered througlvthe back kitchen door She had.me an assistant/Sarah and anothcr.assisiantA.drianna Sarahbrought her upstairs as she observed EpstetearnmM towef add laid omthetable 273.stated.W oils he wanted her to usetand requested shq reni0Ve:her iothihgto:prb ethemassage.M tatea.thaLonfthefirstmassage5 hfc;.proyided reinbve 221Her ciotli 273stated she had returned several times-after that Each.time than.aanassaue Epstein would walk into the master bedroom/bathrooni.area wearing pnly-a/towef He wduYd-masfcrba Wsiated.sfe wakuhsure.rf he pljmaxed as nnist under.the towei Additionally she never looked belbw his waist She claimed thaLEpstei wquld lemovehe.r clothes.She eventually rem use a masbager/vibfator which she descfibed in i lq d.a.large vibratbr/massager on her vagina area as he would masturbate The foregoing instrument was sworn to or affirmed before me this-ls dawpfjMayj by Det Joe Ketaiiey who is personally known to tpe State of Florida County of i a e/A Ffe tln fficer li igjiatUiie pfipbricqb ilcer Date Fagedy CA/Aronberg-0822 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Phi/J 265lfie AJfilia,vit Pifrn _lf?.V:ffutJil c:A;geiicx ORI FL0 11gi ojfa ol1 2671g;,apprqac tdi oik.ff t,J;p 267steh1 tated she was offer vorEf.or:Epstefo but declin yXJ?!sihwd,.tliaJ wqrk".ll hs ve 1l1i es Sh aS.a Red a99tit rY 6rmal riflii JQ,,provi4irig 267n:iass iGs Whfch she sii9 rio siici sh Rgbsqfr 9t et fem_ale l10,,ver6-:takertfo Epste1i1 oiis cl.o j:irQ tj inass ges 1rther tated 267she nads.ll _tp he hq aforo jtj_:i ft Ofi 225tim.es:ipJq.e Uear Slk aJ:corrtpaniecUZ wrni_ __ f,-!EacliJi1!1e.-the-gfrJs,,iJefetaR _oy _i,,;thfvwerc pr.evib 1sly toQ th Yio.l_fliave pi:pvid 2671Uassa.g a so,JoJa;tl a.t hij_ J,l CEps_tef quirf.t_he11y tci ai1yti:Ung extr an,cf they?,vt n0t:c6trifprtai;1 iu Ne.ll i1tl_ hi Vo 6R ted Rqbs9!1 267,fecefve l1_girshe,;bi i er lO 225,fl?,ffss Jeffrey 267jspste_iil Vhe!l/l-,a,iKed,whidf gi_fL ppearec:l to bethe;y6 J_ngest rep_i iect S,lf a lf;1:Y,QUF1Jt fifteen ycars 267-oJd.alC 225the;mp furth d;e cli tEile shl nf tj i 267She at il i qh c1nd 267:waite yith qn itil th n:i ss ge a She 265rthentated tMt:ib.e cooK-wo g1f u:n or n.a fct l_lep1 cis:fh wai te JJ1sked l1er if thecr As ftn;th:iQg tha c?-tl hilfor a ph iitirf!_ 1:l_oni sJa cl fre ver cp Jqtqfn i 242d,glflsii11,;pho.tqgr p_hs 267oqi 267theJi6t1?e 1Joyeipbcr:8 oos 225appr9 ihliftely:2 QQp1-.;,J1net ilf tthe Pa_lpi,1J?e_3.ch Ollc::e bep itn,1en u.6ng:p v!ott1 i,apeB:staJ i!iiht _;?tat ihe iiteJtg 260pste_in_ appr xi_ni t:wo-_ ears agtr i1 she y_qs fir5-f pp_roaclfed 6i le-yJ oo_s9_q ssm 1te c:ll __ Rob o!l appr9a.ct1 e:d her abp;ul o,f k,j11g i:Epite fri prov.idintt Jfias ie t9 hj_rn for Ko 9s6ri-lfad,mad the.,?-rt ng e.1eri,ts,l1,o Ve er rn al cf JQ take hei 267tJie d;Jy"the 267aiTaifg em 5ts e-rn de gc bsoi1limi _t k.l __ soatit;il a ptjN iniYiar viJl1 p_ fr1 c;ill slie vas brought re and eht red io 1g 267Gac kfrch _n Jjipr 267She Jaq.ajet itli n_ a?sisiariH3!rrah apd aoot et tlSsl-s_tant dfiflD..!lst Sar btoilgt:ii hers1:1psjai ciI she OP e_o,se,y nil pho.togr p11s C!J1il,r il UheJ16t1st __ fot 4-J::ps1ei came,in tfo roqn y,i Mh Ci!Y,,a tQ veii on,the:taJile a picl,:yd OPt tt,e-oHsJie 225;watJ!ed her 1S anirique Jed:dli fe.moy r1:ci othi.frg t_o,p o,j9e a:s age sf ted that.,ci,1 tfle fir rna age tided she cljd ql e-ii1ove-l1 J9thing it?te he-had tet 265_t.rwff vcrciKti11ies;a_ft th l;:ii b.ti j1e1sh tur:i1ecl it y.,as m0r fhai1,a1naf ge Bpsie 0l lchyaik.J!1tqthe rnas eroe,dio:9fnJ tl_lro.9r t1,ctrea.,,v.earingphl_y t9w fl ulci rt1 r;tuj9ate,as sHe:provi le a,ma;,sagc in tilt stat sl_re va fhSt1f ifhe ylirnax ci as ti,1r.b_a 243eci uiid rJl1e:tovi i 1ionall slre pe _ei,lookcicl belqwhis Va sf S,h1 t:laime i tlj J;::pste.il COfl1ince He toi reJnoy_e her:cloflierr he.,evertt iallyre:n1 ved;h d0Jhes tayed in y1.:tho11g,pantfos Off tc iion;.Ep jd;1 ohl_o u;e il mas ager i tardr Ytticfr cii?tti.Geq iite c.c lqt.:anq Ji JZpsteii1 n.ib;.t11e 267v1hrnrbr/rita sager lier i gi i area as vo qinasturbil I aJ d:s i enJo,the-hou_se 1:egFii1;g,iin iru-m c11t ai to 267;fti_hl c:g 225before mc:tfosd Of;M by et:Ji Jl tho;is 267g.ets_dnally fown to CA Aronberg-0822 SJa ti.f:-Fl ri4:la ol lm FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO numerous times added she has no formal training in providing a massage 243tated she brought two females during her visits to provide massages stated she brought a girl named an WB stated she received for each girl she brought Department During a 2swom taped statement stated she had met Jeffrey Epstein approximately one year ago She was approached by a subject known to her as had asked her if she wanted to make money providing massages to Epstein heard that several girls doing this and making money She agreed and was taken to the house by ad introduced her to Sarah and Epstein and brought her upstairs to a master bedroom where a massage table was prepared mid the proper oils were selected kft the room and waited downstairs for her stated Epstein entered theroom wearing a towel and laid on his stomach She provided a massage wearing only her thong panties advised Epstein had masturbated every time she provided a massage She stated Epstein continued to masturbate until he climaxed Once that occurred the massage was over She felt the whole situation was weird but she advised she was paid for providing the massage She also stated was paid by Epstein for bringing tated she had gone a total of times to Epstein residence to provide a massage and things had escalated from just providing a massage Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated Epstein also grabbed her breasts and fondled her breasts with hi tends as she provided the massage 273stated on one occasion while she was only seventeen yearsofag offered extra monies to have vaginal intercourse She stated this all occurred on the massage table stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the pom climax Epstein removed his penis from her vagina and climaxed onto the massage tab recewe for her massage I asked her if she had any formal training in providing massages,stated she not iXontinued to state on one other occasion Epstein introduced his girlfriend Nadia into the massage Nadia was brought into room with to provide a massage Epstein had them kiss and fondle each er around the breasts and buttocks as they provided a massage to Epstein Epstein watched an ed this occurred On other occasions Epstein introduced the large white vibrator/massager in the massage Epstem stroked the vibrator/massager onOHM vagina as she provided the massage On November Det Sandman and I met with dob taped statement she advised started going to the house approximately one ear ago and approximately five or six times also stated she was sixteen years old when shefirst went to Epstein house On her first visit she was brought by a fellow student The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer S.S State of Florida County of Palm Beach Signatuw nfesKng Officer Date oWv2OO6 CA/Aronberg-0823 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORJ FLO nwnerous times added she has no formal training in providing a massage she brought two females during her visits to provide massages 225stated she brought a girl named and 225tstated she received for each girl she brought On November I met with W/F at the Palm Beach Police Department During a sworn taped statement,_ stated she had met Jeffrey Epstein approximately one year ago She was approached by a subject known to her as Illa ahad asked her if she wanted to make money providing massages to Epstein had heard that several girls were doing this and making money She agreed and was taken to the house by Alaiad introduced her to Sarah and Eps.tein and brought her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected lieft the room and waited downstairs for her 225astated Epstein entered the room wearing a towel and laid on his stomach She provided a massage wearing only her thong panties advised Epstein had masturbated every time she provided a massage She stated Epstein continued to masturbate until he climaxed Once that occurred the massage was over She felt the whole situation was weird but she advised she was paid for providing the massage She also stated was paid by Epstein for bringing stated she had gone a total of times to Epsteins residence to provide a massage and things had escalated from just providing a massage Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated Epstein also grabbed her breasts and fondled her breasts with his hands as she provided the massage 225stated on one occasion while she was only seventeen years of age he offered extra monies to have vaginal intercourse She stated this all occurred on the massage table stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax Epstein rnoved his penis from her vagina and climaxed onto the massage table received for her massage I asked her if she had any formal training in providing massages 225tstated she did not ontinued to state on one other occasion Epstein introduced his girlfriend Nadia into the massage Nadia was brought into room with provide a massage Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein Epstein watched and masturbated as this occurred On other occasions Epstein introduced the large white vibrator/massager in the massage Epstein stroked the vibrator/massager on 225evagina as she provided the massage On November Det Sandman and I met with dob During a sworn taped statement she advised she started going to _the house approximately one year ago and has been thet approximately five or six times also stated she was sixteen years ol_d when she first went to Epsteins house On her first visit she was brought by a fellow student from known to her The foregoing instrument was sworn to or affirmed before me this st day of May by Det Joe Recarey who is personally kno,vn to me Signature of Police efm.cer F.S.S TL CA/Aronberg-0823 State of Florida County of Palm Beach FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ProbableCause Affidavit Palm Beach Police Department Agency ORI as OMHpr mt ed bi ought her into he house and she was introduced to Sarah Sarah then brought hei upstans into a master bathroom located within the bedroom stated she met Epstein in the bathroom HelaidsOn the tuble and picked the massage oils She provided the massage as he laid naked on the massage bed She staled she rubbed his calves and back.area Upon the end of the massage Epstein removed himself from the massage table and paid her JOTO for the massage ftsaid each.subsequent time she went to the house she was notified by Sarah Kellen that Epstein was in town and would like her to work CUglUgH tated sire returned to the house and was again led upstans by Sarah She provided the massage TwhZTgWMM wns asked if she ever removed hei clothing to provide a massage stated it was not until the third time that she went that she removed her clothing stated she was notified by Sarah that Epstein wanted her to come to work She arrived.at the house and wasled upstairs by Sarah She started pividihg the massage when Epstein asked.her to remove hei clothing WHMjWtrcnro ed her pants irtrand bra She stayed in hei thong parities and continued rubbing Epstein Epstein turned over onto his back and she rubbed his chest area Bbtaud she knew he was masturbating himself as she providing the massage stated she beheved he chriiaxedbased on his breathing She did not uant to iew-either thepjirnax or the fact that he was masturbating MIMBst.ated once the.breathing relaxed he got up and told her to get diessed She was paid for hei services bstatcd on the last timeshe went to proc ide a massage she was notified bv Saiah Kellen to come to the house and 223work stated she was now dating her cuncnt boyfriend and didmot feel comfortable going She lecalled it was approximately January She said she went already thinking that this would be the last time She went upstans tbe maslcr bathroom She met-with Epstein/who vas wearing only a towel and laid onto the table Epstein caught Iter looking at the clock on several occasions Epstein a ked her if she was in a hurry seated hebbovfriend was in the car waiting for her MM further stated.that Epstein gut upset as he wasnt enjoving the massage She told him that she didnt want to continue and she would not be.back Epstein told her to leaves she was ruining his massage 256Mdvised she had no formal training mpioviding any manages agM vmted although she had a falling out with Epstein she still received a Christmas bonus from Epstein stated she was wned money from Western Union for her Christmas bonus Subpoenaresults fiom Western Union revealed money was sent fiom Jeffrey Epsteinon December tKSv received from Epstein for her Chr istmas bonus iOn November Det Sandman and met withflB dobQlM During a sworn taped statement Unstated she met Jefti ev Epstein ov er a 2year ago She was sixteen eai of age and as approached byflMBa fellow tudent who informed herdhat she could make providing a massage to Epstein Miad informed her that she would have to provide this The foregoing instrument was sworn tp oraffirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Ihilice ficer j/.S I State of Florida Conntv of Palm Bppch Signa rfl/Ar i Offt per Date IU CA/Aronberg-0824 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM nfpg_b eC lfi,ltniit fairrh a a fl PolJ JJep rtm A QRI FLO;MO iOO t.ed c;.h,:ought l!er.tntb anq,sne s-:ifltrodt1c arnh arabHi1 i1 br:ought r,,upst isihto crri lfr bathrq 1i cci!9 I itl i1i"the 0"ohr statect ii rfiet pste in,th ba ljroo1n He 267laiJJ;9 the.tablc;ar1ci d._the ipa,s?.ageoils sfre 225,providid,ithe fo tage as;he:l:a:icl,11 ked 267o1Nrii massageJied She 267slaie lshe rtibbe hitqIIYis aI ti;:bfc ai 267cfl tlpo,ntlie:rn i orth J1ia?s3:ge 267Epst ih rr;mov lii,Q1 Cl ffrom ge ble,;attd pai i lier JOJtOOfor the mas,s i aid,ea.tb subs,equyhl tinie sh e,illb the.l;fotis Ji 119tiJ1ed qy 1ja,rah elie11.thatJ ps ejn S;ip;lO:Ynarid io.uldJikehetio VOrl tiiteg he.;reitiei:11 lQ Jl a,n1 3,s,c1gal ri eel tlj5stafrs bf Sarah Shepf:ovfde ihe.mass,ag cJ th,e;d ya askec:l if r:c;Jo iing 9:provide,a 267ma:ss?ge st11tecfit y,1as n9t jin_t I 267ii1ird frrn ctharspe:,,ve11Ltfi 1t she,xemqvecF 1er:dotl1ing st?r she v,if nbti lfah that Epst 265tcil her to co1etd Work Sh atfiveffat tb l10Use ai1d:,waf1 lairs Sflrah She 267siarted pi:byidii1g the n1assag J1e:n E,pstcin:c1sked her toren1qvt;.,J er ciothfrig 267w,rertioved her:tpants 247llirLancr br She ta ii Jfe thofrg,panties an:d ll ih ed:/ubhing Epsteili Epsieiri tuttied;over;onto his ck id sJ1c chesi.:w,y ated she irne,,i rnasturbating hiin elft.1s Hej1roviding tfi massage 267siated sheJ;ieved lieclirirnxed edofl 267.fosbreathinl Sl;e did,nciCwanttb view 225eithe:r 21,max tbe 1hat 1iwas rmisturbating iaiedgnc:e,,Jhe breii igr lax 200d:Jk,go up iat9Jci lier fo ge dr ed lkwa,s pciid 3.0JtOQJor hen tViye,s tir11 Venttc5;provide,:i rnas sagt 19,vas.n9iifi e.dby a1 267ah.Kel le11fo c,oni fo ili house fr1d y,Qrk statei:l 267sJif was 267now dati11ghe CllI;lCllt Q,oyffrend arid d1df:not,fe6l ortabl gdifrg Sl;ie Galle it was:;appr in:at 1;1.laJY Sl a1cJ she vent alret1B thillkiilg th?VtHis OU!d.,q Jl elist tjint,i Slie nt,vpstairs nd.:y,ent Jlt ii1e.:9rnster haihi,oo.m She rnet Mith E1:i tei11 267lrn Weifring on ly iel imdJaiq,onto the bJe staitlq fpsitilr 267caugh 1er o.okit1g ut the dock oii se eraroccas16n,s tpsteil1 Skeg sh lasiri hurry statedhei 225;boyfden9,.wa jn the car wafti11gfop he,c fofther st d.1hat Epst in,g9t ui.isevas he vasn!,t 1joyli th iTif!SSage she;:tolq 1_irrdh,at.sl1e didri.t:waq1 io co,ntit1tie and she IQtlld 9i back Er1 gld iief fo a ie,as she ash1ini hisil ts idyise9;sheHad,110 fqfl 1ql Ta,ihirig ihpro,dcling any i 3S_sages a g1Je:cI,altl1pcig11 pChad a falli11g out 225i!th,Edsfeiri 267s,tilJ t:e ei.Ye a Clifi fmas boiitis Jf-orri Epsfe1,1L stated sH wa ij:e,d West r6 Uniqii:for-he;r;Cpi1 QO!lSL:S,t!R results,fron Wester!i,Li1ii9n re Jleg,11ior yy:was se;11t fro1:Je,ffr fr r1:p,e,cembr:r:,2 242eiwd i 2QO,OO frpmEpsteiri H;:her Clu sfrnas-bonJJs Qn Novemberf fahdiJiarr i1dJn1eh9itl d9 Duii1g worn pe s.taten1eri ajsfafedshe::1i1et JeffreY-:Eps e1 ief"_ayear ago 225Sht;-.Cwassixt year 9f geand,wa ii1ptqri,ch a.fell_o tutlefih whointbrme9 1erith coiil,4 1i a_ke 1QO,QQ,,pfo i4in ftf1S tci:!:.pstein i11fcirn:i dh rthat:sh_e-wouldJ1a..;reto pr,9 fd Tbc,Jo:r gi irig;jfr truhienf ia irh,;tp:9r,affit1ed b,cfore ni thif daV ila:f D;et Joe Retare i;:ilf me CA Aronberg-0824 rare ElmJda Counfr of Palm Officcfr FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ProbableCiseAfjidavit Palm Beach PolBe Department A nc ORI statedis ndidle enteredthrough.a;glass:do She!was taken upstairs to a blaster bedroom Shefoctilied the master?bathi 256mdiaci.a largepiEEouch 221smma andmatchr thong underwear She further stated thatEpsten Duel on his chest on the table otoere-sel te ones to use on Kis4egs ba andjfeet forty pitnutes.intp tl massage Epstein turned over onto his kacfeaiidlfeqpested wait downstairs tn fotehep insiciedBRlo Efnishlhe-m Ak Ot-dress schpV left-the1 room 2And Epstein began.masturbatihg rubbed Epstein 2s chest stalgd Epstein con inued ma urbatinu un When asked if hc had removed the towel she stated Te.fornedfoefowefaround Uh the towel he instructed the massage was done and to get dressed mid meetwthfoi vot dressedand met With Epstein in the kitchen area She was paid dollars for stated she-was momcs-forWesanrwthmgx phe second time she went tp massaee agmed and the arrangements wetc made by for her to return to the house stated dfovelehtb4he:kouse and knocked ohkhe.same gl ass door whiehjeads toThofc pewwei owe entrvimo the house by one cdthe staff men 273led her upstairs to the ma Stef bedroom and Wer brirdom area Epsteitfienteredsthe.TOOm.agaih weaiing op towel 256tegamrerhdvii Epstein tnsgged hem Xii-bTh-sidriWback-ahdTe iW chest Epstein leaned over and produced He turned it on Chest as this.was occurring She rubbed her vagina dbTapproximately two to three minutes/With owelaoaih and informed her Wihle massage was done 273got:drcss and in the ldicbeh area She,received for the massa Wsaidlshe never she had fhp hniisb asked if she i ec ved any formalmiassage training She gdvisecl sh if Epstein knew herWi ofiW hei el and sdlwi Wwas waie she attended and is still.attendmg The foregoi ng ins tru in ent was sworn to or affirmed beforeme this 1st day of May,ZOObyb Det Joe Recarey who is personally known to me State of Elorida County of Ta Im Beach Signatu rr stAig ficer Signature of Police-Officer F.S.S Date WOlgOW 2npe CA/Aronberg-0825 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Fro/Jq,Mgd;aiisf-J fifi,g,it each PQU I ep ittintnf Xuen v--ORI T1 SSag 225lopf 267niade:.the auang i-its Epsiein-?n i-hisassisja t;;.and 267tciok lcFthe.,hotise stat_ed id 225she enterepthrough a 267glass doqt:thatle.d 267niro,a kitcheh She vas:ta eri psiE!iisll:Y_ t9 a ihaster drpo1,n_ she-r.ecalleail1e aster;baJliciQnyhaid.,a i rg,e iili J1 atchitjg sljb et Epstd11r o1ered mo e.rOb1 weaf_ing_,oi:liy i_Wf cf aJid _f,rndve he lotbtngJe"n1ainii1g orily-Sih_ thong UJ lcrwe:!L Slfe f-urther/stat 260fhat;6psfoi11Jaid i;,11:j1iicQeSton thCtt;ble_ ti1hf re.s e,t oi ih ch to BOtli a_n-d ided:.t e:ii1a st.fge 9n;liis,-legs ba ap Jeet l?orty minute fi;to tl1c nJassagc_ Ep k11f:tup1ed ovcr9r1t9-is bflcki11 tt m1ested v4it_cl6Wp j_rs he:ki tcll,t:il aryaf psiei11 i,isli:.l,tStecwlJto nisli.the tnas a As ffLJ g_otdres Cl rtiqg ru it psf effr Jyft Jlleroo.1;_;mcl E1r:itfin gat1 i wsturbating,11s-rti pe_cl 243psteini_,nihe a_ttc:l P,!l t?iff continued mzistlfr.b tittg unhf he c:I ii11a:f ed-oq t.6",.vethi w_as aring When c!Skeg i J,e hadt nio,ved:the she isJa1 b_e/t9mdd thoe io r9un tha 9pen ng,wo 11liLal IQW l"li into e:-:.pos 11se-lf After Cflij;lhirt1se ff i th the;_tQ elJ!e iJ1s.tru ted 267the.rtictssag_e vl/l doile cl fo getQrt!SSed ni ei vi ii h11n.do Vi1stails.;"9 g9 dressc_d:A11 i itlyEps ein-in th lcit9he11 afe,ll he was 1id s200:0:0-dolfiirs 267foi:,pr r1di g:,the,11ia,ssage 267tat sl!c a arp 267tfra alsore,sejyed for 267Jlie Ahii1g Jhe set911d Cl-1 ltl_ie 267house as;agaih 225qpprbached yisedifshe Vf!I1ie 1q_re,tufir to;Jhe,,h.0Us tqjpr9:vi ie a.11other 1"ilassage..,iigr,ye 243rrd l1e rr iigeJh"ept wer ma,df fpr to,rft_u,rp,19 He:hou?e st3:t li vebei:-ti tht frouse ilfld:J nocked dnJhe ame gl_a_ss.:d Oj wh1th 1d,st,6:JheJjg:Ji n.:;:ire:a TJ1e vei:l!:sii 0Wi bnlry,into 267.the:Jfo,t1s:C by,q_i_:fe ofth.e t.aff 1e,mbers ilf!e-:dh1:a:,i.Jj stafrs fr,nhe i:ri;a 267s:r6rbeqroci1i lcl h1pSter baili601il area ie,f this-,til1 e-t9 di tfre gt Jilt _n EpsJeib nter,ed:t e:foofn ga1,l rJr1g towel pegan clothing i she didJh sl Jrhe:-sifo lil Lthe E1?steili_ns_t_r.u tedi_1 r,t9 gehii1ked t-J 1i 1J le i1to hii irohi ich t;g0c 225:rnarf agihg,.his bucjlc_ As n_i he.d i th:Epstei11.s_-back.aiidl Jj?stf.ip turne Ct gr1to-:His Jiact 247tatte.cr t9 mfr h1s-9best:and 1e qega,1y i:l S.llJi"b r:ubbed his chest Ep_st in k3.!iedover ancfp1:odu V1 ige_r 225/ihra lQL turned it a 1cJ gan rt;bbi11g gina i11astt1i iaJ_iqg-h/1ns lfati.he iam time tf,lt sHe.ccintJn to::rnb.h c_liesl_as this as otcurring s1ie.cits:ctibej:l 0the,:iil _n1tor/tnass_ager asJarge,grey iJh rf,lrg heacl Epstein bbed_ giqa lot _apP:r9xim tely 267two f.g.t_hrr;e i11i IiUt vi,f h,1iw.-ijiass gerfvi pta_tOL eJtlJe,ri!emo vecrti vi_brator fr.6m;J.1er flginaCarea iina cqqcerttrateo QI m;isfutb ting;hfrns,cl 1fea Ep i1j cl!fi1a.-;Gdfl!llO;the lO VCI ai1d it1fot11kd-herlliafllie riiassa.1;:e vas doi1f fill QoU:ir.essed nd.mdtvfai who wZis w,iiJ1 1g in tl1e ki;cb area e1 ss gi 1fsa_i l;_si1 rt,ever:-r.e:t _lf:h tb hobs ncl:h ltj Il _s1tc rd rn JO the ho,ifse vas ked1 i1e"reQei otm n1as _a,g tra iriinjf tt!vtsed hy ad no.forirni1 tW1fof-kasas ip.ifEpst in.kne i:h_e.r.re._al agei t1 ci:J-i e,y;as,.lie:._ ke!db_er.q Sti611s aboui hcrselfand i1igh sci1tYOL Hewas,awai:e-she att6;1ded a11ct 2671sstili.attehdin as Tl1 o-r.egoirl in.strq nf a 9-fa fripi1 e:c1 eforc.,nie this:1 di1h;il 2Qff6 267bct:iloe Recarcv tho ls pcrsonaih;_ know-ri:-to inc CA Aronberg-0825 sratc_ofi:Elorid:l 267oct f?lm ach 3.tc FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Duri the course of the investigation a search warrant was executed at Jeffrey Epstein 2s home located at El Brillo Way in Palm Beach While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned The stairway which is located from the kitchen area to the master bedroom area is lined with photos of naked young girls Additionally numerous photographs of nake young females some of which appeared to be the girls I previously interviewed were on display throughout the house Also located in the house were various phone message books The telephone message books have a duplicate copy Carbon Copy which once a phone message is written into the book the top copy is then torn on the perforated edge and the carbon copy is left in the book First names of girls dates and telephone numbers were on the copy of the messages I recognized various numbers and names of girls that had already been interviewed The body of the messages were time of the day that they called for confinnation of work names and telephone numbers were located in which the body of the messages were I have girls for him have girls for him These messages were taken by Sarah Kellen who signed the bottom of die messages the execution of the warrant I located foiOm Epstein bedroom desk This desk had stationary marked Jeffrey Epstein I located a wood colored armoire beside Epstein 2s bed that contained a bottle of 223Joy Jelly which is used to provide a warm massage Several massage tables were located throughout the second floor of the residence including a massage table found in Epstein bedroom On the first floor of the residence I found two covert cameras hidden within clocks One was locate the garage and the other located in the library area on a shelf behind Epstein 2s desk A computer was located Xh wasbeheved to contain the images from the covert cameras The computer 2s hard drive which showed several images of Haley Robson and other witnesses that have been interviewed All of images appeared to come from the camera positioned behind Epstein 2s desk On December Det Dawson and met with dob During a sworn taped statement 227stated that when she was sixteen years old she was taken to Epstein house to provide a massage formoney stated it was before Christmas last year when an associate approached her and Xd7she"ded to make money for Christmas W-de arrangements to take 227tothe house and drove to the house to 223work They were encountered by a white female with long blond ham 227was unable remember the name of the white female with blond hair but knew she was Epstein 2s assistant She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose th lotion he wanted her to use She was led through a spiral staircase which led to a master bedroom and bathroom The massage table was already set up in the bathroom 227described the bathroom as a larg spaX baSoom with a steam room and shower beside it 225was introduced to Epstein who was onthe phone when she entered the room Epstein was wearing a white towel and laid on his stomach so that The foregoing instrument was sworn to or affirmed before me this ls day of May by Det Joe Recarey who is personally known to me Signature of Police officer F.S.S State of Florida County of Palm Bea Signature?AimB titJ Officer Date CA/Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO During the course of the investigation a search warrant was executed at Jeffrey Epsteins home located at El Brillo Way in Palm Beach While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned The stairway which is located from the kitchen area to the master bedroom area is lined with photos of naked young girls Additionally numerous photographs of naked young females some of which appeared to be the girls I previously interviewed were on display throughout the house Also located in the house were various phone message books The telephone message books have a duplicate copy Carbon Copy which once a phone message is written into the book the top copy is then tom on the perforated edge and the carbon copy is left in the book First names of girls dates and telephone numbers were on he copy of the messages I recognized various numbers and names of girls that had already been interviewed The body of the messages were time of the day that they called for confirmation of work Other nam and telephone numbers were located in which the body of the messages were I have girls for him or I have girls for him These messages were taken by Sarah Kellen who signed the bottom of the messages During the execution of the warrant I located a 225tr,anscript fortltin Epsteins bedroom desk Tlus desk had stationary marked Jeffrey Epstein I located a wood colored armoire beside Epsteins bed that contained a bottle of Joy Jelly which is used to provide a warm massage Several massage tables were located throughout the second floor of the residence including a massage table found in Epsteins bedroom On the first floor of the residence I found two covert cameras hidden within clocks One was located in the garage and the other located in the library area on a shelf behind Epsteins desk A computer was located which was believed to contain the images from the covert cameras The computers hard drive was reviewed which showed several images of Haley Robson and other witnesses that have been interviewed All of these images appeared to come from the camera positioned behind Epsteins desk On December Det Dawson and I met with do_b During a sworn taped statement,.stated that when she was sixteen years old she was taken to Epsteins house to provide a massage for money stated it was before Christmas last year when an associate approached her and asked if she needed to make money for Christmas emade arrangements to take1t to the house arid drove to the house to work They were encountered by a white female with long blond hair was unable to remember the name of the white female with blond hair but knew she was Epsteins assistant She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion be wanted her to use She was led through a spiral staircase which led to a master bedroom and bathroom The massage table was already set up in the bathroom described the bathroom as a large spacious bathroom with a steam _room and shower beside it was introduced to Epstein who was on the phone when she entered the room Epstein was wearing a white towel and laid on his stomach so that-may The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me CA Aron State of Florida Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO 7-7ithe massage with the oils Epstein chose and rubbed his feet and calves massage his feet and calves his back as well 225began rubbing his back and got to Epstein got off the phone and requested she her to get comfortable He requested she about herself enj she was sexually active Before continued rubbing his chest Epstein reached ewasshya Xifsheiikehavt removed his her vagina area by ebbing her masturbated as he touched her breasts.p lin and stated Enstein was aware that she was uncomfortable siaieo inai nysuci moved her thong panties to one side Epstein commented to her how beaunM my dit was He then inserted two fingers in During this time he kept his hand on her vagmal area and 223Ously wearing and got number with his assistant as he wanted to see her again XeXXZXXhTdX Sw Wha happened to her was wrong She further stated that she had never been contacted or any additional work doh 225was identified me-EpsUtaw told she would be able The foregoing instrument was sworn to or affirmed before me this I5 day of May by Det Joe Recarey who is personally known to me State of Florida County of Palm Beach Signature7 8sting Officer Signature of Police Officer F.S.S Date Hof CA/Aronberg-0827 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM el Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO massage his feet and calves 9started the massage with the oils Epstein chose and rubbed his feet and calves Epstein got off the phone and requested she massage his back as well began rubbing his back and got to the small of his back During the rubbing of his back Epstein asked her to get comfortable He requested she remove her pants and shirt removed her shirt and pulled her pants off stayed in her bra and thong panties As she finished massaging the small of Epsteins back he then turned onto his back Epstein instructed rub his chest and pinch his nipples As she began to rub his chest Epstein asked her questions about herself remembered telling him she attended Epstein asked her if she was sexually active Before-could answer he also asked what sexual position does she enjoy stated she was shy and didnt like talking about those things She continued rubbing his chest Epstein reached up ancl unsnapped her bra from the front explained the bra she used had a front snapping device Epstein rubbed her breasts and asked her if she like having her breasts rubbed tlasaid no I dont like that Epstein then removed his towel and laid on the bed naked exposing his penis He began touching his penis and masturbated as he touched her breasts explained Epstein then touched her vaginal area by rubbing her vagina with his fingers on the outside of her thong panties aitensed up and stated Epstein was aware _that she was uncomfortable stated that Epstein said to her Relax lm not going inside She further explained Epstein commented to her how beautiful and sexy she was Epstein then moved her thong panties to one side and began stroking her clitoris said He commented how hard my clit was He then inserted two fingers in her vagina and was stroking her within her vagina She tried pulling back to pull out his fingers from within her vagina Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her During this time he kept his hand on her vaginal area and continued to rub her vagina stated he rubbed her really hard as he was masturbating said he climaxed onto the towel he had been previously wearing and got up from the table Epstein told her there was dollars for her on the dresser within the master bathroom Epstein also told her that there was an additional that was to be given to-fo bringing her there to massage him Epstein told her to leave her telephone number with his assistant as he wanted to see her again Epstein stated his assistant would contact her to work again soon I asked her if she ever received any formal massage training to which stated she did not tated it was the only time she ever went to work for Jeff and knew what happened to her was wrong She further stated that she had never been contacted for any additional work On January I located and interviewed another victim dob was identified as a potential victim/witness from information obtained during trash pulls from Epsteins residence 225stated she met Epstein when she was fifteen years of age She was approached by a friend to be taken to Jeffrey Epsteins house to work She was originally told she would be able The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known.to me Signature of Police CA/Aronberg-0827 Dnnollnf State of Florida County of Palm Beach FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORT FLO tTmndel lingerie for a wealthy Palm Beacher Wwas taken to Epstein 2s house located onElBnlloWay introduced Wto Jeffrey Epstein Epstein had his personal chef prepare dinner foiWandJ A er Epstein brought tpstairs into a master bedroom area obsen arge massage table with a sheet on it Epstein entered instead routi and rub his calves and feet Epstein had omfoX her blouse 225stated she stayed only in panties as she thd prepared the room for the massage Epstein entered the.room wearing family eighteen oroide htterviews by Sarah KeUen and massage routine when they went to work forbP 1H come to Epstein 2s house and were made appointments for the females to work or pstein t0 Rnstein 2s bedroom Epstein would then led upstairs through a stairwell from the kitchen area by Sarah Kei en the hls utll,2e he The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police 5ffice F.S.S State of Florida County of Palm Beach Signature/M inlj ffR Date CA/Aronberg-0828 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO to model lingerie for a wealthy Palm Beacher.-was taken to Epsteins house located on El Brillo Way introduced9to Jeffrey Epstein Epstein had his personal chef prepare dinner fot9and At the conclusion of dinner I md Epstein brought pstairs into a master bedroom area observed a large massage table with a sheet on it Epstein entered through a door and exited wearing only a towel infonned 225that they were going to provide a massage on Epstein.aitaasked why were they doing this instead of modeling lingerie plained toethat this was his routine and to rub his calves and feet Epstein had toldtllato get comfortable removed her pants and blouse tlastated she stayed only in panties as she did not wear a bra that evening 225stated while rubbing his calves and feet Epstein turned over onto his back Epstein toldaato rub his chest and rub his nipples aa,tated that as she started rubbing his chest Epstein began masturbating himself Epstein touched her breasts and stroked her vagina with his fingers Epstein continued to masturbate himself as he stroked her vagina Epstein ejaculated on his towel and paid for the massage 267Epstein told lthat if she told anyone 267what happened at his house that bad things could happen 9end ere brought borne by Epsteins houseman anc las afraid that Epstein knew where she lived--stated that several days later she received a telephone call from Sarah Kellen who coordinated for l/lto return to work etm11ed to the house and was brought to Epsteins bedroom area by Sarah who prepared the room for the massage Epstein entered the room wearing only a towel Epstein had remove clothing and provide the massage naked began rubbing his feet and calves and Epstein turned over onto his back Epstein rubbed her vagina with his fingers Epstein began to masturbate himself with an upwards and downward motion on his penis Epstein continued to touch her vagina with one hand and masturbate with the other hand Once Epstein ejaculated onto the towel he was wearing the massage was over was paid for the massage Epstein again told not to speak of what happened at his house or bad things would happen wanted to notify authorities however she was afraid of what would happen to either her or her family During the course of the investigation several subjects were identified as a potential witness/victim through information obtained during the trash pulls physical surveillance and telephone message books retrieved from the search warrant While conducting research on the subjects I discovered that the females were age eighteen or older Interviews were conducted on the consenting ad 265lts whose statements provided the same massage routine when they went to work for Epstein The females would be notified by Sarah Kellen and made app.9intments for the females to work for Epstein The females would come to Epsteins house and were upstairi 267through a stairwell from the kitchen area by Sarah Kellen t.o Epsteins bedroom Epstein wouid then enter the room wearing only a towel and ask them to get comfortable The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this l5 day of May by Det Joe Recarey who is personally known to me Signature of Policefficer F.S.s CA/Aronberg-0828 State of Florida County of Palm Bea Date fficer FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO their vaginal area He would masturbate during the massage and upon his climaxing the massage would end The girls were then paid two or three hundred dollars for the massage On November I interviewed Jose Alessi a former houseman for Jeffrey Epstein Alessi stated he was employed for eleven years with Mr Epstein from approximately through Alessi stated he wXTouse manager driver and house maintenance person It was his responsibility to prepare the house or Epstein arrival When asked about cooks or assistants Alessi stated they traveled with Epstein on his private plane I asked Mr Alessi about the massages that have occurred at Epstein 2s home Alessi stated Epstein recedes Xee massages a day Each masseuse that visited the house was different Alessi stated that towards the end of his employment the masseuses were younger and younger When asked how young Mr Alessi stated they appeared to be sixteen or seventeen years of age at the most The massages would occur in Eps bXm or bLoom He knew this because he often set up the massage tables I asked rf there were 261mgs going on other than a massage Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis which were in the sink after the massage Additionally he stated the bed would almost always have to be made after the massage On January I interviewed another former houseman Mr Alfredo Rodriguez During a sworn taped statement Mr Rodriguez stated he was employed by Jeffrey Epstein for fr November through May of His responsibilities as house manager included being the butler XX Xf houseman errands for Epstein and provide for Epsteins guests I asked Rodriguez about masseuses coming to the house Rodriguez stated Epstein would have two massages a day Epstein would hi one massage in the morning and one massage in the afternoon everyday he was in residence Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epsteiri wo he masseuses would amve he area and offer them something to dnnk or eat They would then be encountered by either Sarah Kellen or Epstein They would be taken upstairs to provide the massage I asked Rodriguez if any masse XZe Rodriguez staled he girls the would come appearedtobe stated one time under Epsteins direction he delivered a dozen roses to one of die girls that came to provide a massage He knew the girls were still in high school age I asked Rodriguez about the massages He felt there was a lot more going on than just massages He would often clean Mr Epsteins bedroom after the alleged massages and would discover massagers vi Xscattered on the floor He also said he would wipe down the vibrators and sex toys an put diem away in an armoire He described the armoire as a small wood armoire which was on wa The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me State of Florida County of Palm Bea Signature Officer Signature of Police/6fficer F.S.S Date CA/Aronberg-0829 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO their vaginal area He would masturbate during the massage and upon his climaxing the massage would end The girls were then paid two or three hundred dollars for the massage On November I interviewed Jose Ales a former houseman for Jeffrey Epstein Alessi stated be was employed for eleven years with Mr Epstein from approximately through Alessi stated he was the house manager driver and house maintenance person It was his responsibility to prepare the house for Epstein arrival When asked about cooks or assistants Alessi stated they traveled with Epstein on his private plane I asked Mr Alessi about the massages that have occurred at Epsteins home Alessi stated Epstein receives three massages a day Each masseuse that visited the house was different Alessi stated that towards the nd ofhis employment the masseuses were younger and younger When asked how young Mr Alessi stated they appeared to be sixteen or seventeen years of age at the most The massages would occur in Epsteins bedroom or bathroom He knew this because he often set up the massage tables I asked if there were things going on other than a massage Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis which were in the sink after the massage Additionally he stated the bed would almost always have to be made after the massage On January interviewed another former houseman Mr Alfredo Rodriguez During a sworn taped statement Mr Rodriguez stated he was employed by Jeffrey Epstein for approximately 267six months from November through May of His responsibilities as house manager included being the butler chauffeur chef houseman run errands for Epstein and provide for Epsteins guests I asked Rodriguez about masseuses coming to the house Rodriguez stated Epstein would have two massages a day Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epstein would meet with them Rodriguez stated once the masseuses would arrive he would allow them entry into the kitchen area and offer them something to drink or eat They would then be encountered by either Sarah Kellen or Epstein They would be taken upstairs to provide the massage I asked Rodriguez if any of the masseuses appeared young in age Rodriguez stated the girls that would come appeared to be too young to be masseuses He stated one time under Epsteins direction he delivered a dozen roses or one of the girls that came to provide a massage He knew the girls were still in high school and were of high school age I asked Rodriguez about the massages He felt there was a lot more going on than jtistmassag He would often clean Mr Epsteins bedroom after the alleged massages and would discover_ massagers/vibrators and sex toys scattered on the floor He also said he would wipe.down the vibrators and sex toys and put them away in an armoire He described the armoire as a small wood armoire which was on the wall close to Epsteins The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police,6ffice F.s.S CA/Aronberg-0829 State of Florida Officer Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORW FLO a On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl 223brought she could drive her self to Epsteins house without mcdent Rodriguez sa.d the girl always needed rides to and from the house Rodriguez produced a green foider which contained documents anda note with Mr penary performance enote direction to rent a ear for nd direction to extend the rental contract During the course of the investigation subpoenas were obtained for cell phone and home phone.records These records indicate the dates the calls were made are consistent with the dates and times ey the encounters with stated they occurred Pursuant to a lawful subpoena I obtained Epstein 2s private plane records for from Jet AviaUon ttep!a 204erecords showarnv.andde fEp RedenXXtiL were made in the days just prior to their arrive or dering the time Epstein was in Palm Beach Therefore as Jeffrey Epstein who at the of ne yX this Florida State Statute a second degree felony The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County Palm Beach Signature/ArresHmyOfficer Date CA/Aronberg-0830 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affldavii Palm Beach 267Police Department Agency ORI FLO bed On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same gi_rl be brought the roses to so that she could drive her self to Epsteins house without incident Rodriguez said the girl always needed rides to and from the house Rodiiguez produced a green folder which contained documents and a note with Mr Epsteins stationary with direction to deliver a bucket of roses to 225a:fterltugh school drama performance Also in that same note was direction to rent a car for a.nd direction to extend the rental contract During the course of the investigation subpoenas were obtained for cell phone and home phone records from several victims and witnesses along with the cell phone records of Sarah Kellen An analysis of these records was conducted which found numerous telephone calls were made between Sarah Kellen and the victims These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted Specifically The phone records showed Kellen called Haley Robson during the exact times and dates when victim eadvised the incident occurred Kellen also coordinated the encounters with and during the time frame the girls stated they occurred Pursuant to a lawful subpoena I obtained Epsteins private plane records for from Jet Aviation The plane records show arrival and departure of Epsteins plane at Palm Beach International airport These records were compared to the cell phone records of Sarah Kellen is comparison found that all the phone calls Kellen made to Robson and the victims were made in the days just prior to their arrival or-during the time Epstein was in Palm Beach Therefore as Jeffrey Epstein who at the time of these incidents was fifty one years of age did have vaginal intercourse either with his penis or digitally with and 225who were minors at the time this occurred there is sufficient probable cause to charge Jeffrey Epstein with four counts of Unlawful Sexual Activity with-a Minor in violation of Florida State Statute a second degree.felony As Epstein wh at _time of the incident was fifty two years of age did use a vibrator on the external vaginal area of a fourteen year old minor there is sufficient probable cause to charge him with Lewd and Lascivious Molestation in violation of Florida State Statute a second degree felony The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of PolieOfficr F.S.S CA/Aronberg-0830 State of Florida County Palm Beach Date fficer FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM OBTS Number LU Agency ORl;Number FLOt I I I ARREST NOTICE TO APPEAR Juvenile Referral Repori Charge-Typer ChDCxasmsny as 2appiy sFejony jTraffip Felony Agency Name PALM BEACH POLICE-DEPARTMENT Misdemeanor R5 Ordinance Traffic Misdemeanor D6 Other Location of Arrest Induding Name of Business Arrests ReguesUqr Warrant 2/N.TA Agency Report Number N.TA 2S only Weapon Seized Ehler Typb tio orprtebses Business NamelAddfesj Oaiedf Arresi Tmebl Arresi Booking pate Booting Times JaiDaie I II I Jail-Tune Name I Lbcaiidribf Vehicle Juvenile Multiple Clearance Ingsatof sAlias Naniei DOB?Sbc.-Sdc?i Eit Race Seju loatoofBirth While I.American indiant Black 0-Oriental/Asian ivKj i Ssi xi/jMi Height We 253ghii Eye Color Hak.Cotor Compleiioh BuRj Local Ad sXSlresL-Apt iNumoer City States Uio Phone it Permaheni AddressJStreej AptiNumber Stale Business Adless Name Street State tYr Zip Phono Paone DA Number.-Stalo Co-Defenoant Name Last First Middle iNS;Numboc Race Sex Date pl Birth Indication of Uhk Alcohol Influence Drug Influence Ql Residence Type T.;C l.Fbrida Countyi Out pt Stale Addres Souite Occupation Piace oLBirtn City State WTAfresied At,Large Cm/onship TTelOny 04.-Misdemeanor aSrduveniie Felony Misdemeanor CorDefendamName Last/FifsuMidtfe Race Dale pl rih Arrested O2.AI Large D5?Juvenile Parente Name Last Local Custodiari Otner FirslXj Residenee/pnone Address UJ I C-lj-l Siatel Zip Business Phono tot/jac Date Time School Attended Grade 2ST The above address wasjxovided by defendant and Let Thechild to eep the Juvenile Court.Cieiv.s Office Phone informed ol anyjcharige bl a D?YeSibyHNamej No Reason Property.Crime Description ol Property Yes 2N.o Value of Property N?N/A iBi Buy D.?Defiver Distribute Produce Possess 2T.-Trnhic Cuiivate Charge Description A ug Activity Drug Type Amount Unit Offense Cwnts Domestic Valence GM ugType T-nSrb wA C?Cocaine AMmohetamtrie E.Heroin Statute Violalion Numbor WangritZCapias umber FHaBanogerr ar Marijuana Zi Other O/OphjnVDeriv Synihetic Violation of ORD Bond IX JC harge Description Counts Domestic Violence violence CM Statute Violation Number Violation of ORD Drug Activity DrugType ChargeiOescription Amounl/U Offense Counts Domestic Violence OY 2Q Warrant Capias Number Statute Violation Number Bono Violation otORD Drug Activity1 Drug Type Amount Ural Offense A Warrant Capias Number Bond ChargeDescription Drug Activity Drug Type Amount Unit OlfensoJ Counts Domestic Violence DY DM Statute Violation Number Warrant CapiasNumber iJnstruciidh Nd 2Mandatory Appearance in Court Instruction No.2 You need net appear in Court but must comply with instructions on Reverse Side Location Court Room Number Address Court Date and Time Month Day1 Year Timb Violation ORO Bond A,MJ RM 0BT.S_MlmD fiJ REST1NOTfCE fOAPREAR Arres1 i Request 1orwarranI I I rweriH_e,FelerralRepoi1 X:fa 1ro,cai,ia Busi_ne Addr tl Stale Paone __ P.foi;orti Crime f!ScilPiion li perty i fherge_:Oescriptio_ _Drug AC1ivjl ClrugJyPf _A tlnl Ufit tig AC ivity_ I Qfug Type _Atno iu I Unil lnsfruc1;ori 8:n,da OIY Appf nco jn C:Ou.rt lnstructlo_n 1SIotel I Sia.tuts _v,o!ation moor I JI I Warranl fapq,s Njimber SchOolAnellde 267Ill _BlisjO:e P_hoiio Gr/Jdri tjBono Violation of I V,olatio I ORI I I ou ne appea,,in 267CoUn_ ravSI fp i a_f!d_ Jim iO On,J ev e-5k!e Moniti oar Year Tim __ P.M AGREE TO APPEARAT 225THE TIMEAND PLACE DESIGNATEDJ0.ANSWER,THE OFFENSE CHARGED ORTO PAV,,THEFtNE 267SUBSCRIBED I.UNOERSTANDTHAT SH0Ulo:I WILLFULLY FAIU0 P.PEA,fl qou T-AS.A 2470UIRED_BVTHl!l NOTIC r9 PPEAR T:I AY_BE 1-iELI IN cqNTE,MPTQFCOU_F!TAND A WAF1Rprr,Ft MYARlIE Hi _9 0Jor olher cf lame i DanQlltOUS Arresi O,Su1c;_dal O,Qther oueh WHITE_ COURT COP YELLOw,.,,.c AGENCY CA Aronberg-0831 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA/Aronberg-0832 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aronberg-0832 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Police Case Defendant Race/Sex DOB Sarah Kellen White Female Charges Principal in the Unlawful Sexual Activity with a Minor counts Principal in the 1st Lewd and Lascivious Molestation count From March through February the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein Sarah Kellen and Haley Robson Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein El Brillo Way Palm Beach Several of the victims were recruited by and brought to the residence by Haley Robson to perform massages for Epstein for which Robson received monetary compensation During the visit they would be introduced to Sarah Kellen Epstein 2s assistant who in turn would record their telephone numbers and name The victims would be brought to Epstein 2s bedroom to provide the massage Epstein would enter the room and order the victims to remove their clothing to provide the massage As the victims complied and provided the massages Epstein would rub his fingers on their vaginas On occasion Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage On three separate occasions Epstein had intercourse and inserted his penis/fingers in the victims vaginas At the conclusion of the massages the victims were paid sums of money ranging from The facts as reported are as follows On A fourteen year old white female hereinafter referred to as dobl and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach reported that a subject known to her as 223Jeff had touched her vaginal area with a vibrator/massager while within his residence 223Jeff was later identified as Jeffrey Epstein through a photo line up During a sworn taped interview 225stated that Haley Robson dob a cousin ofttl boyfriend and classmate worked for a wealthy man and did sexual favors for him She also admitted that Robson had offered her an opportunity to make money During the beginning of the month of February 225explained that she was first approached by Robson to go with her to Epstein 2s house 225Stated that Robson along with a Hispanic female later identified at MfeO MH pick her up at her father 2s house on a Sunday i vas not sure of the exact dates but knew it was a Sunday told her father that they were going shopping but in reality Robson drove them to Palm Beach During the drive a The foregoing instrument was sworn to or affirmed State of Florida before me this day of May by County of Palm Beach Det Joe Recarey who is personally known to me Signal rkesting Officer Signature of Police Officer F.S.S Page I of CA/Aronberg-0833 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Defendant Race/Sex DOB Sarah Kellen White Female Agency ORI FLO Police Case Charges Principal in the st Unlawful Sexual Activity with a Minor counts Principal in the pt Lewd and Lascivious Molestation count From March through February the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein Sarah Kellen and Haley Robson Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein El Brillo Way Palm Beach Several of the victims were recruited by and brought to the residence by Haley Robson to perform massages for Epstein for which Robson received monetary compensation During the visit they would be introduced to Sarah Kellen Epsteins assistant who in turn would record their telephone numbers and name The victims would be brought to Epsteins bedroom to provide the massage Epstein would enter the room and order the victims to remove their clothing to provide the massage As the victims complied and provided the massages Epstein would rub his fingers on their vaginas On occasion Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage On three separate occasions Epstein had intercourse and inserted his penis/fingers in the victims vaginas At the conclusion of the massages the victims were paid sums of money ranging from The facts as reported are as follows On A fourteen year old white female hereinafter referred to as IJ dob and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach reported that a subject known to her as Jeff had touched her vaginal area with a vibrator/massager while within his residence Jeff was later identified as Jeffrey Epstein through a photo line up During a sworn taped interview tated that Haley Robson dob a cousin of boyfriend and classmate at 225worked for a wealthy man and did sexual favors for him She also admitted that Robson had offered her an opportunity to make money During the beginning of the month of February 2005,altexplained that she was first approached by Robson to go with her to Epsteins house etated that Robson along with a Hispanic female later identified at I pick her up at her fathers house on a Sunday t/8Nas not sure of the exact dates but knew it was a Sunday told her father that they were going shopping but in reality Robson drove them to Palm Beach During the drive a The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S Page I of22 CA/Aronberg-0833 State of Florida County of Palm Beach FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO conversation occurred between Robson and whereas Robson reportedly told 225that if Jeff asked her age she should say she was eighteen It was later confirmed by the father that Robson picked his daughter up on February According to 225father Robson drove a pick up truck described Epsteins house as a two-story pink house with a Cadillac Escalade parked in the driveway She recalled that Jeffs house was on a dead end street Upon arriving at the house stated that they walked up a driveway past what appeared to be a small guard/security room A male approaching them asking what they wanted Robson stated they were there to see Epstein The male allowed them to continue walking up to the house tated 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 thereafter Epstein and his assistant described as white female with blond hair and later identified as Sarah Kellen entered the kitchen Epstein introduced himself to described Epstein as being approximately forty-five years old having a long face and bushy eyebrows with graying hair Robson and Epstein left the kitchen leaving alone in the kitchen They returned a short time later They all spoke briefly in the kitchen was instructed to follow Kellen upstairs recalled walking up a flight of stairs lined with photographs to a room that had a massage table in it Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room There was a door on each side of the sofa 225recalled there being a mural of a naked woman in the room as well as several photographs of naked women on a shelf Kellen told the victim that Epstein would be up in a second Epstein entered the room wearing only a towel and told take off her clothes stated Epstein was stem when he told her to take off her clothes she did not know what to do as she was the only one there in the room so she took off her shirt leaving her bra on Epstein had removed his towel and told the to take off everything stated Epstein was nude when he took his towel off placing it on the floor as he laid down on the table Bstated she then 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 AsBB began to give Epstein the massage he told her to get on his back BB stated she straddled herself on Epstein 2s back whereby her exposed buttocks were touching Epstein 2s bare buttocks 225said Epstein was specific in his instruction to her on how to massage him telling her to go clockwise or counter clockwise Epstein then turned over and instructed massage his chest 225was now standing on the ground and resumed massaging Epstein 2s chest area 225stated Epstein held onto the small of her back as she massaged his chest and shoulder area Epstein then turned to his side and started to rub his penis in an up and down motion Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County of Palm Beach Signature/Anrekting Officer Date Page 2of CA/Aronberg-0834 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO conversation occurred between Robson and whereas Robson reportedly told that if Jeff asked her age she should say she was eighteen It was later confirmed by the I father that Robson picked his daughter up on February According to father Robson drove a pick up truck described Epsteins house as a two-story pink house with a Cadillac Escalade parked in the driveway She recalled that Jeffs house was on a dead end street Upon arriving at the house9stated that they walked up a driveway past what appeared to be a small guard/security room A male approaching them asking what they wanted Robson stated they were there to see Epstein The male allowed them to continue walking up to the house.9stated 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 thereafter Epstein and his assistant described as white female with blond hair and later identified as Sarah Kellen entered the kitchen Epstein introduced himself to described Epstein as being approximately forty-five years old having a long face and bushy eyebrows with graying hair Robson and Epstein left the kitchen leaving alone in the kitchen They returned a short time later They all spoke briefly in the kitchen ewas instructed to follow Kellen upstairs recalled walking up a flight of stairs lined with photographs to a room that had a massage table in it Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room There was a door on each side of the sofa ecalled there being a mural of a naked woman in the room as well as several photographs of naked women on a shelf Kellen told the victim that Epstein would be up in a second Epstein entered the room wearing only a towel and told take off her clothes stated Epstein was stern when he told her to take off her clothes tlasaid she did not know what to do as she was the only one there in the room so she took off her shirt leaving her bra on Epstein had removed his towel and told thellt to take off everything stated Epstein was nude when he took his towel off placing it on the floor as he laid down on the table estated she then removed her pants leaving her thong panties on Epstein then instrucJed her to give him a massage pointing to a specific lotion for her to use As began to.give Epstein the massage he told her to get on his back 225stated she straddled herself on Epsteins back whereby her exposed buttocks were touching Epsteins bare buttocks 225said Epstein was specific in his instruction to her on how to massage him telling her to go clockwise or counter clockwise Epstein then turned over and instructed-o massage his chest Was now standing on the ground and resumed massaging Epsteins chest area lstated Epstein held onto the small of her back as she massaged his chest and shoulder area Epstein then turned to his side and started to rub his penis in an up and down motion Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this l5 day of May by Det Joe Recarey who is personally known to me Signature of Police Pagelof22 CNAronberg-0834 State of Florida County of Palm Beach Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO massage MB vaginal area IM stated there was no penetration as the vibrator was on top of her underwear iMrecalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table Epstein then left the room andl got dressed She went back downstairs where she met with Robson BBsaid she was paid three hundred dollars in cash from Epstein Before she left Epstein asked Bto leave her phone number AsM Robson and were leaving the house Robson told she received two hundred dollars that day for bringing her During the course of the investigation parental consent was granted for to assist with the investigation At our direction 225conducted controlled taped phone calls to Robson 2s cellular telephone Wspoke with Robson in an attempt to arrange another meeting with Epstein 225usked Robson what did she need to do to make more money Robson stated 223the more you do the more you get paid Robson had subsequently called back Mand left a voice mail message for her indicating that she had set up an appointment foiBMto go to Epstein 2s house at am on April This message was recorded from 1MB voice mail Based on the above trash pulls were established at Epstein 2s residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach The trash pull from April revealed a telephone message for Epstein which stated Haley and 225name at am This was the time frame Robson had informed to be ready to go work at Epstein 2s house On October Sgt Frick and I went to Robson 2s residence and viewed her vehicle parked in the driveway a red Dodge Neon 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 Way in Palm Beach Robson was asked if she would 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 Robson voluntarily came us back to the Palm Beach Police Department Upon our arrival at the police station Robson was brought to the interview room in the Detective Bureau where I obtained a taped sworn statement I began the interview by asking Robson how she became acquainted with Epstein Robson stated that approximately two years ago just after she turned years of age she was approached by a friend named Molly at 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 Robson thought about the offer and agreed to meet with Jeffrey The foregoing instrument was sworn to or affirmed State of Florida before me this 1st day of May by County of Palrii Beach Det Joe Recarey who is personally known to me Signature/Anresling Officer Signature of Police Officer FfS.S Page3of CA/Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO massage vaginal area stated there was no penetration as the vibrator was on top of her underwear 9recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table Epstein then left the room and-got dressed She went back downstairs where she met with Robson 225said she was paid three hundred dollars in cash from Epstein Before she left Epstein asked.to leave her phone nwnber As Robson and were leaving the house Robson told she received two hundred dollars that day for bringing her During the course of the investigation parental consent was granted for ltto assist with the investigation At our direction-conducted controlled taped phone calls to Robsons cellular telephone 225spoke with Robson in an attempt to arrange another meeting with Epstein 9isked Robson what did she need to do to make more money Robson stated the more you do the more you get paid Robson had subsequently called backtl9e.nd left a voice mail message for her indicating that she had set up an appointrnt:nt for9iltto go to Epsteins house at am on April This message was recorded from voice mail Based on the above trash pulls were established at Epsteins residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach The trash pull from April revealed a telephone message for Epstein which stated Haley andlatname at am This was the time frame Robson had informed to be ready to go work at Epsteins house On October Sgt Frick and I went to Robsons residence and viewed her vehicle parked in the driveway a red Dodge Neon 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 Way in Palm Beach Robson was asked if she would 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 Robson voluntarily came with us back to the Palm Beach Police Department Upon our arrival at the police station Robson was brought to the interview room in the Detective Bureau where I obtained a taped sworn statement I began the interview by asking Robson how she became acquainted with Epstein Robson stated that approximately two years ago just after she turned years of age she:was approached by a friend named Molly at 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 Robson thought about the offer and agreed to meet with Jeffrey The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Page,3of22 CA Aron State of Florida FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Molly Unknown last name and Tony Unknown last name picked Robson up and she was taken to Epstein 2s house Upon her arrival to the house she was introduced to Epstein in the kitchen of the house She was also introduced to a white female known to her as Sarah She was led upstairs to the main bedroom known to her as Jeff Epstein bedroom Sarah 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 Sarah then left the room and informed Robson Jeff would be in in a minute Jeff entered the bedroom wearing only a towel He removed the towel and laid nude on the massage table He laid on the table onto his stomach and picked a massage oil for Robson to rub on him During the massage Robson stated tried to touch me and I stopped him I asked how he tried to touch her Robson stated that Epstein grabbed her buttocks and she felt uncomfortable Robson told Epstein massage you but I don 2t want to be touched Robson stated she performed the massage naked At the conclusion of the massage Epstein paid Robson After the massage Epstein stated to Robson that he understood she was not comfortable but he would pay her if she brought over some girls He told her the younger the better Robson stated she once tried to bring a year old female and Epstein stated that the female was too old Robson stated that in total she only remembers six girls that she brought to see Epstein each time she was paid Robson stated she had brought the follovnn irls al6 year old female I a year old female andflflP Robson said that at the time she brought these girls to Epstein 2s house they were all through years of age I asked Robson which one was the youngest Robson advised was the youngest as she was fourteen when the massage occurred Robson stated every girl she brought knew what to expect when they arrived They were told they would provide a massage possibly naked and allow some touching I asked her if was aware She stated every girl she brought knew what to expect She explained she knew thatM wanted to make money She approached nd explained about going to work for JeffOagreed and arrangements were made to bring her to Epstein 2s house on a weekend Robson stated that she andMH Later identified picked up Ofc her house Robson stated that at that time she was driving a red pickup truck They traveled to Epstein 2s house and entered through the kitchen door They met with the house chefand Epstein assistant Sarah kvas introduced to Epstein while they were in the kitchen area Sarah led upstairs and Epstein went upstairs When the massage was over Oteturned to the kitchen area Robson stated she was paid for bringingflfco Epstein 2s house Robson stated OOtold her she was paid for the massage Robson stated that was the last person she brought to Epstein 2s house She had changed her cellular number to avoid being contacted by Sarah She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County ofPalm Beach Signature/Arresting Officer Date PageMof22 CA/Aronberg-0836 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Molly Unknown last name and Tony Unknown last name picked Robson up and she was taken to Epsteins house Upon her arrival to the house she was introduced to Epstein in the kitchen of the house She was also introduced to a white female known to her as Sarah She was led upstairs to the main bedroom known to her as Jeff Epsteins bedroom Sarah 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 Sarah then left the room and informed Robson Jeff would be in in a minute Jeff entered the bedroom wearing only a towel He removed the towel and laid nude on the massage table He laid on the table onto his stomach and picked a 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 Robson stated that Epstein grabbed her buttocks and she felt uncomfortable Robson told Epstein Ill massage you but I dont want to be touched Robson stated she performed the massage naked At the conclusion of the massage Epstein paid Robson After the massage Epstein stated to Robson that he understood she was not comfortable but he would pay her if she brought over some girls He told her the younger the better Robson stated she once tried to bring a year old female and Epstein stated that the female was too old Robson stated that in total she only remembers six girls that she brought to see Epstein each time she was paid Robson stated she had brought the following girls al6 year old female a year old female and-Robson said that at the time she brought these girls to Epsteins house they were all14 through years of age I asked Robson which one was the youngest Robson advised was the youngest as she was fourteen when the massage occurred Robson stated every girl she brought knew what to expect when they arrived They were told they would provide a massage possibly naked and allow some touching I asked her i was aware She stated every girl she brought knew what to expect She explained she knew that wanted to make money She approachedlliltand explained about going to work for Jeff,.agreed and arrangements were made to bring her to Epsteins house on a weekend Robson stated that she and Later identified as picked up9:it her house Robson stated that at that time she was driving a red pickup truck They traveled to Epsteins house and entered through the kitchen door They met with the house chef and Epsteins assistant Sarah.119Nas introduced to Epstein while they were in the kitchen area Sarah led.upstairs and Epstein went upstairs When the massage was over etumed to the kitchen area Robson stated she was paid for bringing-to Epsteins house Robson stated 225told her she was paid for the massage Robson stated thatawas the last person she brought to Epsteins house She had changed her cellular number to avoid-being contacted by Sarah She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Pageiof CA Aron be State of Florida County of al Beach FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO when he was going to travel to Palm Beach Robson said when Epstein announces to his assistant Sarah that he is traveling to Palm Beach Sarah would then contact Robson to arrange girls to 223work for Epstein 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 Sarah still tries to call Robson 2s house and leaves messages Sgt Frick entered the room and explained to Robson that based on her own statements she had implicated herself by bringing underage girls to Epstein 2s house 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 2m like a Heidi Fleiss Hollywood Madam who sent girls to clients for sexual favors in California Robson was dropped off at her house without incident On October Sgt Frick and I went to speak with a sixteen year-old female who was brought to Epstein 2s residence by Haley Robson We met with mother at their frontdoor We explained the ongoing investigation and asked to speak with we had information that she had 223worked for Jeff Mrs us to her husband and allowed us entry into the home We sat in the dining room and met with Date of BirthAs she was under the age of eighteen Mrs was advised we would be speaking with her She expressed if her daughter had information she wanted to assist We interviewed who denied having any inappropriate encounters with Jeff Epstein She stated she had gone to Jeffs house with Haley Robson approximately eight months ago and sat in the kitchen with the house chef but nothing happened As the parents were present during the interview we felt that 225was withholding information from us She made several comments as to putting the entire incident behind her I left my telephone number and advised should she wish to speak with me again to telephone me Sgt Frick and I thanked Mrs for her time and left the area She stated she would askl again after we left as to what happened at Epstein 2s house I informed her thatO had my telephone number and hopefully she would call On October Det Dawson and I drove to theMHKiome and met withflHIB and doblMm During a sworn taped statement Vstated approximately a year ago when she was seventeen years old she was taken to a house by Haley Robson she knows Robson because they both attend She was told she could make money working The foregoing instrument was sworn to or affirmed State of Florida before me this day of May by County of Palm Beach Det Joe Recarey who is personally known to me Kj Signati re/Arresting Officer Signature of Police Officer F.S.S Date Page Sof CA/Aronberg-0837 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO when he was going to travel to Palm Beach Robson said when Epstein announces to his assistant Sarah that he is traveling to Palm Beach Sarah would then contact Robson to arrange girls to work for Epstein 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 Sarah still tries to call Robsons house and leaves messages Sgt Frick entered the room and explained to Robson that based on her own statements she had implicated herself by bringing underage girls to Epsteins house 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 Im like a Heidi Fleiss Hollywood Madam who sent girls to clients for sexual favors in California Robson was dropped off at her house without incident On October Sgt Frick and I went to speak with.a sixteen year-old female who was brought to Epsteins residence by Haley Robson We met with mother at their front door We explained the ongoing investigation and asked to speak with we-had information that she had worked".for Jeff Mrs 225introduced us to her husband and allowed us entry into the home We sat in the dining room and met with Date of Birth As she was under the age of eighteen Mrsewas advised we would be speaking with her She expressed if her daughter had information she wanted to assist We interviewed who denied having any inappropriate encounters with Jeff Epstein She stated she had gone to Jeffs house with Haley Robson approximately eight months ago and sat in the kitchen with the house chef but nothing happened As the parents were present during the interview we felt that-was withholding information from us She made several comments as to putting the entire incident behind her I left my telephone number and advised should she wish to speak with me again to telephone me Sgt Frick and I thanked Mrs for her time and left the area She stated she would ask9again after we left as to what happened at Epsteins house I informed her that had my teleph0ne number and hopefully she would October Det Dawson and I drove to the L.ome and met with and dob During a sworn taped statement 9!itated approximately a year ago when she was seventeen years old she was taken to a house by Haley Robson 225stated she knows Robson because they both attend She was told she could make money working The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Page5of22 CA/Aronberg-0837 State of Florida County Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO for Jeff She was told she would have to provide a massage to Jeff stated upon her arrival to the house she was brought to the kitchen area by Robson They met with the house chef who was already in the kitchen area Bstated Haley Robson would wait for her in the kitchen was introduced to Sarah Jeffs assistant who brought her upstairs to the master bedroom Sarah prepared the room and massage table for a massage Epstein entered the room wearing only a towel and she provided a massage OIB stated she kept her clothes on during the massage She advised sometime during the massage Epstein grabbed her buttocks and pulled her close to him said she was uncomfortable by the incident involving Jeff At the conclusion of the massage she was paid for the massage I asked if has any formal training in massages to which she replied no I asked her if Robson received any monies for taking her to perform the massage stated Robson had received money for taking her there but was unsure in the amount fl stated she returned to Epstein 2s house on another occasion with Robson and another girl stated she waited in the kitchen with Robson while was taken upstairs by Sarah I Bstated she only did the massage once as she was uncomfortable with the whole experience At the conclusion of the interview the tape was stopped I was informed that Sarah had attempted to via cell phone A voice mail message on October at am revealed a female voice who identified herself as Sarah who call her back reference the police questioning provided the incoming telephone number as 225stated she inadvertently told about the police investigation becauseBHB had called her to tell her about how she just received a rental car from Jeff Epstein called her to tell her that she was given a rental car a Silver Nissan Sentra to utilize to visit family and visit Epstein asked her what was going on at the house that the police would be asking questions stated then called Jeff and Sarah and asked what was going on reference the ongoing police investigation According toiM Sarah has since then been trying to contact her to ask about the police questions I instructedB not to contact Sarah and do not provide any more information to she would notify Jeff Epstein and Sarah what was transpiring On October4 made telephone contact withBbwho had left several messages for me to contact her During the message she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened She further advised she did not want to speak of this incident in front of her mother At approximately pm I made telephone contact withBB During a taped recorded statement Bstated the following approximately a year ago when she was sixteen years of age Robson took her to Epstein 2s house twice Shejcnows Robson because they both attend time she went Haley Robson drove to the house They entered through the kitchen area where she was he first The foregoing instrument was sworn to or affirmed before me this lsl day of May by Det Joe Recarey who is personally known to me State of Florida County of Palm Beach Signature/Arresting Officer Signature of Date Page of CA/Aronberg-0838 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO for Jeff She was told she would have to provide a massage to Jeff stated upon her arrival to the house she was brought to the kitchen area by Robson They met with the house chef who was already in the kitchen area tated Haley Robson would wait for her in the kitchen was introduced to Sarah Jeffs assistant who brought her upstairs to the master bedroom Sarah prepared the room and massage table for a massage Epstein entered the room wearing only a towel and she provided a massage stated she kept her clothes on during the massage She advised sometime during the massage Epstein grabbed her buttocks and _pulled her close to him said she was uncomfortable by the incident involving Jeff At the conclusion of the massage she was paid for the massage I asked if she has any formal training in massages to which she replied no I asked her if Robson received any monies for taking her to perform the massage stated Robson had received money for taking her there but was unsure in the amount stated she returned to Epsteins house on another occasion with Robson and another girl 225tstated she waited in the kitchen with Robson while was taken upstairs by Sarah tated she only did the massage once as she was uncomfortable with the whole 267experience At the conclusion of the interview the tape was stopped I was informed that Sarah had attempted to reach via celJ phone A voice mail message on October at am revealed a female voice who identified herself as Sarah who requested to call her back reference the police questioning provided the incoming telephone number as _stated she inadvertently told abc;rn_t.the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein had called her to tell her that she was given a rental car a Silver Nissan Sentra to utilize to visit family and visit Epstein t1ll9 asked her what was going on at the house that the police would be asking questions 225stated 225then.called Jeff and Sarah and asked what was going on reference the ongoing poli investigation According to 225Sarah has si 225nce then been trying to contact her to ask about the police questions I instructed not to contact Sarah and do not provide any more information to she would notify Jeff Epstein and Sarah what was transpiring On October4 I made telephone contact with awho had left several messages for me to contact her During the message she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened She further advised she did not want to speak of this incident in front of her mother At approximately pm I made telephone contact with8 During a taped recorded a eed i oxb::t ae oble tl was sixteen years qf _a Jt-Rpbn ti t;;he went Haley Rob drove to the house They entered thl gh th 267kftch ar a where she was The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Page-of CNAronberg-0838 ll State of Florida County of Pal Beach FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO introduced to Sarah and Epstein She was taken upstairs to a bedroom by Sarah who set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel He laid on the table and picked out a lotion for to rub on him At one point during the massage he tried to remove her shirt at which point she became very upset and discontinued the massage Both and Epstein had a verbal disagreement at which time she left without being paid She got with Haley Robson who was sitting in the kitchen and told her 223let 2s go 225Badvised she received no money for that day Balso said that Haley Robson had told her if she was uncomfortable with what was going on to let him know and he 2ll stop She knew that the more you do the more you get paid that several weeks later she agreed to be taken a second time by Haley Robson Once they arrived at the residence Haley Robson sat in the kitchen and Sarah took her upstairs to the master bedroom again Sarah set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel He laid on the table and picked out a lotion for to rub on him At one point during the massage he tried to touch her buttocks As 225vas wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks Epstein then rolled onto his back during the massage and then attempted to touch her breasts 225then became upset again and told Epstein she didn 2t want to be touched the massage and was paid then went downstairs where Haley Robson was waiting for her She told Robson she wanted to leave aid she never returned to the house Bstated she is aware that her ffiend,IBlB 4BB was also at the house and had a problem with Epstein later researchedBIBB BB dob and met with her at her residence During a sworn taped statement,stated the following on or about November she was approached atB 225HBHBby Haley Robson a fellow student Robson asked I if she wanted to make money She agreed and was told she would provide a massage to wealthy man in Palm Beach Robson picked her up and drove her to a house in Palm Beach She was brought into the kitchen area of the house She further stated that fellowflBMH BBHBB HP tudents and BHMbB came with them They were brought into the kitchen where she was introduced to Epstein and other females OB stated she was introduced to a female helper of Epstein the female was described as white female unknown name with blond hair She stated that the assistant was familiar with Robson The assistant brought her upstairs into a master bedroom area The assistant set up the massage table and put out lotions to be used She told BHIB Epstein would be available in a minute Epstein entered the room wearing only a towel Epstein removed his towel and laid naked on the massage table and picked a lotion to rub on his thighs and back BMV further stated during the massage Epstein asked her to remove her clothes She complied and removed her pants and blouse didn 2t remember if she had removed her bra but feels that she did Awas certain that she stayed in her thong underwear BBSB continued the massage and one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this ls day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County of Palm Beach Signature/Arresting Officer Date Page7 of CA/Aronberg-0839 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO introduced to Sarah and Epstein She was taken upstairs to a bedroom by Sarah who set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel He laid on the table and picked out a lotion for ato rub on him At one point during the massage he tried to remove her shirt at which point she became very upset and discontinued the massage Both 225and Epstein had a verbal disagreement at which time she left without being paid She got with Haley Robson who was sitting in the kitchen and told her lets go advised she received no money for that day.-also said that Haley Robson had told her if she was uncomfortable with what was going on to let him know and hell stop She knew that the more you do the more you get paid 225advised that several weeks later she agreed to be taken a second time by Haley Robson Once th_ey arrived at the residence Haley Robson sat in the kitchen and Sarah took her upstairs to the master bedroom again Sarah set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel He laid on the table and picked out a lotion for9to rub on him At one point during the massage he tried to touch her buttocks As Vas wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks Epstein then rolled onto his back during the massage and then attempted to touch her breasts.athen became upset again and told Epstein she didnt want to be touched ealiscontinued the massage and was paid 9fuen went downstairs where Haley Robson was waiting for her She told Robson she wanted to leave aid she never returned to the house estated she is aware that her friend,Q was also at the house and had a problem with Epstein I later researched dob and met with her at her residence During a sworn taped statement stated the following on or about November she was approached at Haley Robson a fellow student Robson asked she wanted to make money She agreed and was told she would provide a massage to wealthy man in Palm Beach Robson picked her up and drove her to a house in Palm Beach She was brought into the kitchen area of the house She further stated that tudents 225and came with them They were brought into the kitchen where she was introduced to Epstein and other stated she was introduced to a female helper of Epstein the female was described as white female unknown name with blond hair She stated that the assistant was familiar with Robson The assistant brought her upstairs into a master bedroom area The assistant set up the massage table and put out lotions to be used She told Epstein would be available in a minute Epstein entered the room wearing only a towel Epstein removed his towel and laid naked on the massage table and picked a lotion to rub on his thighs and back further stated during the massage Epstein asked her to remove her clothes She complied and removed her pants and blouse.9lltdidnt remember if she had removed her bra but feels that she did 225was certain that she stayed in her thong underwear I continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Page7 of22 CA/Aronberg-0839 State of Florida County of Palm Beach ting Officer Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO table straddling Epstein to massage his back While doing this her buttocks were touching Epsteins 4H was instructed to return to the ground at which time Epstein turned to have his chest rubbed advised she was sure he was masturbating based on his hand movements going up and down on his penis area flflifldid not want to look at his penis area because she was uncomfortable Epstein removed a large white vibrator which was next to the massage table and turned it on stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area Shortly thereafter Epstein ejaculated and removed himself from the table He walked over to where the shower was and opened the glass door She waited as he was taking a shower in her direct view When I asked flhow old she was when this occurred she stated she had just turned seventeen At the conclusion of the shower,fl fl was paid either or She stated she wasn 2t sure but knows it was close to flM stated she never returned to provide a massage for Epstein At approximately pm Det Dawson and I met with fl dob at her residence As fl was only seventeen years of age I had notified her mother that she would be interviewed reference an ongoing investigation in Palm Beach I assured her that her daughter was not a suspect I explained the possibility of her being either a witness or victim Mrsfladvised she wanted to cooperate and consented to the interview During a sworn taped statement,fl stated the following at the age of sixteen during the month of September she was approached by Haley Robson for a chance to make money flwas friends with associates of Robson and knew the same people fl had been previously told by her friends from flH fl flflBB flwhat Robson did for Epstein Robson called a person known tofl as Sarah and scheduled the appointment Robson picked fflup and drove her to Palm Beach to a street called 223Brillo Way They drove to the end of the street and entered a large driveway They entered the kitchen area of the house and met with Epstein fl was introduced to Jeff Epstein Robson ledfl upstairs to the main bedroom area and set up the room with a massage table and set out the oils flflstated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls Robson dimmed the lights and turned on soft music Robson exited the room and Epstein entered the room wearing only a towel Epstein picked oils and instructed her to rub his legs under his buttocks back and chest area Epstein asked her to get comfortable fl advised she did not remove her clothes She was wearing tight jeans and a cropped tank top exposing her belly area During the massage Epstein removed his towel and laid on the massage table naked As flrubbed Epstein 2s chest area he attempted to reach down her pants to touch her buttocks area however was unable to due so due to the tightness of the jeans and a tight belt fl advised Epstein began to masturbate as she rubbed his chest Epstein moaned as she rubbed his chest She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this Is day of May by Det Joe Recarey who is personally known to me Signature of PoliceZfrficer F.S.S State of Florida County of Palm Beach SignatureU/rreYting Officer Date Page8of CA/Aronberg-0840 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO table straddling Epstein to massage his back While doing this her buttocks were touching Epsteins was instructed to return to the ground at which time Epstein turned to have his chest rubbed advised she was sure he was masturbating based on his hand movements going up and down on his penis area 225ladid not want to look at his penis area because she was uncomfortable Epstein removed a large white vibrator which was next to the massage table and turned it on stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area Shortly thereafter Epstein ejaculated and removed himself from the table He walked over to where the shower was and opened the glass door She waited as he was taking a shower in her direct view When I asked old she was when this occurred she stated she had just turned seventeen At the conclusion of the shower 225was paid either or She stated she wasnt sure but knows it was close to she never returned to provide a massage for Epstein At approximately pm Det Dawson and I met with a dob at her residence Asaa was only seventeen years of age I had notified her mother that she would be interviewed reference an ongoing investigation in Palm Beach I assured her that her daughter was not a suspect I explained the possibility of her being either a witness or victim Mrs.dvised she wanted to cooperate and consented to the interview During a sworn taped statement,-stated the following at the age of sixteen during the month of September she was approached by Haley Robson for a chance to make money Was friends with associates of Robson and knew the same people a had been previously told by her friends from hat Robson did for Epstein Robson called a person known to9as Sarah and scheduled the appointment Robson picked-up and drove her to Palm Beach to a street called Brillo Way They drove to the end of the street and entered a large driveway They entered the kitchen area of the house and met with Epstein was introduced to Jeff Epstein Robson led-upstairs to the main bedroom area and set up the room with a massage table and set out the oils tated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls Robson dimmed the lights and turned on soft music Robson exited the room and Epstein entered the room wearing only a towel Epstein picked oils and instructed her to rub his legs under his buttocks back and chest area Epstein asked her to get comfortable advised she did not remove her clothes She was wearing tight jeans and a cropped tank top exposing her belly area During the massage,_ Epstein removed his towel and laid on the massage table naked As 225rubbed Epsteins chest area he attempted to reach down her pants to touch her buttocks area however was unable to due so due to the tightness of the jeans and a tight belt advised Epstein began to masturbate as she rubbed his chest Epstein moaned as she rubbed his chest She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Page8of22 CA/Aronberg-0840 State of Florida FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO attempted to reach up her tank top and touch her breasts pulled back and EpStein stopped however he kept masturbating until he climaxed He cleaned himself with the towel he was previously wearing lb was paid for the massage and left the area She met with Robson who was waiting in the kitchen area and left the house 225then explained she never provided another massage for Epstein She did however go to the house with Robson and as they took another friend of Robson 2s Badvised she was present when tffl flHH vent to work for Epstein She advised she over and sat in the kitchen area with Robson to wait for 225advised while they waited the house chef prepared lunch for them as it was almost lunchtime when they went When fl was finished with the massage they left the area I asked A if Robson ever told her what would be expected when she provided a massage stated yes Robson told her that a massage would be expected possibly naked and possibly some touching involved has no formal training in providing massages spoke about a third and last time she went to Epstein 2s house Robson drove another girl sixteen years of age who istf Bfriend to Epstein 2s house stated 225knew that made money massaging Epstein and wanted to make money herself Robson took them in the kitchen area of the house and introduced fl to Sarah Robson and Sarah took upstairs to the main bedroom advised she doesn 2t know what happened as did not speak about what happened in the room from Robson for going with her to Epstein 2s house and recommending On October at am I met with at and explained to her why we there to interview her She advised she was aware of the ongoing investigation stated she had previously spoken with told her she was interviewed by detectives During a sworn taped statement,stated she knew that Haley Robson worked for Jeff Epstein in Palm Beach flb advised she originally had been taken to the Epstein house by Haley Robson whom she met when they both attendedShe began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years I asked her if she had formal training in providing massages whichlH 256stated she had not flBiadvised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the providing massages and advised she kept her clothes on She considered Epstein a pervert and he kept pushing to go further and further she would keep telling him she had a boyfriend and would not be right to her boyfriend It wasn 2t until recently that began removing her clothes and staying in her thong underwear to provide a massage The foregoing instrument was sworn to or affirmed State of Florida before me this lsl day of May by County of Palm Beach Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S Signaturl rkesting Officer Date Page CA/Aronberg-0841 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO attempted to reach up her tank top and touch her breasts pulled back and Epstein stopped however he kept masturbating until he climaxed He cleaned himself with the towel he was previously wearing a was paid for the massage and left the area She met with Robson who was waiting in the kitchen area and left the house then explained she never provided another massage for Epstein She did however go to the house with Robson and as they took another friend of Robsons 225advised she was present when ent to work for Epstein She advised she rode over and sat in the kitchen area with Robson to wait for dvised while they waited fo,ra the house chef prepared lunch for them as it was almost lunchtime when they went WheJ finished with the massage they left the area asked if Robson ever told her what would be expected when she provided a massage stated yes Robson told her that a massage would be expected possibly naked and possibly some touching involved bas no formal training in providing massages spoke about a third and last time she went to Epsteins house Robson drove another girl sixteen years of age who i 225friend to Epsteins house.-stated knew that ehad made money massaging Epstein and wanted to make money herself Robson took them in the kitchen area of the house and introduced to Sarah Robson and Sarah took-upstairs to the main bedroom advised she doesnt know what happened did not speak about what happened in the room 225received I from Robson for going with her to Epsteins house and recommencling On October at am I met with 225IN-ltdob md explained to her why we there to interview her She advised she was aware of the ongoing investigation stated she had previously spoken withll9 a 225t1who told her she was interviewed by detectives During a sworn taped statement stated she knew that Haley Robson worked for Jeff Epstein in Palm Beach advised she originally had been taken to the Epstein house by Haley Robson whom she met when they both attended She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years I asked her if she had formal training in providing massages whichlastated she had not alladvised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue began providing massages and advised she kept her clothes on She considered Epstein a pervert and he kept pushing to go further and further explained she would keep telling him she had a boyfriend and would not be right to her boyfriend It wasnt until recently that began removing her clothes and staying in her thong underwear to provide a massage xplained The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Page of CA/Aronberg-0841 esting Officer FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated He would try to touch her breasts as she rubbed his chest 223Jeff would try to get away with more and more on each massage Epstein would try to touch her more and on one occasion he attempted to use a massager/vibrator on her Robson drove the house for the original massage left Sarah her cell phone number and every time Epstein would come into town Sarah would call her for an appointment to 223work Each time she went Sarah would meet her at the kitchen door area She would bring her upstairs and prepare the massage table Epstein would ask her questions about herself Epstein knew she was a soccer player and would be attending iBflS I asked Epstein knew her real age stated Epstein did and didn 2t care The most recent massage she provided was on October During the massage she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Orlando Florida Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car She continued with the massage as Epstein grabbed her buttocks and caressed the buttocks cheeks I askedOB if she was wearing undergarments to which she replied_her thong underwear Once he tried to touch her breasts she would pull away from him and he would stop was asked if he ever used a vibrator on her aware of the vibrator but advised she never would allow him to use the vibrator on her She described 4he vibrator as the large white vibrator with a huge head on the tip of the vibrator She stated he kept the vibrator in a closet near the massage table that on October she was contacted by Epstein 2s assistant Sarah who informed her that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up Sarah informedOBBshe would have the car for a month stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable the car is currently parked next to theB BflH Gym field I asked her if she ever took any one to the house explained she took a friend of hers who attendedBBPIHMBMBI B_who has relocated to Orlando to attend college I asked if she ever allowed another female in the room 225advised no one was brought into the room with her At the conclusion of the interview Det Dawson and went to the gym area and located the Silver Nissan Sentra bearing Florida tag X98-APM The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport The vehicle was rented by Janusz Banasiack later learned to be Epstein 2s houseman and paid with Epstein 2s credit card On September w/f dob was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or affirmed State of Florida before me this Is day of May by County of PalmJBeach Det Joe Recarey who is personally known to me I Signatur iting Officer Signature of Police Officer F.S.S Date PagelOof CA/Aronberg-0842 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated He would try to touch her breasts as she rubbed his chest tated Jeff would try to get away with more and more on each massage stated Epstein would try to touch her more and on one occasion he attempted to use a massager/vibrator on her Robson drove-to the house for the original massage left Sarah her cell phone number and every time Epstein would come into town Sarah would call her for an appointment to work Each time she went Sarah would meet her at the kitchen door area She would bring her upstairs and prepare the massage table advised Epstein would ask her questions about herself Epstein knew she was a soccer player and would be attending I askedalltifEpstein knew her real age stated Epstein did and didnt care The most recent massage she provided was on October I Duripg the massage she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Orlando Florida Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car She continued with the massage as Epstein grabbed her buttocks and caressed the buttocks cheeks I askedtll9if she was wearing undergarments to which she replied her thong underwear Once he tried to touch her breasts she would pull away from him and he would stop alawas asked if he ever used a vibrator on her was aware of the vibrator but advised she never would allow him to use the vibrator on her She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator She stated he kept the vibrator in a closet near the massage table stated that on October she was contacted by Epsteins assistant Sarah who informed her that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up Sarah informed would have the car for a month stated Epstein lrnew her car was not working properly and that she had missed appointments in the past because of her car being inoperable 225explained the car is currently parked next to thletl 225Gym field I asked her if she ever took any one to the _house explained she took friend of hers who attende who has relocated to Orlando to attend college I asked if she ever allowed another female in the room advised no one was brought into the room with her At the conclusion of the interview Det Dawson and I went to the gym area and located the Silver Nissan Sentra bearing Florida tag X98-APM The vehicle is registered to Dollar Rent a Car out-of the P_alm Beach International Airport The vehicle was rented by Janusz Banasiack later learned to be Epsteins houseman and paid with Epsteins credit card On September w/f dob was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Pagel CNAronberg-0842 FILED PA BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO for misdemeanor possession of marijuana During the arrest Octoid the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein Additionally during the ongoing trash pulls from Epstein 2s residence discarded papers were found which contained name and cell phone number On October Det Dawson and I met with HBhnd obtained a sworn taped statement explained she had been going to Epstein 2s house since when she was sixteen years of age Since then she has gone to the house hundreds of times 225stated she became his 223number one girl She explained that on her first visit she was brought to the house by feIlow4HpOHMBMH HHM classmate,fllHO Oi said she was brought through the kitchen area where she met Sarah Kellen for the first time 225was led to the master bedroom Epstein room 0explained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house Bfurther explained that she was brought into the bedroom where Sarah prepared the room by setting up the massage table and provided the oils for her to rub on Epstein 225explained she remembered the steam room area which contained two large showers Epstein entered the room from the steam room area and introduced himself Epstein lay on the table and told her to get comfortable 225emoved her skirt and kept her shirt on Epstein then instructed her to remove her shirt removed her shirt and remembered she was not wearing a bra she provided the massage wearing only her panties She continued rubbing his legs thighs and feet advised he turned over onto his back Epstein touched her breasts and began to masturbate Epstein ejaculated which meant the massage was over At the conclusion of the massage 225was paid They walked together downstairs where Sarah Kellen and BJPMU vere waiting 0stated received an unknown amount of money for taking her to Epstein Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town stated that during her many visits a routine was established between her and Epstein She would enter the house and get naked in the bedroom She would then start with a back massage Epstein would roll on to his back and allow her to massage his chest area 225stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers 225Explained Epstein would continue this process until he ejaculated He would then utilize a vibrator/massager on her vagina until climaxed 225advised that during her frequent visits Epstein asked for her real age,MB stated she was sixteen Epstein advised her not to tell anyone her real age advised that things escalated within the home as Epstein would instruct and pay to have intercourse with his female friend Nada Marcinkova 225xplained the intercourse included using strap on dildos large rubber penis and other devices that Epstein had at his disposal Epstein would watch them have intercourse and masturbate himself Occasionally Epstein would then join in The foregoing instrument was sworn to or affirmed State of Florida before me this I5 day of May by County of Palm/Beach Det Joe Recarey who is personally known to me I Signature ing Officer Signature of Police Officer F.S.S Date Pagel of CA/Aronberg-0843 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO for misdemeanor possession of marijuana During the arrest llttold the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein Additionally during the ongoing trash pulls from Epsteins residence discarded papers were found which contained name and cell phone number On October Det Dawson and I met with lmd obtained a sworn taped statement explained she had been going to Epsteins house since when she was sixteen years of age Since then she has gone to the house hundreds of times stated she became his number one girl She explained that on her first visit she was brought to the house by said she was brought through the kitchen area where she met Sarah Kellen for the first time 119was led to the master bedroom Epstein room iaexplained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house lturther explained that she was brought into the bedroom where Sarah prepared the room by setting up the massage table and provided the oils for her to rub on Epstein explained she remembered the steam room area which contained two large showers Epstein entered the room from the steam room area and introduced himself Epstein lay on the table and told her to get comfortable emoved her skirt and kept her shirt on Epstein then instructed her to remove her shirt tlltrernoved her shirt and remembered she was not wearing a bra stated she provided the massage wearing only her panties She continued rubbing his legs thighs and feet advised he turned over onto his back Epstein touched her breasts and began to masturbate Epstein ejaculated which meant the sage was over At the conclusion of the massage as paid They walked together downstairs whe;e Sarah Kellen and ere waiting received an unknown amount of money for taking her to Epstein Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town fl/I stated that during her many visits a routine was established between her and Epstein She would enter the house and get naked in the bedroom She would then start with a back massage Epstein would roll on to his back and allow her to massage his chest area 225stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers xplained Epstein would continue this process until he ejaculated He would then utilize a vibrator/massager on her vagina until_ climaxed advised that during her frequent visits Epstein asked for her real age stated she was sixteen Epstein advised her not to tell anyone her real age advised that things escalated within the home as Epstein would instruct and paytlltto have intercourse with his female friend Nada Marcinkova xplained the intercourse included using strap on dildos large rubber penis and other devices that Epstein had at his disposal Epstein would watch them have intercourse and masturbate himself Occasionally Epstein would then join in The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personaUy known to me Signature of Police Officer F.S.S Pagelfof CA/Aronberg-0843 each Officer Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO during the female on female intercourse and provide oral sex to bothl fcnd Marcinkova This occurred during the time iflBwas sixteen years of age this continued to escalate during two years The routine became familiar to Epstein 2s assistant Sarah would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein Each time something new was introduced additional monies were produced and offered for Bo allow the acts to happen flflBconsented to perform all these acts but was adamant that there was an understanding with Epstein that no vaginal penetration would occur with his penis fl explained that Epsteins penis was deformed explained that his penis was oval shaped claimed when Epsteins penis was erect it was thick toward the bottom but was thin and small toward the head portion fl called Epstein 2s penis 223egg-shaped fl stated Epstein would photograph Marcinkova and her naked and having sex and proudly display the photographs within the home fl tated during one visit to Epstein 2s house in which she provided a massage to Epstein his female friend Nada Marcinkova was also present fl fl provided the massage in which Marcinkova and her would fondle each others breasts and kiss for Epstein to enjoy Towards the end of this massage Epstein grabbed fl and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina fl stated Epstein began to pump his penis in her vagina became upset over this She said her head was being held against the table forcibly as he continued to pump inside her She screamed and Epstein stopped She told him that she did not want to have his penis inside of her Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit fl stated she knows he still displays her photographs through out the house On October Det Dawson and I met withlMHflflflfl dobwho stated during a sworn taped statement that nothing happened between her and Epstein fljf appeared nervous during the interview I assured her that I have spoken with other people who advised differently stated on several occasions she provided a massage to Epstein She stated she was brought to the Epstein house in March of fl fl a cl assmate approached her and asked her if she wanted to 223work Bmade the arrangements with Sarah Epstein 2s assistant Bwho has no formal training in providing massages stated she provided a massage fully clothed for As I sensed hesitancy in her answers I askedim if she had been contacted by anyone from Epstein 2s organizations or his house stated she was interviewed already by a private investigator for Epstein He identified himself as 223Paul and inquired about the police investigation and left his telephone number for additional contact 4feH rovided no additional information as it appeared her responses were almost scripted The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County of Palm Beach Signature/Arrtasbng Officer Date O5/OlWo6 Pagelif CA/Aronberg-0844 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO during the female on female intercourse and provide oral sex to both tliaind Marcinkova This occurred during the time aawas sixteen years of age a9:tdvised this continued to escalate during two years The routine became familiar to Epsteins assistant Sarah would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein Each time something new was introduced additional monies were produced and offered for lato allow the acts to happen onsented to perform all these acts but was adamant that there was an understanding with Epstein that no vaginal penetration would occur with his penis explained that Epsteins penis was deformed explained that his penis was oval shaped claimed when Epsteins penis was erect it was thick toward the bottom but was thin and small toward the head portion called Epsteins penis egg-shaped stated Epstein would photograph Marcinkova and her naked and having sex and proudly display the photographs within the home tated during one visit to Epsteins house in which she provided a massage to Epstein his female friend Nada Marcinkova was also present provided the massage in which Marcinkova and her would fondle each others breasts and kiss for Epstein to enjoy Towards the end of this massage Epstein grabbed 225and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina Stated Epstein began to pump his penis in her vagina became upset over this She said her head was being held against the table forcibly as he continued to pump inside her She screamed No and Epstein stopped She told him that she did not want to have his penis inside of her Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit 225stated she knows he still displays her photographs through out the house On October Det Dawson and I met with doh I who stated during a sworn taped statement that nothing happened between her and Epstein peared nervous during the interview I assured her that I have spoken with other people who advised differently stated on several occasions she provided a massage to Epstein She stated she was brought to the Epstein house in March of a classmate approached her and asked her if she wanted to work ade the arrangements with Sarah Epsteins assistant who has no formal training in providing massages stated she provided a massage fully clothed for As I sensed hesitancy in her answers I asked she had been contacted by anyone from Epsteins organizations or his house stated she was interviewed already by a private investigator for Epstein He identified himself as Paul and inquired about the police investigation and left his telephone number for additional contact provided no additional information as it appeared her responses were almost scripted The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Signature of Police Pagel CA/Aronberg-0844 Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO On November at approximately pm I met withdob at the Palm Beach Police Department BI9was identified as a potential witness/victim through information obtained during the trash pulls During the sworn taped statement BBndvised she was at Jeffrey Epstein 2s house one time approximately two months ago She was approached by a girl,who was dating BBM oommate for an opportunity to make some quick money advised she needed to make some quick cash to make the rent that month She agreed to go to the house She had been told by that the massage would have to be done in her underwear She advisedBBAdrove with her and brought her into the house They walked into the kitchen area and took the stairs upstairs Bfurther stated she was brought into a master bedroom area She advised she recalled seeing portraits of naked women throughout the room A massage table was already out near the sauna/shower area in the master bedroom Epstein entered the room wearing only a towel and introduced himself as 223Jeff At Epstein 2s direction,BMBAndMBBtemoved their clothing down to their panties Epstein laid on his stomach area and they provided a massage on his legs and feet area I asked if she had any formal massage training and she replied MBAadvised she was topless and the panties she wore were the boy shorts lace panties She andMMfcontinued the massage until the last ten minutes of the massage Epstein toldMMftto leave the room so that ISlBcould finish the massage MMBgot dressed and left the room as Epstein turned over onto his back Epstein then removed the towel and laid naked Epstein requested that his chest area Mstated as she did this Epstein began masturbating Mstated Epstein pulled down her boy short panties and he produced a large white vibrator with a large head She stated it was within his reach in a drawer in his master bathroom He rubbed the vibrator on her vaginal area MMAadvised he never penetrated her vagina with the vibrator He continued to rub her vagina with the vibrator as he continued to masturbate stated she was very uncomfortable during the incident but knew it was almost over Epstein climaxed and started to remove himself from the table He wiped himself with the towel he had on previously and went into the shower area Hbgot dressed and met with MBin the kitchen area Epstein came into the kitchen and providedMBB for bringing MMand paid toiBHB providing the massage MAwas told to leave her telephone number with Sarah for future contact BF rov her cellular telephone number BA A was asked if she was recently contacted about this investigation by anyone from the Epstein organization She replied she was called but it was for work She stated she was called by Sarah for her to return to 223work for Epstein Bstated 223work is the term used by Sarah to provide the massages and other things MA advised she declined as she was not comfortable in providing that type of 223work On November Det Sandman and I met withMMBMBB dob MBMBDuring a sworn taped she met Jeffrey Epstein through Haley Robson when they were still The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County of PalmiBeach Signature/AMe ing Officer Date Page Oof CA/Aronberg-0845 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO On November at approximately pm I met with dob at the Palm Beach Police Department identified as a potential witness/victim through information obtained during the trash pulls During the sworn taped statement idvised she was at Jeffrey Epsteins house one time approximately two months ago She was approached by a girl who was dating oornmate for an opportunity to make some quick money she needed to make some quick cash to make the rent that month She agreed to go to the house She had been told by that the massage would have to be done in her underwear She advised drove with her and brought her into the house They walked into the kitchen area and took the stairs upstairs.-.rurther stated she was brought into a master bedroom area She advised she recalled seeing portraits of naked women throughout the room A massage table was already out near the sauna/shower area in the master bedroom Epstein entered the room wearing only a towel and introduced himself as Jeff At Epsteins direction 1d 225emoved their clothing down to their panties Epstein laid on his stomach area and they provided a massage on his legs and feet area I asked if she had any formal massage training and she replied no advised she was topless and the panties she wore were the boy shorts lace panties She and 225kontinued the massage until the last ten minutes of the massage Epstein told leave the room so that could finish the massage got dressed and left the room as Epstein turned over onto his back Epstein then removed the towel and laid naked Epstein requested that his chest area stated as she did_ this Epstein began masturbating stated Epstein pulled down her boy short panties and he produced a large white vibrator with a large head She stated it was within his reach in a drawer in his master bathroom He rubbed the vibrator on her vaginal area 225advised he never penetrated her vagina with the vibrator He continued to rub her vagina with the vibrator as he continued to masturbate stated she was very uncomfortable during the incident but knew it was almost over Epstein climaxed and started to remove himself from the table He wiped himself with the towel he had on previously and went into the shower area _.got dressed and met with the kitchen area Epstein came into the kitchen and provided for bringing ind paid to-or providing the massage was told to leave her telephone number with Sarah for future contact _,rovided her cellular telephone number 225was asked if she was recently contacted about this investigation by anyone from the Epstein organization She replied she was called but it was for work She stated she was called by Sarah for her to return to work for Epstein work is the term used by Sarah to provide the massages and other things 225tadvised she declined as she was not comfortable in providing that type of work On November Det Sandman and I met with dob During a sworn taped statement tated she met Jeffrey Epstein through Haley Robson when they were still The foregoing instrument was sworn to or affirmed before me this st day of May by Det Joe Recarey who is personally known to me Signature of Police Pagel CA/Aronberg-0845 State of Florida County of Pal Beach ing Officer Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO attendingSMU I BHO Robson would approach females who wished to work for Epstein stated she was offered to work for Epstein but declined explained that 223work means give massages She was asked about any formal training in providing massages which she said 0Bkaid she accompanied Robson and other females who were taken to Epstein 2s house to provide massages further stated she had been to the house approximately or times in the past year She accompanied Robson with HKMb Each time the girls were-taken over they were previously told they would have to provide a massage possibly naked They were also told that should Epstein require them to do anything extra and they were not comfortable just to tell him and he would stop pHb stated Robson received for each girl she brought over to massage Jeffrey Epstein When I asked which girl appeared to be the youngest she replied WB who was really young fifteen years old at the most m0B further stated each time she went to the house she sat in the kitchen and waited with Robson until the massage was over She further stated that the cook would make lunch or a snack for them as they waited I asked her if there was anything that caught her attention within the home stated there were a lot of naked girls in photographs throughout the house On November at approximately I met withflfllWMBb dobOtf at the Palm Beach Police Department During a sworn taped statement stated she had met Epstein approximately two years ago when she was first approached by Haley Robson a classmate Robson approached her about working for Epstein and providing a massage to him for Robson had made the arrangements however was unable to take her the day the arrangements were made Robson had take MMso attended WB HBBband was familiar with Epstein Bb recalled she was brought there and entered through the back kitchen door She had met with an assistant Sarah and another assistant Adrianna Sarah brought her upstairs as she observed several photographs of naked females throughout the house Bib stated Epstein came in the room wearing only a towel and laid on the table Bb stated he picked out the oils he wanted her to use and requested she remove her clothing to provide the massage WBbstated on the first massage she provided she did not remove her clothing BB bstated she had returned several times after that Each time she returned it was more than a massage Epstein would walk into the master bedroom/bathroom area wearing only a towel He would masturbate as she provided a massage stated she was unsure if he climaxed as he masturbated under the towel Additionally she never looked below his waist She claimed that Epstein would convince her to remove her clothes She eventually removed her clothes and stayed in her thong panties On occasion Epstein would use a massager/vibrator which she described as white in color and a large head Epstein would rub the vibrator/massager on her vaginal area as he would masturbate BHB stated she had been to the house The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officer F.S.S State of Florida County of Pairfi Beach SignaturpA Asting Officer Date Page of22 CA/Aronberg-0846 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO attendin Robson would approach females who wished to work for Epstein tta stated she was offered to work for Epstein but declined explained that work means give massages She was asked about any formal training in providing massages which she said no she accompanied Robson and other females who were taken to Epsteins house to provide massages further stated she had been to the house approximately or times in the past year She accompanied Robson with I I 2251tand Each time the girls were-taken over they were previously told they would have to provide a massage possibly naked They were also told that should Epstein require them to do anything extra and they were not comfortable just to tell him and he would stop stated Robson received for each girl she brought over to massage Jeffrey Epstein When I asked which girl appeared to be the youngest she replied who was really young fifteen years old at the-most fwther stated each time she went to the house she sat in the kitchen and waited with Robson until the massage was over She further stated that the cook would make lunch or a snack for them as they waited I asked her if there was anything that caught her attention within the home stated there were a lot of naked girls in photographs throughout the house On November at approximately I met with dob 225aat the Palm Beach Police Department During a sworn taped statement stated she had met Epstein approximately two years ago when she was first approached by Haley Robson a classmate at Robson approached her about working for Epstein and providing a massage to him for Robson had made the arrangements however was unable to take her the day the arrangements were made Robson had attended and was familiar with Epstein 225recalled she was brought there and entered through the back kitchen door She had met with an assistant Sarah and another assistant Adrianna Sarah brought her upstairs as she observed several photographs of naked females throughout the house stated Epstein came in the room wearing only a towel and laid on the table stated he picked out the oils he wanted her to use and requested she relJlOVe her clothing to provide the massage tated that on the first massage she provided she did not remove her clothing 2259stated she had returned several times after that Each time she returned it was more than a massage Epstein would walk into the master bedroom/bathroom area wearing only a towel He would masturbate as she provided a massage stated she was unsure if he climaxed as he masturbated under the towel Additionally she never looked below his waist She claimed that Epstein would convince her to remove her clothes She eventually removed her clothes and stayed in her thong panties On occasion Epstein would use a massager/vibrator which she described as white in color and a large head Epstein would rub the vibrator/massager on her vaginal area as he would masturbate tated she had been to the house The foregoing instrument was sworn to or affirmed before me this st day of May by Det Joe Recarey who is personally known to me Signature of Police Page of CNAronberg-0846 State of Florida County of Pal Beach ting Officer Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit i Palm Beach Police Department Agency ORI FLO I numerous times HB added has no formal training in providing a massage stated she brought two females during her visits to provide massages 9HBB 6tated she brought a girl named WHIP and om stated she received for each girl she brought On November met with9 MH9W/F the Palm Beach Police Department During a sworn taped statement she had met Jeffrey Epstein approximately one year ago She was approached by a subject known to her as fl Bhad asked her if she wanted to make money providing massages to Epstein Bfl 243had heard that several girls from were doing this and making money She agreed and was taken to the house by flB MBhad introduced her to Sarah and Epstein and brought her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected Bleft the room and waited downstairs for her stated Epstein entered the room wearing a towel and laid on his stomach She provided a massage wearing only her thong panties advised Epstein had masturbated every time she provided a massage She stated Epstein continued to masturbate until he climaxed Once that occurred the massage was over She felt the whole situation was weird but she advised she was paid for providing the massage She also stated Bwas paid by Epstein for bringing stated she had gone a total of times to Epstein 2s residence to provide a massage and things had escalated from just providing a massage Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated Epstein also grabbed her breasts and fondled her breasts with his hands as she provided the massage I B9stated on one occasion while she was only seventeen years of age he offered extra monies to have vaginal intercourse She stated this all occurred on the massage table stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax Epstein removed his penis from her vagina and climaxed onto the massage table received for her massage I asked her if she had any formal training in providing massages stated she did not continued to state on one other occasion Epstein introduced his girlfriend Nadia into the massage Nadia was brought into room with to provide a massage Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein Epstein watched and masturbated as this occurred On other occasions Epstein introduced the large white vibrator/massager in the massage Epstein stroked the vibrator/massager on VIBO vagina as she provided the massage On November Det Sandman and I met withSMB dob During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times also stated she was sixteen years old when she first went to Epstein 2s house On her first visit she was brought by a fellow student from known to her The foregoing instrument was sworn to or affirmed before me this Is day of May by Det Joe Recarey who is personally known to me State of Florida County of PalA Beach Signature/A ting Officer Signature of PolicZofficer F.S.S Date Page CA/Aronberg-0847 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affulavit Palm Beach Police Department Agency ORI FLO I numerous times added she has no formal training in providing a massag stated she brought two females during her visits to provide she brought a grrl named and fo.Jm she received 20o:oo for each girl she brought On November I met with the Palm Beach Police Department During a sworn taped statement tated she had met Jeffrey Epstein approximately one year ago She was approached by a subject known to her as iad asked her if she wanted to make money providing massages to Epstein ad heard that several girls from were doing this and making money She agreed and was taken to the house by ad introduced her to Sarah and Epstein and brought her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected left the room and waited downstairs for her stated Epstein entered the room wearing a towel and laid on his stomach She provided a massage wearing only her thong panties advised Epstein had masturbated every time she provided a massage She stated Epstein continued to masturbate until he climaxed Once that occurred the massage was over She felt the whole situation was weird but she advised she was paid for providing the massage She also stated.,as paid by Epstein for bringing stated she had gone a total of times to Epsteins residence to provide a massage and things had escalated from just providing a massage Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated Epstein also grabbed her breasts and fondled her breasts with his hands as she provided the massage stated on one occasion while she was only seventeen years of age he offe ed extra monies to have vaginal intercourse She stated this all occurred on the massage table stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax Epstein removed his penis from her vagina and climaxed onto the massage table lreceived for her massage I asked her if she had any formal training in providing massages,-stated she did not.1 continued to state on one other occasion Epstein introduced his girlfriend Nadia into the massage Nadia was brought into room with to provide a massage Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein Epstein watched and masturbated as this occurred On other occasions Epstein introduced the large white vibrator/massager in the massage Epstein stroked the vibrator/massager on 2251tvagina as she provided the massage On November Det Sandman and I met During a sworn taped statement she advised she started going to the house approximately on year ago and has been there approximately five or six times also stated she was sixteen years old when she first went to Epsteins house On her first visit she was brought by a fellow student from known to her The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me Seof Page CA/Aronberg-0847 State of Florida County of Pal Beach Signa Date I ting Officer FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO Esposito statedBHB brought her into the house and she was introduced to Sarah Sarah then brought her upstairs into a master bathroom located within the bedroom BBH stated she met Epstein in the bathroom He laid on the table and picked the massage oils She provided the massage as he laid naked on the massage bed She stated she rubbed his calves and back area Upon the end of the massage Epstein removed himself from the massage table and paid her for the massage Bsaid each subsequent time she went to the house she was notified by Sarah Kellen that Epstein was in town and would like her to 223work she returned to the house and was again led upstairs by Sarah She provided the massage clothed was asked if she ever removed her clothing to provide a massage JBB stated it was not until the third time that she went that she removed her clothing HH stated she was notified by Sarah that Epstein wanted her to come to work She arrived at the house and was led upstairs by Sarah She started providing the massage when Epstein asked her to remove her clothing removed her pants shirt and bra She stayed in her thong panties and continued rubbing Epstein Epstein turned over onto his back and she rubbed his chest area I BBstated she knew he was masturbating himself as she providing the massage she believed he climaxed based on his breathing She did not want to view either the climax or the fact that he was masturbating BI BBF stated once the breathing relaxed he got up and told her to get dressed She was paid for her services stated on the last time she went to provide a massage she was notified by Sarah Kellen to come to the house and 223work BIIMBstated she was now dating her current boyfriend and did not feel comfortable going She recalled it was approximately January She said she went already thinking that this would be the last time She went upstairs and went into the master bathroom She met with Epstein who was wearing only a towel and laid onto the table stated Epstein caught her looking at the clock on several occasions Epstein asked her if she was in a hurry stated her boyfriend was in the car waiting for her stated that Epstein got upset as he wasn 2t enjoying the massage She told him that she didn 2t want to continue and she would not be back Epstein told her to leave as she was ruining his massage vised she had no formal training in providing any massages Mstated although she had a falling out with Epstein she still received a Christmas bonus from Epstein stated she was wired money from Western Union for her Christmas bonus Subpoena results from Western Union revealed money was sent from Jeffrey Epstein on December received from Epstein for her Christmas bonus On November Det Sandman and I met with dob During a sworn taped statement 225stated she met Jeffrey Epstein over a year ago She was sixteen years of age and was approached by MiB fellovM BHII BM student who informed her that she could make providing a massage to Epstein informed her that she would have to provide this The foregoing instrument was sworn to or affirmed State of Florida before me this day of May by County of Palm Beach Det Joe Recarey who is personally known to me Vx/lj Signature ling Officer Signature of Police Officer F.S.S Date Page CA/Aronberg-0848 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO as Esposito state brought her into the house and she was introd ed to Sarah Sarah then brought her upstairs into a master bathroom located within the bedroom stated she met Epstein in the bathroom He laid on the table and picked the massage oils She provided the massage as he laid naked on the massage bed She stated she rubbed his calves and back area Upon the end of the massage Epstein removed himself from the massage table and paid her for the massage each subsequent time she went to the house she was notified by Sarah Kellen that Epstein was in town and would like her to work tated she returned to the house and was again led upstairs by Sarah She provided the massage clothed asked if she ever removed her clothing to provide a massage l9llt stated it was not until the third time that she went that she removed her clothing stated she was notified by Sarah that Epstein wanted her to come to work She arrived at the house and was led upstairs by Sarah She started providing the massage when Epstein asked her to remove her clothing removed her pants shirt and bra She stayed in her thong panties and continued rubbing Epstein Epstein turned over onto his back and she rubbed his chest area she knew he was masturbating himself as she providing the massage tated she believed he climaxed based on his breathing She did not want to view either the climax or the fact that he was masturbating _,stated once the breathing relaxed he got up and told her to get dressed She was paid for her services stated on the last time she went to provide a massage she was notified by Sarah Kellen to come to the house and work _.stated she was now dating her current boyfriend and did not feel comfortable going She recalled it-was approximately January She said she went already thinking that this would be the last time She went upstairs and went into the master bathroom She met with Epstein who was wearing only a towel and laid onto the table stated Epstein caught her looking at the clock on several occasions Epstein asked her if she was in a hurry stated her boyfriend was in the car waiting for her er stated that Epstein got upset as he wasnt enjoying the massage She told him that she didnt want to continue and she would not be back Epstein told her to leave as she was ruining his massage advised she had no formal training in providing any massages tated although she had a falling out with Epstein she still received a Christmas bonus from Epstein stated she was wired money from Western Union for her Christmas bonus Subpoena results from Western Union revealed money was sent from Jeffrey Epstein on December received from Epstein for her Christmas bonus On November Det Sandman and I met with dob During a sworn taped statement,.-Stated she met Jeffrey Epstein over a year ago She was sixteen years of age and was approached by fello student who informed her that she could make providing a massage to Epstein had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed before me this l5 day of May by Det Joe Recarey who is personally known to me Signature of Polke Officer F.S.S CA/Aronberg-0848 State of Florida County qf Palm each Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO i i_ massage topless Pmade the arrangements with Epstein and his assistants and took MB to the house stated and she entered through a glass door that led into a kitchen She was taken upstairs by9i9 to a master bedroom She recalled the master bathroom had a large pink couch sauna and matching shower Epstein entered into the room wearing only a towel andflBBtemoved their clothing remaining only in thong underwear She further stated that Epstein laid on his chest on the table The oils were selected on which ones to use Both0l 0and0 Bprovided the massage on his legs back and feet Forty minutes into the massage Epstein turned over onto his back and requested Bwait downstairs in the kitchen area forl Epstein instructed finish the massage AsBBIBgot dressed starting rubbing Epstein 2s chest BHb left the room and Epstein began masturbating asrubbed Epstein 2s chest stated Epstein continued masturbating until he climaxed on the towel he was wearing When asked if he had removed the towel she stated he turned the towel around so that the opening would allow him to expose himself After he cleaned himself off with the towel he instructed massage was done and to get dressed and meet with him downstairs got dressed and met with Epstein in the kitchen area She was paid dollars for providing the massage she was aware thatBalso received monies for the same thing The second time she went to the house she was again approached by9i9 fedvised if she wanted to return to the house to provide another massage99 agreed and the arrangements were made byWIBfor her to return to the house BB drove her to the house and knocked on the same glass door which leads to the kitchen area They were allowed entry into the house by one of the staff members her upstairs to the master bedroom and master bathroom time to do the massage alone Epstein entered the room again wearing only a towel flbbegan removing her clothing as she did the last time she was at the house Epstein instructed her to get naked He laid on the table onto his stomach asO began massaging his legs and back As finished with Epstein 2s back and legs Epstein then turned over onto his back started to rub his chest and he began masturbating As OB rubbed his chest Epstein leaned over and produced a massager/vibratof He turned it on and began rubbing 9B vagina and masturbating himself at the same time IB stated she continued to rub his chest as this was occurring She described the vibrator/massager as large grey with a large head Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator He then removed the vibrator from her vaginal area and concentrated on masturbating himself Bstated Epstein climaxed onto the towel again and informed her that the massage was done got dressed and met withB who was waiting in the kitchen area She received for the massage.B9 said she never returned to the house and had no desire to return to the house Bwas asked if she received any formal massage training She advised she had no formal training was asked if Epstein knew her real age he knew as he asked her questions about herself and high school He was aware she attended and is still attendingBH HBMH The foregoing instrument was sworn to or affirmed before me this Is day of May by Det Joe Recarey who is personally known to me Signature of Polic/Officer F.S.S State of Florida County of Palm Beach SignaturelAhA ting Officer Date O5/WoO6 Page CA/Aronberg-0849 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO massage topless ade the arrangements with Epstein and his assistants and took to the house stated and she entered through a glass door that led into a kitchen She was taken upstairs by to a master bedroom She recalled the master bathroom had a large pink couch sauna and matching shower Epstein entered into the room wearing only a towel and 225,emoved their clothing remaining only in thong underwear She further stated that Epstein laid on his chest on the table The oils were selected on which ones to use Both a tlaprovided the massage on his legs back and feet Forty minutes into the massage Epstein turned over onto his back and requested wait downstairs in the kitchen area for Epstein instructed-a finish the massage As 225tot dressed,_ starting rubbing Epsteins chest a left the room and Epstein began masturbating as-rubbed Epsteins chest stated Epstein continued mastu,rbating until he climaxed on the towel he was wearing When asked if he had removed the towel she stated he turned the towel around so that the opening would allow him to expose himself After he cleaned himself off with the towel he instructed lathe massage was done and to get dressed and meet with him downstairs got dressed and met with Epstein in the kitchen area She was paid dollars for providing the massage tated she was aware th 1t also received monies for the same thing The second time she went to the house she was again approached by 2251dvised if she wanted to return to the house to provide another massage agreed and the arrangements were made by for her to return to the house lstated drove her to the house and knocked on the same glass door which leads to the kitchen area They were allowed entry into the house by one of the staff members led her upstairs to the master bedroom master bathroom area leftaahis time to do the massage alone Epstein entered the room again wearing only a towel egan removing her clothing as she did the last time she was at the house Epstein instructed her to get naked He laid on the table onto his stomach as began massaging his legs and back As finished with Epsteins back and legs Epstein then turned over onto his back started to rub his chest and he began masturbating As rubbed his chest Epstein leaned over and produced a massager/vibrator He turned it on and began rubbing vagina and masturbating himself at the same time stated she continued to rub his chest as this was occurring She described the vibrator/massager as large grey with a large head Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator He then removed the vibrator from her vaginal area and concentrated on masturbating himself lastated Epstein climaxed onto the towel again and informed her that the massage was done got dressed and met with who was waiting in the kitchen area She received for the massage said she never returned to the house and had no desire to return to the house was asked if she received any formal massage training She advised she had no formal training was asked if Epstein knew her real age __ stated he knew as he asked her questions about herself and high school He was aware she attended and is still attending The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Poli Pagetff22 CA Aronberg-0849 State of Florida County of Pal I Date ting Officer FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO i_ During the course of the investigation a search warrant was executed at Jeffrey Epstein 2s home located at El Brillo Way in Palm Beach While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned The stairway which is located from the kitchen area to the master bedroom area is lined with photos of naked young girls Additionally numerous photographs of naked young females some of which appeared to be the girls I previously interviewed were on display throughout the house Also located in the house were various phone message books The telephone message books have a duplicate copy Carbon Copy which once a phone message is written into the book the top copy is then tom on the perforated edge and the carbon copy is left in the book First names of girls dates and telephone numbers were on the copy of the messages I recognized various numbers and names of girls that had already been interviewed The body of the messages were time of the day that they called for confirmation of work Other names and telephone numbers were located in which the body of the messages were I have girls for him or I have girls for him These messages were taken by Sarah Kellen who signed the bottom of the messages During the execution of the warrant I located transcript for Epstein 2s bedroom desk This desk had stationary marked Jeffrey Epstein I located a wood colored armoire beside Epstein 2s bed that contained a bottle of 223Joy Jelly which is used to provide a warm massage Several massage tables were located throughout the second floor of the residence including a massage table found in Epstein 2s bedroom On the first floor of the residence I found two covert cameras hidden within clocks One was located in the garage and the other located in the library area on a shelf behind Epstein 2s desk A computer was located which was believed to contain the images from the covert cameras The computer 2s hard drive was reviewed which showed several images of Haley Robson and other witnesses that have been interviewed All of these images appeared to come from the camera positioned behind Epstein 2s desk On December Det Dawson and I met with dob During a sworn taped statement stated that when she was sixteen years old she was taken to Epstein 2s house to provide a massage for money OBstated it was before Christmas last year when an associate approached her and asked if she needed to make money for Christmas Bmade arrangements to take to the house and drove to the house to 223work They were encountered by a white female with long blond hair Bwas unable to remember the name of the white female with blond hair but knew she was Epstein 2s assistant She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use She was led through a spiral staircase which led to a master bedroom.and bathroom The massage table was already set up in the bathroom.Ml described the bathroom as a large spacious bathroom with a steam room and shower beside it was introduced to Epstein who was on the phone when she entered the room Epstein was wearing a white towel and laid on his stomach so thalBB maY The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me State of Florida County of Palm Beach Signature of Signature Date sting Officer Page CA/Aronberg-0850 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO During the course of the investigation a search warrant was executed at Jeffrey Epsteins home located at El Brillo Way in Palm Beach While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned The stairway which is locat from the kitchen area to the master bedroom area is lined with photos of naked young girls Additionally numerous photographs of naked young females some of which appeared to be the girls I previously interviewed were on display throughout the house Also located in the house were various phone message books The telephone message books have a duplicate copy Carbon Copy which once a phone message is written into the book the top copy is then torn on the perforated edge and the carbon copy is left in the book First names of girls dates and telephone numbers were on the copy of the messages I recognized various numbers and names of girls that had already been interviewed The body of the messages were time of the day that they called for confirmation of work Other names and telephone numbers were located in which the body of the messages were I have girls for him or I have girls for him These messages were taken by Sarah Kellen who signed the bottom of the messages During the execution of the warrant Ilocated a transcript for 9n Epsteins bedroom desk This desk had stationary marked Jeffrey Epstein I located a wood colored annoire beside Epsteins bed that contained a bottle of Joy Jelly which is used to provide a warm massage Several massage tables were located throughout the second floor of the residence including a massage table found in Epsteins bedroom On the first floor of the residence I found two covert cameras hidden within clocks One was located in the garage and the other located in the library area on a shelf behind Epsteins desk A computer was located whi was believed to contain the images from the covert cameras The computers hard drive was reviewed which showed several images of Haley Robson and other witnesses that have been interviewed All of these images appeared to come from the camera positioned behind Epsteins desk On December I Det Dawson and I met with-doh During a sworn taped statement stated that when she was sixteen years old she was taken to Epsteins house to provide a massage for money lstated it was before 267Christmas last year when an associate approached her and asked if she needed to make money for Christmas made arrangements to fake a to the house and drove to the house to work They were encountered by a white female with long blond hair was unable to remember the name of the white female with blond hair but knew she was Epsteins assistant She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use She was led through a spiral staircase which led to a master bedroom.and bathroom The massage table was already set up in the bathroom.A described the bathroom as a large spacious bathroom with a steam room and shower beside it was introduced to Epstein who was on the phone when she entered the room Epstein was wearing a white towel and laid on his stomach so tha may The foregoing instrument was sworn to or affirmed before me this st day of May by Det Joe Recarey who is personally known to me Signature of PolicOfficeiF.S.s CA Aronberg-0850 State of Florida County of Pal Beach i I ting Officer Date I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO massage his feet and calves started the massage with the oils Epstein chose and rubbed his feet and calves Epstein got off the phone and requested she massage his back as well began rubbing his back and got to the small of his back During the rubbing of his back Epstein asked her to get comfortable He requested she remove her pants and shirt removed her shirt and pulled her pants off stayed in bra and thong panties As she finished massaging the small of Epstein back he then turned onto his back Epstein instructed to rub his chest and pinch his nipples As she began to rub his chest Epstein asked her questions about herself remembered telling him she attended mHHMH Bl Epstein asked her if she was sexually active Before Mbcould answer he also asked what sexual position does she enjoy stated she was shy and didn 2t like talking about those things She continued rubbing his chest Epstein reached up and unsnapped her bra from the front I bexplained the bra she used had a front snapping device Epstein rubbed her breasts and asked her if she like having her breasts rubbed tflsaid I don 2t like that Epstein then removed his towel and laid on the bed naked exposing his penis to He began touching his penis and masturbated as he touched her breasts explained Epstein then touched her vaginal area by rubbing her vagina with his fingers on the outside of her thong panties tensed up and stated Epstein was aware that she was uncomfortable stated that Epstein said to her 223Relax I 2m not going inside She further explained Epstein commented to her how beautiful and sexy she was Epstein then moved her thong panties to one side and began stroking her clitoris said commented how hard my clit was He then inserted two fingers in her vagina and was stroking her within her vagina She tried pulling back to pull out his fingers from within her vagina Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her During this time he kept his hand on her vaginal area and continued to rub her vagina.stated he rubbed her really hard as he was masturbating fl said he climaxed onto the towel he had been previously wearing and got up from the table Epstein told her there was dollars for her on the dresser within the master bathroom Epstein also told her that there was an additional that was to be given to WBfor bringing her there to massage him Epstein told her to leave her telephone number with his assistant as he wanted to see her again Epstein stated his assistant would contact her to work again soon I asked her if she ever received any formal massage training to which stated she did not stated it was the only time she ever went to work for Jeff and knew what happened to her was wrong She further stated that she had never been contacted for any additional work On January located and interviewed another victim dob IBHB Pwas identified as a potential victim/witness from information obtained during trash pulls from Epstein 2s residence Ostated she met Epstein when she was fifteen years of age She was approached by a friend from HHU HHMBB to be taken to Jeffrey Epstein 2s house to work She was originally told she would be able The foregoing instrument was sworn to or affirmed before me this ls day of May by Det Joe Recarey who is personally known to me State ofFlorida County of Palm Signature of Polide Officer F.S.S SignatureM rresti Date ig Officer Page of CA/Aronberg-0851 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO massage his feet and calves started the massage with the oils Epstein chose ahd rubbed his feet and calves Epstein got off the phone and requested she massage his back as well began bbing his back and got to the small of his back During the rubbing of his back Epstein asked her to get co fortable He requested she remove her pants and shirt removed her shirt and pulled her pants off stayed in her bra and thong panties As she finished massaging the small of Epsteins back he then turned onto his back Epstein instructedla to rub his chest and pinch his nipples As she began to rub his chest Epstein asked her questions about herself remembered telling him she Epstein asked her if she was sexually active Before9could answer he also asked what sexual position does she enjoy stated she was shy and didnt like talking about those things She continued rubbing his chest Epstein reached up_ and unsnapped her bra from the front aexplained the bra she used had a front snapping device Epstein rubbed her breasts and asked her if she like having her breasts rubbed said no I dont like that Epstein then removed his towel and laid on the bed naked exposing his penis to He began touching his penis and masturbated as he touched her breasts explained Epstein then touched her vaginal area by rubbing her vagina with his fingers on the outside of her thong panties tensed up and stated Epstein was aware that she was uncomfortable stated that Epstein said to her Relax Im not goinginside She further explained Epstein commented to her how beautiful and sexy she was Epstein then moved her thong panties to one side and began stroking her clitoris said He commented how hard my clit was He then inserted two fingers in her vagina anq was stroking her within her vagina She tried pulling back to pull out his fingers from within her vagina Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her During this time he kept his hand on her vaginal area and continued to rub her vagina stated he rubbed her really hard as he was masturbating 9said he climaxed onto the towel he had been previously wearing and got up from the table Epstein told her there was dollars for her on the dresserwithin the master bathroom Epstein also told her that there was an additional that was to be given or bringing her there to massage him Epstein told her to leave her telephone number with his assistant as he wanted to see her again Epstein stated his assistant would contact her to work again soon I asked her if she ever received any formal massage training to which-stated she did not stated it was the only time she ever went to work for Jeff and knew what happened to her was wrong She further stated that she had never been contacted for any additional work On January I located and intervi wed another victim,_ dob 9was identified as a potential victim/witness from information obtained during trash pulls from Epsteins residence stated she met Epstein when she was fifteen years of age She was approached by a friend from to be taken to Jeffrey Epsteins house to work She was originally told she would be able The foregoing instrument was sworn to or affirmed before me this day of May by Det Joe Recarey who is personally known to me CA/Aronberg-0851 State of,Florida FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO __ to model lingerie for a wealthy Palm Beacher was taken to Epstein 2s house located on El BrilloWay introducedBBto Jeffrey Epstein Epstein had his personal chef prepare dinner foiiMandflHB At the conclusion of dinner and Epstein broughl upstairs into a master bedroom area observed a large massage table with a sheet on it Epstein entered through a door and exited wearing only a towel MH informedBBthat they were going to provide a massage on Epstein asked why were they doing this instead of modeling lingerie explained toWBthat this was his routine and to rub his calves and feet Epstein had toldf to get comfortable removed her pants and blouse stated she stayed only in panties as she did not wear a bra that evening stated while rubbing his calves and feet Epstein turned over onto his back Epstein told Bto rub his chest and rub his nipples stated that as she started rubbing his chest Epstein began masturbating himself Epstein touched her breasts and stroked her vagina with his fingers Epstein continued to masturbate himself as he stroked her vagina Epstein ejaculated on his towel and paid Bb for the massage Epstein told that if she told anyone what happened at his house that bad things could happen BBand BI Bwere brought home by Epstein 2s houseman and was afraid that Epstein knew where she lived bstated that several days later she received a telephone call from Sarah Kellen who coordinated for return to 223work BRreturned to the house and was brought to Epstein 2s bedroom area by Sarah who prepared the room for the massage Epstein entered the room wearing only a towel Epstein had B-emove her clothing and provide the massage naked BBbegan rubbing his feet and calves and Epstein turned over onto his back Epstein rubbed her vagina with his fingers Epstein began to masturbate himself with an upwards and downward motion on his penis Epstein continued to touch her vagina with one hand and masturbate with the other hand Once Epstein ejaculated onto the towel he was wearing the massage was over BBwas paid for the massage Epstein again toldBBnot to speak of what happened at his house or bad things would happen wanted to notify authorities however she was afraid of what would happen to either her or her family During the course of the investigation several subjects were identified as a potential witness/victim through information obtained during the trash pulls physical surveillance and telephone message books retrieved from the search warrant While conducting research on the subjects I discovered that the females were age eighteen or older Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to 223work for Epstein The females would be notified by Sarah Kellen and made appointments for the females to 223work for Epstein The females would come to Epstein 2s house and were led upstairs through a stairwell from the kitchen area by Sarah Kellen to Epstein 2s bedroom Epstein would then enter the room wearing only a towel and ask them to get comfortable The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this Is day of May by Det Joe Recarey who is personally known to me State of Florida County 243Palm each Officer Signature of Police Officer F.S.S Date Page CA/Aronberg-0852 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO to model lingerie for a wealthy Palm Beacher ewas taken to Epsteins house Iodated on El Brillo Way introduced-to Jeffrey Epstein Epstein had his personal chef prepare dinner fo:rtlltand At the conclusion of dinner Epstein brough pstairs into a master bedroom area bserved a large massage table with a sheet on it Epstein entered through a door and exited wearing only a towel infonned that they were going to provide a massage on Epsteintaasked why were they doing this instead of modeling lingerie 225explained tolathat this was his routine and to rub his calves and feet Epstein had told get comfortable removed her pants and blouse estated she stayed only in panties as she did not wear a bra that evening stated while rubbing his calves and feet Epstein turned over onto his back Epstein told 9to rub his chest and rub his nipples tated that as she started rubbing his chest Epstein began masturbating himself Epstein touched her breasts and stroked her yagina with his fingers Epstein continued to masturbate himself as he stroked her vagina Epstein ejaculated on his towel and paid for the massage Epstein told a that if she told anyone what happened at his house that bad things could happen taand brought home by Epsteins houseman andlawas afu that Epstein knew where she lived.-stated that several days later she received a telephone call from Sarah Kellen who coordinated for to return to work ereturned to the house and was brought to Epsteins bedroom area by Sarah who prepared the room for the massage Epstein entered the room wearing only a towel Epstein had--emove her clothing and provide the massage naked aabegan rubbing his feet and calves and Epstein turned over onto his back Epstein rubbed her vagina with his fingers Epstein began to masturbate himself with an upwards and downward motion on his penis Epstein continued to touch her vagina with one hand and masturbate with the other hand Once Epstein ejaculated onto the towel he was wearing the massage was over was paid for the massage Epstein again toldlfnot to speak of what happened at his house or bad things would happen wanted to notify authorities however she was afraid of what would happen to either her or her family During the course of the investigation several subjects were identified as a potential witness/victim through information obtained during the trash pulls physical surveillance and telephone message books retrieved from the search warrant While conducting research on the subjects I discovered that the females were age eighteen or older Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to work for Epstein The females would be notified by Sarah Kellen and made appointments for the females to work for Epstein The females would come to Epsteins house and were led upstairs through a stairwell from the kitchen area by Sarah Kellen to Epsteins bedroom Epstein would then enter the room wearing only a towel and ask them to get comfortable The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this st day of May by Det Joe Recarey who is personally known to me CA Aronberg-0852 County Signature/Ar I Date Officer FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO I_ their vaginal area He would masturbate during the massage and upon his climaxing the massage would end The girls were then paid two or three hundred dollars for the massage On November I interviewed Jose Alessi a former houseman for Jeffrey Epstein Alessi stated he was employed for eleven years with Mr Epstein from approximately through Alessi stated he was the house manager driver and house maintenance person It was his responsibility to prepare the house for Epstein arrival When asked about cooks or assistants Alessi stated they traveled with Epstein on his private plane I asked Mr Alessi about the massages that have occurred at Epstein 2s home Alessi stated Epstein receives three massages a day Each masseuse that visited the house was different Alessi stated that towards the end of his employment the masseuses were younger and younger When asked how young Mr Alessi stated they appeared to be sixteen or seventeen years of age at the most The massages would occur in Epsteins bedroom or bathroom He knew this because he often set up the massage tables I asked if there were things going on other than a massage Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis which were in the sink after the massage Additionally he stated the bed would almost always have to be made after the massage On January I interviewed another former houseman Mr Alfredo Rodriguez During a sworn taped statement Mr Rodriguez stated he was employed by Jeffrey Epstein for approximately six months from November through May of His responsibilities as house manager included being the butler chauffeur chef houseman run errands for Epstein and provide for Epsteins guests I asked Rodriguez about masseuses coming to the house Rodriguez stated Epstein would have two massages a day Epstein would have one massage in the morning one massage in the afternoon everyday he was in residence Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epstein would meet with them Rodriguez stated once the masseuses would arrive he would allow them entry into the kitchen area and offer them something to drink or eat They would then be encountered by either Sarah Kellen or Epstein They would be taken upstairs to provide the massage I asked Rodriguez if any of the masseuses appeared young in age Rodriguez stated the girls that would come appeared to be too young to be masseuses He stated one time under Epsteins direction he delivered a dozen roses to HtaHH Mbfor one of the girls that came to provide a massage He knew the girls were still in high school and were of high school age I asked Rodriguez about the massages He felt there was a lot more going on than just massages He would often clean Mr Epsteins bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor He also said he would wipe down the vibrators and sex toys and put them away in an armoire He described the armoire as a small wood armoire which was on the wall close to Epsteins The foregoing instrument was sworn to or affirmed before me this 1st day of May by Det Joe Recarey who is personally known to me Signature of Police Officep F.S.S State of Florida County of Pdlm ach Signature/Arrmtihg Officer Date iWo I Page2 0f CA/Aronberg-0853 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO their vaginal area He would masturbate dwing the massage and upon his climaxing the massage would end The girls were then paid two or three hundred dollars for the massage On November I interviewed Jose Aessi a former houseman for Jeffrey Epstein Alessi stated he was employed for eleven years with Mr Epstein from approximately through Alessi stated he was the house manager driver and house maintenance person It was his responsibility to prepare the house for Epstein arrival When asked about cooks or assistants Alessi stated they traveled with Epstein on his private plane I asked Mr Alessi about the massages that have occurred at Epsteins home Alessi stated Epstein receives three massages a day Each masseuse that visited the house was different Alessi stated that towards the end of his employment the masseuses were younger and younger When asked how young Mr Alessi stated they appeared to be sixteen or seventeen years of age at the most The massages would occur in Epsteins bedroom or bathroom He knew this because he often set up the massage tables I asked if there were things going on other than a massage Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis which were in the sink after the massage AdditionaJly he stated the bed would almost always have to be made after the mas age On January I interviewed another former houseman Mr Alfredo Rodriguez During a sworn taped statement Mr Rodriguez stated he was employed by Jeffrey Epstein for approximately six months from November through May of His responsibilities as house manager included being the butler chauffeur chef houseman run errands for Epstein and pr_ovide for Epsteins guests I asked Rodriguez about masseuses coming to the house Rodriguez stated Epstein would have two massag a day Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epstein would meet with them Rodriguez stated once the masseuses would arrive he would allow them entry into the kitchen area and offer them something to drink or eat They would then be encountered by either Sarah Kellen or Epstein They would be taken upstairs to provide the massage I asked Rodriguez if any of the masseuses appeared young in age Rodriguez stated the girls that would come appeared to be too young to be masseuses He stated one time under Epsteins direction he delivered a dozen roses for one of the girls that came to provide a massage He knew the girls were still in high school and were of high school age I asked Rodriguez about the massages He felt there was a lot more going on than just massages He would often clean Mr Epsteins bedroom after the alleged massages and would piscover massagers/vibrators and sex toys scattered on the floor He also said he would wipe down the vibrators and sex toys and put them aw in an armoire He described the annoire as a small wood armoire which was on the wall close to Epsteins The foregoing instrument was sworn to or affirmed before me this l5 day of May by Det Joe Recarey who is personally known to me Signature of PoHOffice CA/Aronberg-0853 State of Florida County Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO bed On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to so that she could drive her self to Epsteins house without incident Rodriguez said the girl always needed rides to and from the house Rodriguez produced a green folder which contained documents and a note with Mr Epsteins stationary with direction to deliver a bucket of roses to after high school drama performance Also in that same note was direction to rent a car for flband direction to extend the rental contract During the course of the investigation subpoenas were obtained for cell phone and home phone records from several victims and witnesses along with the cell phone records of Sarah Kellen An analysis of these records was conducted which found numerous telephone calls were made between Sarah Kellen and the victims These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted Specifically The phone records showed Kellen called Haley Robson during the exact times and dates when victimflbadvised the incident occurred Kellen also coordinated the encounters withflflW WflB MB,during the time frame the girls stated they occurred Pursuant to a lawful subpoena I obtained Epstein 2s private plane records for from Jet Aviation The plane records show arrival and departure of Epstein 2s plane at Palm Beach International airport These records were compared to the cell phone records of Sarah Kellen This comparison found that all the phone calls Kellen made to Robson and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach Jeffrey Epstein who at the time of these incidents was fifty one years of age did have vaginal intercourse either with his penis or digitally with Ml Ml and who were minors at the time this occurred and who at the time of the incident was fifty two years of age did use a vibrator on the external vaginal area of a fourteen year old minor Therefore as Sarah Kellen coordinated and aided in the recruitment of minors to frequent Epstein 2s house so that sexual services were provided to Epstein scheduled the said minors to return to the work for Epstein secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors there is sufficient probable cause to charge Sarah Kellen with four counts of Principal in the 1st degree Unlawful Sexual Activity with a Minor in violation of Florida State Statute a second degree felony and there is sufficient probable cause to charge her with Lewd and Lascivious Molestation in violation of Florida State Statute a second degree felony The foregoing instrument was sworn to or affirmed State of Florida before me this day of May by County fPalm Beach Det Joe Recarey who is personally known to me YMm Signature/Arr snng Officer Signature of Poli Officer F.S.S Date Page of CA/Aronberg-0854 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Probable Cause Affidavit Palm Beach Police Department Agency ORI FLO bed On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to so that she could drive her self to Epsteins house without incident Rodriguez said the girl always needed rides to and from the house Rodriguez produced a green folder which contained documents and a note with Mr Epsteins stationary with direction to deliver a bucket ofroses to after tllhigh school drama performance Also in that same note was direction to rent a car for 9and direction to extend the rental contract During the course of the investigation subpoenas were obtained for cell phone and home phone records from several victims and witnesses along with the cell phone records of Sarah Kellen An analysis of these records was conducted which found numerous telephone calls were made between Sarah Kellen and the victims These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted Specifically The phone records showed Kellen called Haley Robson during the exact times and dates when victim dvised the incident occurred Kellen also coordinated the encounters and during the time frame the girls stated they occurred Pursuant to a lawful subpoena I obtained Epsteins private plane records for from Jet Aviation The plane records show arrival and departure of Epsteins plane at Palm Beach International airport These records were compared to the cell phone records of Sarah Kellen This compariso found that all the phone calls Kellen made to Robson and the victims were made in the days just prior to their arrival or during the time Epstein inP Jeffrey Epstein who at the time of these incidents was fifty one years of age did have vaginal intercourse either with his penis or digitally with and who were minors at the time this occurred and who at the time of the incident was fifty two years of age did use a vibrator on_ the xtemal vaginal area of a fourteen year old minor Therefore as Sarah Kellen coordinated and aided in the recruitment of minors to frequent Epsteins house so that sexual services were provided to Epstein schedul the said minors to return to the work for Epstein secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors there is sufficient probable cause to charge Sarah Kellen with four counts of Principal in the l5 degree Unlawful Sexual Activity with a Minor in violation of Florida State Statute a second degree felony and there is sufficient probable cause to charge her with Lewd and Lascivious Molestation in violation of Florida State Statute a second qegree felony The foregoing instrument was sworn to or affirmed before me this JS day of May by Det Joe Recarey who is personally known to me Signature of PoHeOffic F.s.s Page_z CA/Aronberg-0854 State of Florida County Palm Beach Signatu ng Officer I I Date FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Appendix CA/Aronberg-0855 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CA/Aronberg-0855 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i INDICTMENT ATRUE BILL IN THE NAMEOF AND BY THE AUTHORITY OF THE STATE OF FLORIDA IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OE THE STATE OF FLORIDA For Palm Beach County at the Spring Term thereof in the-year of our Lord Two Thousand and Six to-wit TheGrandjJurors of-ttie.StaJeof Florida inquinngJmand or the/body of said County of PalrruBeach ypon their paths do present that JEFFREYS EPSTEIN in theCounty of Palm 221Beach aforesaid in the Circuit and State aforesaid COUNT ONE FELONY SOLICITATION OF PROSTITUTION dnor abOLitfor betweerrthe IsLday of August inthe-year oLour Lord Two Thousand and Four and October solicit;.induce,pentice;.wprocure another to commit prostitution lewdness or assignation contrarysto Florida Statute on three or more occasions;between August and October contrary to Florida Statute and DEG FEL LEVEL I I against the.fprm of the statute to the evil example of all others and against the peace and dignity of the State of Florida i I 2herebyicertify that I have advised the Grand Jury returning this indictment as authorized and required by law Assistant state Attorney of thep Fifteenth Judicial Circuit of the State ofElorida;-;prosecutingdor:the said State 2i i I GRAND JURY.:FQREPERSON c"vF DATE Jeffrey Epstein Race White,?Sex 221Male DOB January SS Issue Warrant Page42 of Public Records Request No CA/Aronberg-0856 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i l1 i i i ij 1N?THE NAMEi0 ANO JliE A,UTHORITYt"OE,.THE,STAT:EiOFrFllORIDA e.tti __ i i 267qqltra,ty tq:fl_qfi_ atu_tij,J 0J i;i 1T D5 J.t i,s i,ti iit iir Qj i iif ii plt tQit 6t 260gl!lD i,lfi?i 1il1 1tt.r 9f fif I I I Ji ffebyii ctl1:itb,iiJ:iHb,e lcfy1 if iH iG,t fy/rjjyglnfJ ij i r:ist H!if tJl 9i ti ft RAND Jl.JBYJEORERERS6r-.f I i gst;rq,,ijacef Whi jSex:;M ie;00Eic.Jan iiO,J fiSSli n1 Page PubHc Rec rds Request No __ ac a CA/Aronberg-0856 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM IN THE CIRCUI JOURT OF THE FIFTEENTH JUDI XL CIRCUIT IN And for palm beach county Florida criminal division COURT CASE NO AGENCY CASE NO INVESTIGATING OFFICER NAME TO ALL SHERIFFS OF THE STATE OF FLORIDA YOU ARE COMMANDED TO ARREST AD RESS TBUSINESS?ADDRESS:T Ll_2Li __ MIRAGE HAIR eye BUSINESS DOB I i HEIGHT _SSil_K WEIGHT G2 Us FORAPPEARANCE a FCIC i NCIC x1 of i EXTRADITION AUTHORIZATION YES NO This capias is issued pursuanfto an,informatiori liled by the.State Attorney,sFifteenthJudicial.Circuit Palm Beach County Flonda APPEARANCE BOND set by Court Order per bondjschedule WITNESS my hand and the seal oMhls Court on this of I ARREST WARRANT BAIL ENDORSEMENT The defendant is to be admitted to bad in Me sum of K"Fer schedule OWN RECOGNIZANCE OTHERS_ returnable to this Court on the third Friday following the date ol arrest at A.M before the Judge assigned Ihe case SEAL DOROTHY WILKEN bLERKpF COURT GIVEN UNDER my hand and seal on the day of BY Deputy-Clerk Stalo of Florida SEAL 2at Palm Beach County UUOG 1FTEEIJTH i Executedionthe//L day of by namediv By PBSO 253OOia REV.:lO/95 i.d ritf_-Palm Beach fe Records Request NoS a CA/Aronberg-0857 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM it i i Jt CA Aronberg-0857 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM yr OBTSNumoer i i i i i I A HX XRRESTi/cNOTlCE-TO ARPEARvX 7v iy 3-2Request tor-Warrant Juvenite Juvenile Referral Report entat Request to Capias i Age ORl Number floZs Zb o,"o Agency Name a PALM BEACH COUNTY SHERIFF 2S OFFICE Agency Report Number i o/6l-l i lwLx-r i UiVlvJ ctSr.1 as;apply Ji LJ Traflic Fokjny T4 Tra!fte Misdemeanor Ortfnance Zb Otrw_ IIWeaponSeUed Ent er Type Mumpie 2Clearance s-i indicator Locafeon otAnost Including Named Business 37ZC ZP YnrP Location of Offense Busmess Name.-Address Date of arrest ax yO uV Time Of AttMT 6rU Booking Date Booking Time Jamaals Ja Tune1 Localton ot vehicle UJ Nairn Las MHMH Alias Nama OOB Soc Sac Ele Lz W-r/r ZZk _2 Race American Indian i B-Black OnentaVAslan Sex Dele otiBirth Height Weight Hain Color Comptexion Quito Seats MarX5?.TaloM Un Physkaj Features locdw.?Typc.8Descnpnonh-v a Mental Status Religion cr Indication ct A Unk5 Alcohol inftoence iiDrug mnuenco Uj Local Address Street Apt Number tXk Slate Zip Tz ft rtf a A Az Phone Residence Type rcityt Ftoiida5 i County Ou of Stale Permanent Address fStreet.:Apt.-.Nurnoer Ctfy State fr7t fi-rO Phona Address Source I Business Address Name7 Street City State Zip 2lA Phone rK i Occupation D/k Number state Soc Sec Number INS Number Ptace of Binn Cny Stale CrtiSonahtpc 7a UJ CODefendantNama LasuFirstjMtddle Race Sex Date of Bsrth Arrested Fetony Qt2.W.Urge Oi Misdemeanor A Race Sea Date el Birth i Jt t-Arrestod Felony S-Z AtiLarge DiarMtsdemeonorz GS Juvenite UJ rj.Pwanl Name Last Middle 4T 2Legal CusUxhan.j ChfSr Residence Phone i A Addiass Suaei Api Numtei 2A CoYb 2l/XJ Stalo Ze jv Busrncss,Phono Notitled by Name cA a r.A Trmo Juveroie Dtsposibdnr HAndlodrprocessad within 221HRS/DYS Dept end Reteasod incarcerated Released To Name 227Rfflat 2onship a ZS a Ki eaA a Time The abova-addiesswaspqYidM twiO dalandanranqVorG ddlendant parana 2qwkl and/jor rent was lold keep The Juvenile Coun 2Clerk Once Phone inlormed ol any change oladdress Yas by Name CNo Reason SchooLAnendod j/w I Grade tx i PfOpenyCrkms7.il Description cfPropertyr i EYes G3no xJ vv T-y Value of Propeny 2V UJ Orug ActivttyA SeU R.-Smuggles MCOwponso Manuiacturtfv Z-Olher Nihi BLBuy D50eliver:f tDrsirtbute ftfOducW,:Y Posaoss E?Um A Cultivate BiBarplUiwe I PxPaiaphBrnaliaA U.-Unknown NWAX Cocaine Maryuana Eeuipmont Other A.-Amphetamine Herptn i OrOprum/Denv S/.Syntnatic ul a Charge Description fa a Counts Domestics Vloldncoy ON Statute Violation Number fL Violate of.ORD Drug ActrntylDrug TypeXl-Amount Unrtr Offense mb UJ a Charge Doscripton xCcuntsr Domestic Violence CY ON sSuHvte-V 2735Mavon:Num ys I II ORDe Drug Activity Drug 2.Type l.Amount f.Untb I I AOHonsei Warrant/Cap a Number UJ I Charge Description cCounts Domestic Violences CN Slaws Violation Number l-l i KI Violation of i Drug Activity Drug Typo Amount UmU iQHense a warrant iCagAas Number UJ cr Cnaige De cnpton Counts Domestic violence DY CN SlBtut Viot3tiQn.Ni nber Jt II i KI i i xk lViotation ol ORO Drug Acuviiy Drug-Type I Amount Unit Offense i-Warrani Capias-Numbor a I UJ Location Court,Room Number Address Coun Date and Timor Month Day Year Time rAGRFE TO PPEAR ATiTHE-TIME 2ANO PLACeiDESK3NAT6D JO ANSWERSTrtE OFFENSE Ci ARGED!OR TO PAY JiUNDERS FAIlMO 2APPEARBEFORE 221TME COURT AS REQUIRED BY 2THlS!NOTIC 200.TOjAPPEAR,.THAT.-l MAY 8E HELO lN CONTEMPT,OF;COURTLAND A.WARRANT iWILLFULLY OR MY ARREST SH4Ll5nE ISSUED i Signaturool Detondanl or.JuvontlOand.P renV Custodian r?y ateSignod NOLDlor.otha 2Agoncyrr Name a _ss.-r Sjgnaiure olArrestingOtticoix UO Name Vefilicanon Prrnled.by Arrestee PRINT a A EL-Dangerous AEh-Reststed Arrest 2iQ SuKidai Other Name.otArrestmg Officer Pr ID i Pxce X-OF_ Rouch J.a orups i 2-OlSTRIBUTlON 2WHITE COURT COPY GREEN STATE ATTORNEY I YELLOW AGENCY PINK AGENCY GOLD-.pEFENDANT N.T.A.?S.ONLY paso i4s 221rev I CA/Aronberg-0858 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ioh1r I_ tfr tl __ tt i Jqurt if i CA Aronberg-0858 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i Appendix CA/Aronberg-0859 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CNAronberg-0859 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case ocument Entered on FLSD Docket Paqe of IN RE INVESTIGATION OF JEFFRE EPSTEIN __ NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney 2s Office for the 15th Judicial Circuit in and for Palm Beach County hereinafter the 223State Attorney 2s Office have conducted an investigation into the conduct of Jeffrey Epstein hereinafter 223Epstein IT APPEARING that the State Attorney 2s Office has charged Epstein by indictment with solicitation of prostitution in violation of Florida Statutes Section IT APPEARING that the United States Attorneys Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein 2s background and any offenses that may have been committed by Epstein against the United States from in or around through in or around September including knowingly and willfully conspiring with others known and unknown to commit an offense against the United States that is to use a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Section all in violation of Title United States Code Section knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females in violation of Title United States Code Section all in violation of Title United States Code Section using a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Sections and traveling in interstate commerce forthe purpose of engaging in illicit sexual conduct as defined in US-C with minor females in violation Page of i i i CA/Aronberg-0860 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Entered on FLSD Docl et of f-,t Att I I INRE INVESTIGATION OF JE YEPStEIN N_QN PROSECJJDON AGREEMENT IT APPEARING that h_e ty lz Beach Police Department i and th State Attorneys Office for the ISthJud1c11il Crrcwt and,for Pa,lrn l3eacll Co1JI1ty here1IU1.fter the State Attorneys Office h11ve ce nd 265cted an investigation into the conduct of Jeffrey Epstein hereina.fler ijpstein ITAJ PEARIN_G at the State Attorneys Office has charged Epstein by indictment with solicitation of prostitution in violation ofFlorid11.StaMes Sectio11 ITAPPEARING that the United States Attorneys Office and the fed al Bureau of Investigation have conduct thei_r own investigation into Epsteins background and any offenses that may have been committed by Epstein againstthe United Sta from in or arouaj I through in or around September includin i I knowingly and w_illf illy 267conspiring with others known an wikn:own t9 CA/Aronberg-0860 cornmit an offense against the Unite:d States that is fa ijity or means ofinterstilte or foreign COlCICe to knowingly induce or entice minorJCIIl!Ue to engage iJtprostituiion inviolation:ofTitle 18;Unite,d States Code Section aUin violation ofTitle United States;Code Section I knowiogly and Vi fully conspiring with others knowp and unkpovm to travel in interstate commerce for the purpose of engaging in illicit sexual conduct as 267qef ed S.C with minor females in violation-of Title United States Code Section all in violation ofTitlc s;United States Code Section ing facility or meaiill of ihterstate or foreign commerce tc lrnowingly pefstiad induce lf e.JttiCe minor females to engage ifi pfOStitutioii in violation of Title Unit States Code Sections and I I traveling in il rstate commerce for the purpose of engaging ip illicit sexual conduct as defined in U.S.C with minorfemale,s in violation Page I of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I I i Case ocument Entered on FLSD DoJ Page of i of Title United States Code Section and knowingly in and affecting interstate and foreign commerce recruiting enticing and obtaining by any means a person knowing that the person had not attained the age of years and would be caused to engage in a commercial sex act as defined in U.S.C in violation of Title United States Code Sections a and and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that in exchange for the benefits provided,by this agreement he agrees to comply with its terms including undertaking certain actions with the State Attorney 2s Office IT APPEARING after an investigation of the offenses and Epsteins background by both State and Federal law enforcement agencies and after due consultation with the State Attorney 2s Office that the interests of the United States the State of Florida and the Defendant will be served by the following procedure THEREFORE on the authority of Alexander Acosta United States Attorney for the Southern District of Florida prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below If the United States Attorney should determine based on reliable evidence that during the period of the Agreement Epstein willfully violated any of the conditions of this Agreement then the United States Attorney may within ninety days following the expiration of the term of home confinement discussed below provide Epstein with timely notice specifying the conditions of the Agreement that he has violated and shall initiate its prosecution on any offense within sixty days of giving notice of theviolation Any notice provided to Epstein pursuant to this paragraph shall be provided within 60days ofthe United States learning of facts which may provide a basis for a determination of a breach of the Agreement After timely fulfilling all the terms and conditions of the Agreement no prosecution for the offenses set out on pages and of this Agreement nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney 2s Office nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District and the charges againstEpstein if any will be dismissed Page of i i I CA/Aronberg-0861 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM _Entered on FLSD I Pa,ge of oftitle United States Code Section and knowingly i_n and affecting interstaJe and foreign commerce recruiting enticing and obtaining by any a person knowing that the person had not attained the age of 267years and would be caused to engage in a com _ercial sex lCtas defmed in U,S.C IS91 in violation ofTitle United State CC i_e Sectiqns a and 2;,and iT APPEARING thatEpsteinseeks resolve globallyhis sta and federal criminal liability and Ep11tein llnderstan,ds and acknowledges that in exchange for the benefits provided,by tl agreement he agrees to cotnply with its terrns mcludi tmQ rtak.ing cer_tain actions with the State Attorneys Office i:r APPEARING after aniovelltigatjon of the offenses and Epsteins background by both State and Federal law enforcement agencies and after due consultation with the State Attorneys Office the interests of ihe United St,ates the State of Fl9rid!I and the Dc en hlnt will be served by thc Qllowing procedure THEREFORE on the authority of R.Alexander Acosta United,States Attomeyfor th Southern District of FJorid!l prosecution jn this District for these oft-:nses shJl be deferred inf11.vor of prosecution by the State.ofFiorida provided that Epstein abides;by the following conditions and tl1e requirements ofthis Agreement setforth below If the United SJates Attorney should determine qased:on reliable evidence that during the period of the Agreement F;pstein willfully vioiated a:ny of the d.itions of this Agn;cment then the Unite.d States Attorney may within ninety days following the e,q,iratlop of tenn of home confmement discussed below provide;Epst in with timelr notice specifying the condition of the Agreement illathellas yi,9la 1dshall initiate its prosecution.on any offense within sixty daysof giving notice oftheviolation Any notice provided to Epstein pursuant th.is paragraph shal I oe tOvide:d _withiri60 dJiys of the United States leamirtg of facts which may provide a basis for a detcnnination of a breach of theAgreernerit After timely fulfilling all the terms and conditions of the Agreement ho prosecution for the offenseoet qn pages I 267and of this Agreement nor any qther off i that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States.t ttomcys Office nor aliy offenses that arose from the Federal Grand Jury inve,sijgation.will be instituted i11.tliis District and the charges against Epstein if any will be dismissed Page 2of CA Aronberg-0861 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case uocument Entered on FLSD Docket Page of Terms of the Agreement Epstein shall plead guilty not nolo contendere to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach Comity Case No charging one count of solicitation of prostitution in violation of Fl Stat In addition Epstein shall plead guilty to an Information filed by the State Attorney 2s Office charging Epstein with an offense that requires him to register as a sex offender that is the solicitation of minors to engage in prostitution in violation of Florida Statutes Section Epstein shall make a binding recommendation that the Court impose a thirty month sentence to be divided as follows a Epstein shall be sentenced to consecutive terms of twelve months and six months in county jail for all charges without any opportunity for withholding adjudication or sentencing and without probation or community control in lieu of imprisonment and Epstein shall be sentenced to a term of twelve months of community control consecutive to his two terms in county jail as described in Tenn a supra This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney 2s Office and Epstein the details of which are set forth in this agreement The terms contained in paragraphs and supra do not foreclose Epsteinand the State Attorney Office from agreeing to recommend any additional charge or any additional term of probation and/or incarceration Epstein shall waive all challenges to the Information filed by the State Attorney 2s Office and shall waive the right to appeal his conviction and sentence except a sentence that exceeds what is set forth in paragraph supra Epstein shall provide to the U.S Attorneys Office copies of all Page of I CA/Aronberg-0862 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case OCUl lent Entered on FLSD I Page of CA Aronberg-0862 I I I Terms of the ment i I Epsteip sllall plead guilty not ne lo qontendere to the Indictment as currently pending against him in the 15th Judicial Circuitin and for Palm B.eac:h C::oU!ity Case No 5AXMB charging OC IJ count of solicitation of pro!!titution in yiolatipr;i of Pl Stat In addition Epste_in ball plead guilty to ari lnfonnlition filed by the State Attotneys,Office charging Ep ill with offe_!lse thilt requires hiin to register a sex offender that is the 267solicitation of mine rs to engage in prostitution in violation ofFlorida Stat 265tes Section Epstein shall make a iildi.ng recommcmdaiioifthat the Court impose a thirty mon1h sentence.to oe divided as foll.ows a bj Epstc::iD shall be 225sentenced to consecutive tem softwelye J2 months and six months iri CQuntyjaiHor aH charges without anyo?PQrtllnity forwithholdirig adjudication or sentencing and witljout probation cpmrouni_ty control in lieu of itnprisonment,:and Epstein shall be sentenced to a term oftWelve IJl,pnths of comniunitycontrol consecutive to his two tcnns iricoi.intyjall as described in Tenn a supra This agreemc:ntis ce ntingent upon a Judge of the 15th Judicial Circuit a cepting and executing the senteric1e agreed upon be 245een the State Attorneys Office and Epstein the details of whicl are st:t rth in-t is agreexnent The rms contained in paragraphs I supra do not foreclose Epsteut and the State Attorneys Oflit 243from ag eeing lo reconunend llilY 11dditional charge or any additi nal t!7ID of pr batiori and/or incarceration Epstein sha.U v,,aiv all challengcs the Informiltion.fili by the Attorneys Office and shall waive the 225Jigbt to appea his conviction and sentet1ce ex pt a sentence that exceeds what is set forth in paragraph supra Epstein shall provide to the U,S Attorneys Office 267copies of all PageJ of7 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case ocument Entered on FLSD DoJOfOG Page of proposed agreements with the State Attorney 2s Office prior to entering into those agreements The United States shall provide Epsteins attorneys with a list of individuals whom it has identified as victims as defined in U.S.C after Epstein has signed this agreement and been sentenced Upon the execution of this agreement the United States in consultation with and subject to the good faith approval of Epstein 2s counsel shall select ah attorney representative for these persons who shall be paid for by Epstein Epstein 2s counsel may contact the identified individuals through that representative If any of the individuals referred to in paragraph supra,elects to file suit pursuant to U.S.C Epstein will not contestthe jurisdictionof the United.States District Court for the Southem Disttict ofFlonda overh is person and/or the subject matter and Epsteinwaives his right te contest liability and also waives his right to contest damages up to ah amount as agreed to between the identified Individual and Epstein so long as the identified individual elects to proceed exclusively under U.S.C and agrees to waive any other claim for damages whether pursuant to state federal or common law Notwithstanding this waiver as to those individuals whose names appear on the list provided by the United States Epstein 2ssignature on this agreement his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability Epstein 2s signature on this agreement also is not to be construed as an rimission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States Except as to those individuals who elect to proceed exclusively under as set forth in paragraph supra neither Epstein 2s signature.on this agreement nor its terms nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whether or not her name appears on the list provided by the United States Epstein shall use his best efforts to enter his guilty plea and be Page of CA/Aronberg-0863 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case 9:08,cv;.;80736-KAMttocument Entered on FLSD Pqg_e of IL CA Aron I I proposed agreements with the State Attorneys Office prior enterj_ng i.rlto those;agreerilerits The United States shall provide Epsteins attorneys 225with a list of individuals vih01 It has identified as victims as defined in U.S.C after Epstein has signed this agreement J,een ntenced Upon the execution of 1his agi:eemerit the United States in consultation with IIld subjectto the good faith:approval ofEpsteill counsel shall select an attorney representative for these persons who shall be paid for by Epstein Epsteins counsel may contact thcfidentifi cf individlJ!lls througll that representative lf:any.:of_lfi i;di_vidual_s:referred to in pajagrapll SUJlrq i file sult.PIJ,SUIUlt Jo ct te_iri Liiot_,i;_on ibe jurisdictioh:ofthe United StatesDistrictCouri for the SouthemOistrict qf;f_i9 j:v,if;hj pi rs and/oJthe subjeH att iuJd EJ ie iic his rigltfiocontest liability imchlso waives tilifJigbl C9ntesi 225ies up to ail amoW1t as agreed to between the identified individual and Epstein so long as the 267identified incljviduaJ elec to proceed exch,1siv 1lY under U.S.C 1:1,grec to waive any other claim for damages,whethcr pursuantto state federal or common law l-lotwithstandirig this waiver as to those irulividuals-whose names appear on th list provided by the United States Epsteins signat on 267tJus agreement his waivers and failw-es to contest liability and such damages in-any are not to be constnied as an adIDission of any crit;rlihal or,,civi li oHity Epsteins signature on this agreemen..t also is notto be construed as an admission of civil or criminal liability ora wai er of anyjuri!l iictio_nal Qr other defense as to any person whose does 267not appear-on the listprovided by the United States Except es to those in ilviduals who,elect t9 proceed exclusively under fs asset.forth in parag,raplf supra i erEpsfi ins signature.on this agreetnent nor its terms nor anyresulting waiv.ersor settlements by Epstein are to be construed as aWI issjonsor evidence of civil or crimin liabiHty or a waiver of any jurisdictional or other defense as to arty person whether or noi her n_ame appears on the list provid by the United States Epstein shell use his est efforts to enter his guilty pl and:be Page of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case ocurnerit Entered on FLSD Do Page of not later than October The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January Epstein agrees that he will not be afforded any benefits with respect to gain time other than the rights opportunities and benefits as any other inmate including but not limited to eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida At the United States request Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration The parties anticipate that this agreement will not be made part of any public record If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement it will provide notice to Epstein before making that disclosure Epstein understands that the United States Attorney has no authority to require the State Attorney 2s Office to abide by any terms of this agreement Epstein understands that it is his obligation to undertake discussions with the State Attorney 2s Office and to use his best efforts to ensure compliance with these procedures which compliance will be necessary to satisfy the United States interest Epstein also understands that it is his obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein 2s binding recommendation regarding the sentence to be imposed and understands that the failure to do so will be a breach of the agreement In consideration of Epstein 2s agreement to plead guilty and to provide compensation in the manner described above if Epstein successfully fulfills all of the terms gnd,conditions of this agreement the United States also agrees that it will riot institute any criminal charges against any potential co-conspirators of Epstein including but not limited to Sarah Kellen Adriana Ross Lesley Groff or Nadia Mareinkova Further upon execution of this agreement and a plea agreement with the State Attorney 2s Office the federal Grand Jury investigation will be suspended and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of thw agreement The defendant likewise agrees to withdraw his pending motion to intervene and to qyash certain grand jury subpoenas Both parties agree to maintain their evidence specifically evidence requested by or directly related to the grand jury subpoenas that have been issued and including certain computer equipment inviolate until all of the terms of this agreement have been satisfied Upon the successful completion of the terms of this agreement all outstanding grand jury subpoenas-shall be deemed withdrawn Page of CA/Aronberg-0864 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case Emered on FLSD I I sentenced not later y,an October the UnitedjStates bas objection to J;:pstein seJfsreporting to begin rving hls sentence 267not later than January Epstein agrees that.he will not be aff otded.any benefits With respect to gain time c;,iqer than the rights,_opportuniti 1f1d bepefits anyother lDlate including but not liDiited to eligibility for gain time credit 267based ori dard rules and regulations that Elpply the State of Flonda A_t the United States request Epstein agrees to provide an acc Witing of the gaiQ time he earned during his 267period of n:icarceration Theparties anticipate that this agreement will i:ie be made part of any public record If the United States receives a Freedom oflnformation Act request 267ora,ny Illp 265lsory process commanding the disclos of the agreement it will provide notice to Epstein before making that disclosure 267Epstein widerstands t_hat the United States rney has no authority quire the State Attonteys Office te a.bide by any terms of this agr ent Epstein UlOCistands that itis his obligation to 265ndertake discussions the.State Attomefs Office and to use hi best efforts to ensure 256mpliance with these pioced 265rcs whic compliance will be necessary to satisfy the United Statesinterest Epstein also understands that if is.hisobl_1gation to-use his best efl"orts.to convince the Judge of the 15th Judicial Cir:cuit to acceptEpstein binding mmendation regarding the sentence t9 lxl imposed and understands that the failure to do so will be a breach of the agr ement In e9r1 ideration of Epsteins agreement to plea guilty and to 267provide compensation in the tQanner aescribed ab ye ifEpsteirt successfully fulfills allt fthe tenns _conditi9M of this agreement the United Stat agrees that it will niH institute BilY criminal charges against any potential onspirators ofEpstein incl 265ding but not limited toi Sarah Kelle Adriana Ross Le ley Groff or lf qi Marciftkoya Further upon execution of this agreem nt and a plea agreement with the State Attorneys Office the federal Orand Jury investigation will be suspended and_ all:pending federal Grand Jury subpoenas will be held in abey ce unless and lm,til the defendant violates lY tenn of.this agreement The defendant likewise agrees withdraw pending motion toiniervcn and tq quash certain gr subpoenas Both p!lrties agree to maintain their evidence specifically evidence requested by or cli tly related to 267the gI1U1g jury subpoenas that have bc Jl issu and including certain computer equipment inviolate until all of the terms of this agreement have been satisfied Upon the successful complet on of the terms of this een:ient ell outs ding grandjury subpoenas,shall be deemed withcirawn Page of CA/Aronberg-00O864 Pqge 6of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case ocument Entered on FLSD Dodft Page of I i I By signing this agreement Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect toterminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses By signing this agreement Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial Epstein further is aware that Rule of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment information or complaint for unnecessary delay in presenting a charge to the Grand Jury filing an information or in bringing a defendant to trial Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution as provided for in the terms expressed herein shall be deemed to be a necessary delay at his own request and he hereby waivesany defense to such prosecution on the ground that such delay operated to deny him rights under Rule of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury 2s investigation Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule a of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented,to a grand jury Epstein hereby agrees and consents that if a prosecution against him is instituted for any offense that was the subject of.the grand jury investigation it may be by way of an Information signed and filed by the United States Attorney and hereby waives his right to be indicted by a grand jury as to any such offense Ill Ill iri Page of i i i I CA/Aronberg-0865 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case 80736-KAM.ocumenJ Entered on FLSD I I By signing this agrcemen Epstein asserts and ccrlifi th ach qfthese terms is material t9 this agreement and issupponed;by independent consideration and that a breach of any one of these _conditioll flows United States to elect to terminate _the agreement and to investigate and prosecute Epstein and any other individual qr entity for any and a:JJ fcde offenses By signing this agreemen Epstein asserts a.ild certifies that he is aware of the facttbat the Sixth Amendment to the Constitution lli United States provides that 1n all criminal prosecutiqns the llSed shall enj the right to a speedy and public trial Epstein further aware that Rule oftheFederalRules ofCriminalProce provides thauhe Court may dismiss an indictment,_ info i or mplaint for unnecessary delay in presenting a charg to the Grand Jury filing an.information or in bringing a defendant.to trial Epstein hereby requests that theUnite fStates Attomey for the So 265therqPistrict of Florida defer such prosecutio Epstein agrees and CQnsen any delay from the date of thisAgreemenno ge of the date-of initiation ofprosecuti as providedforin the term_s expressed herein aU be deemed to bl a 267necessary delay at his own request and he hereby waiveiumy defense to such prosecution on the gi und that such:delay operated to deny hiin rights under Rule 4S of the Federal Rules of Criminal Procedure andthe Sixth Amendment to the Constitution of the United States to a trialor to bar-tm:.prosecution by son of the running of the statute of limitations for a period of months equal to the perjO between the s!gning of this agreemc:nt breach of this agreemeI!tas to those offenses that were th subject of the grand jufy investiga,tion Epstein further asserts and etmifies that he understand that the Fifth Amendm and Rule a of.the FederafRules:of Criminal Procedure provide that all f.elon1es must be charged in.an indictment presente:dJo a grand,jqry Ep tein:hereby agrees a.r1d consen that if a prosecution agai him is in ituted fot any offense that was the subJectoftJu gnmdjury_s invt:stigation itInay be by way qfan lnfQIJllation signed and filed by the t.Jnitc_d Sm,te Attorney and 1erebyw i:ves hisriJht.to be indicted by-a grand jury.as to such.offense Page.6of CA Aronberg-0865 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i Case Document Entered on FLSD Docket Page of By signing Ihis agreement Epstein asserts and certifies that the above has been read and explained to him Epstein hereby states that he understands the conditions ofthisNon Prosecution Agreement and agrees to comply with them ALEXANDER ACOSTA UNITED STATES ATTORNEY By A MARIE VILLAFANA ASSISTANT U.S ATTORNEY EPS Dated GERALD LEFCOURT ESQ COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ ESQ ATTORNEY FOR JEFFREY EPSTEIN Pago of CA/Aronberg-0866 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case 9_:08-cv.s8.Q736-KAM4ocument Entered on FLSD Pqge a of i By signing this agreement Epstein assert,und certifies that the ab;o has read and explained to hiDl Epstein hereby states he understands the conditions of this Non Proi.c tion Agreement and a to comply with them Paled CA/Aronberg-0866 By AL.EXANDER ACOSTA UNITED STATES ATTORNEY A MARIEVILLAF A ASSI_STANT U.S ATTORNEY OERALDLEFCOURT ESQ COUNSEL TO JEFFREY 267EPS:rEIN LILLY ANN SANCHEZ ESQ ATTORNEY;FORJEFFREY EPSTEIN Page of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case ocument Entered on FLSD Docket Page of By signing this agreement Epstein asserts and certifies that the above has been read and explained to him Epstein hereby stales that he understands the conditions of this Non Prosecution Agreement and agrees to comply with them ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated __ AMARIE VILLAFAN A ASSISTANT U.S ATTORNEY Dated:_ Dated C7 JEFFREY EPSTEIN feRALDTEFCOtfRTiESQ 221OUNSEL TO JEFFREY EPSTEIN Dated:_ LILLY ANN SANCHEZ ESQ ATTORNEY FOR JEFFREY EPSTEIN Page of CA/Aronberg-0867 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case 9:08-cv,8.0736-KAMttocument Entered on FLSD Do!o Page of I I By signing this agreement Epstein asserts and ccrtitfos that;thc a has read and explained to him Epstein hereby states that he 265nderstands the conditions of:th1s _Non Prosecution Agreement ld agrees to comply withJhym Dated Dated __ Dated Daied CA Aronberg-0867 ALEXANDER ACOSTA NITEDSTATESAITO:RNEY By A MARIE VP:,LAFANA ASSISTANT U.S A TIO Lll,LY ANN SANC_HEZ ESQ ATIORNEY f0 JEFfREY PSTEIN Pago of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I i I I I i I I Case ijocument Entered on FLSD Docket Page of Bv sinning this agreement Epstein asserts and certifies the above has beerread and exSdnSto him EfrsSn hereby states that he understands the conditions of this Non Prosecution Agreement and agrees to comply with them ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated A MARIE VILLAFANA ASSISTANT U.S ATTORNEY Dated JEFFREY EPSTEIN Dated GERALD LEFCOURT ESQ COUNSEL TO JEFFREY EPSTEIN Dated na ANNW Sffi ESQ ATTORNEY FOR JEFFREY EPSTEIN Page of CA/Aronberg-0868 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case cument Entered on FLSO Page of tbts agreement Eps ili assertund certifieBthat th bas read and expl hizii_ Epstein bcrcby states tb.at;hc undetstands the conditions:QfthJS Non Prosec.ution Agreement and agrees to comply with lhc,m Dated Dated D_ated CA/Aronberg-0868 By ALEXANDER ACOSTA t.JN1TED STA ATTO EY A.MARIEVU.LAF ANA ASSISTAllfu:s ATTO JEFfR EPSTEIN GERALD LEFCOURT F.sQ COUNSBL TO mfFREY EPSTBIN ATIORNEY FOR JEFFREY EPSTBll,J Page 7of FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i I Case Document Entered on FLSD Docket Page of IN RE INVESTIGATION OF JEFFREY EPSTEIN ADDENDUM TO THE NON-PROSECUTION AGREEMENT IT APPEARING that the parties seek to clarify certain provisions of page paragraph of the Non-Prosecution Agreement hereinafter paragraph that agreement is modified as follows 7A 7B 7C The United States has the right to assign to an independent third-party the responsibility for consulting with and subject to the good faith approval of Epsteins counsel electing the attorney representative for the individuals identified under the Agreement Jflhe United States elects to assign this responsibility to an independent third-party both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of theattorney representative The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions of paragraph infra Pursuant to additional paragraph 7A Epstein has agreed to pay the fees of the attorney representative selected by the independent third party piis provision however shall not obligate Epstein to pay the fees and.costs of contested litiga1ian.filed against him.Thus if after consideration ofpotential settlements an attorney representative elects to file a contested lawsuit pursuant to U.S.C or elects to pursue any other contested remedy the paragraph obligation of the Agreement to pay the costs of the attorney renresentative as opposed to any statutory or.Other obligations to pay reasonable attorneys fees and costs such as those contained ins to bear the costs of the attorney representative shall cease CA/Aronberg-0869 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case 4ilcument Entered on FLS.O I I I rN INVESTIGATION OF JEF17REV EPSTEIN ADDENDUM:O NON-PROSECUTION AGREEMENT ITAPJJEARING,that-the parti ck.to clarify certain provisjpns page A paragraph ofthc secution AgreemcnJ hcrcinaflcr paragraph that l!g ent ls modified as t9llows A Tho United States has the right to assign io an ndependent third party the SPO ibility fur consulting Vith and llubject to the 267good faith approval of Epsteins couns I selecting the attorney rep tativefor the individuals identified under the A Jf thc United St11tes elects to assign this re nslbllitfto an indcpenden _third-part l,oth the United States and Epstcin:rcta.in the right to make good faith-objections to tho littomoy representative lggested by the independent third party prior to the final des1gnation.of theattorney 267represen tivC 7C The p11rties will Jointly prepare a short written submission to the lndepe dent third-pmy regl!fding the role of the attqmey representative and regarding Epsteins Agri:emcnt to pay.such attorney presentatNe bis or regular customary hourjy r11te for presenting such 1ctims subject to the provlslc ns of paragraph c_ infra Pi.nsuant to additional paragraph 7A Ep in has agreed to:pay tl,e fees of the attorney repl"C:Scntative selected by the _ind_ep 4entJhird party/Ibis provision howe:v_er;sha!l not Page of obligate Epstein to pay the:fCCS-:and,oostsofconteste UitigationJiled.against h.h:n Th __ __ __ if utter consideration of potential scttl nta an arlQ_mcy rep.esentaiiv_e Mets to fi 1f contested lawsuit pu11uant to tts or elects to pursue any other _conJested __ remedy the g"-fh obflgation of.the A rnent to pay the costs of the 267ati9mey representative as opposed to any statutory or other obligatio11s t_o pay onab attorneys fees and costs such a thqsc conu.in in 2_ to the costs ofthe attorney representative shall cease i I CA Aronberg-0869 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I i I Case Document Entered on FLSD Docket Page of i been read and By sisniw ih ALEXANDERACOSTA UNITED STATES ATTORNEY Dated By A MARIE VILLA ANA ASSISTANTU.S ATTORNEY Dated STEIN Dated GERALD LEFCOURJ bSq COUNSEL TO JEFFREY EPSTEIN Dated LILLY ANN SANCHEZ ES ATTORNEY FOR JEFFREY EPSTEIN CA/Aronberg-0870 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case 9:qa-cv Document Entered on FLSD Docket CA/Aronberg-0870 nd cettifies thal tbe above has been read_ and By 267signing thi.s,Acldendll,ll1 understands die larificatfon to the Non xplaine to lilm Bp,tedln comply with them ProsecutJoffASreanent an bated Dated it ALEXANI ER ACOSTA ATESATTO UNITED Case bcument Entered on FLSD Page of By signing this Addendum Epstein asserts and certifies that the above has been read and explained to him Epstein hereby states that he understands the clarifications to the Non Prosccution Agreement and agrees to comply with them ALEXANDER ACOSTA UNITED STATES ATTORNEY A MARIE VILLAFANA ASSISTANT U.S ATTORNEY Dated Datcd JEFFREY EPSTEIN RALD LEFCOWRT ESQ COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ ESQ ATTORNEY FOR JEFFREY EPSTEIN CA/Aronberg-0871 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case 80736,KAM.cument Entered.on FLS.D Page of i I I By igning this Addendum Epstein asserts _i:titi that the ab9v has beet read and explained to him Epstr:in hc by states th11t he understands the clarifications the Nol Ptosecuti A.grc ment and agrees to comply with them Dated By Dated Dated CA Aronberg-0871 ALEXANDERACOSTA l/NITED STA TES A lTQ A MARIE VILI..AFA A ASSISTANT A TTORNE:Y JEFJ7R,EYEPSTeIN PSTEJN LILLY ANN.SANCHEZ ESQ ATTORNEY fb JEFFRE EPSTEIN FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i I I I Case Document Entered on FLSD Docket Page of By signing this Addendum Epstein asserts and certifies that the above has been read and explained to him Epstein hereby states that he understands the clarifications to the Non Prosecution Agreement and agrees to comply with them ALEXANDER ACOSTA UNITED STATES ATTORNEY A MARIE VILLAFASA ASSISTANT U.S ATTORNEY Dated JEFFREY EPSTEIN GERALD LEFCOURT ESQ COUNSEL TO JEFFREY EPSTEIN Dated LILLY ANNSANCHEZ BS ATTORNEY FOR JEFFREY EPSTEIN CA/Aronberg-0872 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Case 8-cy-80736-KAM.cument Entered on FLSO Page of I By slgnlngthls ddend1 Epstein asserts and certifies that the abovo has been.read_ and explticd to him Ep ln hereby states that ho undcrm.iids the lanfitjdi9ns i.o the Non Pr;osecutiori Agreement and ogrecs to comply with them Dated Dated __ Dated frrA t:fr CA Aronberg-0872 ALEXANDBRACOSTA UNITBD STATBS AT:rORNBY A MARIE YILLAF A ASSISTANT U.S A TIORNEY JEFFRBY 267EPSTEIN GBRALD LEFGO BSQ COUNSEL TO JEFFREY EPSTEIN ATIORNEY FOR IBFFRBY EPSTEIN FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I i i I I Case Document Entered on FLSD Docket Page of B4:S5pa Fron-Fwlir-Wil Burnitt AffinnatiBn IJeSny i Epsteindohereby ro-effinn theNan-Proseoulicn Agreement and Addendum to Mme dated October CA/Aronberg-0873 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Entered on FLSD Docket Page of I Dac-DT-07 il FrorFowlu-whl Burnett I m1 r-,ss P.ooum M_T I AJJ!niiadu I Je5,,y da hereby llffiim thi NmrProseagtign Ap:cmc:Dt and ddemd:lnn liADlC Oc:tiJbm CA Aronberg-0873 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i Appendix I CA/Aronberg-0874 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CA/Aronberg-087 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I IN THE CIRCUn COURT OF THE-FIFTEENTH JUDICiAL RCUIT IN ANDFORPALM BEACH COUNTY STATE OF FLORIDA CRIMINAL DIVISION LB STATE OF FLORIDA ARISES FROM BOOKINGNO I vs JEFFREYEEPSTEIN W/M INFORMATION FOR PROCURING PERSON UNDER FOR PROSTITUION Circu!TC.--T-r Oon In theName and by Authority of the State of Florida BARRYE KRISCHER,State Attorneyforthe Fifteenth Judicial Circuit Palm Beach County,.Florida by and through his undersigned Assistant state Attorney,-charges that/JEFFREY EPSTEIN on.or/about or-between thc dayiOf Augustnn the year of ourLord Two Thousand and Four and OctoberP OOSi did knowingly and unlawfully procureTor,prostitution or caused to be prostituted A.D a person under the age of I8;years contrary to Florida Statute DEG FEL UANNABELOHLAVE FL BAR NO Assistant State Attorney STATE OF FLORIDA COUNTY OF PALM BEACH i Appeared bcfore mc ANN A BELOHLA VEK Assistant State Attorney for.Palm Beach County Florida personally known to me who being first duly sworn,;says that the allegations as setiforth in the foregoing information are based upon facts that have been swom to as true and which if true would constitute the offense thercinzcharged that this prosecution,is institutedjn good faith and certifies thabtestimony under oath hasbeen received5 from the material witness or witnesses for the ofiensey zA ssistant-State Attorney womTo and subscribed to before me thisoUtzday of June NOTARY PUBLIC/Statc of Florida Damaris Pina DDS60T98 EXPIRES d7 i 5t ArfflUStT FCIC REFERENCE NUMBERS FELONY.SOLICITATION OF PROSTITUTION Page of Public Records Request No CA/Aronberg-0875 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM N0TA.RYPlJBLl Stafci6f Rlollda GIC?RERE 267NGE.iNtfMBERS t:i;r1o KYsbJi!s;1:zi xlf at osJti tl:Jj i9J i Page if 1j P.ublicj Re cirds Request No CA/Aronberg FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I 4?FFy G5 BGЈ A Hz?Jm KH?aU Hh ZP ЌD?M I HRJj??I AE KH?"J RA a ʏdyR I i k?R B?ř?X 3Dx?Fy Žh D?I!?D f?O??QH UgzH?4 I?G:?ˣ?k?X em)b?л I k/B A I I ZS??QJ??H UA GA 4?1hhRT?Ƣ?Y TI1T?hDDif ψR Sq?t g??Z?MUR R?Ut DE A?x O??I IInt??q?t??AuK H0 I?m?C I.z T?I鑚a"EiRJxi H?Q?O?yi ZHRI gҧ mŌ!A A I4?i6zSII?i Z;?T I A Hj1H 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Page,2 of Public Recoril.s Reque l;No CA Aronberg-0876 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I i I I CLOSE OUT I Pled fo:1:e:sseJ:2Felony __ J;f edc,ici sseitMisd 4if __ __ J?rJggJq iij,i.ti I Non rJu ffiriah _f a gi J!f __ ri:iisifd I i I dt1iai1T el corl 1Non tibc i 267:filtngjJQti fui iift ln f_ te litulio-n::_.,._ CA Aronberg-0877 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I i Toons and conditions of community control and criminal quarantine community The court sholldctermino the terms and conditions of community control Conditions specified fri this sulisoctfon do not require oral pronouncement at the time of sentencing and may beenntidorod standard conditions of community control aj The court shall require irrtonsvs supervision and surveillance for an offender placed into communftycontnAi which may include but is not Limited to Specified contact with the parole and probation officer Confinement to an agreed-upon residence dunng hours away from employment and public Mandatory public service Supervision by the Department of Corrections by means ofan electronic monitoring device The standard conditions of probation sot forth in For an offender placed on criminal quarantino community control the court shall require Electronic monitoring hours day Confinement to a designatediotidtmee during designated hours Tha enumeration of specific kinds of terms and conditions doos not prevent the court from adding thereto any other terms or conditions that the court considers proper.However the sentencing court may only.impose a condition of supervision allowing an offender convicted of or to reside in another stato.lf tho order stipulates thet-it is contingent upon the approval of tha receiving state interstate compact authority The court may rescind or modify at any hmo tha terms end conditions theretofore imposed by It upon tho offender in community control However If the court withholds adjudication of guilt or imposes a period of incarceration as a condition of community control the period may rot exceed days and Incarceration shall bo restricted to a county facility a probation and restitution canter under tho jurisdiction of tho Department of Corrections a probation program drug punishment phase I secure residential treatment institution or a community roridentiat facility owned or operated by arty entity providing such services Tho court may place a defendant who is being sentenced for criminal transmission of-HiV In violation of on criminal quarantino community control Tho Department of Corrections shall develop and administer a criminal quarantine community control program emphasizing intensive supervision with 24-hour-por day electronic monitoring Criminal quarantine community control status must include surveillance and may include other measures normally asswnatedwithcommunfty control except that specific conditions nocossary to monitor this population may-bo ordered gig A Jr XT Page of Public i Recdrds;RequesVNoJJ17 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offenders required to roaster with Che dojurlracnt penalty As used in tills section th tenn a Soxual offender moans a person who moots Uio criteria in sub-subparagraph a sub subparagraph wb-cubparag or sub-subparagraph as follows a I Has boon convicted of committing or attempting soliciting or conspiring to commit any of the critninal-oflonsos proscribed in the following statutes in this state or similar offenses in another jurisdiction or B5 where ths victim is a minor and tho defendant is not Ute victims parent or guardian excluding excluding or or atty similar offense committed in this state which has boon redesignated from a former statute number to one of those listed in this sub-sub-subparagraph and II Kas been released on or after October from the sanction imposed for any cpnvtalon of an offense described in I For pteposos of sub-sub subparagraph I a sanction imposed in tills state or in any other jurisdiction includes but is not limited to a fine probation community control parolo conditional ratoare control igIoosc or incarceration in a state prison fadrral prison private correctional facility or local detention facility Establishes or maintains a residence in this state ond who has not boon designated os a saxual predator by a court oi tins slate but who has been designated as a sexual p/odatoi as a sexually violent predator or by another sexual of fond or designation in snothsr state nr jurisdiction and was as a result of such designation subjected to registration or community or public notification or both or would be if the person were a resident of that state or jurisdiction without regard to whether tho person otherwise meets the criteria for registration a sexual offender Establishes or maintains a residence in this state who is in the custody or control of or undqr tho supervision of any other states or jurisdiction as a result of a conviction for committing or attempting soliciting or conspiring tn commit any of the criminal offenses proscribed in the following statutes or similar offense in another Jurisdiction or where tho victim is a minor and the defendant is not tho victims parent or guafdian excluding excluding or or any similar offense committed in tills state which has been redesignated from a former statute number to eno of these listed in this sub-subparagraph or On or after July i Iuk boon adjudicated delinquent for committing or attempting soliciting or conspiring to commit any of ths criminal offenses proscribed In tiie following statutes in this state or similar offenses in anotiter jurisdiction when the juvenile was years of ago or older at tho timo of tiro offense I Section excluding II Section whore the victim is under years of ago or whore tiro court finds sexual activity by the use of force or coercion I Section where tho court finds molestation involving unclothod genitals or Page Public Records RequesI No Ml CA/Aronberg-0879 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i CA Aron berg FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I IV Soction MO.M where the court fin tho use of force or coercion and unclothed For all qualifying offenses listed in sub-subparagraph 1Ka the court shall make a for each violation of a qualifying offense listed In this subsection the court stall make a written finding of the ageof tho victim at the time of the offonso For a violation of 800.MW/the court slall additionally make a written finding Indicating that the offense did or did hot irivrivosoxual activity and Indkatlngthat the offensedid dr did notffwrive farce or coercion For a.viplation of tho court stall additionally mate a written finding that the oflomo dl or did hot involve unclothed genitals or genital area and that tho offonso did cr.did-not involve thouse of force or coercion Convicted moans that there has boon a determination of guilt as a result of a trial or the entry of a plea of guilty or holo contendere regardless of whether adjudication Is withhold and includes an adjudication of delinquency of a juvenile as specified in this station Conviction of a similar offense Includes but 1s not limited to a conviction by a federal or military tribunal Including courts-martiat conducted by tho Armed Forces of tho United States and.lnidud a conviction or entry of a plea of guilty or nolo contendere rosulting In a sanction tn any state of the United States or other jurisdiction A sanction includes but is notlimltcrl community control parole conditional release control release or incarceration In a state prison federal prison private cornoctional fccllity or local detention Permanentresidence and temporary rcsldence havo the samp meriting awrtbed.fh Institution ofhigher education means a career center community college utitege state university or independent postsecondary Institution 221Change in enrollment or employment status moans tho commencement or termination of enrollment oremployment or a change In location of enrollment or employment Electronic mall address has tho samo moaning as provided in Instant message name moans an identifier that allows a person to communicate in real time with another.person using the Internet Asexual offender stall a 247fiSiw Jn i in tho cauntyfnwhich tiro offender establishes or maintains a permanent oi temporary a Establishing permanent ri temporary residence in,this state or firing rriri tfrW.tiw citr i if tho Department of Corrections or from tho custody,of a pnvato corrcctiorul facillty or In tho.coimty where ho or she was convicted within hours after being co rrictod for a under this section if the offender is riot In tho custody or Pagej6 of Public Records Request Nj CA/Aronberg-0880 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aron berg FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM control of or undor the supavision of tho Department of Conroctions or is not in tho custody of a private correctional facility Any change fn tho sexual offender 2s permanent or temporary residence name any electronic mail address and any instant message name required to be providod pursuant to paragraph niter the sexual offender reports in person at tho sheriffs office shall bo accomplish in the manner provided in subsections and Provide his or her name date of birth social security number race sex height weight hair and cyo color tattoos or other identifying marks occupation and place of employment address of permanent or legal residence or address of any current tamporary rasidence wilhin the state and out of state Including a rural route address and a post office box any electronic mail address and any instant message name required to bo provided pursuant to paragraph dj date andptaoeof each conviction,-and a brief description of tho crime or crimes conmittod by,the offphdor.Apost office box shad not bo provided In Ifsu.of a physical reddontial address if tho sexual offendors pteco of rasdonoa fs a motor voltaic trailer mobilo homo or manufactured:homQ es daflnad in chapter tho sexual offender shall also provide to tiio department through tho sheriffs office written notice of the vohlclo.Tcfentlfication number tho liconso tag number the registration number and a doscription Including color scheme of tho nibtor veHclo,-trailer mobile home or manufactured homo If tho sexual offenders ptaco of residence is a vessel livo-abcord vessel or houseboat as defined in chapter tire sexual offender shall also provide to the department written notice of tho hull identification number tho tnanufacturer 2s serial numb6r;-th name of tho vassal livo-aboard vessel or houseboat tho registration number and a description including color scheme of the vassal live aboara vassal or houiebaat i if tha sexual offender is enrolled employed or carrying on a vocation at an institution of higher education ri this state tho sexual offender shall also provide to the department through the sheriffs office thonarrio address and county of each institution includihgeach campus attended and the sexual offender enrollment or employment status Each change in airaUmont or employment states shall be reported in person at tho sheriffs office within hours after any change in states The sheriff shall promptly notify oach institution of tho sexual offenders presence and any change in tho sexual offenders enrollment or employment static When a sexual offender reports at the sheriffs office tho sheriff shall take a photograph and a sol of fingerprints of the offender and forward tho photographs and fingerprints to tius department along with tho information provided by tha sexual offender Tho sheriff shall promptlyprovfda to the department tho information rocofvod from tho sexual offender Within 48hours after tho report required under subsection a sexual offender shall report In person at a drivers liconso office of the Department of Highway Safety and Motor Vehicles unless a drivers license or Identification card tliat complies with tho requirements of was previously secured or updated undor At tho drivers license office tho.taxual offender shall a If otherwise qualified secure a Florida drivers license renew a Florida drivers license or secure an idoritificatiori card Th saxual offender shallidGntifyhimself or herself as a sexual offender who fs required to comply with this section and shall provide proof tlwt Hie sexual offender reported as required in subsection The sexual offender shall provide any of tho information specified in subsection if requestor I Tho sexual offender shat su-xnit to tho taking of a photograph for use In Issuing a drivers liconso ronowed license or Identification card and for use by the department in maintaining current records of sexual offenders I2age7of114 _z Public RecordsRequesINo ZOS CA/Aronberg-0881 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM A A a A G?A A A FD G?.?yt?Dyu ќE??c E1 A p?K?ߎ W??x?ƄX LBZA??E A A?q _A Gv_ pV a l??ZwK??C A I PB A a A A 㩇H t?:K O?3ݼG a A A 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costs assessed by the Department of Highway Safety and Motor Vehicles for issuing or renowing a drivort Ucomo or identification card as required by this section The driwA liconio or Identification card issued must be In compliance with Provide upon request any.addltienal information necessary to confirm the identity of the sexual offender including a sot of fingerprints fa Each time a sexual offenders driiws license identification card is subject to renewal and without regard to the status of the offenders drivers license or Identification card within hours after any change in tho offenders permanent or temporary residence or change in the offenders name by reason of marriage or other legal process the offender shall report in person to a driver license office and shall be subtact to tho requirements specified in subsection Tho-Departmont of-Hlghway Safety and Motor Vehicles stall-forward to tho dopartnumt allphotographs and 2infennation provided bysexuatoffenders Notwithstanding tho restrictions set forth in tho Department of Highway Safety and Motor Vohlete is authorized to roleass a reproduction of a color-photograph or digital-image license totho Department of Law Enforcement for purposes of public notification of sexual offenders as provided in this soction and ss and ffl A sexual offender who vacate a permanent residence and fails to ostaHi i or main another permanent or temporary residence dall within 48hqurs after vacatin titoJiiGr resldonco roportin parson to tho sheHffs office of tho county in whichf or steJbl Uw Tho sexual offender stall specify tho date upon which he or sho intends to or did vacate such residence Tho sexual offender must provide or update all of tho registration information required under paragraph The sexual offender must provide on addressWIh dorwx orothor location that ho or sho Is or will-be occupying during the timo in to establish or maintain a permanent or temporary residence intent iiMwriyHon ti i shBblo as provided In ml083r6r A sexual offender must register any electronic mall address instant message name with I I Octebsfl department dwir Mtab shan online systemithreugh offeftft in 273yisceui wad nameinformation This section does notspply/foasexual offortdorwho is also soxual pn W.iCmmty and local taw enforcement agencies in conjunction with th departmdnt,shiU verifyt ho addresses of sexual offondors who are not urxfor the caro custody contr or supervision of tho Departmont of.Corrections in a mannor that is consistent with the provisions of the federal Adam Waisht Child Protection and Safety Act of and any other federal standards applicable to such verification or required tu be met as a condition for ths receipt of federal-funds by five state LocaUaw enforcement agencies shall roport to the department any failurebya.soxuatoffcndar to comply with registrationraqireinents and update all electronic mail address and instant message in Page 8of Public SB iiawf ho St wu I CA/Aronberg-0882 FILED PALM BEACH 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A3?S mK GI??A?Y a lD b?B1 A A A A a H?H L?w _K?k DTD?EDlqT?Dw 6R a 0A A A a4 L6 a A A A0 a?S?y a E?tGAK F?Dt a a _S DGe?_ i?ݡ Dq RB D0 a Cb a A F0 gs G??a w?F _?pE _?O?ta WW Fᄂ A c?zdA A8 lS A D0?A A gs?A A a w3 煗F4 6J ta)?n?t Qo0?hG?k A ŋb B"?PG?A A A A A a a I yua ѦG m?E?Dm?ء M5 s?PS pE Dx Dc I A A Dt A A A0 A A"?H A3 TO w0 G?gp M??u O?ӯ_B?е h1 G?e?j O?w PB4 ƃB a a A A a A 0A I A A A A4G gN U0?q _?G?N?Mk HX?b A A lC?B 0A A A A a A3 A A H4 a0 E??gp E:gr A2 G?_eAPw DDX lp P?b i pE 0?ˠE RF!?a eyN A A0A?H A A??a d?K?Dx Nw Ժ??7K?al i uէ?ooU QP?b A S?D A A s??E a G??u pD G_o?Y ض6 a A 0A A L2 OZT?L hGhG z?q A hE DDB PA A A A A A a A A A e?Gv pDx G?Dq a:a s?F a N?e qhqQ?q A CCA A A F0A tc Gь?_ a?C NE A A A F2 G?镡??z A soxuat offender who Intends to establish residence in another state or jurisdiction other than the State of Florida shall report in person to the sheriff of tho county of current resdcnco within hours boforo too date ho or sho intends to loew this state to establish residence In another state or Jurisdiction Ths notification must include too address municipality county and state of intended residence The sheriff shall promptly provide to tin department the information racsivod from the sexual offender The department shall notify the statewide taw enfort nont agency or a comparable agency in tho intended state or jurisdiction of rasfdonco of the sexral offenders intended residence Tho failure of a sexual offender to provide Ms or her Intended place of residence is punishable ns provided insubsection A sexual offender who indicates Ms or her intent to reside In another state or jurisdiction other than the State of Florida and later docidas to remain In this state shall within hours after tho date upon whfehthe sexual offender indicated he or too would leave this state report in person to the sheriff to which the sexual offendor reported the.intended change of rotidenco and report his or her intent to remain in this state The sheriff shall promptly report this information to the department A sexual offender who reports Ms or her intent to rcsido in another state or jurisdiction but who remains in this state.without reporting to ths towiff In the manner required by this subsection commits a felony of the second degree punishable as provided in or ZZ5sQg A sexual offender who does not comply with tho requirements of this section commits a felony of the third degree punishable as provided In or A sexual offendor who commits any act or omission in violation of this section may bo prosecuted for the act or omission in tho county in which tho act or omission was committed the county of the last registered address of the sexual offender or tho county in which tho conviction occurred for the offonso or offenses that meet the criteria for daignaHnga person An arrest on charges of failure to register whon tho offender has bean provided and advised of Ms or her statutory obligations to registerunder subsection the soryfee of an information or a complaint for a violation of this section or an arraffptmont on charges fora violation of this section constitutes actual notice of the duty to register A sexual offender 2s failure to fimnedlateiy register as required by this section following such arrest wrvico or arraignment constitutes grounds for a subsequent charge of failure to register A sexual offendor charged with tho crime of failure to register who asserts or Intends to assart a lack of notice of tho duty to register as a defense to a charge of failure to register shall immediately register as required by this section A sexual offender who is charged with a subsequent failure to register may not assert the defense of a lack of notice of the duty to id Registration following such arrest sorvico or arraignment Is not a defense and does not relievo the sexual offender of criminal liability for tho failure to register Tho department,,the Department of Highway Safety and Motor Vohlclos,tlio Department of rrections,tho Department of Juvonila Justice any.law enforcamontagoncyinthissteto and th personnel of thosa departments an elected or appointed official public employed,:or school administrator or an emptoyoe/agency 2or any individual-or entity acting at tho rcqUost or upon tho direction of.any enforcement agency isimmune from.clvllti lity for good faith compliance with tho requirements of this section or for tho reisase of intormation under this section und shall bo pnasumedto hnva acted ingoedfaithjn compiling recording reporting or releasing tiro information The presumption of goodfafth is not overcome If a technical or clerical error ismado by tho department 2tho Departmont of Highway Safety and Motor Vchicles thQ ttaparbnent of Corroctlons tho Depertmont ofJuvwrile Page of CA/Aronberg-0883 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aron berg FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EH 7vc ւz ڑG m?x??d?E G??c?б a A e?E8Dx?_?G a a dx EE??T cb X?z 4yj j?A??!Gnԉ 8eB?wM LX?M?A L2 A A A a a 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v?b-?D a LB A pH"?a u?a A PA A a A a l?t?Ȑ?GYt pD a A I اC?DX??2?i d?b?6ƈ Fq cG F?j?ˠE GF Ga2 _W g?C?Kb?H jM?M?W Xa aTQC M?u u?U VDv?a?c?g v-pE?t A CL A A?G?Dtq Y?YQNuFj20?DC D0 DDC a A A A NB?i iPt i Zq a?ƒ t?Ua Rm r?a Ib G?X kh Ty Justice the personnel of those departments or any Individual or entity acting at the request or upon the direction of any of.those departments In compiling or providing Information or if Information fs Incomplete or Incorrect because a sexual offender fails to report or falsely reports hts or her current place of permanent or temporary raridonce Except as provided in a sexual offender must maintain registration with tho department far tho duration of hfs or herUfo unless tho sexual offender has racofvod a full pardon or has had a conviction set aside ina posbconviction proceeding for any offered that moots tho criteria for classifying tho person as a sexual offender far purposes of registration However a sexual offender a Who has boon lawfully released from confinement supervfsfon or sanction whichever Is later fer at toast years and has not been arrested for any felony or misdemeanor offense since rcloase provided that tho sexual offenders requirement to register was not based upon an adult conviction a Por a violation of or For a violation of excluding For a violation of where the court finds the offense involved a victim 2under years of ago or sexual activity by the use of force or coercion For a violation of For a violation of whore the court findstho offense involved unclothed genitals or genital area For any attempt or conspiracy to commit any such offense or For a violation of similar law of another jurisdiction may petition tho criminal division of the circuit court of the circuit tn which tho soxual offender resides for the purpose of removing tho requirement for registration as a sexual The court may grant or deny relief If tho offender demonstrates to the court that he or sho has not bean arrested for any crime since release tho requested relief complies with tho ft provisions of the federal Adam Walsh Child Protection and Safety Act of and any other federal standards applicable to tho removal of registration requirements for a sexual offender cr required to bo met as a condition for ths receipt of federal funds by the state and the court is otherwise satisfied that tho offender is not a current or potential tiiroat to public safety Tho state attorney in tho circuit in which tho petition is filed must be given notice of tho petition at least weeks before tho tearing on tho matter Tho state attorney may present evidence in opposition to theroquested!rellef or mayothsrwfsctdemanstrat the reasons whythe petition sh dbedohioddf the court denios the petition thecourt may sot a futuro date at which the sexual offetufar mayagain petition tho court forrolibf,subject to tho starwiards 2for relief providedthis subsection The department slwtl remoire an qffondpr frqm classlflcationasa sexual offender for purposes of registration if tho offondorprovides to the department axertified copy of tho courts written findingsprerdar that indicates that tho offender is nd longer required tn lA I comply with thorequirements for rogistratton.as a sexual offender Page of A si Public Records Request No CA/Aronberg-0884 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aronberg-0884 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM OO lDV?PA PA A A A A?E??p A c0 yt QT a gp A v?ƞ a 0H PA?A Qt L?w C??C R.H!b?qLB 0M A PA A F4 C?K Э?B b?D1 PwA VՀ A A A4 A Gp l?wo Ђ)??w?hDD6 A6 E?A a XA A S쎽 B?s??A qQ lX 0A PA a H?A A a?t A w8 ÄG?-?u E??Gs A3?P?VK4?u??aF v?o?q??k?m?Q L0?A Gp A A A A w;?s S?au I I a0 ÝՄS Z?x㯸Ÿ?l a a?b A a A A A b?G?V cb?;a HR A A A A A Ju A?l E?v a A A C?k?I aW?h wC Db!6 DP a A A 8A A A T2 ʆz T9 i??i ⴵ?B/b A A A A i?G?e E?J _A eC??aK?0?s Ҝu e?"0qڽ SoC?b,0 cB2 DDC a A E??t A o??O?_ok o?ݰU x??B?b CM B?D CA w;?a vG?d A??A Ph A E8A0 E8G A ڈ?cw APB A A AGp A t?G A V?t LE RL0?"Î A A 3?PW?ŗ Oh a 0LR A 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a must maintain registration with the dppartment for tho duration of his or hw 2liftj 2until tiki person provides the department withanordor issued by tho court that as a1 sexual predator as a sexually violent predator or try anothe exual offender designation in tho state or jurisdiction Inwhich tho order was issued which states that such designation has been removed or demonstrates to tho department that such designation if not imposed by a court has been removed by operation of tew or court order in tho state or jurisdiction tn which tho dusignation-was made and provided such person no longer moots the entona for registration as a sexual offender under the laws of Tho Logidatura finds that sexual offenders especially those who have committed offenses against minors often peso a Heh risk of engaging in sexual offenses oven after being ratoasod from irtcarceretion er commitment and that protection of the public from sexual offenders is a paramoimt government interest Sexual offenders have a reduced expectation of pnvacy because of the publics interest in pubtfesofoty and In the effective operation of government Releasing information Concerning soxuaVoffonders to law enforcement agencies and to persons wf requortsuch information arid thercloaso of such information to tho public by a taw enforcement agency or public agency will 2further tho governmental interests of public safety The dedgnatidn ef a personasa texuaTaiffendor is not a sentence of a punfshment but is simply the status of the offender whtchis the result of a conviction fair having committeti certain Any person wire has reason to believe that a sexual offender is not complying,.or has-not complied with the requirements of this section and who with thointont to assist th sexual offender in.eluding a taw enforcement agency that is seeking to find the sexual offender to quextion the sexual offender about or to arrest tho sexual offender for his or her noneomptianco with tha requirements ofthis section a WitWxXds information from or doos notnotify the law enforcement agency about the sexual offenders noncomplfanc with tho requirements of this section and if known tho whereabouts of.the sexual offender Harbors or.attempts to harbor or assists another person in harboring or attempting.to harbor the sexual offender or Conceals or attempts to conceal or assists another person in concealing or attempting to conceal tho sexual offender or Provides Information to tho taw enforcement agency regarding tho sexual offender that tho person knows to bo false information commits a felony of the third degree punishable as provided in or gte a A sexual offender must report in person each year during the month of tho sexual offenders birthday and during tho sixth month following tho sexual offenders birth month to office in,t couhty/fh ich Iw.ortsh Idos.ords to reregister j.ktojwvor 2a soxual offender wl 273.fs!requtnBi toregister aswrasult of a-conviction for Section or whore tho victim minor and the offender is not the victims iuwdfen;-r Rage Public Records Request No CA/Aronberg-0885 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aronberg FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM a Section 794.QH.oxcludlnsts.794.6l1 Station 8OO.O4 4Mb where.the court finds the offense involwd a victim under 12years of ago or sexual activity by tho uso of force or coercion j5oc fl Section 8OO.M 5l where the court finds molestation involving unclothed genitals or jjgartfCBrwoa Section 5lc where the court finds molestation involving unclothed genitals or Section gOO.MiSKd whore the court finds the use of force or coercion and unclothed genitalsorgcnftal area gjgjlliMMIM Utt Any attempt or conspiracy to commitsuch offense or A violation of a similar tew of another jurisdiction must reregister each year during tho month of the sexual offenders birthday and every third fnenth theroofter Thoshoriffs office may dot rmf no tho appropriate times end days for reporting by the withtho reporting reqirfremontsof th subsection Reregistration stall include any changes to the following information UY Name social security member age rare;1 sex date of birth height weight tair and oyo r-cblprjaddrassof any permanent rosidonce and uddress of any current temporary residence wifitin thostatecr out of state,including a rural route address and a post office box any electronic mail address and any instant meAsago name required to bo provided pursuant to pan raph of any employment vehicle make model color and license Itag numbar;.fingerprints and photograph A postoffice box shall not bolprovfdcd tn Hou of a physical residential address If the sexual offender is onrollod employed ar carrying on a vocation at an institution of higher education In this state the sexual offender shall also provide to tits department the name address and county.of oach institution including each campus attended and tho sexual offenders enrollment or employment status If tho of residence is an manufactured hDmq,as.defln9d:ln chapter the wMclo idtmtiflcaHj uml tag num description includingcoloir scheme ofthe mofory manufactured lj tlw or houseboat asi ofined in chapter327 tho sexual identification vessel or houseboat;.tho rogistration num nd the vessel llve-aboard vessel or houseboat otor vehicle traitor,.mobile homo or 2sexual offendorsheUalso provide tho thej stretipn number and a 3hlcte trancr mobho homo or jfftHidonce.lsa vessel livo-eboard vessel offondorshallalsoprovide tho hull rnberj thonamb of the vessel livo-aboard a description Including color scheme of Any sexual offender who fails to report in person as required at tho shcriffs office or who fails to respond to any address verification correspondence from ti departmont within weeks of the date of the correspondence or who fails to rcjwrt electronic mail addresses or jStsr-irwJy-Srv 2W Put Ik Ri uj dv F6 qu I No CA/Aronberg-0886 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aronberg-0886 FILED PALM BEACH 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i A A A a E8F A A4 B?f aBz A0?jʶ?rҐ xVG?H J?E tDg C??lTDXb?y Mi pDyK?;QJ?p??A q??v?O t?M?j??i pM4 a A eь O?F eyQ A t?g??e A 0LSa LB T2 M?u?p?8a hEBn BU RPED a A0 w?Z gpD Vm??j z?yǪ Ǎ?U J??A i M?q?h 0k H?LV??T A a XA a A V??A b?H A0 p??I A i??w GiWT?B a db LB A a A xE P??膂 cr a aڪt?4?d 8TGR:-IS L??p Kiu a?Xp A ڌn A PA Dx A V!?O ዎ8 ԃM A A0?P D0 G?D GP S?H?j t??(lA vN??A?xqRp?hb eF?ڻ?Dj f??L 0?vm u?j L5M A A6 A A ˠEC dx P?A3?E A Ϣ?K?j5 Uja G?X z?ݹP źՂJ T?T?l?w?Do _p?Z _h I?C?օ0C Dx A A F2 Dt vi3 eA a?wA xd 0LB Qt l?HQNx tں?M ij XA??HR S?GRO i?b yu?n?W T4?E A A E?G2?P?tG f?Ax W??O?v ئ?ǵJպI moA??jP 0T a z?u I??U joi?F A a A e?_?gz D6?V 1E a G??P hPB BH n?r a z??P??i?Zp?I Pn?:G??ѝ LZ n?t ǰ?T LB l0?ta Dx?_l a?pV G?Ǒ?Ӵ a A Gϡu i F0 I??:DWukp Hl Us iu.tGuT MM li Mil Mati ililB third a jii ISOS jil ljl BSSBlBOliW CA/Aronberg-0887 Ws I ill iggaMgi SiWt MaB iMlM SglSaS fig iSWil gfStgfs BM Yr life i IMI jji MiB SMii SB hMM Sags MHii Ww Public1 RecordsRequest No_ FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aronberg-0887 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CTATEp VS IN.THHko-V COURTL f-K IN 2ANDFOR DIVISION OF THE CIRCUIT FTEENTH JUDICIAL CIRCUIT vl BEACH COUNTYfFLORIDAr I CASENUMBERfS GS DEFENDANT DERENDANT writ 3?DEFENDANT DEFENDANT DEFENDANT i i DEFENDANT foLEATNjrHE CIRCUIT COURT jpam 2the defendant in the above-mentioned,matlerfs and i-am represented by;thc attorney indicated below I understand I have theright to berepresentedby an attorncyat all stages pf.the proceeding unti the case is terminated ndif Tcannot afford ah attorney one.will appointed free of charge I Iunderstand I 2have tHe 2rigiif to a speedy and public,trial cither-byjury or by cpurt./I herebywaive and 2givc up this funderstandl Havcthcrightto beconfrontedby the witnessesagainst meand to.crossexaminethemby myself or through my-attorney I,hereby givemp these rights I understand Fhavc the right toteslify-onhiyown behalf but cannorbe compelled to,be a witness against myselj andmay renkin silentifl so choose/1 hereby/gtve upthese rights FA understar 253i.rhaveithelrtght 2to 2cal witnesses todestifyrin mysbehalf and 2,to,inyoke,thexompulsdry processiofthe Gourt to subp a norc:witncss s.isHicreb I AUXS 2kr r,understand fhaveJhe,right to appcal all majtcrs relating to thcchargefs and,unless plea Guilty pr.No CohtesV specifically rcservmginynghi to appeal,"I 253will give up suclFright of appeal DEFENDANT understand that if amindt a United StatesfCitizen,1 my pleamay subject me to deportauon pursuant the laws and regulationS ROvernine the United Statcs Immigration and N0luralization Scrvice;-and this Court has no junsdictipn A authonty insuchmatters miMr authontyjinsuchmatters DEFENDANT A DEFENDANT DEFENDANT Llhavc not received any promises from anyone including my 204attbrney conccmingeligibility for any form of early release authorized byilaw and further ndpromiscshave beenmade tome as to the actual amount of time thpt Twill sefye under the sentence to be imposed 2Further I plea may..fe 2;UstxliU cnhance fa penaltiesin ankcourt system cvch 2if adjudication of guilt is-withhcld I I:offer,my plea/freely.and.volijntarily andofmy:owniaccord with:full;undcrstandingofallmattcrssetforth ih the pleadings and this waiver I have personally placed my initials in each bracket above and I understand each and eyery one of the rights outlined above I Hereby waive andgive pp each ofthem in order to enter my plea to thewithin chargc I understand that cvcn though the Gourt may approvc the agreement of sentcnce tKc;Gourt is not bound by the agreement the Court may withdraw its approval at any timc-bcfore pronouncingyudgincnt,:tn which,case Jisliallitx able to.withdraw.my ipleashouFdiLdc reJodo.so.v I a II DEFENDANT Choose one Ifjapplicable.-I chdose a program which is of.may be spiritually-based Tfappltcable,-l:clioosea;program which i espirituallybase I DEFENDANT DEFENDANT 2S ATTORNEY ONLY DATE I am attorney erf record I have explained each of the above rights tb thc dcfendant and havc expldred the facts wilh him/her and studied his/her possible defenses to the chargc I concurwith:his/her decisipn.to waive the nghtsiand.io enter tfaS:plea.;Ffurthcr stipulate thaithis document may be received by;theCotulas evidcncc of defendant 2s intelligent waiver of these rights and that ilshall be filed by the Clerk as.permanent record of,that waiver AITORiNEY FOR ITIE JOrigmah-Clerlt-/iSrMmf.iStNc.Attonley yellow/iDefe Fonri-Circuit rcySAlO CA/Aronberg-08 DATE Goid form FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ti i i CS;IO:lesll fr Jt vo1untanf fandfot:m 267;ownfatl8rc1 witlrulFGri8eiitinci,n f,t c,-f T-g c1 hliM a:fu i3f is i;:e _1 RPJ W_Y_ l;r f!l:Sg_ss:,;.I,s UJ tJi1 i il i __ __ i al:il 225arP m:wtif is;or na/Hespirituahy;bas I oslit Whirh,i;iNcfii SP.iri:tt biisefi I I f1 Jr te1f iri"m"ef l_ t;riia9 piriiually:tiasc IA CA Aronberg-08 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM RULE a cOllNAL PUNISHMENT CODE PREPARER NAMc DC SAO DOO COUNTY RACE DCtl GENDER eLonyZ F.S DEGREE If Quahfier please check I lMARY date Millie _C_R A At cmpl Sciiclalicn C-Cpnsri racy.-,RvRed issilical on DESCRIPTION OFFENSE LEVEL JOINTS fe4 1G Prior capital felony tnples Pnmary CTfcnse points ft Bl I 2ADDITIONAL OFFENSE Supplemental 221page attached i f.lj i;l i/i,;jli;_f_ f_ CA Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM a a A3 E?a M?B a D:B A A xA PʀM G?!?HR ke?Ќ4B l?j MPAu TS b?n??M A A A LPH A u?TF Pw?F r?ηh _?My a g??E DEǪA PA?7 _H gv گIG?c XC??Ӷ PA 1A 8L A I t?t L"?zE b?㸈 cQ i H??A A M?s?V o??Gc?q A A A e??H Qgp a I lF??E?C?N eD"?j_ 9?xV Xa A KM3?Dt a A D?,S P?CaѱM X??A dx O?D A I?H Bł h3 H??I TS I a hPA A lPC A B??H ta A PA a tG?6 E?K?B ez J?a bІ a a U/e?Ƚ G?t8?x c?駍 DXٴ Da Gq e?p m?A a4a 8MSVapE VS?ze D!a??A I NgN?.?H Gz;?H Hs?G j?t kn?U7b(U A 3ݰ eL i?:x G?U a PD XA H??A I 1?tG?e E??3D?cb Ra!l ha PA uA l6 u?S 0A LP B?K I0 A Gp LB n?b a i a u?pDuX Ra4 a h!M a A"?a x?M A YĚ a IK Cצ b(Xb m?N??C a A v?E9 A4 G??L E:?gp?ߍ??m 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SENTENCE COMPUTATION than i/fs nils 2d lowest pcrmiscbloprison sentence In months maximum senteficeiS.uptbjthe statutory mgjyptum roKthe pnmary.gndapy adcit 2onal otfenses-as provided in ih8 ilowe peiTOls xde;exc 253eds tny tatiit sentencesmay be imposed pncunerilly.or consecutively If totalis,enteTce po nts are.greater than or eqijaitp/363 a Me sentence may:be imposed rnaxin-uni sertencu in years TOTAL SENTENCE IMPOSED i.Y,cars Months Slate Prison GOunty Jail Community Centro Please check if sentenced as Life fl Time Served reoffender or a mandatory nunum applies habitual ofender habitual vioent offender violentcareer cnm.nal prison rcleascej nMitigaled Plea Bargain Other Reason JUDGE SIGNATURE lneosoa Public Records Request No CA/Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Page-1 Subtotal1 i WA qaLStatus vidiatidn 4iEoints VL.i Cbmlputvty-.Sanciioi viQfdtiq the court forscntencing Sji ints.x each 204successive violation OR Ndw:feioriy..convictiori T2;pc iints each-successive violation VII EfrearrnSerni-Autgmatic 2nr.Machine Cun Points 2VI Pricr.Serious Eelony Po-nts VI VII VI Subtotal.Sentence Points IX Enhancements only if the primary offense qualifie sr Enhanced-Subtotal Scntonco Points IX TOTAL SENTENCE POINTS SENTENCE COMP,UTATIO If-tcal-seiitencepuirilsarejess Ilian or equal.to the lowest permissible sentence is any non-state onson sanction i Ji l,,to!al_senr nts are greater than itQlitrseiitencp 2pcints frjfhus lowest pe miss bq prison senco in months js/up lo.Uie stHtutcry nia rmumTor the pdniary arid any additional offenses os provided In Vw jowest pflh the-coSo cxccocs the statutory maximum Such sentences may be imposed 2concurrently or consecubvely if total.ser.tenco points arc greater than or cqdahto a ite sentence may be imposed st mayitrum sentence yeas TOTAL SENTENCE IMPOSED Mcnlhs Days in Slate Prison vtj County Jail Community Control Probalon Please check if sentenced os Life 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wŸ??v긋 A a A C0?H A A A wE XL D1 B??ɂ JS?ԧ sA A?q u?c??G x??Ŋ X??H L0 8H a E9??w;?ONS?sſ t??in?L?V i??P RB??h a 脐A 0D S?_?צ?uN?zx eEha aB A A A A a G?mDC?x PB РhA A ʘ?_H A a.a 1?TЍz Tq B?X EՂ8?p DP?lD0??A A A PLEA IN THE CIRCUIT COURT TH FOLLO MNG IS TO REFLECT ALL TERMS 2OF THE NEGOTIATED ir r:;J i I M:jij,,JH H!I A i OlLO IVING IS tORffLEe1 225AtEJERl fiSi,0F/THENEGOJ,lA tvj tlj i i re c,;ri fu o_ ctiar i oijt 1t te1o J1 ij 200dit tf1,yii fNo fI OQC t.;IB ili iiW e"9N il iiC ro ek 245tii i n,,e t9qijifo i gtRi9 yo A fo SENTENCE __ __ __ OntER.COMMENTS.OR,CONDITIONSi __ lldarWT a/gijA n,fp_ Efiry_c trt;ft fiis ie I Li I Termstahd condttionsof comm control and/crlmlnal quarantine community control 1V The court shall determinetheterms and conditionsipf community control Conditions specified in this subsection do not requiro oral pronouncement at the time of sentencing and may bo considered standard-conditions of communi ty control a Ute court shall require intensive supervision and surveillance for an offender placcdinto community control which;may;include but is not limited to Specified contact 221with the paroleand probation officer I Confinement to an agreed-upon residence during hours away from employment and public Mandatory public service Supervision by the Department of Con actions by means of an electronic inonitorihgdovire or system The standard conditions of probation,set-.forth,in For an offondor placed on crirninal quarantine community control the court shall require 4s Electronic monitoring hours per day Confinement to a designated residence during designated hours The enumeration of specific kinds of terms and conditions doos not prevent tho court from adding thereto any otherAmms or conditions that tho courtconsiders proper I lowovcr the sentencing courtmay only impose a condition of supervision allowing an offender convicted of or to reside in another state if the order stipulates that it is contingent upon the approval of tho receiving state interstate compact authority The court may rescind or modify at any time the terms and conditions theretofore imposed by it upon tho offender in community control However if tho court withholds adjudication of guilt or imposes a period,of incarceration as a condition of community control tho period may not exceed 364.days and incarceration shall bo restricted to a county facility a probationand restitution center under the jurisdiction of-tho Dopartment of Corrections a probation program drug punishment phase I secure losidcntial treatment institution oi a community residential fadHty owned or operated by any entity providing such services The court may place a-dofendant who is being sentcnccd-for criminal transmission of H!V in violation of on ci iminal quarantine community control The Deportment of Corrections shall develop and administer a criminal quaiantine community control program emphasizing intensive supervision with;?4:hour-per day electronic-monitoring Criminal quarantine community control statusmust include surveillance and may include othor measures normally associated with community cohuol,-except that specific conditions ne ossai to monitor this population may be ordered of Public Records Request CA/Aronberg-0894 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I i i 4f i i i/i Sjn i i 225Xic il l!if Jtri f!:t i,i ij i rt;s tiJr gfr yi VQS 8b iir,vqi!tri i f_fit;a tt ffohQ a,i1 t!Ni comirioni conttol wnicn::n1a inclucic butMnot limitad;to ocjfi ii?t ct t!l t.h pa 0,le tpr or rfii il Th Wt r;n,r iir upg 1tit t1i1n li tJf Ji;n ortJ,oiliJ?toYrri9.nta nc ndat ey_.public servici,;_ si Tily!fu Jk t,Of!S.;/i i"f lf i ifO li 225,i,OiJtJ 267;Thjrs t.lc1f i f1rl tj 247ttHiiri"iJ ofa6 cec cfi f!altq adil ff_imti11 1nit.y 260rifrol rl ou al/;r i1i _Jt ij ni ifi e.t rf iin fr 1qc ej ti,itf 1j to tto id i srium ti fi,.9.ffo lfi Jinds;pft a f:i:i a,Jfip_tjs A YS.f Jhgcd yf i mf 225addirC sthelefoian iothe1 t:ern:is qr condi tiofo,th 225tfio 267.touft fa_,1isj9 pro1Je tl:l6 iOYt llifJ Jst6ti rfie i ri tl 247Jifof 1C?ri tfu i,va,j Jqff99Jff1:9_ t;a-9f iOU 11othor at ord i!t?iJ i ififJs if nit-llP,P ihi r1 fl i 1J ti iw,P f::l r1ty;:fi f9u..rt;may,r tc39.y,t1mq qrrn nft,q.1ng1t19n imP4 seo Jfo nf tnj qffoi:fidort inJ:oininl.in1 contf olVit:iowewrr i fth court.withholcisi tli l1 iillit!ll tl ommun1t:y,r:OS1dent1ahfo1:il owruxi 267or:,operatoo;by;any entity pro:v1i:hng such 225scrvices a __ __ f,r __ __ mil""A t11,ritt 1t1r:iidiG t:i1 Gorr halEdove Jaainir,H 267nat/uarzintino-:co1ni11unif con ol trarir _h,Ji ti fifg.jnt itbnS ljj Jf fr fujrf i,g trfo ii tju ran lrn-1 om e,f,statlJ r.;mtisbindudo,su,;veilla ioiridn jcj;j_othdrtn:ic2f,.i1rnr firi is er ij i jttriw Jl;i Ji r.I W,g;ti ri,1ii r;tr Page of CA Aronberg-0894 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Sexuai faused in thissecticn,the term i a Sexual offender 2means a portern whotmeets the criteria in sub/subparagraph a1 sub subparagraph b./wbrsubparagraph c.ror sub-subparagraph as follows a Has been cbhvicted of committing,,pr attempting soliating,iOr conspiring.tojcommit,.anyA of the crimirraboffenses proscribedtin tho rfollowingistatutes in this state or dmflaroffenses in another jurisdiction or wherctho victim is a minprand thedofehdaht if hot-the victimsiparontior guardian;:s..794fh exciudingis excluding or or,.any,similar offense committed in this state 2which has been redosignatedfrom.aformw statutenu one of thoso listed in this sub-sub-subparagraph and A II Haf been released on or after-Octobor from the sanction imposed forany convictionof an 2offensedescribedinsub;sub-subparagraph Foripurposes;ofsub-sub subparagraph i 7asanct onimposcdinthisstateorinanyotherjuri ictioninc lude,s,buti5 not limited to a fine control-,/parole,/conditional-release control release;,or incarceration In a state prison federal-prison,private correctional facility,/prMocal detention facility i Establishes or maintains a rosidencein this stato and who has not been designated as a sexual predatorby a court of as sexually violent predator or/by/another 223sexual offender 2designation in/anotheLstateor jurisdiction and was as a result of such-designation subjectod 2-to registration on community or public notification or both oc would be if thp person were arosidontofthatstateor jurisdiction without regard to whether the person otherwise meets the criteria for registration as a sexuatoffendbr Establishes or maintains a esidoncein-thisstata who is in the custody or control of,-.or junderthb supervisioh.of any.othprstate or juriKUctionas-aresulttofo convictidnfor committing orattampting;,soliciting cr conspirihg to coihmit 2any-of tho crimihal pffch5es proscribod in thb following statutes or similar offense,in another jurisdiction or where the-victini is/a minor and defendant,is notithe victims parent or guardian excluding excluding or oranYsimilar offensoLConimittc this state wliich has been redesignated from a,former.statuteinumbor to 253one:offhoselistcd;in.this sub-subparagraphj-or idiOn.or after July-1 hasbeenadjudicatedideUnquenbfor committing or attempting solicitingpor-conspiring to commit any ofithe criminaldffenses proscnbedinlhe following statutesin tins state or years of ago or older at the 2-time of the offensc I Section Section whore the-victim isundcr yoarsof age or-twhore the court finds sexual activityiby theiuso of.force or coorcidn Section where thecourtifintis fiibipstationjh hnngii icfeth ig ni Page Public Records Request-blo CA/Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Ihr!!ll u..i si i w!thi!ii Jf A iM!tii.fi t:Jili,f.l Jii i i ir.v i,w;ic i H,as.6eon co victed;ofcommih1n o,i ptiha;:souctin or.;to i,i hfcdm tt vt ltho:cri ficnser oscri rh foiio his!atutes-/in te?rstmitaffoffemos iJ i at 02:sqrt i rnf ii the doferidanfls.not:tlie 225vactim ront ior;.guard1an excluding:s ts,1 is azs;,1 ozs _0 lJW Jna:S 0IAS rn s1m.it offomatommittec:Fiifthis:stato wtiictiitiastooer ret1asi oatootfrornia former-statu 243ernumoeri,to itj i f!riithj isl i JL tr JI tla.l ot rS fr.sW9Z J!s i coit ilctfon,of;an foffense describedtfn,sub:sub:.SUb ara i if.or osei:yosub::.sw su fa ii Rr i;"siinctk ilYiwt Jii;rthii st.ar.!o1-a itfleirt cti J;ilti:att tbudit fnomirili it li:iin,F i-oti tia cn it ccintrit iiJr itioilal i onfrciti T/i if iti1 rffii tll ij iJ a tfil il ib 243statili cof 225niafntains f:l"OSidonceio this tatofan 267Wtio JNis 225nit"beori dosi rnit ai:a tt f:ttlt1if lt 1l i ti,tt i W?hl1 w.a 1Jlt,.qf-gicJfd ift tj i i tr.a i nr 1unl y;Jir utilic not1ru::aiior1 or;both o,;:Woula botitXllio rson:w:ereralresidoof6t:thatstiito _:fuif 267rij tf 245iijf tf!?;P n,.i rii rn BJ9ii i l.i i fan f,o illi ll i c!:li:l i i l!;ifi 0S SOO:Of;,cs,:az5 exdijdi_rjirs:8-17 1msr a4zfo1-as;1 fr8 o1 267iJS rls qt ffi simU tfu if t1xtJ.1 4!fa f;.whidit1asiboon i osi nate0fi:omtii1cfoi-mer st.1te1numboiitoro"We:otitnosQ tE1hfi1W ili J:r i 1ii Jj i i it i if ii taJ _ll n,oth J.unsd1ct10_n.:,wl1 o;JIJVQm.l Y,,a ftiY lr o.f a Qf W,?l.j i tjrita tf ri I i i i JJ fage cif l:,iJbhcRE;C9rds Re,qui:5 No CA Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ʚC hCB kHC?Z A(?nm A xi v?Zh a GD ƚq??Dvł i?q HDt G?i pl I?V GD 0Hʤ a Y??ﳵx A 6HD A:B 3-sHE H?Ŭhl4 ՊGEƁ7??v?H B?2A?ey 6v i B??q pa a B"?L A mQ?e t-?a HE?L A?D G?D Ds.Ts Q?9ڒ gc a cTy ȼr9 GH1 a Ա䚀;(B9?W ƅ?R DqQ Cˣ j?b E8f A Da RH?t w?XD rL?_rM 罡??qn ֈ??CN!?r A ʳ??ʒ h?v4H;?F?R Dt XFV Dc/?2J?h gb6 B?uFHB"?b Db 2YE 6aY h(H?N I??L?DtFf rR?p rl A d4v Y7 ez _"Ⱥ"?ԊZV??hCVM??ϝ?!x Jl 9n Lג?E B?P RX?a?e DO?D ǀl?v?"?v LCnY?fEP?ϡs r;?GDtw?a i h?i2 R?vd BLj?N HDa P?F 7G DFȚ;R??-?,FM KA A s??I yn pM fDb?ʳ Na?a?hO?4K?θA a 㺐B?-?t?O M?H Ɗ;E?ZxA JWD?g??A T??m?b шq DtP?2)Du lX _N X?A ɺ?M DDx;)Cdn?9e S??B l?I5?3Ш?L쥑a Y?B S??E ƌ?Gj fJ Q?A h?B xEz??j T?s?tv Q?Z S0 rR Tq Ս?G F?V VD A FAؼ Eл?/?P;G l?G æWX?;?h?P b,Z 5a JB??x;(L t4vh rO 3B 7;tB?UP;(C a Mb F?Z N?(DtI1?v fAha MN VT DE?FA a eq?J Vq q??W Ixj tY??l?Xrމ Dt??樮a 幤uJXA v?;(EM vZ Ks a Lh S3XE gh?EH Dt?H2??DZ Dv 2莠?M 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cb(A n0 EP Dz a B?l P?d l?H Q?ҋ;?C g??C AɎ??dc LE?r Ô??e w?a m3?l GDx?X a N?F F4 z??L Gک/?A G?T RE a r??i?D S9 tN BH3 B?:?㗈?gY HA r?B rS t?P TN ˢ?Y fjʃ4?g??Gp?I?Rv XN H_?A g?ؤ?g??Ո AC 9t q??Uo??E ȶtcFb?L?O F(V Ft ʚ??Dk D!?E D??G XL 4F XA _B DC3 DE DQ N2 i cM c?a tjE p?s??q h6A?Pj?B C0 A?Bi:U?UT 6V ʱ"?L l?B CӒ iK?"?C n??iXw ј:?i?iڧ?;ث??vB ۓv d?,i y;r wn zK?4 ᴃJ:?HXӄE?v?J2:y?g i7OU?2 t?N V?0?UÙ ld O??uwM PR8ԋy Q?ǽ WXAm V?W a H??F?P M?i?PӦ?p?_a PmRm IV Soction 221whero tho;courtifinds the wo of force or coorcionand unclotncd genual I For all-qualifying offonscsjlistedimsubrsubparagraph a the court shall make a writtonfindingof at tho tunc tho offense For eachMolationipfra quatifying offenso listed in this subsection the court shalbmake.a writtbn/finding-of thdiago?of IhoMctimat the.time.otthe offense For a violationof s1 tho courtshalhadditionally make atwritcon finding indicating that;tho offense di did not involve sexual activity and indicating that the offense did or did not involve force or coercion For a violation ofs the court shall additionally make a-written finding that the offensedid ordid notinvolvounr lothed genitals oi genital area and tliat the offense didor did;not 2invoive:tho uso oft-forcoiorcoercion i Xonvictod moans-,thatthere has bcon.a dotirmination of guilt ras/a result of a trial orAhe entry of a plea-of guilty or nolocontondQro regardless of whether adjudication is withholo and includes anjadjudication qfsdelinquoncy of a juvenile as specified in this section i Conviction of a similar offense includcs but is net limitadto a conviction liy a foderabor miUtarytribunal,-including courts-martial conducted by the Armed Forcos of tho United Status and includes a conviction-orentry of a ploa of,guilty or nolo contendere resulting in a-sanctiun in anyistato of dio United-States or other jurisdiction A sanction includes but is not limited to a-finoy control parolopconditionalrelea so control tclease,/or incarccratiomin a state 2pnson federal prison private correctional facility or local deteiitfqu facility i A i Permanent rc idenc 2517andi tempofar.y,re5idehCe;Ha dj lnstitution ofliigher ediicatioiv means a career-center community-college college university/onindopendent postsccondarydnstitution Change in-enrollment or employment status means Ure commimcotiuml pi termination enrollmont or employmehtor aichango invocation of enrollment or employment Qectronlc 221mail address has the same meaning as provided in Instantmessagemame-ineans anndentifier tiuit allows a 221person to communicate real time with another person using tho Internet A wxuafcqff a Report in person al the sheriffs1 office A I In thp.countynn whichithmoffondoi establishes ot maintains arpernianenUoi temporary fesidoiKp/W av Ekhblfshihgip resdciKQ this state br Being icleaspd fcprriWb;Custpdy control or supervision pfithc Dop or from the custody ohaspnvate correctional facility:-m In the countyswhero ho or.sho was convicted within 48mojjr.s afteMwiH convicted for qualifying-off under this,s iction ifxtheio.ffender--is-.notin tho Custedy 2dr Rage;23:of Public Records Request No CA/Aronberg-0896 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM s_lXl t!i W!i.iw iliCf ijni/,::l l.o 225nil i 225rhfd tJW;1!i im;rit i1 i win i!f i ii!l1l it1:r so r,Ji..yi OOJ.Q1 iJ J!t J1d,m p31ly;,f!llI fVi l_tt f1p JQU thatt,ho:offon dfd;or,.oi f;notfinvolw1unr;ltithod 225onitals enitararoa,ano tl i 1ooffo1 i 253ilil itiif i rnilitar 7tnbunaHini:l courts"imirtiitl"cBnductoo1b",th,f eif.F,orcosoLtnc 267:Ui,iteiJ-Sfatci i,r,r iji qi ii itl i tj iJf:1 i FX to;:a!fino-t rooatiori-coirimuhi c:ontfol rofo-/Conditictrialrelease coritrof:rcleiliio!;oJ Jl CK cy __ 7_ rcoratfoniin a::statorP.ii1-o,n/f ora!l:1w1son i;iiyifto co,.-roctionaliracility i,f 1oca1,,ai;it:6,jtr,n i __ i Jaci it i k;tfmari,o t_ rosi et i nd.;"-t9Tpp,rary,2rosi er,1ce"1 t_hi lm-:Gnl n.fh 242.ii.b,J:iil tll i r1ilil i t!t A ri.ii i Jl qll ta i11ars Jn;.enr9llfnei tio 267e,.nplpY!flii tat0 iij c_on;i1ne,h il-!r1cn 9i i o1:i i.hiitppr1 ill_irwntoi mploymen oi.::a 225cl1:ar.igo in:locatioiiof enf9llment:orj:imRloy1l?flL ff ontc1 laif t1,g inaia W?vi aj iQ tt i ii tfgi1rt fief tJ halP,_ l1 nVrii afotjij r:e A:S8xutikotfohiJor;;sttaH P?r fii,.P;9SS!J"t_ c,ffi t;it i t.Jt ii i a,;t!.li ecMB Ota jf ol iJt;Q Stj,01 l!ii i _it i1 i;!ii ia,rt5 l_sf 1t/J i in tt Q1 lncn gf tt o_n 9rfr ll te rpQv rr a c1l,l,tYt si iiti titi i titt:it l::ir t;h1it it Page;:23:cif ublic Records R-equE;st:No CA Aron berg FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Da ҠP i?簂 LP 3Ƃ cN?9 Ai?f Ս??łWŷi?S FGA ȧ??I d?"??GDdG2 u??o Ri?F tf Ř4 r??B?E:v DCB??CD L?!p fa pE eC qz A q?Nq?n Wb A I??ܫ O?dA A φP??vP?D?0 7iw uRc?9?N,Û d?a Fi pB?MB jK vL??xm ՐGDuM5vh G0 1qkCA ib?v6 QNwt?P Kj??i??c Dd?J 1펗 м?A yi?R?Ҧ DtA GT ul l?u"??cϓv?ra6?h6A??h S.?I?t лza p??iӴ P-?E PM ԝ?H ZM u髏V Um?N?p??F Z??ߧC N??kx?m?S u?K Lj??Y Ӥ??W?lDCj DG??;i M?_?Hm HKw a I a0?uo?m _j?a a?Z n?M Og??/c?B Ҡ?Qf ykm Ϣ?"뻵?Z U?/o?hq?s ox o?IҴ?յ?և 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iB??VGn K?m?㺾?ޗ?!?GD ȉpDnS??"Sx A i o?B wC M?ںo C?P Ol azRFz IP?b??B7t AW V??M??lX?w?Jڒ I PE:k ät 2Y?p?J z??J aZH IWMi mWH??S?j?1ވA qt?lD WhE Wt a8Ȯ?L?mӻ?Y ݮ?D ZO Ј?N??U ŕ?:?ml Bq Jm?IY M?꾡G?_?UO?R za qoi gr I u??D?z Kz?ڄ?n?U?G 4Ű w?(S ݦڷZd i a Zչ cחZv?Ǯ I v?D Ϣ4 yN??OQMur??U?b l/?B հG I?ض P??m L2 lB eYNW?d?E V?v:j?n?hG Sb W?Piڵ control of or undor the supervision of the Dbpai tmenVof Corrections or is not in tho custody of a pnvate correctional facility i Wiychange inThe texualMfendersipGrmanenhorjtemporary rcsidonco;inamej any eloctronic mail address and any instant message name requiredto 2bo providedpursuant tpi paragraph after the sbxual offender roportsTn person at the sheriffsoffice shall boaccomplishod in the mannor provided in.subsections and J8 i Provide his or her name date of-birth social security numberi rac sex,?hc hair and cyo color tattoos or other identifying rnarkSjAoccupation ahdplaceqfjcmployment address of permanent or legajjosidence or address of any current temporary residence within the state andout.of state including a rural route add ess and a postoffice box any electronic mail address and any instant message name required to-be providodpufsuant to paragraph date and place of each conviction and a bnePdescriptionpf the crimeior crimes committed by the offender Apqst office.Box shalhnot be provitlcdJnfbeu of a-physical residentialaddress If tho sexual offenders place of residcncp.is amotor vehicle trailer mobile homo or manufactured homo as defined in chapter the sexual offender shall also provide to the department throughjhe sheriffs offico wnttenmotico of tho vehicleidontification number the license tag number;"the registration number and a description including color scheme of tho motor vohictertrailer mobile homo or,manufactured home If tho sexual offenders place of residence is"avossdi liw-aboard-vossol or;housoboat;-asdcfincd in.chaptor.327 the sexual offender shall alsoprovide to ths department,yzntton notice-oftho hull identificationinumber tho mahufecturers soriat numbof tho namo,of tho vessel;4ive?aboard vessel or houseboat the registration numborjrandta dGscripbon,including,color-scheme,:of the vessel,-livoraboard i vessel or houseboat i If the sexual offender is enrolled employed or carrying on a vccatiomat an institution higher education in this state the sexual offonderr shall ajso providesto the department through tho sheriffs office:thd name;zaddrossj.and couhtyiof each institution including each:campus attendedpand the exualoffenders enrollment pr employment status Each change irv enrollment shall be reportedimperspmat the sheriffs of free,within hounsaftcranychangcan status The sheriff 2shall promptly-notify each-institution ofthe se/nat soffondersipresencciand-any-chango in.the sexual offenders enrollment-oi employment status When asexualoffender reports at the sheriffs office the;sh riff shall taite a photograph and a sot.cf Withe idepartrnontjialohg with the information provided by the sexual offender Tlie sheriff shall promptly provide to tlie idenartment the.information;receivod from the sexual.offender Within 48jhours;afterthc jreport required ijriaersubsc ticn.iZ a sexual 2ropcrbin person at a;driycr 2silicense 221Officc:ofithc Department otHighway Saretyiand Motor Vehicle unless-adrivorTbccnseor tliatcomplies-witothe.i.equireirieiiuM 4T 3Vwasprevicusly secured or updates under At tho drivers license office ithGisaxualoffandbr-shisU i I 4a If secure a Florida drivers license./enow a lorida driver 2s license or securoian iaontincationxardi lhe sexual offendersliall identify hmisolfot herself asja soxuSl offender whons-required to comply withlthis section end shall provide proof that the;sexual offender reportodas requirodiinsubspcuonUl Tho sexual offender-.shall ovide any of the inforrnatiomspemficdin.sub-section vif roquestarj Tho sexual offender dull submit to tl taking of a photogi aph for use in issuing a drivei Ybccnse renewed license or identification card ano for use byThQdepartinent-in.matntaining currontfreccrds-.of.sexual offenders Page of Public Records Request-No CA/Aronberg-0897 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM titiltt t:l 1i lt.i i if illS itl.ilW!lfltit fl a:P,f sly SO Jf qd il.lP il_te.a Jtl lqcs At t!io s1f:!Yct 1.ce tf iY mf i.i toffin HF ha i I r1 i.t 2c 1Vf q,;r d!tf i jr _rd i ftcn,d lf sl s,t tl gff iS:P51 qr:np nhi Li?.ttan 1:sh _p thet i S_t1 1il fon 9PP OO lJi.O ii11si1l iori rJZ Tlj:O i_ off cn IJ al P.f 9:.trof thJ inf tfon p9q i idf cc,tior1 ft ei.il j,totJ Tho si fii ff_ r,,tl l_l toAi Jrjg,of li farAP J:;for,;i.i_ fe i U!r:i r;itCl A cgn.u igf1 10J_idq WJ li ana fo us.,,bY,JJi 225diap tmO.n.ttn,,neiOraOiftt.su"oco,n 6ff jlr CPJAronb pa9e 225roro FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 9p;D q?a J?XQ _gx DhS sm 1r4?b;ADv??DC I Db uI?i b7 V?;v Q??G I鈫 eь?L a e?F A Cb??Ӥs X??b A?D igь?ˢ3 Gґ P?O3an?/??ㅜCmb A y?r C1 i?VsL?B DE?K kJM?3 V??y EH?V g2莂G eҦG??v??P?b a xB Fh6 l?a g9 A?dv Vl h뇱 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T?b"?;DAr ts Hiv?6?G I5i?w i?X"?u DZ?z?i N?oh i 鶻?Y N?F dwa ɿI??IV I?X?4?mL 0R MGilRa G?M ȂP LT s(F x??vK?t NDe AY M3ɋl W?Mt?㲍?;?a i?a I XA A?QZ?ŧ k?E ȺI?km Cl d?f 4д U?h v?q ܟv uko?t Pw??L?L 3TV?L a ˡ?J R?NʘAB L;A 6Ȳ Ѥ_ ei j?L A L?m s?/M?y H?W H?Jи6 A i E?ʲ??a s?G6 A?GB Dt A B0?k zt I jO?E?!MNB!μ?ҡi JL3R 1ţ DDC??E L?BZ?2u d?V L4?L?E C?U xT"??N eL Qta ww8??A?t?D ߢuz EЧ DlPEЈ eB yx?K??v_ǡ??š E?0آ qi??ߥ DklD(?E?(?L t?a De 莈?G?c 4a ZC Dq i a Gф Aɕ Net ZƔZR?9?,D2 θ?o On X?k H0?h?Ge E?D2 i??B?lF!PDx HՐ?E Qa?jF i4 I b?Ѵ?ވ3?a a??tr S?Qq G?C??l?w VwR??B pD g?Y?t쏲 VT hE?Z a?І S?ȼ yB4?H":A KT??o ϡ?Q Da 4U?B x?ڷ?S Yt PA b?P B?V F0 g2?tId?2 ZR6?Cm i Xgp CD sr a d1 u?e??H ڡ?m Xb G?S tZ M0 ej EYP A wv Ċ,?ؾΝ r?:e?S N?i AB ȨN NHΘA?-,C P??t Sv?(H8f eDղ?Xg9PUA 6z A 6H?lF xDz a F?n FiE Ib Hq Y?tkD ΔE MЈ?ő?ʢ QhZg??l?7 A A u?Fp?D_ q?Gqt?Dl A eІ Db sA P?,Z T.?ҢJ jB?tuH hDE?Y?y?cL e?R ҠGH F?Wԁ?L i a tGG2 O/?F jGPE?F lDF?E r??b a a lg DuW XhBB L?d??q B5 a L??x V?drA??pgǂw?j ZQ?8 a A GI F?B C?A I 0H7Twvy D??D i??a ԹߠN 0DxC;?nw Q(A M3L c?C m?dv GFx?6 RH60?C S?لa a.O A E?-m m7a7 I M?l 7cl4 Frn A?D X?U cM Nw?m Һt??T l8A ڊP 莂vf дA SL Hs aQ??b ՠ?oiҭՄ WJ?O IF2 L??B i?Y NՑ M??ӯ a?t?V ok K?kº?Zw??P A GL?C?E a E?u g?ja??㨪 t?D M?XI??Z I x?m!IX??Oi իxi?m 2Q H?IY a4а?zhh C?n?a Ћ?A dc?A4 y??P V??C?k?x?nS wm?P P5 FsB eg q?iU hl zh PLåcQ뇱J?LÄ-?A SE StejV M4 XM nل I Zv?ڊ A a GO la ZT?Ա I I Pay 2the;costs assessed byTheDepartmonvqfdJighway Safetytand Motor Vehides fordswiing fer tenewing a 2drivcrs 2licensa oridontificationxard asirequired by this section I ho dnyors license oridontiftcationxard issued must-be in compliance.with Provide Upon 2request any additionalinforination-nocessary to confirm.-thc identity;ofi4he sexual offendi Ta.set of fingerprints a Each time a sexual offenders drivors hcGnso or idontificationxard-is.subject to renewal and withouVrcgard to the status of the effonder drivePs license or within hburs aftorariy cKango in tho;offendor permanent,or or chahgedn the offorderyname byrrdason pf marria or dther legal process,vthQ offendor sha person to adnwrsTicense ofhcej andshallbe subject 2itO 2tho requirements spoafiod in subtectipm The Department of Highway Safety and Motor Vehicles shalbforward to the ithstaiidingtha restrictions seVforth ini 322.142Hhc;Department of Highv/ay5afoty and MotorVehicles is authorized-to roleasea raproduetton of a colorrphotograph orsdigital-image Uconsoto the 2Dopartrnont:ofLaw Enforcement for purposes of;publicnotification:of xual;offenders as prdvidedTnitfiLslrcfibh i A sexual offender who.vacatesia permanent residence and fails to establish or maintain anotherpermanent or temporary residenceishall,;withm 48;hqurs aftorvacating the permanent resfcfonco report iniporson;toithe.sheriffs officetof tho county in which he qr-she is located The soxual-offondor shall specifythesdate upon;which ha orshe ihtends to oridichvacatesuch residonco The sexuahoffender must provide or update albof tho registration information requiredmnder paragraph The;sexuaOoffender must provide an.addross forithe residence or otherjocation that he or sho-is or wilkbe occupying during the time in vvhich hejor sho fails to;eztabli or;maintain a pcrmanenVor temporary residences A sexual-offender whoiremains at apermanent residence after roporting his or her intent to vacate such residence shall within 48.hours after the date upon which the.offender indicated he or she would or did 273vacate such-residence report in person to the agency to which he;or shQireportedpursuantto;paragraph for ithe purpa5o of reporting.his or honaddress at the,sheriff receives-the roportj-Vhe shixiff the informationito the dopartmenteAn offender who makos,a roport as required undorr paragraph sbut failslqirnal arcport as.required-underthis paragraph commits a felony of tho;second 225dcgroo;:punishablo as provided ims or i A:sexuaLoffendsr:must,register;any electronicsmairaddresor instant message name with tfio;departmont prior to.usmE such electronic mail address or instant message name on of after 2October he department shall.establish an online sexual offonrlerssmay securely eiccoss and update all electronic mail address andinstant message i This sectioncoes not apply to a sexual offender who is also-a sexual f5redator,.6s defimvl in A.sexuahpredBtor must ragistanas.required uitderis I ibT-Gounty and-.local law;eilforcement.agencies;Tn conjunction.withithe:department shall vorify the addresxis ofsexual offenders who aie not under the caie custody ntioi or supervision of thcjDepartmoiit of Correction in a manner that is consistent w.th the provision of thcTodoral Adam WalshChild Protection and Safety Act of and any other federal standards applicable tc such verification or required to be met as a condition die rcceipi of federal fundsby tin-"state ocal law enforcement agencies shall loport to the department failuraby-a sexuahoffender toxomply witn registration re Page of Public Records Request No CA/Aronberg-0898 i FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM l?,lo J_ p_r l.s ts9.r-i Jm 11Ktt tt 1ti rr;t;JI tnlt llr ofi fl fd,e a sha I i:il_is:1 irto,1 1tf!f th:-b h;t!h1d-i 9"x,uf off nd_i;t sm1!lY y-n_c apg pqat0 i.tl tron1c;l!1 _1 d.dfc.?J I1thflS eB orm i l;,l!J i?_QJ lp tiI ais?1t1 VfFJn rr;J cir fajf l1p..r,e ta,toiJ ffefri,Sirfi1J s./Z t,ialP,f ftr,to.r _t r,am:.i clS,r!f 1Jlf 9.U..IJCl r;S _c if il Jf!IJJ ltISill t!,1;1.Q,sJ.JJYiHl!?i t9r 267tJt a i!.QfOft 1r QC::lf Vi:l EOP r:t tb,G d9!l?f il5 1t ii illff ie lf oJf1 rCfJfll ll ii:.4i.f Page of 8u6ncc ords CA Aronberg FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i A sexualteffonder whomteiids to establish residencoJin anodior,stato?cr jurisdiction otlior than the Stateohfiionda shall report in person to tho.shanff of the.coiinty cocurrent residence within hours bofcrc;tho date ho1 or she intends to leave this state to establish residence another stateor 221jurisdiction must includetheaddr;o5s 253municipality,i county and state of intohdedtresioence-iThe sheriff shall promptly provide to the department the information recdivodfrom the sexual offender Pio department shall notify the statewide law enforcement agency ora comparable agency in the intendedstate or jurisdiction of residence of the sexual offenders ihtenood residence The failure of a sexual offoncier to provide his or her Intended-place oft residoncels punishable asiprovided in subsection A sexual offender whohndicates his or her intent to roside in another state or jurisdiction other than the State of Florida and later decides to remain in this state shall within hours aftoKtho elate upbnwhich thissoxuaboffender mdicated he or.she.swould leave this state report in pdfsoh to the sheriffito wl-nch the sexual offender reportod the/intended change of residqiica and report his or her intent to remain in this state The sheriff shalVpromptly report this information to 2tho dapartrnent A sexual offenderwho reports his onher intent-.reside in anothdrstato of jurisdiction;tiut wltosreniains in thisstafe without reporting td the;sHenff in the manner required by this subsection commlts a felonyoft 2tho second degree punisliableias provided in ors a A scxual offonder 2who does.not comply wicb:the;rcquirGihentsiof this section comiTiiu a felony of tliia;third degree punishablQias provided in;5 Asexual offender;who commits any act or omission In vlolation:ofrthis section may be prosecuted for the act of cinission in the county in which.tho act or omission was committed the county of thelast registered address of the sexual offender or tho county in which tho conviction occurred for tlic offbnso or offenses that meet the criteriafor designating a person as asexualoffendor An arrest on charges:of failuro 2to.register;when the offender has;been provided;cind,ad ted of hisiot hei statutory obligations to register under subsection the-service of pn information or a complaint for a violation.of this section or an arraignmentoncharges for a of this-soctioniconstitutes-actual notice oh the duty to register A 25exual,offendcr failure to immediatelyYcgister?as uirod 2by this sectioiT.followingjSuch,arrest seiM arraignment constitutes,groundsifor a subsequent charge of failurq;to;r,egistor A sexual offender:charged with?tho ci imoof failure to rcgistertwho asserts or IntGnds 2to assert a lack of noticc of tho.duty tc.rGgister asfa defonso.to a charge of failure to registor-shall immediately registeras required by this section A sexual offoridei who is charged witKa subsoquenUfailuretoxegister may not assort thodofenso of a lack of noticf the duty to register i Registration follow ng such arrestpservicepun 2aFraigninentiis-ino atdefetisc and deus nut tile sexual offender of criminal liability fortho failure to rogirter HOr-Tho department the,Department of Highway Safety and Motor Vehicles the Departmc.c of Gorrections.-rthe Department of Juvenile Justice any law enforcenuntiagcnr in this state thepersonnelof thoseidopartnientsjten elected or appointee officjaU public employee sdTOobadministretor;iorAan employee agency or any individual or entity actin-,fat the req x-rt or upon tlie diroctiontef any law enforcement agency is immuno from,civn liabilTtyfoi damages for good faith compliance-with the requirements of tins section oi for the rcleas of information-under this 2section and shall be presumed to have actodhn pood faith in compiling racoiding importing or.i 2leasing the information Tne presumptions pood-failings not overcome if a technical or clerical error is made by the department the Department Hignway-Sofotyand-Motop nhiclas the Department of Cori odium the Department of Ju mtc Page of Public Recoils Request No CA/Aronberg-0899 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 6l MW iA if fa i ti ff nd Wfu rpjr i as5oi rrf ll:itt!r J9 fr rr1qt if rim secute Jfor;,tho:acf,or 267oinisgcin:itho,cQUi"!fy,ill:.w nicn;tho:act:Ioi"1oissioh_ as 225c:"0Wimitto i ci ci Bt!f i 1f gf t1f tViiddf irit XMtl ffe.tide1 ir h9i uflit mi rni tom-1 cti01,:c:urrod for tli i off0nso oi"of onscs tfultmtiiof tlict todi.dorri:lcsi nc1thi ta er,spn i ti qtt br 9t:UR9 f;.i9Y,c,l 1flQ,1y:yt1s flJ liJP,n rpp1 c;1v!Hgi_b1b1.ty 11tiM llilill!liW!ilitt P?ge2f3 of Public Recoti:Js ReqJ_esi:No.j CA Aronberg-0899 I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i Justice tho personnel of those departmont qr,any indiwdua acting at the request or upon the direction of anysof those departments in compiling/or/pro information or if information is incoinpleteorincorrect because a sexual offender fails to report or falsely reports his or her current place of permanent or temporary residence Except as provided jn a sexual offender must maintain registration with the department for the duration of his or her life unless the sexual offender has received a full pardon or has had a conviction set aside in a ppstconviction proceeding forany offense that moots tho criteria for classifying the person as a sexual offender for purposes of registration However a sexual offender a Who has beotvlawfully released frorn confinomcmt supervision,.or sanction whichewr is later 2for at least years and has not been arrested for any folony misdemoandroffenso since release provided thattho sexual offender 2s requirement to register was not basodsupon an adult conviction For a vioiation of or For a violation of excluding i For a violation of where tho court finds the offense involved a victim tinder years of age or sexual activity by the use of force or coercion For a violation of For aviolation of where tho courtjinds the offense.involved unclothed genitals or genital area For any attempt or conspiracy to commit any sm-h offense or gi For a violation of similar law of another jurisdiction may petition tho criminal dhision of the circuit court of the circuit in which th sexual offender resides for the purpose of removing the requirement for registration as ajsexual offender i Tho court may grant or deny relief if the offender demonstrates to tho courtthat he or,she has not been arrested for any crime since release the requested relief complies,with the provisions of the federal Adam Walsh Child Protection and Safety Act and any other federal standards applicable to the removal of ragiotraticn 2raquiromonts for a soxuahoffender or required to.be met as acondition for,the receipt"of federal funds by the state and tho court is othorwiso satisfied that the offender Anol a cur out oi potential throat to public safety lh state attorney in the circuit in hich the petition is filed-must be givoh notice of the petition at least weeks before the hearing omthe mattbi The state attorney may present ovidor.ee in opposition to the requestedrelief or may otherwise demonstiato the reasons why the petition should bo denied If the courtdonics the petition tho court may set a,future date at which the sexual offender may again petition the court foi rabof subject to the standards for relief provided in this subsectioni Thp department shall remove an offender from classification as a sexual offender for purposes of registration if the offundoi pi ovidcs to tho department a ceitifiod copy of the court written findings or order that indicates that the offender is no longer rcquiredAo comply with Xhorcquirernentsifor registration as a sexual,offender Page 2/of Public Records Request No CA/Aronberg-0900 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i f9 f-il j,a.tii rrifi g!t J,rI1J r,z9,i3J ft ffot i trJ i it tr tti fo I Vttffili __ __ v,io at t1 tf trli.1ti ii i 1,rt V!Jff 1w 1sjfi it for 9t tt r,npr;o 2l sgjf y,t iEV:!1J:Tif J1t:Af11ib Jf li or itit iH1 fltltill;i1 i6 titjtif"A l11il!itl::tli iilil i!lii pr,r t,nrcd tOib J!met 267c9nd1t1onJe r,:th0recQ federa.lA thes and,ttj if9 ll..t lf il itt tli fif i Cs itltoff oilcler;J-r1.iiyfi!gisfn,i10tit.ior thccoud flf!:,rdliof;.:-sul:ij t;to;tlic:.st ridar.diif,::,r1rot iofi tti lift:Si fitt:e.12J1nd,iDJ?:.;9 ir leiJh t-jndfoatc 1b ff QdirctS t1 tr,e.q1fl _rhf?Jy:wJthJhI?:i i1W or.,r atiRn f9,iJ Page of 8ublit Reqxds Regu sFNa CAI Aronberg-0900 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i As dofintri jn subTSUbparagraph a maintain registration with:the department for thQ duratiorfof hisior her.4ifo;untibthe person provides.the depaftmont-with arvofderi issued by tho courtlthat-designated the person as.asexual predator,jas-a sexually violontjpredatorr or by/anothcrisoxuaFoffondor designation in thejstate or jurisdiction in/which the ordpr-iwas fssued-which states thabsucludesignationshns been removed or I department that such designation if not imposed by a court has boon rotnovtxTby operation of I aw or courtorderin thoistate/or jurisdiction in.,which the designation was;mado,;andjpfpvidcd such person nolongermeets die criteria for registration as a sexual1 offender under the laws of thisstoto The Legislature findsithat.sexualioffenders especially those who,havexommitted ffenses againstminors ofton pose a?high:riskof engaging in sexual offenses even after being released the pubhc from:sexuahoffenders a paramount government interest Scxuahoffendersthave a reduced expectation privacy1 because of tlie publicsiinterast.in public safety anddntthe offective 2operation of government Releasing.information concerning sexual offenders to law enforcementragenciesandltopocsons who request sUchdnformation and the release of such informationtoitho publicby alaw enforcement agencyorpubhcjagoncy,will furtiiertho governmental-interests of;pub ic,safely Tho dosignation ofaperson;as arsoxual offender.is;not sentence.or punishment buttis.sunply.i the status of tho offender which is the result of;a conviction for having committed certain crimes.1 Any person who has reason to believe tl at/a sexual offender is not complying or has not complied with the requirements of this section and who with the,intent to assist tho sexual offender in eluding a law enforcement agency that is seeking to find tlio sexual offender to question the sexual offender about or to arrest the sexual offender for his orher noncornpliaiic witlrtlie.requiremontsLof.this section a Withholds informatioivfrom or does not notify the law enforcement agency aboutithe sexuaLoffendensioncompUance v.tth theToquiremonts.of this section and ifknownj tho wheroabouts.of 2the 2sexuakvqffendcr Harbors or attempts4toharbor or assists another parson tn.harboring or attomptingito harbor tholsQxuaK6ffehder;;6f i Conccalsor attempts tpConceal or-.assikkanother personal concealingior atterhptig to dk-Providesunformation 2tOthedaw enforcement agency.regarding-the.soxuakoftender that person knows to be/false,information commits a felony of the thirddegroe punishable as provided in a A sexual.offendoiunustooport in persorreach yearduring the month of-.thosexuaL offendersibirthday andidunngXhe.sixtirmonth following thG:sexual 2offeiideds birth montlrto the sheriffs office in tho county,m which Iki or sho residos 204or,is otherwise,located,tor rcgi:.iar I luwevur asaxuul offender who required tu register as a result of a conviction ror Section or s.tfSv.lQ-jwhci the victim minor and the offenderll not the victim parent?or 2guardian Page of Public Records Request Na CA/Aronberg-0901 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM et A ti qJ jJ aJ iritiif fr tl Yi ft Jor tho furation"of Hed 1fc1until 225ttH per son,p OYI depnrtmoiit with 225aii"orcler sueq lf ur_t _P Q_n xual,p fi tu!JlY.f 1gf it9rt9 Yia Al pr t_t i or i Jiti1f:_h tf1 sych,19es1_g11 1p,n.l as n:.p r:i tra i rtmcint::tliliHsucll aesi nation i riot1impo tby;acourt,/lias 0oon,romo J;1f 0c 267",iratioi,j oft _e?jij,th JohJ rJ dj2tfi ffiry Jfh1ihf i Jf Slict,irfersohrniil8 er;;meei:fall cfitc 1Ji fof:reeis,tta o,ra a tC ftenoefiundor.-;th,t ta s,sf Xtni ts __ 267!l.liJtl!i1fll1 WOO re uostsuch;ihformatiori anditho release:of-sucffinfofmatiorhtoithor ublii::b;zflaw fof ri eO:rif:y;f fPHl?.li_ t1 11fY f;fL!;!,!lilt nl.!lcri tJri i irJii 1j 0tt i i ii j:P,Ji 1tli fo end9r J.f_K1,s th r;,q ulrgtcfC r,l or nmit ed gft CcH i a ob to:,bi on r1l furftVJNt/?r/hilt i corrfptied th;tlje:rqquiietrieiits.of:thi_s:soctio nd who 225with;too!inti..int,to;assfsti,th,:t..otual flit i iit i!i-,t iz tii i JVJ:ifl sii_ or Jijfitf cirn.,,or th 225-.:Aflfot i ricy i4 1cll e.!tdei s_1no co,r.np i:,,inc v.JiP1 th t::o,quib iJlqiits of this oi,:;;aodi if rioY!.rt;:,i:l:i 247fii ti 6ff di?r 0i it lrf 1tl i i ls ot t,e rj_i1j i1 4hn o_r:;a Hiri,i I Jit fi t:!J1P nt9ai;_:9fia i is:nn?Wcr.p or Ji1l.corilie ti 247rn1ttui;ngi Jc conc:oal tha;_sexua offendet or Pti Qg J.t1Pl9 tlfl rf2 fr.t 119tzj Jrig;t ui:ili o!i i;_r,:fh il _l J5 cf rl,Y Pfl:,l_tlQ i it y,o i.i.n 1il9 a2 royi jj iir tff fE i f:l Ji ttii 267pJi tr?:s 1_Jr 9j;f ti ll ii t,ii plfQ t1 J,dyn!f,t,th X,t ntl.lto,llo!l JO,iL sexva..tio!f01_1 _er sb1rth1fTIO ttigt,itt offit i o.vii iJii ijN l1 o.st t.f;H gr:t isi J9git tt rt ff i,i.f o1i2 age:28 of CA/Aronberg-0901 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Section excluding Section8b0.04 where tho.courtfihdsthGoffenscinvolved,avictimun jer years of ago or sexual actMtyjby thcIusc:qf force or coercion 7k Section Section where the court finds molestationcinvolving;unclothed genitabarca I b.Section where the courtfinds molcstatiohnnvolving unclothed genitals or genitalarea Sectioh800/04 whore-the;court finds the/uso/of forco or coercion/and unclothed genitals or genital-arqa Any attempt or conspiracy to commit such offense or Aviolation,of a similar law of another jurisdiction i must reregister each yearduring the month of the sexual offenders birthday and every third month thereafter i i The sheriffsoffico;may.detormino;tlio appropriate timos and days for rcportingvby the sexual offender which shall be consistent with tho reporting1 rcquiiomonts of this subsection Reregistration shalbinclucieanychanges to the fotlowingnhformation i Name social security number age;-race sox date ofhirth height weight hair.and oye color address of ahy permanent residencmand address of any current temporary residence within the stato oroutiof/state including a-fural route addr.ess and-a post officp.box any electronic.maikaddress 2andahyanstantmessage namo ro iuirod to:beiprovid pursuant to paragraph date and-place of any employment vehicle malm/.modol//color,;and bcense tag number;?fingerpririts;:and photograph..A.post offico:;box shall.be provided in hornet physical residential address If the sexual offender is enrolled employed oi carrying on a vocation at an institution pi higher education in this state the sexual offender shairalsd-provide to,the department the name address aruJ/county.of each institution including each campus attended and the sexual offendersonroUmentor employment status If aco of residence is,a motor vehicle trailer manufacturedihomo 2sas;definedfin chaptf;r the sexual offepder.Shall also;provide,the vehicle.identification number;.the licensQitag numberj 2Xha registration description,;including colop.schome of the motor/vehicle;,trailer mobile/homa or rnanufactured;hornewlf tiij sexuaioffendcr placciof residence;is?a,;,vessel livc-abo 2ard vessel oi houseboat as dofinQdhn chaptor the sexual offender shall also provide the hull identificatioivnumberj/the manufacturers soriabnumbarj/tno nameipf the-vcsscl liye-,abo 253ruh vessel or houseboat the:registratiorT.numbar;iand.a description,.including color 3chr 273mo,sot tho vessel livelaboard vessabbrh Any sexual offender who fails to rapmt 2in pet sun ajequncd at the sheriffs office or v.Lu fails to respond to uny ddress verification cotresnondeneb from the department s.ithin weeks ofthedatemfithOjCorrespondence 2.Qncwho-fails to;?cport 2.c4QCtronic mad addresses.cv Page of Public RecordsRequest hip CA/Aronberg-0902 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM v,C I i tI l.t uJ.!iq Xop tj lf J;f i i ief iffl!tii;J t,a,:sof kaa 5;,-,Sectit nsoo:d4csHc Where tho cicirttffndsrri tationti11volvintJ:inclothrid gd talto ijI a tti I r.t cj FTl9l iOn;in j0;n uncJ 1if-j lf io z"hoi u,f fl jifa itJ j,,b CiO lt ii/i AJiy f3r!ipr9r:.c;.gr.t rJ i.t:imlf sfr or y.t9iteh 225r;oddit I sh Vfi Y;.s.t r.f _i a pr,9r s::tlfyg A YJ faej i ff i1 er:i hii ll r91,.o,ttJoe.focf lJ b1 Ggi tt Si i lliJh IJ ei.;tc1y ng ll!.ie,l ll9 i,h Hn.f9t,m.i3-t.i_on A tr;:rtt.i:ittri lt1tt11 tir tit;J1 nt1 ii c:i Mt 253;lc;lr,es i c1 i y;qf;91Jdl R:9a l1:C ITIP S/al.t1 nq ni:i tl-!.Or.S ugi1 9,ff ri 247Jl!Jlorit?f!:iJnp gi;!t tu I If_ Xlial:offender.:s laco;of resi dhnto"ii a.mo tor venide fruilor _1_cijlo In nitVcs 1,;ti_ye J:i9 ff ii i i 5f i i!liimtlli tli1V!i i llfit i Rage of M4 RubliclRecords esl No CA Aronberg I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i instant message names commits afelony of the third degree punishable as provided in or i The:shoriffs office shall,twithin:2 working days electronicallyisubmit and update all information provided by the sexual offender to the department in a manner proscribed by tho department Page.30of114 Public Records Request No I CA/Aronberg-0903 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CA Aron berg I I i I i I I I I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Appendix CA/Aronberg-0904 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 2i Appendix CNAronberg-0904 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM U.S Department of Justice United States Attorney Southern District of New York The Silvio Mblld Building One Saint Andrew 2s Plaza New.York New York July VTAECF The Honorable Henry Pitman United States District Court Southern District of New York United States Courthouse Pearl Street New York New York Re United States Jeffrey Epstein Cr RMB Dear Judge Pitman The Government respectfully submits this letter in advance of the bail hearing scheduled for July in the above-captioned case For the reasons set forth herein the Court should Order that the defendant be detained pending trial he cannot meet his burden of overcoming the presumption that there is no combination of conditions that would reasonably assure his continued appearance in this case or protect the safety of the community were he to be released As Set forth below the charges in this case are exceptionally serious the defendant is alleged to be a serial sexual predator who preyed on dozens of minor girls Over a period of years arid he now faces a potentially massive prison sentence predicated on substantial arid multifaceted evidence of his guilt In light of the strength of the Government 2s evidence and the substantial incarceratory term the defendant would face upon conviction there is anextraordinary risk of flight particularly given the defendant 2s exorbitant wealth his ownership of and access to private planes capable of international travel and his significant international ties Indeed the arrest of the defendant occurred when he arrived in the United States on his private jet after having returned from a multi-week stay abroad Finally and as detailed herein the Government has real concerns 227grounded in past experience with this defendant 227that if allowed to remain out on bail the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case including victims and their families and otherwise attempt to obstruct justice Asa result he poses both an acute danger to the community including some of its most vulnerable members and a significant risk of flight The defendant,thus cannot overcome the statutory presumption that detention is appropriate in this case and the Court should order that be detained pending trial I CA/Aronberg-0905 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM VIAECF TheJionorable Henry Pitman United States Di trict Court S.outhern Distri:ct-ofNew York United States Courthouse Pearl Street New York New York I U.S DepartmentofJustice Uni/ed Stat,es A_ttwney I S9uthern D1stnctofNqv Yqrk The Silvio i.io/ld Building One Saint Andrew Plaza New:York New York 2Ql9 Re Uni edStates Jeffrey Epstein Cr RMB Dear Judge Pi tnian The Government respectfully submits this letter advauce of the bail hearing scheduled for.July 2Pl in the above capJioned case Forthe reasons set forth herein the Court should order that the defendant be detained pending trial he cart not meethis burden of overcoming the presumption that there-is no combination of conditions that would reasonably assure his torttinued appearance in thi case or protect th safety the community were he to released As set_ forth below the charges in this case are exceptionally serious the defendant is alleged tci be a serial Sexual predator who pteyed cni dozens of mi hot girls over a period of 267years and he nowfaces a potentially massive ptison sentence predicated oh substantial and multifaceted evidence of his guilt In light of the strength of the Governments evidence and the substantial incarceratory tenn the clefendant would face upon conviction there is anextraordinary risk of flight partic 265iarly g1 yen the defendants exorbitau.twealth h1s ownership of and access to private planes cap 267able ofinternational travel and his significant international ties Indeed the arrest of the defendartt:occurred when he arrived in the United States oil his private jet after having returned from a multi-week stay abroad Finally and as detailed herein the Government has reai concerns-grounded in past periencewiththis lefendant-that.ifallowedto remain out on bail the defendant could attempt to pressure a:nd intimidate witnesses and potential witnesses in this case including victims a:nd their families and otherwise attempt to obstruct justice As a result he poses both an acute danger to thecommunity incl 265ding i,.om ofits most vulnerable memb rs ancl a i,.ignificantrisk pf flight The defendant;tlius cannot overcome the statutory pr.esu1.ption that detention i appropriate io this case and the Court should order that he be detained pending trial CA Aronberg-09O5 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page BACKGROUND A Overview On July a federal grand jury in the Southern District ofNew York returned a sealed indictment the 223Indictment charging the defendant with one count of sex trafficking of minors in violation of U.S.C and one count of conspiracy to commit sex trafficking of minors in violation of U.S.C As charged by the grand jury the facts underlying the charges in the Indictment arise from a years-long scheme to sexually abuse underage girls In particular beginning in at least the defendant enticed and recruited dozens of minor girls to engage in sex acts with him for which he paid the victims hundreds of dollars in cash i He undertook this activity in at least two different locations including his mansion in Manhattan New York the 223New York Residence and his estate in Palm Beach Florida the 223Palm Beach Residence In both New York and Florida the defendant perpetuated this abuse in similar ways Victims were initially recruited to provide 223massages to the defendant which would be performed nude or partially nude would become increasingly sexual in nature and would typically include one or more sex acts including groping and direct or indirect contact with victims genitals The defendant paid his victims hundreds of dollars in cash for each separate encounter Moreover the defendant actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him In this fashion the defendant created a vast network of underage victims for him to exploit in locations including New York and Palm Beach The defendant 2s victims were as young as years old when he abused them Many of his victims were for various reasons often particularly vulnerable to exploitation The defendant intentionally sought out 227and knew that he was abusing 227minors Indeed in some instances his victims expressly told him they were underage before or during the period in which he abused them In creating and maintaining a network of minor victims whom he abused the defendant worked with others including employees and associates who facilitated his exploitation of minors by among other things contacting victims and scheduling their sexual encounters with the defendant both in New York and in Florida The Defendant Jeffrey Epstein designed financed and perpetrated this scheme both as its main participant and through his direction of others including certain of his employees to further facilitate his rampant abuse of underage girls CA/Aronberg-0906 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge Page2 BACKGROUND I I A Overview I I On July a federal grand jury in the Southern District ofNew York returned a sealed indictment the Indictment charging the defendant with one count of sex trafficking of minors in violation of U.S.C and one count ofconspiracy to commit sex trafficking of minors in violation of U.S.C As charged by the grand jury the facts underlying the charges in the Indictment arise from a years-long scheme to sexually abuse underage girls In particular beginning in at least the defendant enticed and recruited dozens of minor girls to engage in sex acts with him for which he paid the victims hundreds of dollars in cash He undertook this activity in at least two different locations including his mansion in Manhattan New York the New York Residence and his estate in Palm Beach Florida the Palm Beach Residence In both New York and Florida the defendant perpetuated this abuse in similar ways Victims were initially recruited to provide massages to the defendant which would be performed nude or partially nude would become increasingly sexual in nature and would typically include one or more sex acts including groping and direct or indirect contact with victims genitals The defendant paid his victims hundreds of dollars in dash for each separate encounter Moreover the defendant actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him In this fashion the defendant created a vast network of underage victims for him tp exploit in locations including New York and Palm Beach The defendants victims were as young as years old when he abus.ed them Many of his victims were for various reasons often particularly vulnerable to exploitation The defendant intentionally sought out-and knew that he was abusing-minors Indeed in some instances his victims expressly told him they were underage before or during the perioa in which he abused th I in creating and maintaining a network of minor victims whom he abused the defendant worked with others including employees and associates who facilitated his xploitation of minors by among other things contacting victims and scheduling their sexual encounters with the defendant both in New York and in Florida The Defendant i Jeffrey Epstein designed financed and perpetrated this scheme both/as its main participant and through his direction of others including certain of his employees to further facilitate his rampant abuse of underage girls CA/Aronberg-0906 I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Honorable Henry Pitman United States Magistrate Judge July Page As has been widely reported the defendant is extraordinarily wealthy and he owns and maintains luxury properties and residences around the world including in Manhattan New York Palm Beach Florida Stanley New Mexico and Paris France Additionally Epstein owns a private island in the U.S Virgin Islands which as noted above is believed to be his primary residence in the United States His mansion in Manhattan alone multi-story townhouse reported to be one of the largest single residences in all of Manhattan which previously housed a school and which he owns through an LLC 227has been valued at approximately million Entities controlled by the defendant also own at least two private jets in active service at least one of which is capable of intercontinental travel As described further below the defendant possesses three active United States passports and his international connections and travels are extensive For example in addition to maintaining a residence in Paris France as described above in the past months alone the defendant has traveled abroad via private jet either into or out of the country on approximately more than occasions The Prior Florida Investigation In or about the defendant was investigated by local police in Palm Beach Florida in connection with allegations that he had committed similar sex offenses against minor girls The investigation ultimately also involved federal authorities namely the U.S Attorney 2s Office for the Southern District of Florida 223SDFL and the FBI 2s Miami Office and included interviews with victims based in the Palm Beach area including some of the alleged victims relevant to Count One of the instant Indictment.1 In fall the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation which the non-prosecution agreement identified as including investigations into the defendant 2s abuse of minor girls in the Palm Beach area The Southern District of New York was not a signatory to that agreement and the defendant was never charged federally.2 In June the defendant pled guilty in state court to one count of procuring a person under the age of for prostitution a felony and one count of solicitation of prostitution a felony As a result the defendant was designated as a sex offender with registration requirements under the national Sex Offender Registration and Notification Act The non-prosecution agreement further discussed below was entered into at the conclusion of the SDFL investigation and did not purport to cover any victims outside of the State of Florida As noted above the instant Indictment expressly alleges the existence of dozens of victims who were abused in this District in addition to dozens of victims who were abused in Florida While beyond the scope of a bail hearing as discussed further below it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement one District is not bound by the terms of an agreement entered into between a defendant and a U.S Attorney 2s Office in another district See page infra I CA/Aronberg-0907 i FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page I As has been widely reported the defendant is extraordinarily wealthy and he owns and I maintains luxury properties and residences around the world including in Vlanhattan New York Palm Beach Florida Stanley New Mexico and Paris France Addition!ally Epstein owns a private island in the U.S Virgin Islands which as noted above is believed to be his primary residence in the United States His mansion in Manhattan alone-a multi-story townhouse reported to be one of the largest single residences in all of Manhattan which previously housed a school and which he owns through an LLC-has been valued at approximately million Entities controlled by the defendant also own at least two private jets in active service at least one of which is capable of intercontinental travel As described further below the defendant possesses three active United States passports and his international connections and travels are extensive For example in addition to maintaining a residence in Paris France as described above in the past months alone the defendant has traveled abroad via private jet either into or out of the country on approximately more than occasions The Prior Florida Investigation In or about the defendant was investigated by local police in Palm Beach Florida in connection with allegations that he had committed similar sex offenses against minor girls The investigation ultimately also involved federal authorities namely the U.S Attorneys Office for the Southern District of Florida SDFL and the FBIs Miami Office and included interviews with victims based in the Palm Beach area including some of the alleged vic6ms relevant to Count One of the instant lndictment In fall the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation which the non-prosecution agreement identified as including investigations into the defendants abuse of minor girls in the Palm Beach area The Southern District of New York was not a signatory to that agreement and the defendant was never charged federally In June the defendant pied guilty in state court to one count of procuring a person under the age of for prostitution a felony and one count of solicitation of prostitution a felony As a result the defendant was designated as a sex offender with registration requirements under the national Sex Offender Registration and Notification Act The non-prosecution agreement further discussed below was entered into at the conclusion of the SDFL investigation and did not purport to cover any victims outside of the State of Florida As noted above the instant Indictment expressly alleges the existence of dpzens of victims who were abused in this District in addition to dozens of victims who were abused in Florida While beyond the scope of a bail hearing as discussed further below it is lell-established in the I Second Circuit that absent an express provision to the contrary in the agre ment one District is not bound by the terms of an agreement entered into between a defendant and a U.S Attorneys Office in another district See page infra i CA/Aronberg-0907 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page ARGUMENT I I Applicable Law Under the Bail Reform Act U.S.C et seq federal courts are empowered to order a defendant 2s detention pending trial upon a determination that the defendant is either a danger to the community or a risk of flight U.S.C condition or combination of conditions would reasonably assure the appearance of the person as required and the safety of any other person and the community A finding of risk of flight must be supported by a preponderance of the evidence See e.g United States Jackson F.2d 2d Cir United States Chimurenga F.2d 2d Cir A finding of dangerousness must be supported by clear and convincing evidence See e.g United States Ferranti F.3d 2d Cir Chimurenga F.2d at In addition a court may also order detention if there is serious risk that the defendant will attempt to obstruct justice or to threaten injure or intimidate a prospective witness or juror U.S.C see also United States Friedman F.2d 2d Cir The Bail Reform Act lists four factors to be considered in the detention analysis the nature and circumstances of the crimes charged the weight of the evidence against the person the history and characteristics of the defendant including the person 2s 223character and financial resources and the seriousness of the danger posed by the defendant 2s release See U.S.C Evidentiary rules do not apply at detention hearings and the government is entitled to present evidence by way of proffer among other means See U.S.C see also United States LaFontaine F.3d 2d Cir government entitled to proceed by proffer in detention hearings Ferranti F.3d at same United States Martir F.2d 2d Cir same Where a judicial officer concludes after a hearing that condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of any other person and the community such judicial officer shall order the detention of the person before trial U.S.C Additionally where as here a defendant is charged with committing an offense involving a minor victim under U.S.C it shall be presumed subject to rebuttal that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community U.S.C II Discussion The defendant should be detained pending trial For the reasons set forth below it is difficult to overstate the risk of flight and danger to the community if the defendant is released and for those reasons the defendant cannot overcome the statutory presumption in favor of detention in this case I CA/Aronberg-0908 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page4 I Applicable Law ARGUMENT Under the Bail Reform Act U.S.C et seq federal courts are empowered to order a defendants detention pending trial upon a determination that the defendant is either a danger to the community or a risk of flight U.S.C no condition or combination of conditions would reasonably assure the appearance of the person as required and the safety of any other person and the community A finding of risk of flight must be supported by a preponderance of the evidence See e.g United States Jackson F.2p 2d Cir United States Chimurenga 2d 2d Cir A finding of dangerousness must be supported by clear and convincing evidence See e.g United States Ferranti F.3d 2d Cir Chimurenga F.2d at In addition a court may also order detention if there is a serious risk that the defendant will attempt to obstruct justice or to threaten injure or intimidate a prospective witness or juror U.S.C see also United States Friedman F.2d 2d Cir The Bail Reform Act lists four factors to be considered in the detention analysis the nature and circumstances of the crimes charged the weight of the eviden against the person the history and characteristics of the defendant including the persons character and financial resources and the seriousness of the danger posed by the defendants release See U.S.C Evidentiary rules do not apply at detention hearings and the government is entitled to present evidence by way of proffer among other means See S.C see also United States LaFontaine F.3d 2d Cir government entitled to proceed by proffer in detention hearings Ferranti F.3d at same United States Martir F.2d 2d Cir same Where a judicial officer concludes after a hearing that no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of any other person and the community such judicial officer shall order the detention of the person before trial U.S.C Additionally where as here a defendant is charged with committing an offense involving a minor victim under U.S.C it shall be presumed subject to rebuttal that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community U.S.C II Discussion The defendant should be detained pending trial For the reasons set forth below it is difficult to overstate the risk of flight and danger to the community if the defendant is released and for those reasons the defendant cannot overcome the statutory presumption in favor of detention in this case CA/Aronberg-0908 I I I I I I I I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I Honorable Henry Pitman United States Magistrate Judge July Page A The Defendant Poses an Extreme Flight Risk Each of the relevant factors to be considered as to flight risk the nature and circumstances of the offense the strength of the evidence and the history and characteristics of the defendant counsel strongly in favor of detention The Nature and Circumstances of the Offense and the Strength of the Evidence The 223nature and circumstances of this offense plainly favor detention U.S.C specifically enumerating 223whether the offense involves a minor victim as a factor in bail applications Indeed the crime of sex trafficking of a minor is so serious that for a defendant charged with that offense there is a presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community U.S.C Here as specified in the Indictment the defendant 2s conduct was committed serially over a period of years and affected dozens.of victims The seriousness of the charge is also reflected in the penalties the defendant faces which include up to years of incarceration for Counts One and Two of the Indictment.3 As the Second Circuit has noted the possibility of a severe sentence is a significant factor in assessing the risk of flight See Jackson F.2d at see also United States Cisneros F.3d 10th Cir defendant was a flight risk because her knowledge of the seriousness of the charges against her gave her a strong incentive to abscond United States Townsend F.2d 9th Cir 223Facing the much graver penalties possible under the present indictment the defendants have an even greater incentive to consider flight Here the defendant is facing a statutory maximum of decades in prison Even in the absence of means 227which as discussed in detail below the defendant has in abundance 227this fact alone would provide a compelling incentive for anyone to fail to appear It is particularly compelling for a defendant who is years old and therefore faces the very real prospect of spending the rest of his life in prison if convicted The likelihood of a substantial period of incarceration is buttressed by the strength of the evidence As set forth in the Indictment the evidence in this case is strong The Indictment alleges that the defendant sexually abused dozens of minor victims and the conspiracy count lists numerous overt acts committed in furtherance of the defendant 2s crimes.4 The current penalties for violations of U.S.C include a year mandatory minimum sentence However that punishment was created through an amendment to the statute in The penalty for a violation of Section during the period charged in the Indictment and therefore relevant here was a maximum of years imprisonment With respect to the evidence in this case the Court should start its analysis by accepting that the Indictment is sufficient on its own to establish probable cause that the defendant committed the crimes of sex trafficking and sex trafficking conspiracy Contreras F.2d at 223Were an evidentiary hearing addressing the existence of probable cause required in every case in which an indictment had been filed the court would spend scarce judicial resources considering that which a grand jury had already determined and have less time to focus on the application of CA/Aronberg-0909 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Heniy Pitman United States Magistrate Judge Page A The Defendant Poses an Extreme Flight Risk Each of the relevant factors to be considered as to flight risk-the nature and circumstances of the offense the strength of the evidence and the histoiy and characteristics of the defendant counsel strongly in favor of detention The Nature and Circumstances of the Offense and the Strength of the Evidence The nature and circumstances of this offense plainly favor detention U.S.C specifically enumerating whether the offense involves a minor victim as a factor in bail applications Indeed the crime of sex trafficking of a minor is so serious that for a defendant charged with that offense there is a presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the I community U.S.C Here as specified in the Indictment the defendants conduct was committed serially over a period of years and affected dozens.of victims The seriousness of the charge is also reflected in the penalties the defendant faces which include up to years of incarceration for Counts One and Two of the lndictment.3 As the Second Circuit has noted the possibility of a severe sentence is a significant factor in assessing the risk of flight See Jackson F.2d at see also United States Cisneros F.3d 10th Cir defendant was a flight risk because her knowledge of the seriousness of the charges against her gave her a strong incentive to abscond United States Townsend F.2d 9th Cir Facing the much graver penalties possible under the present indictment the defendants have an even greater incentive to consider flight Here the defendant is facing a statutoiy maximum of decades in prison Even in the absence of means-which as discussed in detail below the defendant has in abundance-this fact alone would provide a compelling incentive for anyone to fail to appear lt is particularly compelling for a defendant who is years old and therefore faces the veiy real prospect of spending the rest of his life in prison if convicted The likelihood of a substantial period of incarceration is buttressed by the strength of the evidence As set forth in the Indictment the evidence in this case is strong The Indictment alleges that the defendant sexually abused dozens of minor victims and the conspiracy count lists numerous overt acts committed in furtherance of the defendants crimes The current penalties for violations of U.S.C include a year mandatoiy minimum sentence However that punishment was created through an amendment to the statute in The penalty for a violation of Section during the period charged in the Indictment and therefore relevant here was a maximum of years imprisonment With respect to the evidence in this case the Court should start its analysis by accepting that the Indictment is sufficient on its own to establish probable cause that the def ndant committed the crimes of sex trafficking and sex trafficking conspiracy Contreras F.2d at Were an evidentiaiy hearing addressing the existence of probable cause required in eteiy case in which an indictment had been filed the court would spend scarce judicial tesources considering that which a grand juiy had already determined and have less time to focu on the application of CNAronberg-0909 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I Honorable Henry Pitman United States Magistrate Judge July Page Multiple victims including several specified in the Indictment have provided information against the defendant That information is detailed credible and corroborated in many instances by other witnesses and contemporaneous documents records and other evidence 227including as further detailed below evidence from a search of the New York Residence on the night of the defendant 2s arrest that reflects an extraordinary volume of photographs of nude and partially-nude young women or girls Such corroborating evidence also includes documents and other materials such as contemporaneous notes messages recovered from the defendant 2s residence that include names and contact information for certain victims and call records that confirm the defendant and his agents were repeatedly in contact with various victims during the charged period Put simply all of this evidence the voluminous and credible testimony of individuals who were sexually abused by the defendant as minors each of whom are backed by other evidence will be devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention Finally it bears noting that neither the age of the conduct nor the defendant 2s previous non prosecution agreement 223NPA with a different federal district pose any impediment to his conviction As an initial matter all of the conduct is timely charged pursuant to U.S.C which was amended in to extend the limitations period for conduct that was timely as of the date of the amendment to any time during the lifetime of the minor victim See United States Chief F.3d 9th Cir finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running the extension was permissible United States Pier re-Louis No 16Cr CM WL at S.D.N.Y Aug same Moreover with respect to the NPA that agreement to which the Southern District of New York was not a party which by its express language pertained exclusively to the SDFL investigation and which not purport to bind any other Office or District does not preclude prosecution in this District for at least two reasons First it is well settled in the Second Circuit that plea agreement in one U.S Attorney 2s office does not unless otherwise stated bind another United States Prisco App 2x 2d Cir plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction citing United States Annabi F.2d 2d Cir per curiam This is true even if the text of the agreement purports to bind 223the Government See Annabi Tl F.2d at This analysis similarly extends to a non-prosecution agreement See United States Laskow Supp E.D.N.Y 223Defendant 2s argument in effect is that unless there is an explicit statement to the contrary it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are not parties to the agreement This position is at odds with the law in this Circuit which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated citing Annabi F.2d at Second the Indictment charges conduct not covered by the NPA namely the presumptions and the factors in deciding whether the defendant should be detained I CA/Aronberg-0910 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page6 Multiple victims including several specified in the Indictment have provided information against the defendant That information is detailed credible and corroborated in many instances by other witnesses and contemporaneous documents records and other evidence-including as further detailed below evidence from a search of the New York Residenc.e on the night of the defendants arrest that reflects an extraordinary volume of photographs of nu.de and partially-nude young women or girls Such corroborating evidence also includes documents and other materials such as contemporaneous notes messages recovered from the defendants residence that include names and contact information for certain victims and call records that confirm the defendant and his agents were repeatedly in contact with various victims during the charged period Put simply all of this evidence the voluminous and credible testimony of individuals who were sexually abused by the defendant as minors each of whom are backed up by other evidence will be devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention Finally it bears noting that neither the age of the conduct nor the defendants previous non prosecution agreement NPA with a different federal district pose any impediment to his conviction As an initial matter all of the conduct is timely charged pursuant to U.S.C which was amended in to extend the limitations period for conduct that was timely as of the date of the amendment to any time during the lifetime of the minor victim See United States Chief F.3d 9th Cir finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running the extension was permissible United States Pierre-Louis No Cr CM WL at S.D.N.Y Aug same Moreover with respect to the NPA that agreement to which the Southern District of New York was not a party which by its express language pertained exclusively to the SDFL investigation and which did not purport to bind any other Office or District does not preclude prosecution in this District for at least two reasons First it is well settled in the Second Circuit that a plea agreement in one U.S Attorneys office does not unless otherwise stated bind another United States Prisco Appx 2d Cir A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction citing United States Annabi F.2d 2d Cir per curiam This is true even if the text of the agreement purports to bind the Government See Annabi F.2d at This analysis similarly extends to a non-prosecution agreement See United States Laskow Supp E.D.N.Y Defendants argument in effect is that unless there is an explicit statement to the contrary it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are not parties to the agreement This position is at odds with the law in this Circuit which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated citing Annabi F.2d at Second the Indictment charges conduct not covered by the NPA namely I I the presumptions and the factors deciding whether the defendant should be detained CNAronberg-091 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page conduct that occurred in New York The prior NPA included a list of several dozen victims identified in the prior investigation all of whom were abused in the State of Florida and none of whom are a part of the conduct charged in Count Two of the instant Indictment Each of these factors 227the seriousness of the allegations the strength of the evidence and the possibility of lengthy incarceration 227creates an extraordinary incentive to flee And as further described below the defendant has the means and money to do so The Characteristics of the Defendant The history and characteristics of the defendant also strongly support detention The defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt to flee Indeed his potential avenues of flight from justice are practically limitless As the defendant acknowledged in his most recent New York State sex offender registration he has six residences including two in the U.S Virgin Islands including his own private island and one each in Palm Beach Florida Paris France New York New York and Stanley New Mexico The most recent estimated value of the defendant 2s New York City mansion alone is more than million The most recent tax-assessed value of the defendant 2s Palm Beach estate is more than million The defendant 2s primary residence is a private island in the U.S Virgin Islands a place where any sort of meaningful supervision would be all but impossible Moreover the defendant has access to innumerable means to flee His sex registration documentation of 223current vehicles lists no fewer than motor vehicles including seven Chevrolet Suburbans a cargo van a Range Rover a Mercedez-Benz sedan a Cadillac Escalade and a Hummer II These cars are registered in various states and territories including the Virgin Islands New York Florida and New Mexico The defendant also has access to two private jets giving him the ability to leave the country secretly and on a moment 2s notice and to go virtually anywhere he wants to travel He is a very frequent international traveler and regularly travels to and from the United States by private plane In particular between January and the present U.S Customs and Border Patrol has logged approximately more than flights in which Epstein was traveling to or from a foreign country Indeed he was arrested at Teterboro Airport arriving on just such a private international flight after having spent approximately three weeks abroad Extensive international travel of this nature further demonstrates a significant risk of flight See e.g United States Anderson Supp 2d D.D.C There can be no assurance that upon release the defendant would suddenly lack access to such means of travel Finally the defendant has no meaningful ties that would keep him in this country The defendant has no known immediate family He is not married and has no children He has friends and associates worldwide as demonstrated by his extensive international travel and his professional obligations if any can and seemingly are plainly capable of being handled by the defendant remotely Simply put there would be no meaningful reason for the defendant to remain in the country while he would have every incentive and every resource needed to flee Nor would home confinement with electronic monitoring reasonably assure the defendant 2s presence as required At best home confinement with electronic monitoring would CA/Aronberg-0911 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page conduct that occurred in New York The prior NP A included a list of leveral dozen victims I identified in the prior investigation all of whom were abused in the State of Florida and none of whom are a part of the conduct charged in Count Two of the instant Indictnient Each of these factors-the seriousness of the allegations the strength of the evidence and the possibility of lengthy incarceration-creates an extraordinary incentive to flee And as further described below the defendant has the means and money to do so The Characteristics of the Defendant The history and characteristics of the defendant also strongly support detention The defendant is extraordinarily 267wealthy and has access to vast financial resources to fund any attempt to flee Indeed his potential avenues of flight from justice are practically limitless As the defendant acknowledged in his most recent New York State sex offender registration he has six residences including two in the U.S Virgin Islands including his own private island and one each in Palm Beach Florida Paris France New York New York and Stanley New Mexico The most recent estimated value of the defendants New York City mansion alone is more than million The most recent tax-assessed value of the defendants Palm Beach estate is more than million The defendants primary residence is a private island in the U.S Virgin Islands a place where any sort of meaningful supervision would be all but impossible Moreover the defendant has access to innumerable means to flee His sex registration documentation of current vehicles lists no fewer than motor vehicles including seven Chevrolet Suburbans a cargo van a Range Rover a Mercedez-Benz sedan a Cadillac Escalade and a Hummer II These cars are registered in various states and territories including the Virgin Islands New York Florida and New Mexico The defendant also has access to two private jets giving him the ability to leave the country secretly and on a moments notice and to go virtually anywhere he wants to travel He is a very frequent international traveler and regularly travels to and from the United States by private plane In particular between January and the present U.S Customs and Border Patrol has logged approximately more than flights in which Epstein was traveling to or from a foreign country Indeed he was arrested at Teterboro Airport arriving on just such a private international flight after having spent approximately three weeks abroad Extensive international travel of this nature further demonstrates a significant risk of flight See e.g United States Anderson Supp 2d D.D.C There can be no assurance that upon release the defendant would suddenly lack access to such means of travel Finally the defendant has no meaningful ties that would keep him in this country The defendant has no known immediate family He is not married and has no children He has friends and associates worldwide as demonstrated by his extensive international travel and his professional obligations if any can and seemingly are plainly capable of being handled by the defendant remotely Simply put there would be no meaningful reason for the defendant to remain I in the country while he would have every incentive and every resource ne eded to flee I Nor would home confinement with electronic monitoring r6asonably assure the defendants presence as required At best home confinement with electrdnic monitoring would I CA/Aronberg-0911 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page merely reduce his head start should he decide to flee See United States Zarger No Cr WL at E.D.N.Y Aug Gleeson rejecting defendant 2s application for bail in part because home detention with electronic monitoring best limits a fleeing defendant 2s head start see also United States Casteneda No Cr WL at N.D Cal Feb same United States Anderson F.Supp.2d D.D.C same United States Benatar No Cr WL at E.D.N.Y Oct same Finally there can be little doubt that the defendant is in a position to abandon millions of dollars in cash and property-381.4 securing any potential bond and still live comfortably for the rest of his life These resources and the ease with which the defendant could flee and live outside the reach of law enforcement 227particularly considering his vast wealth and lack of meaningful ties to this District 227make the risk of flight exceptionally high in this case particularly when considered in conjunction with the strength of the government 2s case and the lengthy sentence the defendant could receive if convicted i The Defendant Poses a Risk of Danger to the Community and of Engaging in Obstruction of Justice i The release of the defendant under any conditions would pose a significant threat to the community and to the ongoing investigation As described above where there is probable cause to believe that an individual has committed an offense under U.S.C it is presumed that no condition or combination of conditions can reasonably assure the safety of the community U.S.C Here not only is the defendant charged with very serious sex crimes against minors he has already previously admitted to 227and been convicted of 227engaging in related conduct Specifically in June the defendant pled guilty in state court to one count of procuring a person under the age of for prostitution a felony and he currently is a registered sex offender under classification level three in New York 227defined as presenting a 223high risk of committing another sex crime and harm to the community While the conduct presently allegeddoes not post-date the conviction it nevertheless underscores the risk he poses to the community if released Additionally and in connection with the investigation of the defendant 2s offense in Florida there were credible allegations that the defendant engaged in witness tampering harassment or other obstructive behaviors In fact according to publicly-filed court documents there were discussions between prosecutors and the defendant 2s then-counsel about 2the possibility of the defendant pleading guilty to counts relating to 223obstruction as well as 223harassment with reference to U.S.C which criminalizes 223tampering with a witness victim or informant For example in a communication from the defendant 2s then-counsel to prosecutors in SDFL his counsel set forth a possible factual proffer that included statements that the defendant had 223attempted to harass both redacted delay and hinder their receipt of a redacted to attend an official proceeding and that the defendant particular changed travel plans and flew with both redacted to the United States Virgin Islands rather than to an airport in Jew Jersey in order to attempt to delay their receipt of what Mr Epstein expected to be a redacted and 223further verbally CA/Aronberg-0912 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page merely reduce his head start should he decide to flee See United States Zarger No Cr WL at E.D.N.Y Aug Gleeson rejecting fendants application for bail in part because home detention with electronic monitoring at be limits a fleeing defendants head start see also United States Casteneda No Cr WL at N.D Cal Feb same United States Anderson F.Supp.2d D.D.C same United States Benatar No Cr WL at E.D.N.Y Oct same Finally there can be little doubt that the defendant is in a position to abandon millions of dollars in cash and property securing any potential bond and still live comfortably for the rest of his life These resources and the ease with which the defendant could fl and live outside the reach of law enforcement-particularly considering his vast wealth and lack of meaningful ties to this District-make the risk of flight exceptionally high in this case particuiarly when considered in conjunction with the strength of the governments case and the lengthy s_entence the defendant could receive if convicted The Defendant Poses a Risk of Danger to the Community and of Engaging in Obstruction of Justice The release of the defendant under any conditions would pose a significant threat to the community and to the ongoing investigation As described above where there is probable cause to believe that an individual has committed an offense under U.S.C it is presumed that no condifion or combination of conditions can reasonably assure the safety of the community U.S.C Here not only is the defendant charged with very serious sex crimes against minors he has already previously admitted to-and been convicted of-engaging in related conduct Specifically in June the defendant pied guilty in state court to one count of procuripg a person under the age of for prostitution a felony and he currently is a registered sex offender under classification level three in New York-defined as presenting a high risk of committing another sex crime and harm to the community While the conduct presently allegedldoes not post-date the conviction it nevertheless underscores the risk he poses to the comm nity if released Additionally and in connection with the investigation of the defendants offense in Florida there were credible allegations that the defendant engaged in witness tampering harassment or other obstructive behaviors In fact according to publicly-filed court documents there were discussions between prosecutors and the defendants then-counsel about the possibility of the defendant pleading guilty to counts relating to obstruction as well as harassment with reference to U.S.C which criminalizes tampering with witness victim or informant For example in a communication from the defendants then-counsel to prosecutors in SDFL his counsel set forth a possible factual proffer that included statem:ents that the defendant I had attempted to harass both redacted delay and hinder their receipt of a redacted to attend an official proceeding and that the defendant in particular changed travel plhns and flew with both redacted to the United States Virgin Islands rather than to an airport in ew Jersey in order to attempt to delay their receipt of what Mr Epstein expected to be a redacted and further verbally CA/Aronberg-0912 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page harassed both redacted in connection to this attempt to delay their voluntary receipt of process all in violation of USC Doe United States Civ S.D Fla Dkts at through In addition to U.S.C prosecutors also proposed that the defendant could plead guilty to U.S.C that is a knowing of intentional violation of the privacy protection of child victims and child witnesses to which the defendant 2s then counsel replied 223Already thinking about the same statutes Id Dkt They also discussed a possible obstruction plea that 223could rely on the incident where Mr Epstein 2s private investigators followed redacted father forcing off the road Id Dkt The defendant 2s apparent previous willingness to obstruct a federal investigation harass or tamper with witnesses and hire private investigators that 223forced off the road the father of an individual relevant in the investigation is alarming It should especially weigh on the Court 2s consideration here because the defendant was apparently willing to take those steps before even being charged and thus facing federal indictment the incentive to interfere in the Government 2s case here where an Indictment has been returned is exponentially greater And as discussed above the defendant has nearly limitless means to do so Finally despite having been previously convicted of a sex offense involving an underage victim the defendant has continued to maintain a vast trove of lewd photographs of young-looking women or girls in his Manhattan mansion In a search of the New York Residence on the night of his arrest on July pursuant to judicially-authorized warrants law enforcement officers discovered not only specific evidence consistent with victim recollections of the inside of the mansion further strengthening the evidence of the conduct charged in the Indictment but also at least hundreds 227and perhaps thousands sexually suggestive photographs of fully or partially nude females While these items were only seized this weekend and are still being reviewed some of the nude or partially-nude photographs appear to be of underage girls including at least one girl who according to her counsel was underage at the time the relevant photographs were taken Additionally some of the photographs referenced herein were discovered in a locked safe in which law enforcement officers also found compact discs with hand-written labels including the following 223Young Name Name 223Mise nudes and 223Girl pics nude The defendant a registered sex offender is not reformed he is not chastened he is not repentant;6 rather he is a continuing danger to the community and an individual who faces devastating evidence supporting deeply serious charges The redactions above are contained in the publicly filed version of the quoted document See e.g Amber Southerland Billionaire Jeffrey Epstein I 2m a sex offender not a predator N.Y Post not a sexual predator I 2m an 223offender the financier told The Post yesterday 2s the difference between a murderer and a person who steals a bagel Philip Weiss The Fantasist New York Magazine the Icarus story someone who flies too close to the sun I said 221Did Icarus like massages Epstein asked CA/Aronberg-0913 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page harassed both redacted in connection to this attempt to delay their voluntary receipt of process all in violation of USC Doe United States Civ S.D Fla Dkts I at through In addition to U.S.C prosecutors also proposed that the defendant could plead guilty to U.S.C that is a knowing or intentional violation of the privacy protection of child victims and child witnesses to which the defendants then counsel replied Already thinking about the same statutes Id Dkt They also discussed a possible obstruction plea that could rely on the incident where Mr Epsteins private investigators followed redacted father forcing off the road Id 0kt The defendants apparent previous willingness to obstruct a federal investigation harass or tamper with witnesses and hire private investigators that forced off the road the father of an individual relevant in the investigation is alarming It should especially r"eigh on the Courts consideration here because the defendant was apparently willing to take those steps before even being charged and thus facing federal indictment the incentive to interfere in the Governments case here where an Indictment has been returned is exponentially greater And as discussed above the defendant has nearly limitless means to do so Finally despite having been previously convicted of a sex offense involving an underage victim the defendant has continued to maintain a vast trove oflewd photographs of young-looking women or girls in his Manhattan mansion In a search of the New York Residence on the night of his arrest on July pursuant to judicially-authorized warrants law enforcement officers discovered not only specific evidence consistent with victim recollections of the inside of the mansion further strengthening the evidence of the conduct charged in the Indictment but also at east hundreds-and perhaps thousands-of sexual I suggestive photographs of fully or partial nude females While these items were only seized this weekend and are still being reviewed some of the nude or partially-nude photographs appear to be of underage girls including at least one girl who according to her counsel was underage at the time the relevant photographs were taken Additionally some of the photographs referenced herein were discovered in a locked safe in which law enforcement officers also found compact discs with hand-written labels including the following Young Name Name Misc nudes and Girl pies nude The defendant a registered sex offender is not reformed he is not chastened he is not repentant rather he is a continuing danger to the community and an individual who faces devastating evidence supporting deeply serious charges The redactions above are contained in the publicly filed version of the quoted document See e.g Amber Southerland Billionaire Jeffrey Epstein Im a sex offender not a predator N.Y Post Im not a sexual predator Im an offender the financier told The Post yesterday Its the difference between a murderer and a person who ste11 a bagel Philip Weiss The Fantasist New York Magazine Its the Icarus story omeone who flies too close to the sun I said Did Icarus like massages Epstein asked CA/Aronberg-0913 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge July Page CONCLUSION set forth above in this case the risk of flight in this case.is extraordinarily real The defendant is extremely wealthy has extensive foreign contacts and is charged with serious offenses that carry a potential statutory sentence of up to years imprisonment 227even a fraction of which could result in the defendant who is years old spending the rest of his life in ail In sum the defendant 2s transient lifestyle his lack of family or community ties his extensive international travel and ties outside the country and his vast wealth including his access to and ownership of private planes all provide the defendant with the motive and means to become a successful fugitive Further the nature of the offenses he is alleged to have perpetrated 227the abuse dozens of underage vulnerable girls 227along with his demonstrated willingness to harass intimidate and otherwise tamper with.victims arid other potential witnesses against him render his dangerousness readily apparent Accordingly the Government respectfully submits that the defendant cannot and will not be able to meet his burden of overcoming the strong presumption in favor of detention that there are ho Conditions of bail that would assure the defendant presence in court proceedings in thi case or protect the safety of the community and that any application for bail should be denied Very truly yours GEOFFREY BERMAN United/States Attorney By:_ Alex Rossmiller Alison Moe/Maurene Comey Assistant United States Attorney Southern District of New York Tel CC Martin Weinberg Esq and Reid Weingarten Esq counsel for defendant Hon Richard Berman United States District Judge CA/Aronberg-0914 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Honorable Henry Pitman United States Magistrate Judge JulyS,2019 Page CONCLUSION As set forth above in this case the risk of flight in this case is extraordinarily real The defenciant is e,ctremely wealthy 1s extensiye fore,igl contcJcts i:tn_d is charged wi seri_ous offenses that.carry a potential stafutqry sentence Qf t1p to years 1mprisonn.ient_:__even afractiQn ofwhi.C:h could result in the defendant who is year:s old spending the rest of his life inJail In sum the defendants transient lifestyle his lack of family or community ties his extensive international travel anil ties outside the country and I1is vasfwealth including his access to and owner_ship of pr.ivate planes all pr9yide the fendant with the motive anci mei:tns become a successful fugi_tive Further the nature of-the offenseS:he is alleged to.have:perpetrated_..:the abuse dozens of underage vulnerable girls:-along with his demonstrated Willingness to harass intimidate a:nd otherwisetamperwith.victims:ahd other potential witnesses against him,reilder his dangerouSileSSreadily apparent Accordillgly 267the Government respectfully submits that the-defendant cannot and wilL not be a:bleJo meethis burden ofovercoming the strong presumption in favor ofdetention that there are ho conditions of bail that would assure the defenda presence in court proceedings in thi case orprotectthe safety ofthe community and that any application for bail should be denied Very tlJly yours By Alex Rossmiller Alison Moe Maurene Corney AssistantUnited States Attorney Southern DistrictofNew York Tel Cc Martin Weinberg Esq and Reid Weingarten Esq counselfor defehdant Hon Richard Berfuan United States District Judge CA Aronberg-0914 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i Appendix CA/Aronberg-0915 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CA/Aronberg-0915 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Lnitccl Stures Dcpnxrmcfir nJ.lustice THE UNITED STATES ATTORNEY 2S OFFICE SOUTHERN pl STRICT 0NEW YORK I U.S Attorneys Southern District of New York News Press Releases Department of Justice U.S Attorney 2s Office Southern District of New York FOR IMMEDIATE RELEASE Monday July Jeffrey Epstein Charged In Manhattan Federal Court With Sex Trafficking Of Minors Alleged Conduct Occurred in both New York and Florida over Multiple Years Involving Dozens of Victims Geoffrey Berman the United States Attorney for the Southern District of New York William Sweeney Jr the Assistant Director in Charge of the New York Field Office of the Federal Bureau of Investigation 223FBI and Jafhes 2Neill Commissioner of the New York City Police Department 223NYPD announced that JEFFREY EPSTEIN was arrested Saturday and charged with sex trafficking of minors.and conspiracy to commit sex trafficking of friiriors The indictment unsealed today alleges that between through EPSTEIN sexually exploited and abused dozens of underage girls by enticing them to engage in sex acts with him in exchange for money Epstein allegedly worked with several employees and associates to ensure that he had a steady supply of minor victims to abuse and paid several of those victims themselves to recruit other underage girls to engage in similar sex acts for money He committed these offenses in locations including New York New York arid Palm Beach Florida EPSTEIN is expected to be presented in Manhattan federal court this afternoon before U.S Magistrate Judge Henry Pitman The case is assigned to U.S District judge Richard Berman U.S Attorney Geoffrey Berman said 223As.alleged Jeffrey Epstein abused underage girls for years operating a scheme in which girls he victimized would recruit others for Epstein to fexploit and abuse Epstein exploited girls who were vulnerable to abuse enticed them with cash payments and escalated his conduct to include sex acts often occurring at his residence on the Upper East Side of Manhattan While the charged conduct,is from a number of years ago the victims then children and now young women are no less entitled to their day in court My Office is proud to stand up for these victims by bringing this indictment FBI Assistant Director William Sweeney Jr said are asking anyone who may have been victimized by Jeffrey Epstein or anyone who may have information about his alleged criminal behavior to please call us The number is 1-800-CALL-FBI We want to hear from you regardless of the age you are now or whatever age you were then no matter where the incident took place The bravery it takes to call us might empower others to speak out about.the crirnes committed,against them It is important to remember there was never nor will there ever an excuse for this type of behavior In the eyes of the FBI the victims will always come first CA/Aronberg-0916 I FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i Ll 1!tcd,St rcs8epr1Fmf_ 11fJusti THE UN!Tf::D STATES TTORNEYS,OFFIC SOUTHERN QlSTRICI 247NEW YORK U.S Attorney Southern District.of New York News Press Releases_ DepartmE!m of JusticEl FOR IMMEDIATE RELEASE V.S Attorneys Office Southern Distdct of New York Monday July Jeffrey Epstein Charged In Manhattan Federal Court With Sex Trafficking Of Minors Alleged Conduct Occurred in both New York and Florida over Multiple Years Involving Dozens of Victims Geoffrey Berman the United States Attorney for 267the Southern District of New York William Sweeney Jr the Assistant Dire_ctor in Charge of the New York Field Office of the Federal Burnau of Investigation FBI and James 6:Neifl commissioner of the NewYork City Police Department NYP announced that JEFFREY EPSTEIN was arrested:Saturday and char_gedwith sex trafficking of minors and conspiracy to commit sex trafficking of minors The indictment unsealed today 225alleges that between through EPSTEIN exually exploited i Jnd abusecl dozens of u_nc:lerage girls by enticing tl to engage in_ sex clefs with him in exchange for money Epstein allegedly wor.ke_d with several employees and 267associates to ensure that he had a steady supply of minor victims to abuse and paid several of those victims themselves to recruit other underage girls to engage in similar sex acts for money He committed these offenses in locations including New York New York and Palm Beach Fiorida EPSTEiN is pecfed to be presented in nh_attan fedt:?rc:il cggri this aftemopn before Magistrate Judge Hen_ry P_itman The case is assignecl to U.S District.Judge Richard Berman U.S Attorney Geoffrey Berman said As allege:d Jeffrey Epstein abused underage girls for years operatinQ a scheme in which girls he victimizedwould recruit others for Epstein to exploit and abuse Epstein exploited girls_ who were vulnerable to abuse enticed them with cash payments and 267escalated his conduct to include sex acts otte occurring at residence onJhe Upper East Sitje-of Manhatta Wnile the coarge.d conclqct is fr.o_m i of years agp the yic_!ims th.en chjl lren an novv ye Lmg wcirnen are no less ntitled to their day in court My Office is proud to stand up for these victirr,ts by bringiqg this indictm nt FBI Assistant Director William Sweeney Jr said We are asking anyone.who may have been victimized by Jeffr.ey Epstein qr anyqne who may have information abo Jt his alleged criminal behavior to please call us The number.is t-800-CALLsFBI We want to hear from you regardless of the ag fyou are now or whatever age you were then no matter where the inc;iQEmt took pl ce Ttie _bravery itt to all us_ rnight empower others to speak out about the crimes committed against them It is impdrtant to remember there never nor will there ver be an excuse forthis 267type of pehavior l_n the eye?cif the FBI the victirns w:ill always come first CA Aronberg-0916 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I NYPD Commissioner James 2Neill said 223Today 2s charges serve as a warning to individuals who continue to prey upon some of our society 2s most vulnerable population we are coming for you I thank and commend the U.S Attorney 2s Office for the Southern District and the FBI for their tirelessefforts to ensure child predators are taken off bur streets The NYPD will continue to work with dur law enforcement partners to eradicate the trafficking of children in our city and nation and work to bring justice to victims of these heinous crimes If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein please contact the FBI at FBI and reference this case According to the Indictmentfl unsealed today in Manhattan federal court From at least through at least JEFFREY EPSTEIN enticed-372.6 and recruited and caused to be entice.d and recruited dozens of minor girls to visit his mansion in New York New York the 223New York Residence arid his estate in Palm.Beach Florida the 223Palm Beach Residence to engage in sex acts with him after which he would give the victims hundreds of dollars in cash In order to maintain and increase his supply of victims EPSTEIN also paid certain victims to recruit additional underage girls whom ha could similarly abuse In this way EPSTEIN created a vast network of underage victims for him to sexually exploit often on a daily basis in locations including New York and Palm Beach EPSTEIN 2s victims were as young as at the time he abused them and were for various reasons often particularly vulnerable to exploitation Moreover EPSTEIN knew that many of his victims were under including because in some instances victims expressly told him they were underage In creating and maintaining this network of minor victims in multiple states to abuse and exploit sexually EPSTEIN worked with others including employees and associates who facilitated his conduct by among other things contacting victims and scheduling their sexual encounters with EPSTEIN at,the New York Residence and at the Palm Beach Residence In both New York and Florida EPSTEIN perpetuated this abuse in similar ways Victims were initially recruited to provide 223massages to EPSTEIN which became increasingly sexual in nature and would typically include one dr more sexacts EPSTEIN paid his victims hundreds of dollars in cash for each encounter In particular during encounters at the New York Residence victims would be taken to a room where they would perform a massage on EPSTEIN during which EPSTEIN would frequently escalate the nature and scope of physical contact with his victims to include among other things sex actssuch as groping and direct and indirect contact with the victims genitals In connection with the encounters EPSTEIN or one of his employees or associates typically paid each victim hundreds of dollars in cash Once minor victims were recruited EPSTEIN or his employees or associates would contact victims to schedule appointments for 223massages As a result many victims were abused by EPSTEIN oh multiple subsequent occasions To further enable to abuse underage girls EPSTEIN asked and enticed certain of his victims to recruit additional minor girls to perform 223massages and similarly engage in sex acts with EPSTEIN When a victim would recruit another underage girt for EPSTEIN he paid both the victim-recruiter and the new victim hundreds of dollars in cash Through these victim-recruiters EPSTEIN maintained a steady supply of new victims to exploit and gained access to dozens of additional underage girls to abuse i JEFFREY EPSTEIN is charged with one count of sex trafficking of minors which carries a maximum sentence of years in prison one count of conspiracy to engage in sex trafficking of minors which carries a maximum sentence of five years in prison CA/Aronberg-0917 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM NYPD Commissioner 267James d.Neill said Todays charges serve as a warning individuals who continue to prey upon some of our societys most vulnerable population we are cohiing forsou I thank and I cQrnmend the AttQrr:,efs Office Jor the Southern District and the FBI for their tireless effQrts to ensure child predators are taken off our streets The NYPD will continue to work with our law enforcement partners to eradicate the tra ffic-kin qf chilclrer in our ity and nc1tion-aocl w-orkt9 bring just--ic_el_ to victims of these heinous crimes._ If you b:elieve you are a Victim of the sexual al Use perpetrated by J.effrey Ep tein please contact the FBI at FBl,-and reference this case According to the lndictrnent1 unsealed today in Manhattan federal court From at least through at least JEFFREY EPSTEIN enticed and recruited and caused to be entice_d and recruited oo.ze_ns of minor girls to visit his mansiprJ in New Yo.Jk New 267York the New rk Residence arid his estate in Palm Beach Florida the Palm Beach Residence to engage in sex acts with him after which he would give the victims hundreds of dollars in cash In order to maintain and increase his supply of victims EPSTEI Nalso paid certain victims to recr,uit additional underage girts whom he could similarly abuse In this way EPSTEIN created a vast network of underage victlms for him to sexually exploit oft.en or a dailY asis in locations including New Yqrk c1ng Palm Beach EPSJEINs victims were as young as at the tim_e he abused them and were for various reasons often particularly vu Iner.able to exploitation Moreover EPSTEIN knew that many of his Victims were under including because in some instances victims expressly told him they were underage in creating and maintaining this network of minor vlctirns in multiple states to abuse and exploit sexually EPSTEIN worked with others including employees and associates who facilitated his conduct by among either things contacting victims and scheduling their sexuai encounters with EPSTEIN at the New York Resic:leJ1 clnd at the Pa.lrn e.aQh Residence Jn _1 oth New York anq FJ9rida EPSTEIN per;petuated th.is at yse in similar ways v.idims were initially recruited to provide massages to EPSTEIN which became increasingly sexual in nature and would typically include one or more sex acts EPSTEIN paid his victims hundreds of dollars in cash for each enco_unter In particular c:IUring encquriters at the Ne lV York Residence victims would be taker to a room wti,ere they wouldperform-a massage on EPSTEIN during Which EPSTEIN would frequently escalate the nature and scope of physical contc:1ct with his 267victims to Jnclu le among,other things seX acts such _as groping and direct and in.direct co:ntact with the victims genitals In cqnnection with the e_ncounters EPSTEIN or one of his employees or associates typically paid each victim hundreds of dollars in cash Once rnirior victims were recruited EPSTEIN or his employe orassqciates would tQntac_tvictims tq schedule appQintments for massages As a res many vidims were abu 267sed by EPSTEIN on multiple subsequent occasions To further enable him to abuse underage girls EPSTEIN asked and enticed certain of his victims to recruit ad_ditio_nc!I minorgirts to PElrform massages and s_im_ilarty engaQe in acts with EPSTEIN VVhen a vic.tirn would re.cruit another underage girt for EPSTEIN he paid b.oth the victim recruiter and the new victim hundreds of doilars in cash Through these victi recruiters EPSTEIN maintafned a steady supply of new victims to exploit and gajneq acc_ess to dozens of addi.tional unqerage girls to abuse JEFFREY EP TEIN is c.harg wit_h Oil co1,1nJ of x.trafficking of _rn_i_nors whicb 9a_rries rn xi.!J1.um sentence of years in prison and o_ne count of conspiracy to engage in sex traffi,cking of minors which carries a maximum sentence offiVeyears in prison I I CA Aronberg-0917 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM The statutory maximum and mandatory penalties are prescribed by Congress and are provided here for informational purposes only as any sentencing of the defendant would be determined by the judge IVIr Berman praised the outstanding investigative work of the FBI and the NYPD He also thanked the U.S Customs and Border Protection for their assistance This case is being handled by the Office 2s Public Corruption Unit Assistant U.S Attorneys Alex Rossmiller Alison Moe and Maurene Comey are in charge of the prosecution with assistance from the Office 2s Human Trafficking Co-Coordinator Abigail Kurland The charges contained in the Indictment are merely accusations The defendant is presumed innocent unless and Until proven guilty As the introductory phrase signifies the entirety of the text of the Indictment and the description of the Indictment set forth herein constitute only allegations and every fact described therein should be treated as an allegation i Attachment Download U.S Jeffrey Epstein Indictment Topic Project Safe Childhood Component USAO New York Southern Press Release Number i Updated July CA/Aronberg-09.18 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM The statutory maximum and mandatory penalties are prescribed by Congress and are provided here for informational purposes only as any 267sentencing ofthe defendant would be determi ed by the judge Mr B.erman r.a the ou.tst.an.di 267inv.estig ativ.e work of the FBI and the NYPD also thanked the U.S Customs and Border Prqtection Jor their assistance This case is being handled by the Offic::es Public Corruption Unit Assistant U.S Attorneys Alex Rossmiller Alison Moe and Maurene Corney are in charge ofthe prosecution with assistanc from the Offices Human Trafficking Co.-Coordinator Abigail Kurland I The charges contained in the Indictment are merely accusations The defendant is presumed innocent unless and until proven guilty I As the introductory phrase signifies the entirety of the text of the Indictment an:d the description of the Indictment set forth herein constitute only allegations and every fact described th rein should be treated as an allegation Attach1ent Download U.S Jeffrey_J;12stein Indictment Topic ProjectSafe Childhood Comporierit USAO New York Southern Press Release Number CA/Aronberg-0918 Updated July FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix i CA/Aronberg-0919 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Appendix CA/Aronberg-0919 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i J8RsEPSl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA CR RMB JEFFREY EPSTEIN Defendant New York N.Y August a.m Before HON RICHARD BERMAN District Judge APPEARANCES GEOFFREY BERMAN United States Attorney for the Southern District of New York BY MAURENE COMEY ALISON MOE Assistant United States Attorneys MARTIN WEINBERG PC Attorney for Defendant BY MARTIN WEINBERG STEPTOE JOHNSON LLP Attorneys for Defendant BY REID WEINGARTEN MICHAEL MILLER SOUTHERN DISTRICT REPORTERS P.O CA/Aronberg-0920 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM J8RsEPS1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA JEFFREY EPSTEIN Defendant Before CR RMB New York N.Y August a.m HON RICHARD BERMAN APPEARANCES GEOFFREY BERMAN United States Attorney for the Southern District of New York BY MAURENE COMEY ALISON MOE Assistant United States Attorneys MARTING WEINBERG PC Attorney for Defendant BY MARTING WEINBERG STEPTOE JOHNSON LLP Attorneys for Defendant BY REID WEINGARTEN MICHAEL MILLER District Judge SOUTHERN DISTRICT REPORTERS CA/Aronberg-0920 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM J8RsEPSl Case called THE COURT Good morning everybody Please be seated So just some housekeeping We have a podium here for both attorneys and others who may be speaking and so we would like you attorneys and others who are speaking to come up to the podium This room is a little cavernous We thought the podium over there would be more comfortable For starters and for this you dont have to go up to the podium if you could just indicate your names This table in front to my left your right are defense counsel and that table to my right your left are government attorneys If we could just ask the attorneys to introduce themselves MS COMEY Good morning your Honor Maureen Comey and Alison Moe for the government Joining us at counsel table are Special Agent Amanda Young of the FBI and Detective Paul Byrne of the NYPD MR WEINGARTEN Good morning your Honor Reid Weingarten MR WEINBERG Martin Weinberg Good morning your Honor THE COURT Good morning MR MILLER Good morning your Honor1 Michael Miller from Steptoe Johnson:on behalf of the i SOUTHERN DISTRICT REPORTERS P.C CA/Aronberg-0921 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM J8RsEPSl Case called seated THE COURT Good morning everybody Please be I So just some housekeeping We have a podium here for both attorneys and others who may be speaking and so we would like you attorneys and others who are speaking to come up to the podium This room is a little cavernous We thought the podium over there would be more comfortable For starters and for this you dont have to go up to the podium if you could just indicate your names This table in front to my left your right are defense counsel and that table to my right your left are government attorneys If we could just ask the attorneys to introduce themselves MS COMEY Good morning your Honor Maureen Corney and Alison Moe for the government Joining us at counsel table are Special Agent Amanda Young of the FBI and Detective Paul Byrne of the NYPD MR WEINGARTEN Good morning your Honor Reid Weingarten MR WEINBERG Martin Weinberg Good morning your Honor THE COURT Good morning MR MILLER Good morning your Honor i Michael Miller from Steptoe Johnson on behalf of the I I SOUTHERN DISTRICT REPORTERS P.C I CA Aronberg-0921 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I J8RsEPSl defendant THE COURT Great Again good morning to all of you This hearing that were having today considers the governments motion to dismiss the indictment in this case I must add that it also serves as the opportunity for me to thank all of you the attorneys and the victims who are here today among others for your very hard work and dedication in this case We also have here today the U.S Attorney for the Southern District of New York Geoffrey Berman who has also been very helpful and indispensable in this matter The news on August that Jeffrey Epstein had been found dead in his cell at the Metropolitan Correctional Center at the MCC was certainly shocking Most of you and myself for that matter were anticipating that the next steps in this case would be defense motion practice including a motion to dismiss followed by a trial on the merits before a jury if the motions were not successful and through which the accusers and the accused would come face to face allowing everyone to get their day in court Mr Epsteins death obviously means that a trial in which he is a defendant cannot take place It is a rather stunning turn of events The governments motion to dismiss the indictment because of Jeffrey Epsteins death on August is SOUTHERN DISTRICT REPORTERS P.C I CA/Aronberg-0922 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM J8RsEPS1 defendant THE COURT Great Again good morning to all of you This hearing that were having today considers the governments motion to dismiss the indictment in this case I must add that it also serves as the opportunity for me to thank all of you the attorneys and the victims who are here today among others for your very hard work and dedication in this case We also have here today the U.S Attorney for the Southern District of New York Geoffrey Berman who has also been very helpful and indispensable in this matter The news on August that Jeffrey Epstein had been found dead in his cell at the Metropolitan Correctional Center at the MCC was certainly shocking Most of you and myself for that matter were anticipating that the next steps in this case would be defense motion practice including a motion to dismiss followed by a trial on the merits before a jury if the motions were not successful and through which the accusers and the accused would come face to face allowing everyone to get their day in court Mr Epsteins death obviously means that a trial in which he is a defendant cannot take place It is a rather stunning turn of events I The governments motion to dismiss th indictment I because of Jeffrey Epsteins death on August is SOUTHERN DISTRICT REPORTERS P.C 8o5-o3oo I CA/Aronberg-0922 i FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM U?vO?OP?F3O 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