166.pdf

Filing # 132529617 E-Filed 0Wy2021 10:20:22 AM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC,
Publisher of THE PALM BEACH POST,
Plaintiff,
v.
DAVE ARONBERG, as State Attorney of
Palm Beach County, Florida; SHARON R.
BOCK., as Clerk and Comptroller of Palm
Beach County, Florida.
CASE NO.:
2019-CA-014681
DIVISION:
AG
Defendants._/
AMENDED MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT DAVE
ARONBERG’S AMENDED MOTION FOR ATTORNEYS’ FEES
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, (the
“State Attorney”), by and through counsel below, hereby submits the following Amended
Memorandum of Law in Support of his Amended Motion for Attorneys’ Fees, as follows:
TIMELINE & BACKGROUND
1.
On November 14, 2019, Plaintiff filed a Complaint against the State Attorney and
Clerk seeking to create a private right of action under Fla. Stat. § 905.27, in the interest of
“furthering justice”, to compel disclosure of the testimony, minutes, and other evidence presented
in 2006 to the Palm Beach County grand jury, as to Jeffrey Epstein, (the “Requested Materials”).
[Def.Ex.A-1],
2.
On November 26, 2019, the State Attorney and his office received an engagement
letter and attorney-client contract from the undersigned, which was later executed. [Def.Ex.A-2],
Party
JOINT
ID#. J29
ev#J25
:
DATE ADMITTED:
Joint Exhibit
J29
Case No. 2019-CA-014681
CA/Aronberg-001133
^Z°s^tXrCtLERK
:
FILED: PALM BEACH COUNTY, FLVJOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
’ - 2 - ■—- I
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NOT A CERTIFIED COPY
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Filing# 132529617 E-Filed 0.12021 l0:2oi;2:~ 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
I 
----------------
CASE NO.: 
DIV...

3.
On December 6, 2019, the State Attorney filed his Motion to Dismiss, which put
Plaintiff on notice that “Defendant Aronberg is not in custody or control of the [Requested
Materials] and is therefore not aproper party to this action.” iDef.Ex.A-3].
4.
Oh January 17,2020, Plaintifffiled its First Amended Complaint, which in addition
to its original claim under § 905.27 Fla. Stat., ("CountH”),added a claim for Declaratory Relief,
(“Count I”), that sought an order declaring that the State Attorney and the Clerk disclose and
release the Requested Materials. [Def.Ex.A-4].
5.
On January 24, 2020, the State Attorney filed an Answer to Count I of the First
Amended Complaint and a Motion to Dismiss Count IL which again notified Plaintiff that:
Defendant Aronberg and the Office ofthe State Attorneyfor the Fifteenth Judicial
Circuit are not in custody or control of the records sought herein, and therefore
DefendantAronberg is notaproperparty to this action. Infact, Defendant, Sharon
R. Bock, as Clerk and Comptroller ofPalm Beach County, Florida, admits that it
is the custodian inpossession ofthe documentsthat are the subject ofthis action.
[Def.Ex.A-5, p. 12],
6.
On June 3, 2020, Chief Judge Marx held a hearing on the State Attorney’s and
Clerk’s Motions to Dismiss Count II. [DefEx.A-6],
7.
On June 8, 2020, the Court entered its Order Granting Defendants’ Motions to
Dismiss Count II of Plaintiff's First Amended Complaint with Prejudice, leaving only Plaintiffs
Count 1 seeking declaratory relief. [Def.Ex.A-7J.
8.
Immediately thereafter, Plaintiff was served with a demand, pursuant to § 57.105
Fla. Stat., to voluntarily dismiss/withdraw the First Amended Complaint and the claims against
the State Attorney, along with a Motion for Attorneys’ Fees (“§ 57.105 Demand”). [DefEx.A-8].
CA/AropJ^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
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3. 
On Decern_ber 6, 2019, tlw State Attorney filed his Motion to Dismiss, which put 
Plaintiff on n...

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9.
In serving his § 57.105 Demand, the StateAttorney properly put Plaintiff on notice
that he would seek sanctions by filing the § 57.105 Motion for Attorneys’ Fees if Plaintiff failed
to dismiss the remainder of the First Amended Complaint within 21 days.
10.
On June 23, 2020, Plaintiff’s counsel sent a response to the § 57.105 Demand
refusing to withdraw the remainder of the First Amended Complaint. [Def.Ex.A-9].
11.
After receiving Plaintiff’s response and waiting the requisite “21 days after service
of the motion,” the State Attorney’s § 57.105 Motion for Attorneys’ Fees was filed with the Court
on July 1, 2020, (“First Motion for Attorneys’ Fees”). [Def.Ex.A-10].
12.
On August 18, 2020, the State Attorney filed his Motion for Summary Judgment,
[Def.Ex.A-11], which includes an Affidavit made by the State Attorney. [Def.Ex.A-12].
13.
On October 21, 2020, Plaintiff filed its Notice of Dropping the State Attorney,
pursuant to Rule 1.250(b), Fla.R.Civ.P. [Def.Ex.A-13],
14.
On November 9, 2020, the State Attorney filed his Amended Motion for Attorneys’
Fees, (“Amended Motion”), pursuant to § 57,105, Fla. Stat,, seeking attorneys’ fees in the amount
of S 19.975.00. plus a multiplier of 2. [Def.Ex.Ai14],
I.
LEGAL STANDARD
As follows, Florida Statutes § 5 7.105( 1) authorizes awards of attorneys’ fees as sanctions:
(1)
Upon the court’s initiative or motion of any party, the court shall award a
reasonable attorney’s fee, including prejudgment interest, to be paid to the
prevailing party in equal amounts by the losing party and the losing party’s attorney
on any claim or defense at any time, during a civil proceeding or action in which
the courtfinds that the losing party or the losing party's attorney knew or should
have known that a claim or defense when initially presented to the court or at any
time before trial'.
(a)
Was not supported by the material facts necessary to establish the
claim or defense; or
(b)
Would not be supported by the application of then-existi...

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“Section 57.105 does not require a finding of frivolousness to justify sanctions, but only a
finding that the claim lacked a basis in fact or law” and “does not require a party to show complete
absence of a justiciable issue of fact or law.” Martin County Conservation Alliance v. Martin
County, 73 So. 3d 856, 865 (Fla. 1 st DCA 2011) (finding that “Courts are not at liberty to disregard
the legislative mandate that courts shallimpose sanctions in cases without foundation in material
fact or law. The word “shall” in § 57.105, Fla, Stat., evidences the legislative intent to impose a
mandatory penalty to discourage baseless claims, by placing a price tag on losing parties who
engage in these activities. Section 57.105 expressly states courts “shall” assess attorney’s fees for
bringing, or failing to dismiss, baseless claims or defenses.”).
In determining an award of sanctions under § 57.105, the trial court’s findings “must be
based on substantial competent evidence” and the trial court “must make an inquiry into what the
losing party knew or should have known during the fact-establishment process, both before and
after the suit was filed.” See Trust Mortg., LLCc. Ferlanti, 193 So. 3d 997 (Fla. 4th DCA 2016).
11.
THE STATE ATTORNEY’S AMENDED MOTION IS NEITHER IN VIOLATION
OF THE 21-DAY SAFE HARBOR PROVISION IN FLA. STAT. § 57.105(4), NOR
WAS THE AMENDED MOTION MOOT UPON FILING.
“Section 57.105(4), Florida Statutes creates an opportunity to avoid the sanction of
attorney's fees by creating a safe period for withdrawal or amendment of meritless allegations and
claims.” Davis v. Bailynson, 268 So. 3d 762, 769 (Fla. 4th DCA 2019). Specifically, the relevant
portion of the Statute states:
A motion by a party seeking sanctions under this section must be served but may
not be filed with or presented to the court unless, within 21 days after service of the
motion, the challenged paper, claim, defense, contention, allegation, or denial is not
withdrawn dr appropriately corr...

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fees with notice and the opportunity to withdraw or abandon a frivolous claim before sanctions are
sought.” MC Liberty Express, Inc. v. All Points Servs., 252 So. 3d 397,404 (Fla. 3d DCA 2018).
Here, Plaintiffcontends that the State Attorney “did not serve his Amended Motion at any
time before filing it, and thus failed to comply with the 21 -day notice provision....” [See, Plaintiff1s
Memorandum of Law in Response to Amended Motion for Attorneys’ Fees, p.6.]. Plaintiffclaims
that for this reason the Amended Motion should be denied and cites in support, Lago v. Kame By
Design, LLC, 120 So. 3d 73, 75 (Fla. 4th DCA 2013) (holding that “if a party files a subsequent
or amended motion for sanctions under section 57,105 and raises an argument that was not raised
in the original motion for section 57.105 sanctions, the subsequent motion must independently
comply with the twenty-ohe-day ‘safe harbor’ provision of Section 57.105(4).”).
The instant case is distinguishable from Lago1. In Lago, because the case was still active
when the plaintiff’s amended motion for attorneys’ fees was filed and was not served on the
defendant in compliance with the 21-day safe harbor provision before it was filed with the court,
pursuant to § 57.105, the defendant was entitled to notice and an opportunity to change its position
and withdraw its offending motion before being subject to sanctions.
Here, despite Plaintiff’s decision to drop the State Attorney as a party, the Florida Rules of
Civil Procedure and the courts of Florida are clear: Because Rule 1.250 specifies that a party is
dropped “in the manner provided for voluntary dismissal in Rule 1.420(a)(1),” dropping a party
therefore “operates as an adjudication on the merits. ” See, Siboni v. Allen, 52 So. 3d 779, 781
(Fla. 5th DCA 2010); Rule 1.420(a)(1) Fla. R. Civ. P. Notably, Plaintiff admits that “the entire
1 Notably, the court in Lago v. Kame By Design, LLC, 120 So. 3d 73, 75 (Fla. 4th DCA 2013),
despite finding that the plai...

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action, which necessarily included Count I [ofthe First Amended Complaint], was dismissed as to
[the State Attorneyj on October 21, 2020. [See, Plaintiff’s Memorandum of Law in Response to
Amended Motion for Attorneys’ Fees, p.7.]. Nonetheless, as a result ofdropping the State Attorney
from the case, Plaintiffnot only effectively made an admission that its allegations against the State
Attorney have no basis in fact or law, but also concluded the case as to the State Attorney and
thereby became the losing party in this action.
Consequently, unlike the fact scenario and timeline in Lago, because Plaintiff concluded
the instant litigation by dropping the State Attorney from the action before the filing of the
Amended Motion, it was impossible to give Plaintiff an opportunity' to respond and withdraw its
Count 1 of the First Amended Complaint since Plaintiff had already done so, thus there can be ho
violation of the 21-day safe harbor provision set forth in Fla. Stat. § 57.105(4). Based on the
foregoing, the State Attorney’s Amended Motion does not violate the 21 -day safe harbor provision
because Plaintiff dropped him from the action prior to the filing of the Amended Motion, and
therefore Plaintiffwas not prejudiced by the filing ofthe Amended Motion. Accordingly, as further
set forth below, Plaintiff has exposed itself to § 57.105 attorneys’ fees as sanctions for failing to
drop the State Attorney as a party within the 21 -day safe harbor period.
Additionally, there is nothing improper about the First Motion for Attorneys’ Fees or the
Amended Motion and no argument or authority has been offered by Plaintiffthat would make the
Amended Motion moot. In fact, amended motions for attorneys’ fees are filed consistently as a
matter of course to include the entirety offees in a lawsuit. Here, the State Attorney’s total legal
fees were able to be calculated arid submitted at die time of filing the Amended Motion.
Finally, despite Plaintiff’s assertion that “[a] motion, f...

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it fails under the [S]tatute”, Plaintiff has failed to provide any supporting authority and there is no
statutory requirement or language in § 57.105 that supporting record evidence must exist to
properly serve a §' 57.105 demand and motion for attorneys’ fees. [See, Plaintiff’s Memorandum
of Law in Response to Amended Motion for Attorneys’ Fees, p.8.]. “The central purpose of §
57.105, Fla. Stat., is, and always has been, to deter meritless filings and thus streamline the
administration and procedure of the courts.” Davis v. Bailynson, 268 So. 3d 762, 769 (Fla. 4th
DCA 2019). In this vein, a § 57.105 demand and accompanying motion for attorneys’ fees Can be
filed at any time after a lawsuit is initiated, even directly in response to the filing of a complaint,
regardless ofwhether any record evidence exists in support of the§ 57.105 demand.
Consequently, the foregoing indicates that the State Attorney’s First Motion for Attorney’s
Fees, as served and filed, is sufficient under § 57.105 to seek sanctions from Plaintifffor its failure
to drop the State Attorney from the instant lawsuit within the 21-day safe harbor provision after
being notified why its First Amended Complaint had no basis in fact or law. Furthermore, as set
forth at length above, the State Attorney had no obligation to serve his Amended Motion prior to
filing it with the Court as Plaintiff had already dropped him from the case when it was filed.
III.
THE COMPETENT SUBSTANTIAL EVIDENCE ON THE RECORD SHOWS
THAT THERE IS NO ARGUABLE BASIS IN LAW OR FACT FOR THE ISSUES
RAISED IN PLAINTIFF’S COUNT I, WHICH NOT ONLY LACK A GOOD
FAITH ARGUMENT FOR THE INTERPRETATION OF EXISTING LAW OR
ESTABLISHMENT OF A NEW LAW WITH A REASONABLE EXPECTATION
OF SUCCESS, BUT ALSO ARE NEITHER NOVEL OR COMPLEX.
Here, Plaintiff relies on § 57.105(3)(a), which sets forth a scenario where sanctions are
improper under the Statute:
3)
Notwithstanding subsections (1) and (2), monetary sanctions may not be
awarded:
(a)
Under parag...

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new law, as it applied to the material facts, with a reasonable expectation
ofsuccess.
Notably, the § 57.105(3)(a) defense only applies to demands,made under § 57.105(l)(b).
Accordingly, Plaintiff’s attempt to prevent an award of sanctions here only applies to whether
Plaintiff or
“knew or should have known” that the First Amended Complaint
“when initially presented to the court or at any time before trial.... (b) would not be supported by
the application ofthen^existing law to those materialfacts necessary to establish their claim.” §
57.105(1^
Regarding the disclosure of grand jury materials, Florida Statutes § 905.17(1) makes clear
that there is no arguable basis in law that the State Attorney provide the Requested Materials:
The notes, records, and transcriptions are confidential and exempt from the
provisions of s, 119.07(1) and s. 24(a), Art. I ofthe State Constitution and shall be
released by the clerk only on request by a grand jury for use by the grand jury or
on order ofthe
pursuant to s. 905.27.
Florida Statutes § 905.17(1). Based on the clear language of § 905.17(1), Fla. Stat, there can be
no good faith reasonable expectation ofsuccess for the State Attorney to produce and disclose the
Requested Materials as he lacks the legal authority to obtain and deliver the Requested Materials
demanded by Plaintiff in Count I of the First Amended Complaint
Even if Plaintiff is shielded from § 57.105(l)(b) sanctions based on the § 57.105(3)(a)
defense, Plaintiff is nonetheless subject to sanctions under § 57.105(1 )(a), because Plaintiff or
Plaintiffs attorneys “knew or should have known” that Count I “when initially presented to the
court or at any time before trial „ . (a) was not supported bv the material facts necessary to establish
the claimF Fla. Stat. § 57.105(l)(a). Specifically, based on Plaintiff’s own research, statutory
constructive notice, the State Attorney’s affidavit, all of the pleadings and correspondence in this
matter as well as through the S...

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ChiefJudge Marx’s statements during the June 3, 2020 hearing, Plaintiff and Plaintiff s attorneys
knew or should have known that Count I of the Amended Complaint was not supported bv the
material facts necessary to establish the claim ” See. Fla. Stat.. § 57J05(J)(a).
The material facts showing that Plaintiff has no reasonable expectation of success arid is
unable to establish its claim for declaratory relief have been open, obvious, arid apparent to
everyone involved in this matter from the start. The State Attorney’s position has been consistent:
neither he nor his office has. possession, custody, or control of the Requested Materials arid
therefore the declaratory relief sought by Plaintiff seeks materials that are impossible for him or
his office to produce and he is not a proper party to this action. [See, Def.Ex.A-12
3-4], Again,
these material facts negating Plaintiffs declaratory relief claitn against the State Attorney were
not only set forth in the June 8, 2020, § 57,105 Demand Letter, but have been the basis for the
State Attorney’s defense in every pleading, filing, and/or correspondence!in this matter.
Accordingly, Plaintiff knew or, should have known that the First Amended Complaint was
not supported by the material facts necessary to establish the claim for declaratory relief. At the
very least. Plaintiff should have known that its First Amended Complaint was not supported by
the material facts after Judge Marx’s statements during the June 3, 2020 hearing on Defendant’s
Motion to Dismiss Plaintiffs Count 11. During that hearing, Chief Judge Marx drew a bright line
as to when Plaintiff knew or should have known that Count I of the Amended Complaint had no
basis in fact or law since the reliefsought thereby is impossible for the State Attorney to perform.
Specifically, ChiefJudge Marx made several unequivocal statements on the record putting Plaintiff
bn notice, if they weren’t already, that the State Attorney does not have arid cannot produce the
R...

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Additionally, Plaintiffs argument for novelty and complexity fails as to Count I, regardless
ofPlaintiff’s reliance on “Constitutional provisions and interpretive case law, along with Fla. Stat.
§ 905.27” ... “to propose a good faith interpretation of existing law in support of its declaratory
relief claim in Count !.” [See, Plaintiff’s Memorandum of Law in Response to Amended Motion
for Attorneys’ Fees, p. 10.]. The simple fact of the matter is that Count 1 is neither hovel or complex
because Count I merely seeks declaratory relief and the State Attorney’s lack of possession,
custody, or control in conjunction with § 905.17(1) creates an impossibility of performance as to
Count I. Here, § 905.17(1) is abundantly clear that only the Clerk can release grand jury materials
pursuant to a court order. The record is likewise clear that not only has the State Attorney never
had possession, custody, dr control ofthe Requested Materials, but he also lacks any legal authority
to obtain and deliver, the Requested Materials..
Thus, there is no arguable “good faith” basis in law and/or fact as to Plaintiffs Count I.
Likewise, under no set of facts does Plaintiff have a reasonable expectation of success against the
State Attorney in obtaining the Requested Materials because he does not have possession, custody,
or control over them.
In fact. Plaintiff acknowledged, admitted, and acquiesced to the
impossibility of the State Attorney providing the Requested Materials when he was dropped from
the action. Consequently, sanctions against Plaintiffare appropriate under § 57.105, Fla. Stat.
CONCLUSION
Based on the foregoing, Defendant, Dave Aronberg, as State Attorney of Palm Beach
County, Florida, respectfully requests the Court enter an order granting his Amended Motion for
Attorneys’ Fees as well as such other and further reliefas the Court deems just or proper.
JACOBS SCHOLZ & WYLER, LLC
/s/Douglas A. Wyler
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
10
NOT A ...

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Arthur I. Jacobs, Esq.
Fla. Bar No.: 10249
Richard J. Scholz, Esq.
Fla. Bar No.: 0021261
Douglas A. Wyler, Esq.
Fla. Bar No.: 119979
961687 Gateway Blvd., Suite 201-1
Fernandina Beach, Florida 32034
(904) 261-3693
(904) 261-7879 Fax
Primary: jacobsscholzlaw@comcast.net
Attorneysfor Defendant, Dave Aronberg
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on this 12th day of August, 2021, a copy ofthe foregoing has
been electronically filed with the Florida E-File Portal for e-service bn all parties ofrecord herein.
/s/Douglas A. Wyler
CA/Aropljjg^O^^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
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Arthur I. Jac:o bs! Esq. 
Fla. Bar No.: I 0249 
Richard J. Scholz, Esq. 
Fla. Bat No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: i 19979· 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 Fax 
.Primary: jacobsscholzlaw@comcast.net 
Attoi'iieysfot Defendcii1t, Dave Atoizbeig 
CERTIFICATE OF SERVICE 
I }IEilEBY CJ::RTJFY thM OQ th.i.s l2th day ofAugust,202l, a copy ofthe foregoing has 
been electronically filed with tlie Florida E-File Portal for e-setvice on all partie·s ofrecord herein. 
Isl Douglas A. Wvler 
11 
CA/Aro~W:flb?{p°¼lfM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

Def.Ex.A-1
e
CA/ArOfft®-WWl BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
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Def.Ex.A-1 
,I 
CA/Aropil7fffo?ihl4A BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

**** CASE NUMBER: 502019CA0WB81XXXXMB Div: AG
Fifing#98869063 E-Filed 11/14/2019 11:06:37 AM
IN THE CIRCUIT COURT, 15th
judicial Circuit, in andfor
BALM BEACH COUNTY, FLORIDA
CASE NO.:
CA FLORIDA HOLDINGS, LLC,
Publisher ofTHE PALM BEACH POST
Plaintiff
v.
DAVE ARONBERG, as State Attorney of
Palm Beach County, Florida, SHARON R
BOCK, as Clerk and Comptroller ofPalm
Beach County, Florida,
Defendants.. ..
,/
SUMMONS
DEFENDANT:
Daye Arpnberg, as State Attorney of
Palm Beach County, Florida
401 N. Dixie Highway
West Palm Beach, Florida 33401
A lawsuit has been filed against you. You have 20 calendar days after this summons is
served on you to file a written response to the attached Complaint with the Clerk of this
Court
A phone call will hot protect you.
Your written response, including the case
number given above and the names of the parties, must be filed if you want the Court to
hear your side of the case. If you do not file your response on time, you may lose the
case, and your wages, money, and property may thereafter be taken without further
warning from the Court. There are other legal requirements. You may want to call an
attorney right away. If you dp not know an attorney, you may call ah attorney referral
service or a legal aid office (listed in the phone book). If you choose to file a written
response yourself, at the same time you file your written response to the Court you must
also mail or take a copy of your written response to the:
Stephen A. Mendelsohn,
Esquire, Greenberg Traurig, P.A., 5100 Town Center Circle, Suite 400, Boca Raton,
Florida 33486, Telephone: (561)955-7600.
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/14/2019 11:06:37 AM
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
-cASE NUMBER 502019CA.1XXXXMBDiv:·_AG .... 
• 
Filmg # 98869063 E-Fil~d l ll14{2019 11 :06:37 AM 
IN THE C1R.CUIT COURT, 15th 
JUDICIAL CIRCUIT, IN AND FOR 
;P.ALM BEACH COlJNTY, FLORIDA 
CA FLORIDA HOLOlliGS, LLC, 
Publisher of...

THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and
a copy ofthe Complaint in this lawsuit on the above named Defendant
DATED on November
,2019
NOV 15 2019
Sharon R. Bock
As Clerk & Comptroller of the Court
IMPORTANTE
Deputy Clerk
DOHI GARCIA
Usted ha sido demandado Icgalmente.
Tiene 20 Dias, contedos a partir del recibo de esta
notificacion, para contestar la demanda adjunta, por escrito, y prcscntarla ante cste tribunal. Una Hamada
telefonica nd lo protegera. Si usted desea que el tribunal considere su defensa, debe presenter su respueste
por escrito, incluycndo el numcro del caso y los nombres de las partes interesadas. Si usted no contesta la
demanda a tiempo, pudiese perder cl caso y podria ser despojado de sus ingresos y propiedades, o privado
de sus derechos, sin previo aviso del tribunal.
Existen otros requisites legates.
Si lo desea, puede usted
consular a un abogado inmediatamente. Si no conocea un abogado, puede llamar a unade las oficinas de
asistcncia legal que aparccen en la guia telefonica.
Si desea responder a la demanda por su cucnta, al mismo tiempo en que presenta su respueste ante
el tribunal, debera usted enviar por correo o entregar una copia de su respueste’a la persona denominada
abajo como "Plaintiff/Plaintiffs Attorney" (Demandante o Abogado del Demandante).
IMPORTANT
Des poursuites judiciares ont ete entreprises contre vous, Vous avez 20.jours consecutifs a partir
de la date de Tassignation de cctte citation pour deposer unc reponse ecrite a la plainte ci-jointe aupres de ce
tribunal.
Uri simple coup de telephone est insuffisant. pour vous proteger.
Vous etes oblige de deposer
vote reponse ecrite, avec mention du numcro de dossier ci-dessus et du nom des parties nominees ici, si
vous souhaitez que Ie tribunal entende votre cause.
Si vous ne deposez pas votre reponse ecrite dans le
relai requis, vous risquez de perdre la cause ainsi que votre salaire, votre argent, et vos bicns peuvent etre
saisis ...

Filing # 98869063 E-Filed 11^^019
11:06:37 AM
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC,
CASE NO.:
Publisher of THE PALM BEACH POST,
Plaintiff.
v.
DAVE ARONBERG, as State Attorney of
Palm Beach County, Florida; SHARON R.
BOCK, as Clerk and Comptroller of Palin
Beach County, Florida,
Defendants.
COMPLAINT
CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Complaint against
Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his official capacity (“State
Attorney”),,and Sharon R. Bock, the Clerk of the Court for Palm Beach County, Florida, in her
official capacity' (“Court Clerk”), alleges as follows:
JURISDICTION
I.
This is an action within the exclusive jurisdiction of the Circuit Court pursuant to
Fla. Stat. Section 26.012(2)(a).
PARTIES
2.
The Palm Beach Post is a daily community newspaper published by Plaintiff CA
Florida Holdings, LLC, with offices located at 275.1 S. Dixie Highway, West Palm Beach, Florida.
3.
Defendant Dave Aronberg. is the duly elected State Attorney for the Fifteenth
Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and
CA/ArGpft®°?M^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
Filing#98869063 E-Filed li.019 ll:06:37AM 
CA FLORIDA HOLDINGS, LLC, 
.Publisher of THE PALM BEACH POST, 
Plaintiff, 
v. 
DAVE ARONBERG, as State Attorney of 
Palm Beach County,- Florida_; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida, 
• 
INTHE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 
COMPLAINT 
CA _Flor1da Holdings, LLC, publisher of The Palm Beach Post, for its Complaint against 
Dave Aronberg; the State Attorney fof Palm Beach County, Florida, ill his official capacity ("State 
Attorney''),. and Sharon R. Bock, the Clerl<: of: tjle Cqllrt for Palm Beach County, Florida, in her 
official capa...

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has authority in grand jury'proceedings pursuant to Fla. Stat, section 27.03. He is sued herein in
his official capacity as his officeis in possession of documents that are the subject of this action.
4.
Defendant Sharon R. Bock is the duly elected Clerk and Comptroller ofPalm Beach
County', Florida.
She is sued herein in her official capacity as her office is in possession of
documents that are the subject of this action.
INTRODUCTION
5.
In what is now widely if belatedly recognized as a colossal miscarriage ofjustice
which led to the further needless victimization of countless young girls and women - a wealthy,
I
politically connected, and powerful financier was not held accountable for, nor even forced to
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confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein’s 2008
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deal with the State of Florida was not consistent with the evidence gathered against him, what
I
remains shrouded in mystery is how that evidence was presented- and the extent to which it was
presented - to the grand jury' that returned an indictment far more limited in scope than expected
and deserved.
6.
Through this action. The Palm Beach Post seeks public access to the testimony,
minutes, and other evidence presented in 2006 to the Palm Beach County' grand jury empaneled
during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for
example, in order to prevent the flight of those whose indictment may be contemplated and their
II
ability to conceal of destroy evidence; to ensure jurors’ candor in deliberations; and to protect an
accused who is later exonerated. However, these factors are inapplicable here; Also, Florida law
expressly authorizes the disclosure of grand jury proceedings under certain circumstances,
including, as here, in the furtherance ofjustice. Fla. Stat. § 905.27(1 )(c).
7.
It can no longer credibly be maintained that continued blanket secrecy over the
proceedings that led to the egregiously ...

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To the contrary, transparency is required to promote public understanding of the criminal justice
system and public confidence in the fair administration ofjustice. As detailed below, Epstein was
accused of sexually abusing and trafficking dozens of women and girls in south Florida (among
other locations) over a period ofseveral years while exploiting his wealth and political connections
to obstruct the administration ofjustice at every turn. Public disclosure of the Epstein grand j ury
proceedings will shed light on the extent to which those in our government entrusted with the
solemn responsibility of enforcing out criminal laws equally as to all citizens fulfilled their duties
in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated
like others accused of similar heinous crimes, or (2) as appears more likely to be- the case, those
who chose to give Epstein favorable- “unusual,” in the words of the Town of Palm BeachPolice
Chief- treatment, are exposed and held accountable. From what limited information is now in the
public domain, the State Attorney’s referral to the grand jury- which would be out ofthe ordinary
for this type of case
gives rise to a strong inference of favoritism and corresponding disregard
for the rights of the minor victims of Epstein’s sex trafficking. Access to the grandjury materials
will allow the public to determine whether the grand jury process, and the secrecy that.comes with
it, was used to further justice dr, instead, operated to shield Epstein and his co-conspirators from
the consequences oftheir criminal activities. Accordingly. Fla. Stat. Section 905.27 authorizes the
disclosure of Epstein’s 2006grandjury proceedings.
8.
Even in the absence of such a statutory basis, this Court is empowered to order
public disclosure pursuant to its inherent authority and supervisory powers oyer the grand jury.
Indeed, courts throughout the country in the past several decades have ordered the disc...

as here, many of the details of Epstein’s criminal misdeeds have already been made available in
the public domain through extensive news reporting by, among others. The Palm Beach Posh by
the many civil suits'brought against Epstein and his co-conspirators; and by the victims:themselves.
9.
In recognition ofthe sensitivity of the materials being sought and in the interest of
protecting any victims who wish to remain anonymous, 77?e Palm Beach Post has no objection to
copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County
grand jury first being submitted to this Court for in camera review, where they may be redacted,
as appropriate, to protect those who deserve such protection.
FACTUAL BACKGROUND
10.
The following facts were gathered, in large part, from documents obtained by
The Palm Beach Post through various Florida Public Records Law requests, documents unsealed
or publicly available in other related judicial proceedings, and information and documents in the
public record.
A.
First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement:
2005-2008.
11.
The investigation into Epstein’s sex crimes began more than fourteen years ago,
when a 14-year-old girl’s stepmother reported to police in the Town of Palm Beach, Florida^ that
Epstein and others who worked for him arranged for her to give Epstein a “massage.” Epstein
required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid
$300. Epstein was 52 years old at the time.
12.
Following this initial report in 2005, the Town of Palm Beach Police, and later, in
2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
disturbingly similar details, with each of the other victims,
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as here, many of...

13.
Both the victim/witness interviews, as well as evidence retrieved following a search
of Epstein’s home, showed that some of the girls involved were under the age of 18. The police
search of Epstein’s residence also found two hidden cameras arid, throughout the house, large
numbers of nude photos of girls, including victims whom the police had not interviewed in the
course oftheir investigation.
14.
In March 2006, a State grand jury was scheduled at which all of the victims were
expected to testify. The proceeding was postponed, however, due to meetings between the State
Attorney’s office and Epstein’s prominent criminal defense lawyer and personal friend, Alan
Dershowitz.
15.
Another grandjury was convened in April 2006, but canceled the day before it was
to begin receiving evidence.
(1)
Police Chief Reiter’s Letter to the State Attorney.
16.
On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wTote a
“personal and confidential” letter to then Palm Beach County State Attorney, Barry Krischer,
stating;
I must renew my prior observation to you that 1 continue to find your office’s
treatment of [the Epstein] 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 arid
messages remain unreturned. After giving this much thought arid consideration.
Imust urgeyou to examine the unusual course thatyour office’s handling ofthis
matter has taken and consider ifgood andsufficient reason exists to requireyour
disqualificationfrom the prosecution ofthese cases. (Emphasis; supplied)
17.
Chief Reiter’s letter to State Attorney Krischer enclosed the Town of Palm Beach
Police Department’s probable cause affidavits charging Epstein and two of his assistants with
multiple counts of unlawful sex acts with a minor and one count of sexual abuse, arid requested
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that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges
against him, which would be public.
(2)
The July-2006 State Grand JmvPresentation.
18.
Instead. State Attorney Krischer elected to refer the case to a grand jury, which is
mandatory for capital cases but rarely used for all other crimes.
According to an official
spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm
Beach County.
19.
In July 2006, after State Attorney Krischer presented testimony and evidence from
one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.
There is no mention in the indictment of the victim being a minor.
20.
On information and belief, a second of Epstein’s victims: was supposed to testify
before the grand jury, but was unable to attend because of a school exam-
21.
No reasonable explanation has been provided as to why the numerous other known
victims were not presented as witnesses and crime victims to the grandjury convened in July 2006.
Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was
initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do
so.
22.
On information and belief, during the grand jury appearance of the single victim
who testified, the State Attorney presented evidence that vilified the victim and attacked her
credibility, including soliciting testimony regarding underage drinking and questionable personal
behavior that was unrelated to the charges against Epstein. Further upon information and belief,
this information was initially brought to the attention of the State Attorney’s office by Epstein’s
defense counsel.
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that either an artestWarrant be issued for Epstein orthe State AttQmey directly initiate the charges 
against him, which woµld be p...

(3)
The FBI’s Investigation and Epstein’s Non-Prosecution
Agreement With Federal Authorities.
23.
On information and belief, following the deficient July 2006 indictment, and with
Chief Reiter’s encouragement, the FBI began its own investigation of Epstein.
24.
Records unsealed in 2015 revealed that the FBI compiled reports on “34 confirmed
minors” that were victims ofEpstein’s sexual predations. Based on evidence gathered by the FBI,
a 53-page indictment was prepared by the U.S. Attorney’s Office in June 2007. However, at the
request of Epstein’s lawyers, the indictment was never presented to a federal grand jury.
25.
Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta,
negotiated a plea deal with Epstein’s team of lawyers to grant immunity to Epstein (along with
four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
charges.
26.
Throughout the remainder of 2007 and through the first half of 2008, Epstein’s
lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
belief, Epstein’s lawyers insisted that (l)the victims riot be notified, (2) the deal be kept
confidential and under seal, and (3) all grandjury subpoenas (including one that had already been
issued for Epstein’s computers) be withdrawn.
27.
On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of
prostitution and one count of solicitation ofprostitution with a minor under the age of 18. He was
sentenced to 18 rnonths in jail, followed bv a year of community control or house arrest, and was
adjudicated as a convicted sex offender required to register twice a year in Florida.
28,
The plea deal, called a non-prosecution agreeihent (“NPA”), allowed Epstein to
receive immunity from federal sex-trafficking charges that could have sent him to prison for life.
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(3) 
The FBPs Investigation an...

On information and belief, based on public records, former State Attorney Krischer communicated
with then U.S. Attorney Acosta concerning the NPA’s negotiation with Epstein’s lawyers.
29,
Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for
which he was convicted.
Instead, he was placed in a private wing of the Palm Beach County-
Stockade, where, after 3
1Z2 months, he was allowed to leave the jail on “work release” for up to
12 hours a day, 6 days a week. His private driver provided his transportation to and from “work.”
30.
Epstein was released five months early,
31.
Upon information and belief, Epstein violated the terms of his probation, but was
not prosecuted.
(4)
The Crime Victims’ Rights Act Litigation.
32.
Epstein’s victims only learned after the fact about his plea in State court and filed
an emergency petition to force federal prosecutors to comply with the Crime Victims’ Rights Act
(18 U.S.C. § 3771, “CVRA”), which mandates certain rights for crime victims, including the right
to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge
Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify
Epstein’s victims before allowing him to plead guilty to only the two State offenses.
33.
The prosecution’s failure to keep the victims apprised, among other things, also
contravenes the Florida Constitution, Article 1. § 16(b) and Fla. Stat. §960.001.
34.
Following publicity exposing the extraordinary leniency of the plea deal, dozens of
civil suits were brought against Epstein, most of which Epstein’s lawyers settled out-of-court.
35.
In 2010, Epstein was registered as a “level three” (i. e. , high risk of repeat offense)
sex offender in New York, a lifelong designation. In 2011, the New York County District
Attorney’s office unsuccessfully sought to lower his registration to low-risk “level one.”
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36.
Upon information and belief during the course of the Town ofPalm Beach and FBI
investigations, Epstein retained private investigators to follow, harass,, and photograph his victims
and their families, as well as ChiefReiter and the Town of Palm Beach detective who investigated
the case against Epstein.
37.
Upon information and belief Epstein’s victims were threatened against cooperating
with law enforcement and told that they would be compensated only ifthey did not cooperate with
law enforcement.
B.
Second,Epstein Sex Crimes Investigation, Indictment, Suicide: 2019.
38.
On July 6, 2019, Epstein was arrested on federal sex trafficking charges.
39.
Upon information and belief, the United States government’s investigation of new
allegations and charges stemmed, in parf from continued press investigations into and reporting
on the mishandling of the 2006 charges and the civil suits that followed.
40.
In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the
Southern District ofNew York, Epstein was described as “a serial sexual predator who preyed on
dozens of minor girls over a period of years ” The letter emphasized that “the Government has real
concerns- grounded in past experience with this defendant- that ifallowed 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, arid otherwise attempt to obstruct justice.”
It also
described the results of the FBI’s search of Epstein?s Manhattan townhouse: evidence of sex
trafficking in the form of “hundreds- and perhaps thousands- of sexually suggestive photographs
of fully- or partially-nude females,” including underage females. In a locked safe, compact discs
were found Wnth handwritten labels including the descriptions: “Young [Name] + [Name],” “Mise
nudes 1and “Girl pics nude.”
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Upon ...

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41,
On July 8,2019, prosecutors with the Public Corruption Unit of the U.S. Attorney’s
office for the Southern District ofNew York charged Epstein with sex trafficking and conspiracy
to traffic minors for sex. The grand jury indictment alleges that “dozens” of underage girls were
brought into Epstein’s mansions for sexual encounters. A few days later, owing to public outcry
over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,
Alexander Acosta, who by then was serving as U.S. Secretary of Labor in the Trump
administration, resigned from office.
42.
Epstein was denied bail and was placed into pretrial detention at the federal
Metropolitan Correction Center in lower Manhattan.
43.
On August 10. 2019, Epstein was found dead in his cell at the Metropolitan
Correctional Center. His cause of death was determined to be suicide.
C
The August 27. 2019. SDNY Hearing: Ebstein’s Victims Speak.
44.
On account of his death, prosecutors sought to dismiss the indictment against
Epstein, while maintaining that they would continue to investigate his cb-coiispirators.
45.
United States Senior District Judge Richard M. Berman ordered a hearing on
August 27. 2019, on the prosecutors’ decision to dismiss the indictment and allowed victims to
speak at the hearing.
46.
In the course of the hearing, more than two dozen victims delivered their personal
stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of
violent rape by Epstein, Many more victims were present in the courtroom but did not testify.
47.
While some questioned the reasoning behind the court’s decision to give the victims
voice after Epstein’s death, District Judge Berman noted that “a public hearing is [the] preferred
vehicle of resolution,” emphasizing that “public hearings are exactly what judges do. Hearings
promote transparency and they provide the court with insights and information which the court
10
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may not otherwise be aware of.” Indeed, even Epstein’s defense lawyer noted at the hearing that
the court “is the institution that most people have confidence in, in these very troubled times.”
48.
At the August 27th hearing,, the girls, now women, spoke about their “exploitation
and coercion,” and to the fact that many of them “were in very vulnerable situations and in extreme
poverty, circumstances where [they] didn’t have anyone on [their] side, to speak on [their]
behalf....” One victim lamented that “as a victim, [she] never got to see what the agreement was
or why the special treatment got approved” in the Florida case years earlier. Another noted how
“completely different” the investigators leading to the 2019 federal indictment were from the
prosecutors in. the Florida, case, both in their treatment of her and their investigation of her
victimization by Epstein.
49.
A former federal judge in attendance at the August 27th hearing emphasized that
“transparency is one of the overriding objectives in our criminal justice system.”
50.
Nearly all of the victims expressed the conviction that the secrecy that shielded
Epstein has caused them “irreparable harm” and that an opportunity to address his criminal
wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
at least some measure ofjustice to be served afterhis death; Indeed, one victim stated: “Any efforts
made to protect Epstein’s name and legacy send a message to the victims that he wins and that he
is untouchable.” Another victim expressed fear that this is a world “where there are predators in
power, a world where people can avoid justice if their pockets run deep enough.” hi short, the
“unusual” treatment Epstein received in Florida in 2006 based on his wealth, social status, and
connections severely eroded the public’s faith in the integrity and impartiality of the criminal
justice system.
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D.
The Palm Beach Post’s Standing and the Public Interest.
51.
Plaintiff. The Palm Beach Post, is a communitynewspaper serving readers in Palm
Beach County and the Treasure Coast vicinity.
52.
The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist
three other times.
53.
Beginning in 2004, The Palm Beach Post has extensively investigated and reported
on the allegations against, the law enforcement investigation of, and the crimes committed by,
Epstein and his co-corispirators.
The Newspaper’s reportage has included publication of the
following articles::
•
“The Man Who Had Everything:: Jeffrey Epstein Craved Big Homes, Elite Friends
and. Investigators Say, Underage Girls.,” published on August 14,2006, reporting that:
Haley Robson, a local community college student, admitted in a sworn statement to
police that “she had taken at least six girls to visit Epstein, all between the ages of 14
and 16;” Palm Beach Police “interviewed five alleged victims and 17 witnesses-”
“Dershowitz, the Harvard law professor, traveled to West Palm Beach with information
about the girls,” including social media discussions about “their use of alcohol and
marijuana;” after meeting with Epstein’s legal team, “prosecutors postponed their
decision to take the case to a grand jury;” Palm Beach Police subsequently “received
complaints that two of the victims or their families had been harassed or threatened;”
“relations between police and prosecutors were fraying” as the investigation continued;
and “one girlwho was subpoenaed- the one who said she had sexual intercourse with
Epstein- never showed up” to testify before the grand jury.
»
■
“Trump Snags Gosman Estate for $41 Million” published on November 16, 2004,
reporting on the bidding war between Donald Trump and Jeffrey Epstein for the
purchase of a
seven-bedroom estate on 6. oceanfront acres along
the storied ‘Raider’s Row”’ in Palm Beach.
•
“Indictment: Billionaire Solicited 3 Times” published on July 25, 200...

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“After Long Probe, Billionaire Faces Solicitation Charge” published on July 26, 2006,
reporting that “Palm Beach police thought there was probable cause to charge Epstein
with unlawful sex acts with a minor and lewd and lascivious molestation.” Ilie article
further reported that “Police Chief Michael Reiter was so angry with State Attorney
Barry Krischer’s handling Of the case that he wrote a memo suggesting the county’s
top prosecutor disqualify himself,” and identified a 20-year-old on-the-record female
source who said “she gave Epstein a massage in the nude, then brought him six girls,
ages 14 to 16, for massage and sex-tinged sessions at his home.”
•
“Police Say Lawyer Tried to Discredit Teenage Girls” published on July 29, 2006,
reporting that “[f]amed Harvard law professor Alan Dershowitz met with the Palm
Beach County State Attorney’s Office and provided damaging information about
teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein,
sexually charged massages” and that “[tjhe state attorney’s office said it presented the
Epstein case to a county grand jury this month rather than directly charging Epstein
because of concerns about the girls’ credibility.”
•
“Expert: Ignorance of Age Isn’t Defense In Sex Cases” published on August 5, 2006,
reporting that “(rjather than file; charges, the state attorney’s office presented the case
to a county grand jury” which “indicted Epstein last week on a single, less serious
charge of felony solicitation of prostitution,” and that “[t]he case raised eyebrows
because the state attorney’s office rarely, if ever, kicks such charges to a grand jury.”
•
“Epstein Camp Calls Female Accusers Liars” published.on August 8, 2006, reporting
that “[a] state attorney’s spokesman would say only that the office refers cases to the
grand jury when there are issues with the viability of the evidence or witnesses’
credibility.”
•
“Palm Beach Chief Focus of Fire In Epstein Case” published on August 14, 2006,
rep...

offender,” and that “[a]s part of the plea deal, federal investigators agreed to drop their
investigation of Epstein, which they had taken to a grandjury.”
•
“Jeffrey Epstein: Scientist, Stuntman, ‘Sex Slave’ Visit Jailed Tycoon” published on
August 13, 2008, reporting that “[djuring his first month of confinement” Epstein was
visited by Sarah Kellen, who allegedly escorted victims “upon their arrival at his Palm
Beach waterfront home to an upstairs room, where she prepared the massage table and
provided the oils for their encounters” with Epstein, and by Nadia Marcinkova, “a
young woman whom Epstein purportedly described as his Yugoslavian sex slave.”
•
“Billionaire Sex Offender Leaves Jail Six Days a Week For Work” published on July
1, 2008, reporting that Epstein “is allowed to leave the Palm Beach County Stockade
six days a week on a work-release program.”
•
“Women Want Epstein Sex Plea Deal Unsealed” published on June 10,2009, reporting
that attorneys for women suing Epstein in various courts “want his [noh-prosecution]
agreement. [NPA] with federal prosecutors unsealed” and were moving to unseal the
agreement in Circuit Court ofthe Fifteenth Judicial Circuit, and that “Epstein now faces
at least a dozen civil lawsuits in federal and state courts filed by young women who
said they had sex with him and now are seeking damages.” On that date. The Palm
Beach Post moved to intervene in the matter for the purpose ofobtaining public access
to the NPA, which was ordered disclosed by this Court on June 25, 2009.
•
“Epstein’s Secret Pact With Feds Reveals ‘Highly Unusual’ Terms” published on
September 19, 2009, reporting that, Owing to Epstein’s non-prosecution agreement,
“federal prosecutors backed down and agreed to recall grand jury subpoenas ifEpstein
pleaded, guilty to
felonies in state court” and “also agreed not to
charge any of Epstein’s possible co-conspirators: Sarah Kellen, Adriana Ross, Lesley
Groff and Nadia Marcinkova.”
The article further reported that, a...

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“Judge Rules Feds’ Agreement With Jeffrey Epstein Pact Violated Teen Victims’
Rights” published oh February 22, 2019, reporting oh a ruling by U.S. District Judge
Kenneth Marra that “Federal prosecutors violated the rights of Jeffrey Epstein’s
teenage victims [under the Crime Victims’ Rights Act] by failing to reveal they had
dropped plans to prosecute the billionaire on dozens of federal charges in connection
with the girls’ claims that he paid them for sex at his Palm Beach mansion ”
•
“Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex
Trafficking, Conspiracy Charges In Federal Court In Manhattan” published on July 9,
2019, reporting on Epstein’s appearance in U.S. District Court for die Southern District
ofNew York in which he “pleaded not guilty to charges accusing him ofcreating a vast
network of girls as young as 14 that he exploited for his sexual pleasure at his homes
in Palm Beach and Manhattan.”
A true and correct copy ofthe above news articles, in either the computerized format in which they
are maintained in The Palm Beach Post's electronic archives or the news print edition in which
originally published, is. annexed hereto as Exhibit 1.
54.
The press has a constitutional right of access to criminal proceedings, see, e.g,
Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal
proceedings. Newman v Graddick, 696 F.2d 796 (11 th Cir. 1983). Indeed, “the integrity of the
judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in
proceedings of this kind [pre- and post-trial] as at trial.” Id. at 801: see also Miami Herald Publ.
Co. v. Lewis, 426 So. 2d 1,6-7 (Fla. 1982) (identifying the news media as a “public surrogate” in
matters concerning the closure ofjudicial proceedings). The press also has a First Amendment
interest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer
Council, 425 U.S. 748, 756-57 (1976) (“Whe...

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has “standing to assert a right to receive speech” by “showing] that there exists a speaker willing
to convey the information to her”).
55 .
Because of the unique role performed by the press as a “public surrogate” (Lewis,
426 So. 2d at 6-7) in protecting the right of access and its interest in .reporting information about
criminal proceedings, news organizations “presumptively have a right to access judicial records,”
Comm 'r, Ala, Dep'tofCorr.v. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11th Cir, 2019),
and “standing to question the validity of an order restricting publicity because its ability to gather
news is directly impaired or curtailed.” Lewis, 426 So. 2d at 4; see also Carlson v. United States,
837 F.3d 753, 757—58 (7th Cir. 2016) (“[a]s a member of the public, [the Reporters Committee]
has standing to assert [its] claim” to grandjury materials because such materials are “public records
to which the public may seek access, even if that effort is ultimately unsuccessful”).
56 .
Here, the continued denial of access to information The Palm Beach Post seeks on
behalf of its journalists and the public it serves “unquestionably constitutes irreparable injury.”
Gainesville Woman Care, LLC V- State ofFlorida, 210 So. 3d 1243, 1263 (Fla. 2017); see also
Zerilli v. Smith, 656 F.2d 705, 711 (D C. Cir. 1981) (noting that “the press’ function as a vital
source of information is weakened whenever the ability of journalists to gather information is
impaired,” as it is by Attorney General’s refusal to disclose unredacted report and underlying grand
jury materials).
E.
The Court’s Supervision of the Grand Jury Process and Its Authority’to Order
Public Disclosure of the Epstein Evidence.
57.
The Florida Supreme Court has noted that “in states such as Florida, where the
grand jury is preserved, it is an important appendage of the court which impanels it. At the same
time it should not be forgotten that the judge of that court is equally important and he is generally...

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maintain the dignity and the integrity of both the grand jury and the presiding judge.” State v.
Clemons, 150 So. 2d 231, 233-34 (Fla. 1963).
58.
Chapter 905 of the Florida Statutes governs the empanelment and conduct of
Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury
about its legal duties. Fla. Stat. § 905.18.
59.
Florida Stat. Section 905.27(1) provides that “the testimony of a witness examined
before the grand jury ... or other evidence received by it” may be disclosed “when required by a
court... for the purpose of: (a) Ascertaining, whether it is consistent with the testimony given by
the witness before the court; (b) Determining whether the witness is guilty of perjury; or (c)
Furthering justice.” Fla. Stat- § 905.27(1 )(a)-(c).
60.
Further, disclosure is appropriate pursuant to this Court’s inherent authority over
grand jury' proceedings because of the exceptional public interest in this case and the compelling
circumstances supporting transparency. Carlson v. UnitedStates, 837 F.3d at 766 (“a districtcourt
has the inherent power to disclose [grand jury] materials in exceptional circumstances and ..,
historic importance can be a sufficient reason when there is little countervailing need for secrecy”).
COUNT!
(Florida Stat. Section 905.27)
61.
Based on information learned by The Palm Beach Post through its Florida Public
Records Law requests, law enforcement sources with direct knowledge ofthe grandjury evidence
and proceedings, judicial documents obtained from independent but related court proceedings, and
documents otherwise available in the public record, the State Attorney for Palm Beach County
presented truncated evidence of Epstein’s criminal wrongdoing to the 2006 grand jury in a mariner
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maintain the dignity and the integrity of both the grand jury and the presiding judge." State v. 
Clemons, 150 So. ...

that precluded his indictment for the serious crimes he committed, including sex trafficking and
sexual assault.
62;
Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's
victims and the public, and to provide public disclosure to illuminate whether Epstein received
unreasonably lenient treatment based on the available evidence. The Palm Beach Post requests
immediate public access to the testimony, minutes, and other evidence presented in 2006 to the
Palm Beach County grand jury. In a case of this magnitude and importance, where the accused is
dead and so many ofhis crimes, as well as the identities arid crimes ofhis co-conspirators, and the
identities of the victims have already been exposed, the need for grand jury secrecy is no more.
See United States v. S.ocony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) C‘[A]fter the grand jury’s
functions are ended, disclosure is wholly proper where the ends ofjustice require it.”).
WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla.
Stat. Section 905.27(1) and the Court’s inherent authority, order the State Attorney arid the Clerk
of the Court to file with,this Court copies of the testimony, minutes, and other evidence presented
in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so
that, following an in camera inspection, it can be made available to The Palm Beach Post and the
public on an expedited basis, and grant any other and further equitable or legal relief the Court
deemsjust and proper.
CA/ArOfft®BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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• 
• 
that precluded his indictment for the serious crimes he committed, in~luding sex trafficking and 
sexual assault. 
62, 
Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's 
victims and the public, and to provide pµblic 4iscJosw-e to illuminate whether Epstein received 
unreasonably lenient treatment based...

e
Dated: November 14, 2019
e
ACTIVE 456787O9v3
Respectfully submitted,
GREENBERG TRAURIG, P.A.
Attorneysfor CA Florida Holdings, LLC,
Publisher of The Palm Beach Post
Stephen A, Mendelsohn, Esq.
5100 Town Center Circle. Suite 400
Boca Raton, Florida 33486
Telephone: (561) 955-7629
Facsimile: (561) 338-7099
By: /s/StenhenA. Mendelsohn__
STEPHEN A. MENDELSOHN
Florida Bar No. 849324
.mendeisohns@gfiaw.com
hasenh@gtlaw.com
FLService@gtlaW;Com
By:
. Isl Michael J Grvaiel
MICHAEL J GRYGIEL .~“
{Pro Hac Vice application forthcoming)
54 State St, 6fh Floor
Albany, New York 12207
Telephone: (518) 689-1400
Facsimile: (518)689-1499
grvgielm@gtlaw.com
By: hi Vincent H. Chieffo
.„
—
.
,
VINCENT H. CHIEFFO
{Pro Hac Vice application forthcoming)
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: (310) 586 7700
Facsimile: (310 586 7800
chieffov@gl Iaw,com
riveraal@gtlavv.com
By:
Isl NinaD.Bovajian___
NINAD.BOYAJIAN
{Pro Hac Vice, application forthcoming)
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: (310) 586 7700
Facsimile: (310) 586 7800
boyajiann@gtlaw.com
riveraal@gtlaw.coin
19
CA/AropjggOgl^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
• 
Dated: November 14, 2019 
ACTIVE 45678709v3 
• 
Respectfully submitted, 
GREENBERG TRAURIG, P.A. 
Attorneys/or CA flori4a iioidi_r,zgs; LLC, 
Publish?rofThe Palrn Beach Post 
Stephen A Mendelsohn, Esq. 
5100 Town Center. Circle, Suite 400 
Boca Raton, <Florida 33:486. 
Telephom;: (56l) 9$5-7629 
F~csim_il~: (56 l) 338-7099 
By: Isl Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHi'f 
Florida Bar No. 849324 
mendeisohns(@rtiaw.com 
hasenh@gtlaw:com 
FLService@gtlaw.com 
By: .. Isl Michael J Grvgiel.-
MIC:HAEL J GRYGIEL 
(Pro Hae Vice application forthcoming) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: {518) 689-1400 
Facsimile: (518} 689-1499 
QIVgielm(ii).!!tlawcom 
By; js! Vincent H Chiefio 
VINCENT H. CHIEFFO 
(Pro Hae Vice application forthcoming) 
1840 ...

EXHIBIT 1
The Newspaper’s Reportage on Jeffrey Epstein
CA/Aropf^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The Newspaper's Reportage on Jeffrey Epstein 
CA/Aro~Pl1fb?itt% BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

The Palm Beach fbst
REALNEWSSTARTSHERE
This Man Who Had Everything: Jeffrey Epstein craved big
homes, elite friends and underage girls
By AndrewMarra
Posted Jul 17,2019 at 6:02 AM
From the archives: When Palm Beach detectives started asking
questions and teenage girls started talking, a wave oflegal resistance
followed.
Editor’s Note: This article appeared in The Palm Beach Post on August 14,2006, three weeks after
Jeffrey Epstein’s arrest in Palm Beach County on a charge offelony solicitation ofprostitution.
WINGED GARGOYLES guarded the gate atJeffrey Epstein’s Palm Beach mansion. Inside,
hidden cameras trolled two rooms, while the girls came and went.
For the police detectives who sifted through the garbage outside and kept records ofvisitors, it
was the lair of a troubling target.
Epstein, one of the most mysterious of the country’s mega-rich, was known as much for his
secrecy as for his love of fine things: magnificent homes, private jets, beautiful women,
friendships with the world’s elite.
But at Palm Beach police headquarters, he was becoming known for something else: the
regular arrival ofteenage girls he hired to give him massages and, police say, perform sexual
favors.
Epstein was different from most sexual abuse suspects; he was far more powerful. He counted
among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
with some ofthe most prominent legal, scientific and business minds in the country.
When detectives started,asking questions and teenage girls started talking, a wave oflegal
resistance followed.
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The Palm Beach Post 
REAL NEWS$TIUOl D 
The ,Man, Wh:o l.Had :iverylbtng{ leff r~y Epsteirt ctav:«ia big· 
lhonies~ :ente·:fri'.e.nds :arid: und·au~age :gitls: 
By Aridrew"Marra 
Posted Jul 17, 2019 at 6:02 AM 
From the .archives: When Palm Beach detectives started asking 
questions and teenage girls started talking, a wave of legal res...

>> NEW; Jeffrey Epstein: Lawyer said financier had sex with woman during work-
release
IfPalm Beach police didn't know quite who Jeffrey Epstein was, they found out.soon enough.
Epstein, now 53, was a quintessential man ofmystery. He amassed his fortune and friends
quietly, always in the background as he navigated New York high society.
When he first attracted notice in the early 1990s, it was on account of the woman he was
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
In a lengthy article, headlined “The Mystery of Ghislaine Maxwell’s Secret Love,” the British
Mail on Sunday tabloid laid out speculative stories that the socialite’s beau was a CIA spook, a
math teacher, a concert pianist or a corporate headhunter.
“But what is the truth about him?” the newspaper wondered. “Like Maxwell, Epstein is both
flamboyant and intensely private.”
The media frenzy did not begin in full until a decade later. In September 2002, Epstein was
flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to
Africa on his private jet.
Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair
published lengthy profiles. The New York Post listed him as one ofthe city’s most eligible
bachelors and began describing him in its gossip columns with adjectives such as “mysterious”
and “reclusive."
Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
Building a life ofextravagance
He was born blue-collar in 1953, the son of a New York City parks department employee, and
raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree
but became a math teacher at the prestigious Dalton School in Manhattan.
The story goes that the father of one of Epstein’s students was so impressed with the man that
he put him in touch with a senior partner at Bear Stearns, the global investment bank and
securities firm.
CA/Aropfg^O^ BEACH COUNTY, FL, JO...

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In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started}.
Epstein and Co, That is when he began making his millions in earnest.
Little is known or said about Epstein's business except this: He manages money for the
extremely wealthy. He is said to handle accounts only of $ 1 billion or greater.
It has been estimated he has roughly 15 clients, but their identities are the subject ofonly
speculation. All except for one: Leslie Wexner, founder ofThe Limited retail chain and a
former Palm Beacher who is said to have been a mentor to Epstein.
Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a
block on Manhattan’s Upper East Side. It is reported to have, among its finer features, closed-
circuit television and a heated sidewalk to melt away fallen snow.
That townhouse, thought to be the largest private residence in Manhattan, is only a piece of
the extravagant world Epstein built over time,
In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch
outside Santa Fe. Many believed it to be the largest home in the state.
In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre
private island in the Virgin Islands.
» PHOTOS: The players in the Jeffrey Epstein saga
Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
the highest echelons ofpower. This includes not only socialites but also business tycoons,
media moguls, politicians, royalty and Nobel Prize-winningscientists whose research he often
funds.
"Just like other people collect art, he collects scientists,” said Martin Nowak, who directs the
Programfor Evolutionary Dynamics at Harvard University and was reportedly the recipient of
a $30 million research donation from Epstein,
Epstein is said to have befriended former Harvard President Larry Summers, prominent law
Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort...

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And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
photographed.
"The odd thing is I never met him,” said Dominick Dunne, the famous chronicler ofthe trials
and tribulations ofthe very rich. "I wasn’t even aware ofhim,” except for a Vanity Fair article.
Epstein's friendship with Clinton has attracted the most attention.
Epstein met Clinton as early as 1995, when he paid tens ofthousands ofdollars to join him at
an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become
close friends until after Clinton left the Oval Office and moved to New York.
Epstein has donated more than SI 00,000 to Democratic candidates'campaigns, including John
Kerry’s presidential bid, the reelection campaign of New Mexico Gov. Bill Richardson and the
Senate bids ofJoe Lieberman, Hillary Rodham Clinton, Christopher Dodd and Charles
Schumer.
Powerful friends and enemies
A Vanity Fair profile found cracks in the veneer ofEpstein’s life story. The 2003 article said he
left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange
Commission violation. It also pointed out that Citibank once sued him for defaulting on a S20
million loan.
The article suggested that one of his business mentors and previous employers was Steven
Hoffenberg, now serving a prison term after “bilking investors out ofmore than S450 million
in one ofthe largest Ponzi schemes in American history.”
As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the
man who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less
than $16,000 in furnishings.
A former friend claimed Epstein backed out ofa promise to reimburse him hundreds of
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
owed him nothing.
» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says
CA/Arop^^Og]^ BEACH COUNTY, FL, JOSEPH ABRUZZO,...

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“It’s a bad memory. I would rather not have ever metJeffrey Epstein,” said Michael Stroll, the
retired former president ofWilliams Electronics and Sega Corp. “Suffice it to say [ have
nothing good to say about him.”
Among the characteristics most attributed to Epstein is a penchant for women.
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian
model
“He’s a lot offun to be with,” Donald Trump told New York magazine in 2002. “It is even said
that he likes beautiful women as much as I do, and many ofthem are on the younger side. No
doubt about it, Jeffrey enjoys his social life.”
Investigation leads to Epstein
Although he was not a frequenter of the Palm Beach social scene, he made his presence felt.
Among his charitable donations, he gave S90,000 to the Palm Beach Police Department and
S 100,000 to Ballet Florida.
In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a green
Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a
private chef and a small staff stood at the ready. From a window in his mansion, he could look
out on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man
who had everything.
But extraordinary wealth can fuel extraordinary desires.
» Epstein wants to leave jail for mansion in sex-trafficking case
In March 2005, a worried mother contacted Palm Beach police. She said another parent had
overheard a conversation,between their children.
Now the mother was afraid her 14-year-old daughter had been molested by a man on the
island.
The phone call triggered an extensive investigation, one that would lead detectives to Epstein
but leave them frustrated.
CA/Aropf^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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j'lfs a bad memory. I would rather not have ever met Jeffrey Epstein," said M...

Palin Beach police and the state attorney’s office have declined to discuss the case. But a Palm
Beach police report detailing the criminal probe offers a window into what detectives faced as
they sought to close in on Epstein.
Detectives interviewed the girl, who told them a friend had invited her to a rich man’s house to
perform a massage. She said the friend told her to say she was 18 ifasked. At the house, she
said she was paid S300 after stripping to her panties and massaging the man while he
masturbated.
Police interview 5 alleged victims
The investigation began in full after the girl identified Epstein in a photo as the man who had
paid her. Police arranged for garbage trucks to set aside Epstein’s trash so police could sift
through it, They set up a video camera to record the comings and goings at his home. They
monitored an airport hangar for signs of his private jet’s arrivals and departures.
They quickly learned that the woman who took the 14-year-old girl to Epstein's house was
Haley Robson, a Palm Beach Community College student from Loxahatchee. In a sworn
statement at police headquarters, Robson, then 18, admitted she had taken at least six girls to
visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said.
During the drive back to her house, Robson told detectives, “I’m like a Heidi Fleiss."
Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls
said they had been instructed to have sex with another woman in front ofEpstein, and one said
she had direct intercourse with him.
In October, police searched the Palm Beach mansion. They discovered photos of naked, young-
looking females, just as several of the girls had described in interviews. Hidden cameras were
found in the garage area and inside a clock on Epstein’s desk, alongside a girl’s high school
transcript.
Two ofEpstein’s former employees told investigators that young-looking girls showed up to
perform massages two or thre...

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t
One employee told detectives he was told to send a dozen roses to one teenage girl after a high
school drama performance. Others were given rental cars. One, according to police, received a
$200 Christmas bonus.
The cops moved to cement their case. But as they tried to tighten the noose, they encountered
other forces at work.
In Orlando they interviewed a possible victim who told them nothing inappropriate had
happened between her and Epstein. They asked her whether she had spbkeh to anyone else.
She said yes, a private investigator had asked her the same questions.
» Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal
When they subpoenaed one of Epsteins former employees, he told them the same thing. He
and a private eye had met at a restaurant days earlier to go over what the man would tell
investigators.
Detectives received complaints that private eyes were posing as police officers. When they told
Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the
high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
Kennedy Smith.
While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law
professor, traveled to West Palm Beach with information about the girls. From their own
profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
their use ofalcohol and marijuana.
He took his research to a meeting with prosecutors in early 2006, where he sought to cast
doubt on the teens' reliability;
The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
did some of the girls have issues with drugs or alcohol but also some had criminal records and
other troubles, Epstein’s legal team claimed; And at least one of them, they said, lied when she
told police she was younger than 18 when she started performing massages for Epstein.
After the meeting, prosecutors postponed their decision to take the case to...

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In the following weeks, police received complaints that two of the victims or their families had
been harassed or threatened. Epstein's legal team maintains that its private investigators did
nothing illegal or unethical during their research.
By then, relations between police and prosecutors were fraying. At a key meeting with
prosecutors and the defense, DetectiveJoseph Recarey, the lead investigator, was a no-show,
according to Epstein’s attorney.
"The embarrassment on the prosecutor’s face was evident when the police.officer never
showed up for the meeting,” attorneyJack Goldberger said.
Later in April, Recarey walked into a prosecutor’s office at the state attorney’s office and
learned the case was taking an unexpected turn.
The prosecutor, Lanna Belohlavek, told Recarey the state attorney s office had offered Epstein
a plea deal that wouldnot require him to serve jail time or receive a felony conviction.
Recarey told her he disapproved ofthe plea offer;
The deal never came to pass, however.
Future unclear after charge
On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four
counts of unlawful sexual activity with a minor and to charge his personal assistant, Sarah
Kellen, now 27, for her alleged role in arranging the visits. Police officials also wanted to
charge Robson, the self-described Heidi Fleiss, with lewd and lascivious acts.
By then, the department was frustrated with the way the state attorney’s office had handled the
case. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter
wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if
he would not act.
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
the grand jury.
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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In the following Weeks, police received complaints that two of the yic~unsi or their famifies had 
be...

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It is not known how many ofthe girls testified before the grand jury. But Epstein’s defense
team said one girl who was subpoenaed - the one who said she had sexual intercourse with
Epstein - never showed up.
The grand jury’s indictment was handed down in July. It was not the one the police
department had wanted.
Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was
charged with one count of felony solicitation of prostitution, which carries a maximum penalty
of five years in prison. He was booked into the Palm Beach Countyjail earlyJuly 23 and
released hours later.
Epstein’s legal team "doesn’t dispute that he had girls over for massages,” Goldberger said. But
he said their claims that they had sexual encounters with him lack credibility.
"They are incapable of being believed,” he said. “They had criminal records. They had
accusations of theft made against them by their employers. There was evidence ofdrug use by
some ofthem.”
What remains for Epstein is yet to be seen.
The Palm Beach Police Department has asked the FBI to investigate the case. It also has
returned the $90,000 Epstein donated in 2004.
In New York, candidates for governor and state attorney general have vowed to return a total
of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein’s powerful
friends have remained silent as tabloids and Internet blogs feast on the public details ofthe
police investigation.
Goldberger maintains Epstein’s innocence but says the legal team has not ruled out a future
plea deal. He insists Epstein will emerge in the end with his reputation untarnished.
“He will recover from this,” he said.
Staffwriter Larry Keller and staffresearchers Bridget Bulger, Angelica Cortez, Amy Hanaway and
Melanie Mena contributed to this story.
amarra@pbpost.com
CA/Arop^eg^l^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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It is not kno\\TIT how many of the girls testified before the grand...

@AMarraPBPost
CA/Aropfg^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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·@AMarraPBPost 
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CA/Aro~Pcffl5?'f>A1t:Rf BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

9
273 / 278 - Tuesday; November 16,2004
Edition: FINAL
Section: A SECTION
Page: 1A
Source: By PAUL OWERS Palm Beach Post Staff Writer
Illustration: PHOTO (C & 2 B&W) & MAP (B&W)
Memo: Rah all editions.
Dateline: WEST PALM BEACH
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
When it came time to bid Monday for the palatial Palm Beach digs ofAbe Gosman, The
Donald was hot about to be trumped.
"Nobody was going to outbid me," the brash developer-turned-TV-personality said from his
New York office.
Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot,
seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row,"
But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at
513 N; County Road; He wants to - what else? - seli .it and make more money.
The star ofthe mega-hit The Apprentice said he intends to redevelop the site into a "super
luxury house” that would be the "finest anywhere in the United States." He might build
another house before flipping the entire package,
"I’ve known about this house for quite some time," Trump said. "It’s probably the best piece
of land in Florida - and probably the country - for luxury real estate.”
Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor
Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith
said she's not worried about Trump's plans.
"He's been a very good property owner in the town ofPalm Beach," she said. "He does his
projects very well. He's a perfectionist.”
Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of
Gosman's Chapter 7 bankruptcy case, Proceeds from the sale wall go into escrow for eventual
distribution to creditors.
The auction began at exactly noon after Judge Steven Friedman dismissed an objection from
an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully
that Trump was hot a qualified bidder because his c...

But Friedman allowed the offer to stand, and Pulte and Trump went back and forth until
Pulte dropped put. at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at
$38.6 million.
Friedman closed the bidding 10 minutes after it started, leaving Trump with the right to buy
the 29,000-square-foot home (atypical Palm Beach County single-family house is about
2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service
quarters.
The closing could take place within a week but probably won't happen until next.month.
Trustee Joe Luzinski and creditors said they were pleased with the outcome,
"We knew we were dealing with some substantial people ... who were going to bid it up a
bit," Luzinski said.
"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.
"In bankruptcy court, the idea is to get the most for creditors, and that’s what happened,"
The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer
former listing agent Sotheby’s International Realty received was $32 million. Sotheby's won't
receive a commission, he said.
Pulte, 42, ofBoca Raton, said he figured Trump wouldn't back down Monday.
"I got the feeling he was willing to go a lot higher, and; I didn't want to chase it" Pulte said.
Pulte said Gosman asked him before the auction whether he would be willing to let him stay
in the mansion after the closing until he decides where he wants to move. Trump and
Luzinski said they have had no such discussions with Gosman.
Gosman, 75, had the house built after paying $12,1 million for the land in 1986.
The former health-care magnate declined interview requests before and after the auction
Monday. He was at the courthouse but left before the auction took place.
The $41.35 million price tag eclipses the $30,35 million sale of Lowell "Bud” Paxson's Palm
Beach home and guest house but falls short of the $45 million that Virginia home builder
Dwight Schar paid for ...

e
The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
an ownership interest in his home and other belongings only to avoid losing them in
bankruptcy . Gosman has denied any' wrongdoing, saying he made the property transfers in
1999, well before he filed for bankruptcy.
Lessen is expected to rule in the next two months whether Gosman made improper transfers,
a decision that will affect how much money will be available to creditors.
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
willing to move forward, in part because the upkeep of the estate now exceeds their means.
"This is not a happy occasion for them, but at least we're moving to the next level," Cimo
said. "That's not a house you want to live in unless you're making large amounts ofmoney
like Donald Trump.”
paul_owers@pbpost.com
CA/Aropf^Og^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The trustee alleged during a weeklongtrial in May that Gosman frauduleµtly gave his wife 
ano,Vnership interest inhis.ho_me, lllld other belqngings only to avoid losing them in 
bankruptcy. -Gosman has denied arty wrongdoing, saying;he made the propetty transfers in 
1999, well before he, filed for: bq!U(11lptcy. 
• • 
Less.en is expected to nile in the next two months whether Gosman made improper transfers, 
a decision that will affect how much money wUl be available to- creditors, 
-
Cimo acknowledged that Monday wasn't the best of days for the Gosrilans but S<:lid they were 
willing to move fonvard, fa part because the upkeep of the estate now exceeds their means. 
"This is not a happy occasion for them, but at least we're moving to the next level," Cimo 
said. "That's riot a house you want to live in unless yo11're making large amounts of money 
like Donald Trump." 
paui _ owers@pbpost.com 
CA/Aropft:ffl5?~A.fM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

iiziiimillionaire boncnea a limes - news -
i ne raim oeacn roe
iraim oeacn. rt
he Bata Beach Post
REALNEWSSTARTSHERE
Indictment: Billionaire Solicited 3 Times
Posted Jul 1,2008 at 12:01 AM
Updated Oct 2,2019 at 2:30 PM
{EDITORS NOTE: This story originally published in The Palm Beach Post on July 25,
2006)
Billionaire money manager and Palm Beach part-time residentJeffrey Epstein
solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31
oflast year, according to an indictment charging him with felony solicitation of
prostitution.
Epstein, 53, was booked at the Palm Beach Countyjail at 1:45 a.m. Sunday. He
was released oh S3,000 bond.
Epstein’s case is unusual in that suspected prostitution johns are usually charged
with a misdemeanor, and even a felony charge is typically made in a criminal
information - an alternative to an indictment charging a person with the
commission of a crime.
His attorney, Jack Goldberger, declined to discuss the charge.
State attorney’s office spokesman Mike Edmondson also had little to say.
"Generally speaking, there is a case that has a number ofdifferent aspects to it,”
Edmondson said of a
charge being submitted to a grand jury;
"We first became aware ofthe case months ago by Palm Beach police.”
Prosecutors and police worked together to bring the case to the grand jury, he
said.
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CA/Ar°plffl>Qm BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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REAL NEW$ STARTS HERE 
Indictment: Billionaire Solicited 3 Tim:es 
Posted Jul 1, 20QB at 12:0J AM 
Updated Oct 2, 20f9 at 2:30 PM 
{EDITORS NOTE: This story originally pubiisiud in The Palm Beadt Post on July 25, 
i006) 
Billionaire money manager and Palm :Beach part-time resident Jeffyey Epstein 
solicited ot procured prostitutes th,ree or .more times between Aug. 1 and Oct. 31 
oflast year, according to an indictment charging him with felony soiicitation of 
prostitution. 
Epstein; 53;Was booked at the PalmBeach County jail at l:45 a.m. S...

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Palm Beach police confirmed that and said the department will release a report
today regarding its investigation.
Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a
pool and a boat dock on the Intracoastal Waterway since 1990, according to
property records. A man answering the door there Monday said that Epstein
wasn't home. A Cadillac Escalade registered to him was parked in the driveway,
which is flanked by two massive gargoyles.
Epstein sued Property Appraiser Gary Nikolits in 2001. contending that the
assessment of his home exceeded its fair market value. He dismissed his lawsuit
in December 2002.
A profile ofEpstein in Vanity Fair magazine said he owns what are believed to
be the largest private homes in Manhattan - 51,000 square feet - and in New
Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the
U.S. Virgin Islands and fleet of aircraft
Epstein’s friends and admirers, according to the magazine, include prominent
businessmen, academics and scientists and famed Harvard law professor Alan
Dershowitz.
larry keller@pbpost.com
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NOT A CERTIFIED COPY
100.: 01111onaire::>oucnea .3 11mes •News• 1ne:fa1rri oeacri ,-.a.st l"airn oeacn, r-L 
Palm Be~ch police confirmed that and said the department will release a report 
today regarding its investigation. 
Epstein has owned a five'"bedrooni, 7 1/2-ba.th, 7,234-square-foot home with a 
pool and a boat dock oh the lntracoasta.l Waterway ~ince 1990,. according to 
property records. A man answering th.e door thgre Monday said that Epstein 
wasn't home. A Cadillac Escalade Jegistered to him was parked ih the driveway, 
which is flanked l:>y two massive gargoyles. 
Epstein sued Property.Appraiser Gary Nikolits in 2001, contend...

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The Palm Beach Post
Hai NETO STARTSHat
After long probe, billionaire faces solicitation
charge
Posted Jul 27,2006 at 12:01 AM
Updated Oct 3,2019 at 3:11 PM
(EDITOR’S NOTE: This story originally published in The Palm Beath Post on July 26,
2006)
Palm Beach billionaireJeffrey Epstein paid to have underage girls and young
women brought to his home, where he received massages and sometimes sex,
according to an investigation by the Palm Beach Police Department.
Palm Beach police spent months sifting through Epstein’s trash and watching his
waterfront home and Palm Beach International Airport to keep tabs on his
private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
him with one count of felony solicitation of prostitution.
Palm Beach police thought there was probable cause to charge Epstein with
unlawful sex acts with a minor and lewd and lascivious molestation .
Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's
handling ofthe case that he wrote a memo suggesting the county's top
prosecutor disqualify himself.
“I must urge you to examine the unusual course that your office’s handling ofthis
matter has taken and consider ifgood and sufficient reason exists to require your
disqualification from the prosecution of these cases/* Reiter wrote in a May 1
memo to Krischer.
While not commenting specifically on the Epstein case, Mike Edmondson,
spokesman for the state attorney, said his office presents cases other than
murders to a grand jury when.there are questions about witnesses' credibility and
their ability to testify.
CA/Arop^-0^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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After long probe, billionaire faces soHcitatlon 
charge~ 
Posted Jul 27, 2006 at 12:01 AM 
Updated Oct3, 2019 at 3:11 PM ...

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By the nature oftheir jobs, police officers look at evidence from a “one-sided
perspective,” Edmondson said. “A prosecutor has to look at it in a much broader
fashion,” weighing the veracity ofwitnesses and how they may fare under
defense attorneys’ questioning, he said.
Epstein’s attorney,Jack Goldberger, said his client committed no crimes.
“The reports and statements in question, refer to false accusations that were not
charged because the Palm Beach County state attorney questioned the credibility
of the witnesses,” Goldberger said. A county grand jury “found the allegations
wholly unsubstantiated and not credible,” and that's why his client was not
charged with sexual activity with minors, he said.
Goldberger said Epstein passed a lie detector test administered by a reputable
polygraph examiner in which he said he did not know the girls were minors.
Also, a search warrant served on Epstein’s home found no evidence to
corroborate the girls’ allegations, Goldberger said.
According to police documents:
- A Palm Beach Community College student said she gave Epstein a massage in
the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged
sessions at his home.
- A 27-year-oId woman who worked as Epstein’s personal assistant also
facilitated the liaisons, phoning the PBCC student to arrange for girls when
Epstein was coming to town, And she escorted the girls upstairs when they
arrived, putting fresh sheets on a massage table and placing massage oils nearby.
- Police took sworn statements from five alleged victims and 17 witnesses. They
contend that on three occasions, Epstein had sex with the girls.
A money manager for the ultra-rich, Epstein was named one of New York’s most
eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with
the likes offormer President Clinton, former Harvard University President
Lawrence Summers arid Dona...

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He has contributed tens ofthousands of dollars to Democratic Party candidates
and organizations, including Sen. John Kerry's presidential bid, and the Senate
campaigns ofJoe Lieberman, Hillary Clinton, Christopher Dodd and Charles
Schumer.
Goldberger is one of five attorneys Epstein has retained since he became the
subject of an investigation, Edmondson said. Among the others: Alan
Dershowitz, the well-known Harvard law professor and author, who is a friend
of Epstein. Dershowitz could not be reached for comment.
Police said the woman who enlisted young girls for Epstein was Haley Robson,
20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in
Wellington and said she was a journalism major at Palm Beach Community
College when she was questioned by police last October. She has an unlisted
phone number and could not be reached for comment,
Robson said she met Epstein when, at age 17, a friend asked her if she would like
to make money giving him a massage. She said she was driven to his five-
bedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs
to a bedroom with a massage table and oils. Epstein and Robson were both naked
during the massage, she said, but when he grabbed her buttocks, she said she
didn’t want to be touched.
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CA/AroPjffi5°^]®I BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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He h.i.s contributed tens of thousands ·of dollars to Democratic Party candidates 
.1.11d organizations, including Sen. John Kerry's presidentlal bid, ~n~ die Senate 
campaigns of Joe Liebennan, Hillary Clinton, Christopher Dodd and Charles 
Schumer. 
Goldberger is one of five <!ttorneys Epstein has retained since he ...

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Epstein said he’d pay her to bring him more girls - the younger the better,
Robson told police. When she tried once to bring a 23-year-old woman to him,
Epstein said she was too old, Robson said.
Robson, who has hot been charged in the case, said she eventually brought six
girls to Epstein who were paid $200 each time, Robson said. “I’m like a Heidi
Heiss,” police quoted her as saying. The girls knew what to expect when they
were taken to Epstein’s home, Robson said. Give a massage - maybe naked - and
allow some touching.
One 14-year-oldgirl Robson took to meet Epstein led police to start the
investigation ofhim in March 2005. A relative of the girl called to say she
thought the child had recently engaged in sex with a Palm Beach man. The girl
then got into a fight with a classmate who accused her ofbeing a prostitute, and
she couldn’t explain why she had $300 in her purse.
The girl gave police this account of her meeting with Epstein:
She accompanied Robson and a second girl to Epstein’s house on a Sunday in
February 2005. Once there, a woman she thought was Epstein’s assistant told the
girl to follow her upstairs to a room featuring a mural of a naked woman, several
photographs of naked women on a shelf, a hot pink and green sofa arid a massage
table.
She stripped to her bra and panties and gave him a massage.
Epstein gave the 14-year-old $300 and she and the other girls left, she said. She
said Robson told her that Epstein paid her $200 that day.
Other girls told similar stories. In most accounts, Epstein's personal assistant at
the time, Sarah Kellen, now 27, escorted the girls to Epstein’s bedroom.
Kellen, whose most recent known address is in North Carolina, has not been
charged in the case.
Palm Beach police often conducted surveillance of Epstein’s home, and at Palm
Beach International Airport to see if his private jet was there, so they would
know when he was in ...

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from Palm Beach sanitation workers, collecting papers with names and phone
numbers, sex toys and female hygiene products.
One note stated that a female could not come over at 7 p.m. because of soccer.
Another said a girl had to work Sunday - "Monday after school?" And still
another note contained the work hours of a girl, saying she leaves school at 11:30
a.m. and would come over the next day at 10:30 a.m.
Only three months before the police department probe began, Epstein donated
$90,000 to the department for the purchase of a firearms simulator, saidJane
Struder, town finance director. The purchase was never made. The money was
returned to Epstein on Monday, she said.
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CA/Arop^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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fro·m Palm Beach sanitation workers,collegingpapers with names and phone 
numbers, sex toys and female hygiene products. 
One note stated that a female could not .come over at 7 p.m. because of soccer. 
Another s.aid a girl had to work Sunday ~ "Monday after school?" And still 
another note contained the work hours ofa girl, saying. she Jea,vE!s school at 11:30 
a.m, and would. come over the next day at 10:30 a.m. 
Only three months before the police department probe began, Epstein dqnated 
$90,000 to the department for the purchase of a firearms simulator( saidJane 
Struder; town finance. director. The purchase was never made. Th~ money was 
returned to Epstein on Monday, sh~ said, 
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Palm Beach DailyNews
Police say lawyer tried to discredit teenage
girls
PostedJul 29,2006at 12;01 AM
Updated Oct 3,2019 at 2:00 PM
(EDITOR'S NOTE: This story originally was published in The Palm Beach Post on July
29, 2006)
Famed Harvard law professor Alan Dershowitz met with the Palm Beach County
State Attorney’s Office arid provided damaging information about teenage girls
who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually
charged massages^ according to police reports.
The reports also state that another Epstein attorney agreed to a plea bargain that
would have allowed Epstein to have no criminal record. His current attorney
denies this happened.
And the documents also reveal that the father of at least one girl coinplained that
private investigators aggressively followed his car, photographed his home and
chased offvisitors.
Police also talked to somebody who said she was offered money ifshe refused to
cooperate with the Palm Beach Police Department probe ofEpstein.
The state attorney's office said it presented the Epstein case to a county grand
jury this month rather than directly charging Epstein because of concerns about
the girls’ credibility. The grand jury indicted Epstein, 53, on a single count of
felony solicitation ofprostitution^ which carries a maximum penalty of five years
in prison.
Police believed there was probable cause to charge Epstein with the more serious
crimes of unlawful sex acts with a riiinor and lewd and lascivious molestation.
Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
Krischer a memo in May suggesting he disqualify himself from the case.
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CA/Aropfte^Ol^a^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The case originally was going to be presented to the grand jury in February, but
was postponed after Dershowitz produced information gleaned from the Web
site myspace.com showing some of the alleged victims commenting on alcohol
and marijuana use, according to the police report prepared by DetectiveJoseph
Recarey.
Haley Robson, a 20-year-old Royal Palm Beach woman who told police, she
recruited girls for Epstein, also is profiled on myspace.com. Her page includes
photos of her and her friends, including one using the name “Pimpin’ Made EZ.”
Robson, who was not charged in the case, is a potential prosecution witness.
According to Recarey, prosecutor, Lanna Belohlavek offered Epstein attorneys
Dershowitz and Guy Fronstin a plea deal in ApriL Fronstin, after speaking with
Epstein, accepted the deal, in which Epstein would plead guilty to one count of
aggravated assault with intent to commit a felony, be placed on five years’
probation and have no criminal record. The deal also called for Epstein to submit
to a psychiatric and sexual evaluation and have no unsupervised visits with
minors, according to Recarey’s report. The plea bargain was made in connection
with only one ofthe five alleged victims, the report states.
Fronstin - who declined to comment on the case - was subsequently fired and
veteran defense attorneyJack Goldberger was hired. He denies there was any
agreement by any of Epstein’s attorneys to a plea deal.
“We absolutely did not agree to a plea in this case,” he said. Neither Belohlavek
nor a state attorney’s spokesman could be reached for comment.
The parent or parents of alleged victims who complained of being harassed by
private investigators provided license tag numbers of two of the men. Police
found the vehicles were registered to a private eye in West Palm Beach and
another in Jupiter, according to Recarey’s report.
“I have no knowledge of it,” defense ...

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who did talk "will be dealt with,” the woman said she was told. Phone records
show the woman talked with the person who allegedly intimidated her around
the time she said, Recarey reported.
Phone records also show that the person said to have made the threat then
placed a call to Epsteins personal assistant, who in turn called a New York
corporation affiliated with Epstein, the report states.
The issue in the Epstein case is not whether females came to his waterfront
home, but whether he knew their ages.
"He’s never denied,girls came to the house,” Goldberger said. But when Epstein
was given a polygraph test, "he passed on knowledge of age,” the attorney said.
After the indictment against Epstein was unsealed this week, Police Chief Reiter
referred the matter to the FBI. “We've received the referral, and were reviewing
it,” said FBI spokeswoman Judy Orihuela in Miami.
The chiefhimselfhas come under attack from Epstein’s lawyers and friends in
New York, where he has a home. The New York Post quoted Epstein's
prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
only “because of the craziness of the police chief.”
Reiter has declined to comment on the case.
Prosecutors have not presented a sex-related case like Epstein s to a grand.jury
before, said Mike Edmondson, spokesman for the state attorney’s office. “That’s
what you do with a case that falls into a gray area,” he said.
The state attorney's office did hot recommend a particular criminal charge on
which to indict Epstein, Edmondson said. The grand jury was presented with a
list of charges from highest to lowest, then deliberated with the prosecutor out of
the room, he said.
"People are surprised at the grand jury proceeding,” West Palm Beach defense
attorney Richard Tendler said. “It’s a way for the prosecutor’s office to not take
the full responsibility for not filing the (charge), and not doi...

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Defense attorney Robert Gershman was a prosecutor for six years.,“Those girls
must have been incredible or untrustworthy, I don't know," he said.
Other attorneys said Epstein’s case raises the issue of whether wealthy, connected
defendants like Epstein - whose friends include former President Clinton and
Donald Trump - are treated differently from others. Once he knew he was the
subject of a criminal probe, Epstein hired a phalanx ofpowerful attorneys such as
Dershowitz and Lefcourt, who is a past president of the National Association of
Criminal Defense Lawvers.
Miami lawyer Roy Black - who became nationally known when he successfully
defended William Kennedy Smith on a rape charge in Palm Beach - also was
involved at one point.
Said defense attorney Michelle Suskauer: "I think it's unfortunate the public may
get the perception that with power, you may be treated differently than the
average Joe.”
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Defense attorney Robert Gershman was a prosecutor for six years., "Those girls 
must have be~n incredible or untrµstworthy, I don't.know/ he said. 
Other attorneys said Epstein's case raises the issue of whether wealthy, connected 
defendants like Epstein -whose friends include forn:ier Ptesideiit Clinton and 
Donald Trump,- a:re treated differently from others. Once he knew he was the 
subject of a crirriihal probe, Epstein· hired a phalanx of powerful attorneys such as 
Dershowfrz and Lefcourt, who is a past president of the National Association of 
Criminal Defense Lawyers, 
Miami lawyer Roy Black - who became natic:mally known when he successfully 
defended William Kennedy Smith on a rape charge in Palm Beach - 3,lso was 
involved at on...

I ne Palm Beach
REALOS STARTSHERE
:
Expert: Ignorance of age isn’t
defense in sex cases
Posted Aug 5,2006 at12:01 AM
Updated Oct 3,2019 at 1:38 PM
(EDITOR’S NOTE: Titis story originally published in The
PalmBeach Post on Aug. 5,2006)
Even if Palm Beach money manager Jeffrey Epstein didn’t
know that girls who police say gave him sexual massages at
his Intracoastal home were under the legal age, that alone
wouldn’t have exempted him from criminal charges of
sexual activity with minors.
“Ignorance is not a valid defense," said Bob Dekle, a legal
skills professor who was a Lake City prosecutor for nearly
30 years, half of that time specializing in sex crimes against
children.
“There is no knowledge element as far as the age is
concerned,” Dekle said.
After an 11-month investigation, Palm Beach police said
there was probable cause to charge Epstein, 53, with
unlawful sex acts with a minor and lewd and lascivious
molestation. They contend that Epstein - friend ofthe rich
and famous and financial patron of Democratic Party
organizations and candidates - committed those acts with
five underage girls.
In the past week, New York Attorney General and
gubernatorial candidate Eliot Spitzer has returned about
S50,000 in campaign contributions he received from
Epstein, and Mark Green, a candidate to replace Spitzer in
CA/Arop^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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. 
' 
• 
• • 
Tlie Palm Beach Post 
REALHSTARTS Hf.'R[ 
Expert: 1·g,n1ranc,e :ol :age isn't 
defense in se?<i:case$ 
Posted Aug 5; 2006 at 12:0l AM 
Updated bet 3, 2019 atl:38 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on Aug. 5, 2006) 
Even if Palm Beach moneymana~er Jeffrey Epstein didn't 
know that girls who police.say gave him sexual massages at 
his Intracoastal home were under the legal age, that alone 
wouldn't have exeII1pted himfrom criminal charges of 
sexual activity with minors, 
"Ignorance is not a valid defense," said Bob Dekle,...

his cur^Kjob, has returned SI0,000 to him becauseW^he
Palm Beach scandal, the New York Daily News has
reported.
Rather than file charges, the state attorney s office
presented the case to a county grand jury. The panel
indicted Epstein last week on a single, less serious charge of
felony solicitation ofprostitution.
The case raised eyebrows because the state attorney's office
rarely, if ever, kicks such charges to a grand jury. And it
increases the difficulty ofprosecuting child sex abuse cases,
especially when the defendant is enormously wealthy and
can hire high-priced, top-tier lawyers.
At least one ofEpstein’s alleged victims told police he knew
she was underage when the two ofthem got naked for
massages arid sexual activity. She was 16 years old at the
time and said Epstein asked her questions about her high
school, according to police reports.
A girl who said she met Epstein when she was 15 said he
told her if she told anybody what happened at his house,
bad things could happeri, the police reports state;
Epstein’s youngest alleged victim was 14 when she says she
gave him a massage that included some sexual activity. She
is now 16. The girl’s father says he doesn't know whether
she told Epstein her age.
“My daughter has kept a lot ofwhat happened from me
because of sheer embarrassment,” he said. "But she very
much looked 14. Any prudent man would have had second
thoughts about that.”
Defense attorneyJack Goldberger maintains that not only
did Epstein pass a polygraph test showing he did not know
the girls were minors, but their stories weren’t credible.
The state attorney’s office also implied that their credibility
was an issue when it decided not to charge Epstein directly,
but instead give the case to the grand jury;
CA/Arop^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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his cur. job, has returned $10,000 to him betaus.he 
Palm Beach scandal, the New York Dally News has 
reported. 
Rather than file charges, the state-a...

A proSButor has to look at it in a much broader fi
a
state attorney’s spokesman said last week.
Epstein hired Harvard law Professor Alan Dershowitz
when he became aware he was under investigation, and
Dershowitz gave prosecutors information that some of the
alleged victims had spoke of using alcohol and marijuana on
a popular Web site, according to a Palm Beach police
report.
Prosecutors typically consider two things in deciding
whether to charge somebody with sex-related offenses
against minors - whether there; is sufficient evidence and
whether there is a public interest in doing so, Dekle said.
Iftwo teens are in a sexual relationship and the boy turns
18 before the girl, he could be charged with a sex crime if
the sex continues. There would be no public interest in
pursuing that, Dekle said.
But where there is a large gap in ages - and especially in
cases of teachers with students - there is a public interest in
prosecuting, he said. Likewise if the accused has a track
record of sex with minors.
CA/Aro^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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"A pro.tor has to look at it in a much broader fail;" a 
state a,ttomeis spokesman saidlastweek. 
I 
! r 
Epstein hired Harvard law Professor AlanDershowitz 
when he became aware h,e was under investigation, and 
Dershowitz gave prosecutors information that some of the 
ajleged victims had spoke of using alcohol and. marijuana on 
a popular Web site, accordin~ to a Palm Beet ch police 
report. 
Prosecutors typically consider two thmgs in deciding 
whether to charge somebody with sex-related offenses 
aga,inst minors - whether there: is sufficient eVidence and 
whether there is a public interest in doing so, D~kle said. 
If two teens are. in a sexual relationship and the boy turns 
18 before the girl, he could be charg~d with .a sex crime if 
the sex continues. Tl:u~_rewoq,ld be no public interest in 
pursuing that, Dekle said. 
But where th.ere· ~s a large gap in ages - ahd espec...

Still th^^rs a'‘universal constant” in prosecuting th^JJF
cases, Dekle said. Menwho exploit underage children for
sex often carefully choose their victims in ways that will
minimize the risk to them, he said.
Victims usually are from a lower social status, and they may
suffer from psychological problems, Dekle said.
"Lots ofchild sexual abuse victims have been victimized by
multiple people over a period oftime. Then the act of abuse
produces behavior in the victims that further damages their
credibility.” Examples include promiscuous behavior and
drug abuse.
Some of the alleged victims in the Epstein case returned to
his home multiple times for the massage sessions and the
S200 to $300 he typically paid them per visit. “That would
be a definite problem for the prosecutor/’ said Betty Resch,
who prosecuted crimes against children in Palm Beach
County for five years and now is in private practice in Lake
Worth.
“The victim becomes less sympathetic” to a jury, Resch said.
"But she’s a victim nevertheless. She's a kid:”
Most men charged with sex crimes against minors look
normal, Dekle said. A jury expecting to see a monster
seldom will. And the victims’ ages work against them and in
favor of the defendant in a trial, Dekle said.
If a child and an adult tell different stories and both swear
they're tellingthe truth, adult jurors are more likely to
believe the adult, Dekle said.
“You have all these things working against you in a child,
sex abuse case. Prosecutors normally try to be very careful
in filing those cases because they know what they’re getting
into. There is no such thing as an irOn-clad child sexual
abuse case.”
CA/Arop^^O^^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
Still th.s a "universal constant" in-prosecuting th. 
cases, Dekle said. Men who exploit underage cluldr~n for 
sex ofte-n carefully choose their vic:dros in, ways that will 
minimize the risk to thein, he said. 
Victims usually are from a lower social sta...

The Palm Beach Post
REALHEWSSTASIS HEM
Epstein camp calls female accusers
liars
Posted Aug 8,2006 at 12:01 AM
Updated Oct 3,2019 at 3:35 PM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on Aug. 8, 2006)
Attorneys and publicists for Palm Beach financierJeffrey
Epstein went on the offensive Monday, contending that
teenage girls who have accused Epstein of sexual
shenanigans at his waterfront home are liars and saying
that the Palm Beach Police Department is "childish.”
“There never was any sex betweenJeffrey Epstein and any
underage women,” his lead attorney,Jack Goldberger, said
from Idaho where he was vacationing with his family,
Epstein did have young women come to his house to give
him massages, Goldberger said. “Mr, Epstein absolutely
insisted anybody who came to his house be over the age of
18. How he verified that, I don’t know. The question is, did
anything illegal occur. The law was hot violated here."
He had no explanation as to why Epstein would pay girls or
women with no massage training - as the alleged victims
said was the case - $200 to $300 for their visits. “The
credibility of these witnesses has been seriously
questioned,” Goldberger said.
Epstein, 53, was indicted by a county grand jury last month
on a charge offelony solicitation ofprostitution. After an
11 -month investigation that included sifting through
Epstein’s trash and surveilling his home, Palm Beach police
concluded there was enough evidence to charge him with
sexual activity with minors. When the grand jury indicted
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
• 
• 
• 
•• 
Tlie Palm Beach Post 
REALNEWS STARTS HIRE 
Epst.eio :ca:rnpicalls ;fe11oile: accusets, 
liats 
Posted Alig 8, 2006 at 12:01 AM 
Updated Od 3, 2019 at 3:35 PM 
(EDITOR'S NOTE: This story originally publi~h~d in The 
Palm Beach Post on Aug. S, 2006) 
Attorneys and pu~licists for Palm Eeach financier Jeffrey 
Epstein went on the. offensive Monday, contending ...

EpsteiWBHthe less serious charge, Police Chief Mid
Reiter referred the case to the FBI to determine whether
there were federal law violations.
After a spate of stories about the case last week, New York
publicist Dan Klores - whose client list has included Paris
Hilton and Jennifer Lopez - said on Saturday that Epstein’s
camp was ready “to get their story out."
They did that Monday via Goldberger and a Los Angeles
publicist for Miami criminal defense attorney Roy Black,
who also has represented Epstein in the case.
“We just think there has been a distorted view of this case
in the media presented by the Palm Beach police,”
Goldberger said.
Reiter has consistently declined to comment on the case
and did riot respond to a request for comment Monday.
The implication that State Attorney Barry Krischer was
easy ori Epstein by presenting the case to a grand jury
rather than filing charges directly against him is wrong,
Goldberger said.
CAW°Pftef|j^1\Wl BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
' 
Epstei. theless serio~s charge! Police Chief Mic. 
Reiter referred the case to the FBI to determine whether 
there were federal law violations. 
After a spate of stories about the case last week, New York 
publicist Dan Kl ores - whose client lisfhas included Paris 
Hilton andjenn.ifer Lopez - said on:Sat.urday that Epstein's 
cc:ll'.Ilp was ready "to get their stotyout." 
They did that Monday via Goldberger and a Los Angeles 
publicist for Miami criminal defense .lttor_ney Roy Black, 
who also has represented Epstein in the case. 
"We just. think there has been a:.distorted view of this case 
in th_e media presented by the Palin Beach police," 
Goldberger said. 
Reiter has consistently declined to comment on the case 
and did not respond to a r~questfor comment Monday. 
The implication that State .Attqrney)3arry Krischer was 
easy oil Epstein by presen.ting the case to a gr:andjury 
rather than filing charges directly against him is wrong...

The P^ffBeach Police Department was "happyand^^
ecstatic” that the panel was going to review the evidence. “I
think what happened is they weren’t happy with the result.
They decided to use the press to embarrass Mr. Epstein.”
But records show that Reiter wrote Krischer on May 1 -
well before the case went to the grand jury - suggesting that
Krischer “consider ifgood and sufficient reason exists to
require your disqualification from the prosecution of these
cases."
Rather than flat-put decline to charge Epstein, Krischer
referred the case to the grand jury to “appease” the chief,
Goldberger said.
A state attorney's spokesman would say only that the office
refers cases to the grand jury when there are issues with the
viability of the evidence or witnesses' credibility.
Both the state attorney and the grand jury concluded there
was not sufficient evidence that:Epstein had sex with
minors, according to Goldberger, “It was just a childish
performance by the Palm Beach Police Department,”
Goldberger said.
The defense attorney said one of the alleged victims who
claimed she was a minor was in fact over the age of 18.
Another alleged victim who was subpoenaed to testify to
the grand jury failed to do so. Epstein’s accusers, he added,
have histories ofdrug abuse and thefts. "These women are
liars. We’ve established that.”
But why would they all invent their stories about meeting
Epstein for sexual massages?
"I don't have an answer as to what was the motivation for
these women to come forward and make these allegations,”
Goldberger said.
CA/Arop^-jO^I^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
The P.each Pohce Departmentwas "happy and. 
ecstatic'.' that the pan·eI was going.to reviewthe evidence. "I 
think what happened is they weren't happy vv:ith the res~lt. 
They decided to use the press to embarrass Mr. Epstein.;, 
But records show th~t Reiter wrote Krischer on May 1 . ..: 
well before the case went to the gta:rtd jury - suggesting...

-
-
e
The Palm Beach Post (West Palm Beach, Florida)
■
14 Aug 2006, Mon • Page 7
Downloaded oh Nov Ik 201$
Palm Brach chief locus
of fire in Epstein case.
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Tne Palm Beach Post
REALNEWS STARTSKM
Delaysin Epstein case unusual,
lawyers say
Posted Mar 13,2007 at 12:01 AM
Updated Oct 3,2019 at 3:48 PM
(EDITORS NOTE: This story originally published in The Palm
Beach Post March 13, 2007)
A federal probe or a plea deal could explain the wait in the
Palm Beacher’s solicitation case.
Nearly eight months after Palm Beach tycoon Jeffrey
Epstein was charged with felony solicitation ofprostitution,
there has been no discernible progress in his case. No
witnesses deposed. No trial date set. Nothing; save for
routine court hearings reset without explanation.
"Usually that would be unusual,” said criminal defense
attorney Glenn Mitchell, who has no involvement in the
case.
“As a general rule, it would be unusual for nothing to have
happened,” agreed Michael Dutko, a criminal defense
attorney in Fort Lauderdale. He represents Haley Robson,
20, of Royal Palm Beach, potentially a key witness in the
case,
A routine hearing for Epstein was pulled from the court
docket last week and reset for May 16. The delays and
inaction could be due to a potential federal probe ofEpstein
or because a plea deal is in the works, attorneys say.
Unusual is the word that best describes everything about
the case against Epstein, 54, an enigmatic money manager
in New York City who counts Bill Clinton and Donald
Trump among his friends.
CA/Aropf^o^a?, BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
• 
• 
• • •  
Tlie Palm Beach Post 
RIAL JIW$,STARTS km£ 
D:elatYl ip :Epstein' case ,uu,Jsu:al, 
law.· ers sa,··· .. 
. ,Y.-. 
y 
Posted Mar 13, 2007at 12:01 AM 
Updated Oct 3; 2019 at 3:48 PM 
(EDITOR'$ NarE: T/tis ~tory originallJJ published in The Palm 
Be<Uh Post March 13, 2007) 
A federal probe or a plea deal could explain the wait iQ th_e 
Palm Beachet'ssolicitation case; 
Neatly eight months after J'alm Beach tycoon Jeffrey 
Epstein was charged with felony solidtation of prostitution, 
there has been no-discernible progr...

“Highl^^usuar
is how Palm Beach PoliceChief,Mi^^l
Reiter described State Attorney Barry Krischers handling
ofthe case in a bluntly critical letter to Krischer last year
before Epstein was indicted.
Reiter referred the matter to the FBI to determine whether
any federal laws had been violated. Epstein’s allies
countered by attacking the chiefpersonally and
professionally.
Reiter s department investigated Epstein for 11 months.
Police sifted repeatedly through his trash and conducted
surveillance on his five-bedroom, 7 1/2-bath, 7,234-square-
foot home on the Intracoastal Waterway.
Police said Epstein paid women and girls as young as 14 to
give him erotic massages at his home. Police thought there
was probable cause to charge him with unlawful sex acts
with a minor and lewd and lascivious molestation.
Epstein responded by hiring a phalanx of lawyers. One of
them, Harvard law professor and author Alan Dershowitz,
provided the state attorneys office with information about:
alcohol and marijuana use by some of the girls who said
they were with Epstein.
Prosecutors then referred the case to the grand jury rather
than file charges directly against Epstein.
Epstein’s attorneys deny he had sex with underage girls.
The lawyers say the girls’ stories are not credible. But if the
court file is any indicator, they’ve made no effort to depose
the girls.
Neither prosecutors nor defense attorneys have sought to
question Robson, said Dutko, her attorney. She recruited
teenage girls to visit Epstein for massages and sexual
activity,, Palm Beach police said, and presumably would be a
key witness.
CA/ArOfW>QW\W1 BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
I 
"Hight.usual" is how Palm Beach Police ChiefM.l 
Reiter described State Attorney Barry Ktischer' s handling 
of the casein a bluntly critical letter to Ktischer last year 
before. Epstein was indicted. 
Reiter referred the matter to. the FBI to determine whether 
any federal laws had been viola...

A
A
EpsteinWttorneyJack Goldberger did not return pnWc
messages.
A source close to the case suggested it is languishing
pending a decision by the FBI on whether to refer it to
federal prosecutors.
“We still have a pending case/’ FBI spokeswomanJudy
Orihuela said Monday.
State Attorney Krischer did not return a call for comment.
His spokesman, Mike Edmondson, declined to say whether
federal investigators are delaying the Epstein case. But, he
added, “if another agency is looking at something, we
wouldn’t want to step on their toes.”
Attorneys say inertia in a criminal case often points to a
pending plea deal.
“It would not.surprise me ifsomething has happened that's
not reflected in the court file,” said Dutko, such as an
agreement that will be formalized later.
Defense attorney Marc Shiner said defense attorneys
sometimes put off overtly conducting discovery — deposing
witnesses, requesting documents and the like — because
doing so creates more work for harried prosecutors who
may become angry and not offer a plea deal.
“Sometimes defense lawyers, knowing that, will try and do
discovery without taking depositions," said Shiner, a former
prosecutor for 13 years.
Instead, they may conduct a below-the-fadar probe such as
having a private investigator check out leads, he said.
Shiner arid others say a plea deal for Epstein probably
would result in pretrial intervention, in which a defendant
may be ordered to undergo a psychological evaluation,
counseling or other conditions in return for dropping the
charge.
CA/Arop^O^, BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 1:04:39 PM
NOT A CERTIFIED COPY
Epstei&orney Jack Goldberger did not return p. 
messages. 
A source close to the case suggested it is languishing 
pending a decision by the FBI on\vhethet to tefer it to 
re·deral prosecutors: 
''We still have a pending case," FBI spo~eswomanJt1dy 
Orihuela said Monday. 
State Attorney Krisc::h.~r did not return a caff for comment. 
His spokesman, Mike Edmondson, declined...

Edmoa, spokesman for State AttorneyKrische^^i
there is no plea offer and no' request for the prosecution to
show its cards.
"To my knowledge, it’s never happened before on a filed
case/ he said.
CA/AW^?® BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
Ed.mo., spokesman for State Attorney Krische. 
there ishb plea.offer and no request for the prosecution to 
showits cards. 
'To my knowledge, it's never happened before on a filed 
case," he said. 
CA/Aropffm:5?~Ai%_ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 
i 
I 
I. 
f 
¥ 
I 

•
e
252 / 278 - Thursday, October 18, 2007
Edition: FINAL
Section: LOCAL
Page: 5B
Source: The Associated Press
Illustration: PHOTO (B&W)
Memo: Rah all editions.
Dateline: NEW YORK
WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16
A billionaire investor, already facing jail in Palm Beach County oh charges of soliciting underage
prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had
sought his help becoming a model.
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had
the teen perform a sex act when she brought photographs of herself for him to review in his Upper
East Side mansion sometime in 2000.
Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get
you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice"
included massages and other favors.
When the girl told Epstein, "l am 16 years old and just want to model," he replied, "Don't worry, I
won't tell anybody," court papers say,
Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been
indicted in Palm Beach bn charges of soliciting underage prostitutes. That case is pending.
The girl visited Epstein "several times over the several months arid erigaged in bizarre and unnatural
sex acts" while shewas a minor, the lawsuit says.
Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends,
stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her
40s). I love girls your age.'"
The young woman, now 23, kept returning to Epstein because she has "mental issues," said her
lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result
of severe mental disease and defect."
Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can
re...

•
o
The Palm Beach Post
REALMS SEMIS HEM
Palm Beacher pleads in sex case
Posted Jul 1,2008 at 12:01 AM
Updated Oct 3,2019 at 1:47 PM
(EDITOR'S NOTE: This story originally published in The
Palm Beach Post on July 1, 2008)
Jeffrey Epstein will serve 1 1/2 years on teen solicitation
charges.
He lives in a Palm Beach waterfront mansion and has kept
company with the likes of President Clinton, Prince
Andrew and Donald Trump, but investment bankerJeffrey
Epstein will call the Palm Beach CountyJail home for the
next 18 months.
Epstein, 55, pleaded guilty Monday to felony solicitation of
prostitution and procuring a person under the age of 18 for
prostitution. After serving 18 months in jail, he will be
under house arrest for a year. And he will have a lifelong
obligation to register as a sex offender. He must submit to
ah HIV test within 48 hours, with the results being
provided to his victims or their parents.
As part of the plea deal, federal investigators agreed to drop
their investigation of Epstein, which they had taken to a
grand jury, two law enforcement sources said.
Epstein was indicted two years ago after an 11-month
investigation by Palm Beach police. They received a
complaint from a relative ofa 14-year-old girl who had
given Epstein a naked massage at his five-bedroom, 7,234-
square-foot, S8.5 million Intracoastal home.
Police concluded that there were several other girls brought
in 2004 and 2005 to an upstairs room at the home for
similar massages and sexual touching.
CA/ArofteS5p?1A% BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
• 
• 
••• • 
Tlie Palm Beach Post 
REAL-'STARTSRIRE 
Palm ',B.eacher leads in :s·ex c'ase 
,.. . . 
•,' p,, , , ...... , ... • .. 
Posted Jul 1, 2QQ8 a112:01 AM 
Updated Oct 3, 2019 at 1 :47 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on Ji~ly 11 200~) 
Jeffrey Epstein will serve 1 1/2 years on teen solicitation 
'charges. 
He lives in a Palm Beach waterfront mansio...

The ijjLientcharged Epstein only with felony
solicitation ofprostitution. The state attorney’s office later
added the charge ofprocuring underage girls for that
purpose.
Prosecutor Lanna Belohlavek said ofthe plea: “I took into
consideration the length the trial would have been and
witnesses having to testify” about sometimes embarrassing
incidents.
Epstein may have made a serious mistake soon after he was
charged. He rejected an offer to plead guilty to one count of
aggravated assault with intent to commit a felony,
according to police documents. He would have gotten five
years’ probation, had no criminal record and not been a
registered sex offender, the documents indicate.
Epstein arrived in court Monday with at least three
attorneys. He wore a blue blazer, blue shirt, blue jeans and
white and gray sneakers. After CircuitJudge Deborah Dale
Pucillo accepted the plea, he was fingerprinted. Epstein
then removed his blazer and was handcuffed for the trip to
jail while his attorneys tried to shield him from
photographers’ lenses.
When he eventually is released to house arrest, Epstein will
have to observe a 10 p.m. to 6 a.m. curfew, have no
unsupervised contact with anyone younger than 18 and
neither own nor possess pornographic or sexual materials
"that are relevant to your deviant behavior," the judge said.
Epstein will be allowed to leave home for work. The New
York-based money manager told the judge he has formed
the not-for-profit Florida Science Foundation to finance
scientific research. “I'm there every day,” Epstein said.
The foundation was incorporated in November. Epstein
said he already has awarded money to Harvard and MIT.
CA/Aropj^OJg^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
The &ent charged Epstein only with felony • 
solicitation of pI'osthution. The state attorney's office later 
addecl the charge of procuring underage girls for that 
purpose. 
Prosecutor Lanna Belohlavek said of the plea: "I took in.to 
consi...

tn
Whenl^^
released from jail, there is a chance that
will be forced to move. Sex offenders are not allowed to live
within 1,000 feet of a school, park or other areas where
children may gather. Nd determination has been made as to
whether Epstein s home complies, but attorneys said it
likely does.
Sex offenders also typically must attend counseling sessions.
Belohlavek said that was waived for Epstein because his
private psychiatrist is:working with him, The judge was
skeptical but agreed to it.
Epstein’s legal woes don't end with Monday’s plea. There
are four pending federal civil lawsuits and one in state court
related to his behavior. At least one woman has sued him in
New York, where he owns a 51,POO-square-foot Manhattan
mansion.
"It's validation of what we’re saying in the civil cases,” said
Miami attorneyJeffrey Herman, who represents the alleged
victims in the federal lawsuits. West Palm Beach attorney
Ted Leopold represents one alleged victim in a civil suit in
state court; He saidhe anticipates amending that lawsuit to
add “a few other clients” as well.
In the criminal case, police went so far as to scour Epstein's
trash and conduct surveillance at Palm Beach International
Airport, where they watched for his private jet so they
would know when he was in town. They concluded that
Epstein paid girls S200 to S300 each after the massage
sessions.
Tin like a Heidi Fleiss,” Haley Robson; now 22, told police
about her efforts in recruiting girls for Epstein.
There was probable cause to charge Epstein with unlawful
sex acts with a minor and lewd and lascivious molestation,
police concluded.
CA/AroPfe®°Wfffi BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
I 
When .released from jail, there is a chance that .in 
will be forced to move. S~x offenckrs are not-allowed to live 
v.ritbin 1_,000 foet of a scho'Ol; park or other areas where 
children may gather\ Nb determination has been made as to 
Whether Epstein's home complies, but at...

The stalRttorney s office said questions about the gnlff^
credibility led it to take the unprecedented step of
presenting the evidence against Epstein to a grand jury,
rather than directly charging him.
Palm Beach Police ChiefMichael Reiter was furious with
State Attorney Barry Krischer, saying in a May 2006 letter
that the prosecutor should disqualify himself. "I continue to
find your office’s treatment ofthese cases highly unusual,”
he wrote. He then asked for and got a federal investigation.
Epstein hired a phalanx of high-priced lawyers - including
Harvard law professor and author Alan Dershowitz - and
public relations people who questioned Reiter’s competence
and the victims' truthfulness.
In addition to mansions in Palm Beach and Manhattan,
Epstein owns homes in New Mexico and the Virgin Islands.
He?s a frequent contributor to Democratic Party candidates.
He also donated S30 million to Harvard in 2003.
Former New York Goy. Eliot Spitzer returned a 550,000
campaign contribution from Epstein after his indictment,
then resigned this year during his own sex scandal. And the
same Palm Beach Police Department that vigorously
investigated Epstein returned his S9O,O0O donation for the
purchase of a firearms simulator.
Staffwriter Eliot Kjeinberg and former staff researcher
Michelle Quigley contributed to this story.
CA/Aroppe^O^C^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The st.rl:orney's office said questions about theg. 
credibility led. it to take. the unprecedented step of 
presenting the eviderice ag~ii;ist Epsteil} to a grand jury, 
rather than cB.re<:tly charging him. 
Palm Beach Police Chief Michael Reiter was furious with 
State Attorney Hatty Knscher, saying in a May 2006 l_etter 
that the prosecutor should disqualify hitnself. "I contim1e to 
find your 9ffice1s treatment of these :cases highly unusual," 
he wrote. He then asked· for and got a federal investigation. 
Epstein hired a: phalanx of high-priced lawyers -....

rf n
1
u n®
1 ne Palm Beach Post
REALUWSSKinS HERE
Jeffrey Epstein: Scientist
stuntman, ‘sex slave’ visit jailed
tycoon
By LARRY KELLER / Palm Beach Post Staff Writer
Posted Aug 13,2008 at 12:01 AM
Updated Jul 16,2019 at 4:54 PM
TycoonJeffrey Epstein mingled with an eclectic mix of
people, including beautiful young women, before he got.
into trouble for paying teenage girls to give him sexual
massages at his Palm Beach mansion.
Not much has changed, even though he now resides in a
dorm at the Palm Beach County Sheriff’s Office s 17-acre,
967-bed stockade near the fairgrounds.
During his first month ofconfinement, Epstein was visited
by the female assistant who, girls told police, had escorted
them to the room at his mansion where they gave him
naked massages.
Also trekking to the jail was a young woman whom Epstein
purportedly described as his Yugoslavian sex slave.
The wealthy financier and science wonk also has been
visited by ah expert on artificial intelligence, as well as a
man who is a mixed martial arts aficionado and sometime
movie stuntman.
The only other people to visit him at thejail, according to
records, are a Singer Island man and an individual who
listed Epstein’s Palin Beach address as his own.
Epstein, 55, pleaded guilty on June 30 to two prostitution-
related charges and was sentenced to 18 months in jail,
followed by a year ofhouse arrest. Epstein paid teenage
CA/Arop^opM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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• 
• 
• • • • •  
Tlie Palm. Beach Post 
REAL mYS STARTS HDlE 
Jeff ~ey Ep:stein: .Scienf ist; 
sf untman, 'sex slave' :visit jailed 
t¥COt'iii 
By LARRY KELLER/ Palm Beach Post Staff Writer 
Posted Aug 13,2008 at 12:01 AM 
Updated Jul 16, 2019 at 4:54 PM 
Tycoon Jeffrey Epstein mingled with an eclectic mix of 
people, including beautiful you.Ii& women, before he got. 
into trouble for paying teenage girls to give him sexual 
massages at his Palm Beach mansion. 
Not much h:3.schanged, even though h...

girlsBo $300 in 2004 and 2005 for massages in^
home that sometimes included sexual touching, Palm Beach
police said.
His jail visitors in July included:
- Sarah Kellen, 29, who some of the teen masseuses said
phoned them when Epstein was in town and escorted them
upon their arrival at his Palm Beach waterfront home to an
upstairs room, where she prepared the massage table arid
provided the oils for their encounters with him. Kellen
visited Epstein three times in July, according to a jail
visitor’s log. Kellen lists a Manhattan home address.
Reached by telephone, she declined to discuss Epstein.
- Nadia Marcinkova, 23, whose family in Yugoslavia
Epstein paid money to so that he could bring her to the
United States to be his “sex slave/’ two teenage girls told
police. One girl told police that Epstein instructed
Marcinkova and her to kiss and have sex while he watched
and masturbated. Another said she engaged in sex with
Marcinkova at Epstein’s urging. Marcinkova visited Epstein
in jail four times in 13 days. She lists her address as on the
Upper East side of Manhattan, not far from Epstein’s
enormous apartment.
- Roger Schank, 62, founder of the Institute for Learning
Sciences at Northwestern University and an expert on
artificial intelligence, paid one visit to Epstein. Schank has
written numerous books on that subject and has a doctorate
degree from Yale University in linguistics. He was one of 19
people who applied to be president ofFlorida Atlantic
University in 2003. He became “chief learning officer” at the
online Trump University in 2005. Schank listed his address
as being in Stuart, and records show he also owns a hoirie
in Lake Worth.
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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girls .o 
$300 in 2004 and 2005 for mass;1ges in. 
home that sometimes included sexual touching, Palm Beach 
polite said. 
His jail visitors ,in J tJly inch1ded: 
- Sarah Kellen, 291 who some of the teen masseuses ~aic,l 
phoned them when Epstein...

e
Epstei.
financed a number ofscientists over the’
including Nobel Prize winners. He gave $30 million to
Harvard University in 2003. In November, he formed the
not-for-profit Florida Science Foundation, which he said
finances scientific research.
- Igor Zinoviev, a Russian mixed martial arts fighter, who
coaches a Chicago team in the International Fight League.
He also has worked as a personal trainer, celebrity
bodyguard and movie stuntman, according to the league's
Web site. The NewJersey resident visited Epstein seven
times in July.
Zinoviev, Schank and Marcinkova could not be reached for
comment.
Staffresearcher Niels Heimeriks contributed to this story.
CA/Arop^0^1^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Epstei. financed a number of scientists over the.s, 
including Nobel Prize winners. He gave $30 million to 
J-larv~rd Oniversity in 2003. In November, he formed tj:te 
not-for-profit Florida Science FO\tndatfon, whi<:h he sajd 
finances scientific researc_h. 
- Igor Zinoviev, a Russi,m mixed martial arts fighter, who 
coaches a Chicago team: in the International Fight League. 
He ,also has worked as a personal tr.iin_er:1 celebrity 
bodyguard and movie stuntman, according to the league's 
Web site; The New Jersey resident visited Epstein seven 
tiIJ1es in July, 
Zi~oviev, Schank and Ma:rcinkova could not be reached for 
comment. 
Staff researchefNiels HeiII1~riks c.ontributed to this story.-, 
CA/Arcp~~~AiWi BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

Palm Beach DailyNews
BiIlion<iife sex offender leaves jail
six days a week for work
Posted Jul 1,2008 at 12:01AM
Updated Oct 4,2019 at 9:27 AM
Palm Beach billionaireJeffrey Epstein, who’s serving 18
months in jail for soliciting an underage girl for
prostitution, is allowed to leave the Palm Beach County
Stockade six days a week on a work-release program.
Teri Barbera, spokeswoman for the Palm Beach County
Sheriffs Office, confirmed that Epstein, 55, has been in the
work-release program since Oct. 10.
“He works six days a week: Friday through Wednesday 10
a.m. to 10 p.m.,” Barbera said via e-mail. "(He) works at his
local West Palm Beach office, monitored on an active GPS
system (he wears an ankle bracelet). Mr. Epstein hires a
permit deputy, at his expense, for his own security at his
workplace during the time he is out.”
Miami attorneyJeffrey Herman represents six young
women who ve sued Epstein, claiming he sexually abused
them at his Palm Beach home when they were minors.
Herman said he received a letter about the work-release
program from the U.S. Attorney’s Office within the past
few days. But Herman says Epstein had been out on work¬
release for several weeks before the notification.
“My clients expressed shock and disappointment,” Herman
said. T find it incredible that he’s on work-release in the
community and my clients aren’t notified ofthis and we get
this letter weeks after the fact.”
Jack Goldberger, Epstein’s criminal attorney, said the
CA/Arop^e^O^I^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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• 
P1m Beach Daily News 
:Billi'oo:alte, 
1sex offende_r 1-eaves jail 
sit days ,:a ,w-eek. f:oi w.or~ 
Posted Jul 1, 2008 at12:01 AM 
Updated Oct4, 2019 at 9:27 AM 
Paim Beach billionaireJeffrey Epstein, who's servin~ 18 
months iii jail.for soHdting an underage girl for 
prostitution, IS allowed to leave the Paltn Beach County 
Stockade six days a week on a work-:release program. 
Teri Barbera, spokeswoman for the Palm Be...

arran>t is not unusual.
“He goes to work every single day and goes back to jail at
night, just like everybody else (in the program),”
Goldberger said.
Epstein pleaded guiltyJune 30 to twp felony counts:
soliciting prostitution and procuring a person under 18 for
prostitution. As part ofthe plea agreement, Epstein must
serve one year ofhouse arrest and register as a lifelong sex
offender.
CA/Aroi^jO^]^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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arran.tis not unusual. 
"He goes to work every single day and goes back to jail at 
night,.just iike everybody else (in the program)," 
Goldberger said. 
Epstein pleaded guilty June 30 to two felony counts: 
soliciting prostitution :u1.d procuring a person under 18 for 
prostitution. As part of the plea agreement, Epstein must 
serve one year of house attest and register as a Hfelong s~.x 
offender. 
CA/Arop~~9'At°% BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

T?ePalm BeachP^t
REALICTS STAKE HERE
Women want Epstein sex plea deal
unsealed
Posted Jul 1,2008 at 12:01 AM
Updated Oct 2,2019 at 2:23 PM
(EDITOR’S NOTE; This story originally published in The
Palm Beach PostJune 10, 2009)
Their attorneys will ask a judge to openJeffrey Epstein’s
records.
When wealthy money managerJeffrey Epstein of Palm
Beach pleaded guilty last year to procuring teens for
prostitution, his case detoured around local and state rules
regarding the sealing Of court documents.
At a plea conference on the state charges, a judge, a defense
lawyer and a prosecutor huddled at the bench and decided
that a deal Epstein had struck with federal prosecutors to
avoid charges should be sealed, according to a transcript of
the hearing.
And so it was.
But Florida rules ofjudicial administration, as well as rules
of the Palin Beach County court system, require public
notification that a court document has been or will be
sealed, meaning kept from public view. The rules also
require a judge to find a significant reason to seal, such as
protecting a trade secret or a compelling government
interest.
Yet ho notification or reason occurred in Epstein’s case,
according to court records.
CA/Arop^r^Of^1^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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. 
• 
• 
-• 
Tile Palm Beach Post 
REAL NEWS srm'S III.lf: 
W.omen ,want 'Epstein sex ,:plea de~t 
utasea'led 
Posted.Jt1l l, 2008 at 12:Q1 AM 
Op dated Oct 2, 2019 at 2:23 PM 
(EDITOR'S NOTE;T/tis story originally published in The 
Palm Beach Post June 1,0, 2009) 
Their attorneys will a:sk a judge to openJeffrey Epstein'.s 
records. 
When wealthy moneyman?,ger Jeffrey Epstein of Palm 
Beach pleaded gµilty last yeas to. procuring teens for 
prostitution, his case detoured around local and state rules 
regarding the sealing oftourt doctiinehts; 
At a plea conference on the state charges, a juclge, ~ defense 
lawyer and a prosecutor huddled a~ the bench and decided 
that a deal Epstein had st...

EpsteiHBcwn attorneys, in federal filings, have refe:
to
his confidential deferred prosecution agreement with the
U.S. attorney’s office, struck in September 2007, as
“unprecedented” and "highly unusual.” And it was “a
significant inducement” for Epstein to accept the state's
deal, observed the state judge who.accepted his plea,
Countyjudge Deborah Dale Pucillo.
Epstein now faces at least a dozen civil lawsuits in federal
and state courts filed by young women who said they had
sex with him and now are seeking damages.
Attorneys for some of those women want his agreement
with federal prosecutors unsealed and will ask CircuitJudge
Jeffrey Colbath to do so today;
"It is against public policy for these documents to be have
been sealed and hidden from public scrutiny. As a member
ofthe public, E.W. has a right to have these documents
unsealed,” wrote former CircuitJudge Bill Berger, now in
private practice and representing one of the women;
The Palm Beach Post also will ask Colbath to unseal the
agreement. Post attorney Deanna Shullman will argue that
the public has a right to knowthe specifics of Epstein’s deal.
According to various media accounts, Epstein moved in
circles that included President Clinton, Donald Trump and
Prince Andrew. “International Moneyman ofMystery,”
declared a 2002 New York magazine profile ofEpstein.
Epstein, 56, is in the Palin Beach County Stockade, serving
an 18-month sentence after pleading guilty nearly a year
ago to felony solicitation of prostitution and procuring
teenagers for prostitution.
He is allowed out from 7 atm to 11 p.m., escorted by a
deputy, said Palm Beach County Sheriffs Office
spokeswoman Teri Barbera.
CA/Arop^e^O^I^I^ BEACH C0UNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Epste.wn attorneys, infedera1 filings, have refe.to 
his confidential deferred prosecution agreement with tlie 
U.S. attorney's office, struck in September 20Q7J as 
"unprecedented" and "highly unusual.'1 And it was "a 
signific...

Purin^Llm Beach. Police Department investigate
victims and 17 witnesses gave statements. They told of.
young women brought by his assistants to Epstein’s
mansion on El Brillo Way for massages and sexual activity,
and then being paid afterward.
At Epstein’s plea conference last year, his attorney, Jack
Goldberger, and then-Assistant State Attorney Lanna
Belohlavek approached Pucillo in a sidebar conference.
Pucillo, who had left the bench nine years earlier, was
filling in temporarily as a senior judge.
According to a transcript, Goldberger told Pucillo that
Epstein had entered a confidential agreement with the U.S.
attorney’s office in which federal prosecutors brokered not
pursuing charges against him ifhe pleaded guilty in state
court. Pucillo then said she wanted a sealed copy of the
agreement filed in his case, and Goldberger concurred that
he wanted it sealed. Belohlavek later signed offon it.
The Florida Supreme Court has expressed "serious concern”
and launched an all-out inquiry into sealing procedures
across the state following media reports in 2006 ofentire
cases being sealed and disappearing from court records.
“The public’s constitutional right of access to court records
must remain inviolate, and this court is fully committed to
safeguarding this right,” justices wrote in their final report.
Epstein’s office on Tuesday referred any questions to
Goldberger, who declined to comment. Pucillo also has
declined to comment.
CAArop^r^-0^1^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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' 
Dt1rin.lm Beach Polke Departmentinvestigad.e 
victims and 17 witnesses .gave statements. They told of, 
young women brought by his assistants to Epstein's 
. 
. 
I 
mansion onEl Brillo Way for massage~s and sexual acti~ty, 
and then being paid aftetwatd. 
At Epstein's plea conference last year, his attorney.Jack 
Goldberger, and. then--,Assistant State Attorney Lanna 
Befohlavek approached Pucillo in a sidebar conference. 
Pucillo, who had ...

The Palm Beach Post
REALKEWSSTARTSHERE
Epstein secret pact with Feds
reveals “highly unusual” terms
Posted Jun 10,2009 at 12:01 AM
Updated Oct 4,2019 at 9:23 AM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on September 19, 2009)
A secret non-prosecution agreement multimillionaire
financierJeffrey Epstein struck with federal prosecutors is
being called “highly unusual” by former federal prosecutors
and downright outrageous by attorneys now representing
young women who serviced him.
The deal reveals that the FBI and the U.S. Attorney’s Office
investigated him for several federal crimes, including
engaging minors in commercial sex. The crimes are
punishable by anywhere from 10 years to life in prison.
But federal prosecutors backed down and agreed to recall
grand jury subpoenas if Epstein pleaded guilty to
felonies in state court, which he
ultimately did. He received an 18-month jail sentence, of
which he served 13 months.
The U.S. Attorney’s Office also agreed not to charge any of
Epstein’s possible co-conspirators: Sarah Kellen, Adriana
Ross, Lesley Groffand Nadia Marcinkova.
The deal was negotiated in part by heavyweight New York
criminal defense attorney Gerald Lefcourt.
Unsealed on Friday after attorneys for some of Epstein’s
victims and The Palm Beach Post sought its release, it offers
the first public look at the deal Epstein’s high-powered legal
counsel brokered on his behalf.
CA/AroPheffiQ^> BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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T1'e Palm Beach P!t 
RfALtlWS STARTS HERE 
Epstein :secret pa_ct wi(h:: feds 
rev~.als 'fhighly ·qnusu~l" lerms: 
Posted Jun 1 o, 2009 at 12:01 AM 
Updated Oct'4, 2019 at 9:23 AM 
(EDITOR'S NOTE: This story originallypublished in Th? 
Palm Beach Post on Septe_mber J9, 2(X)9) 
A secret .non-pro~f!Ctlti,on agreement multimillionaire 
financier Jeffrey Epstein struck:with federal prosecutors is 
being called ,;highly unusual" by former federal pros~cutors 
and downrigh...

Mark^^son of Stuart, a former federal prosecute
described the disparity in potential sentences as unusual,
but even more so a provision on attorney payment.
The first draft ofthe agreement in September 2007
required that Epstein pay an attorney — tapped by the U.S.
Attorneys Office and approved by Epstein --to represent
some of the victims. That attorney is prominent Miami
lawyer Bob Josefsberg.
But an addendum to the agreement signed the following
month struck Epstein’s duty to payJosefsberg ifhe and the
victims did not accept settlements — capped at $150,000 —
and instead pursued lawsuits.
Johnson said it appears the government was trying to
balance the lesser sentence for Epstein with recovering
$150,000 for each victim. “Ive never, ever seen anything
like that in my life,” he said. “It's highly unusual.0
The deal does not say whether any victims were contacted
or consulted before the deal was made.
Attorney Brad Edwards of Fort Lauderdale, who represents
three of the young women, believes that none of the 30 to
40 woman identified as victims in the federal investigation
were told ahead of time. Edwards said his clients received
letters from the U.S. Attorneys Office months afterthe deal
was signed, assuring them Epstein would be prosecuted.
“Never consulting the victims is probably the most
outrageous aspect of it," Edwards said. “It taught them that
someone with money can buy his way out of anything. It's
outrageous and embarrassing for United States Attorney's
Office and the State Attorney’s Office.”
Epstein now faces many civil lawsuits filed by the women,
who are represented by a variety of attorneys. In many, the
allegations are the same: that Epstein had a predilection for
teenage girls, identified poor, vulnerable ones and used
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Mark.on of Stuart, a former federal prosecuto. 
described the disparity in potential sentei:ices a~ unusu.al, 
but even more so a prqvisjon on ~rtom...

otherV? women to lure them to his Palm Beach^j|p
mansion. They walked away with between $200 and
$1,000,
Former Circuitjudge Bill Berger, also representing victims,
called the agreement a “sweetheart deal.’’
“Why was it so important for the government to make this
deal?” Berger asked rhetorically. “We have not yet had an
honest explanation by any public official as to why it was
made
and why the victims were sold down the river.”
Former federal prosecutor Ryon McCabe described the
agreement as “very unorthodox.” Such agreements, he said,
are usually reserved for corporations, not individuals.
“It’s very, very rare. I’ve never seen or heard of the
procedure that was set up here,’’ said McCabe, who has no
involvement in any Epstein litigation.
“He’s essentially avoiding federal prosecution because he
can afford to pay that many lawyers to help those victims
review their cases. ... If a person has no money, he couldn’t
be able to strike a deal like this and avoid federal
prosecution."
The backroom deal with federal prosecutors is all the more
interesting in light ofthe legal powerhouses who have
worked for Epstein, including Harvard professor Alan
Dershowitz and Bill Clinton investigator Kenneth Starr.
Lefcourt is a past president of the National Association of
Criminal Defense Lawyers.
Epstein’s local defense attorney, Jack Goldberger, issued a
statement Friday saying he had fought the release of the
sealed agreement to protect the third parties named there.
“Mr. Epstein has fully abided by all ofits terms and
conditions. He is looking forward to putting this difficult
period in his life behind him. He is continuing his long¬
standing history of science philanthropy.”
CA/AlWfcBEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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other .g women to lure them to his Palm Beach. 
mansion. They walked a.way with be.tween $200 and 
$i,ooo, 
Former Circuit Judge Bili Berger, also representing victims, 
c·aIIed the agreeinerit a usweetheart deal."...

Thein^Okgation.
triggered tensions betweenpolice^
prosecutors, with then-Palm Beach ChiefMichael Reiter
saying in a May 2006 letter to then-State Attorney Barry
Krischer that the chief prosecutor should disqualify himself.
“I continue to find your office’s treatment ofthese cases
highly unusual,” Reiter wrote. He then asked for and got
the federal investigation that ended in the sealed deal.
"TheJeffrey Epstein matter was an experience ofwhat a
many-million-dollar defense can accomplish,” Reiter told
the Palm Beach Daily News upon his retirement.
CA/ArOftebBEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The in.gation, triggered tensions between polfoe. 
prosec~tors, with then-Palm Beath Chief Michael Reiter 
saying in a May 200.6 letter to then-State Attorney Barry 
Krischerthat the chief prosecutor should disqualify himself. 
"I continue to find your office'~ treatlllent ofthese cases. 
highly unus4al," Reit~r wrote. He th.en .asked for and got. 
the Jederai investigation that endedinthe sealed deal. 
"TheJeffrey Epstein matter was an experience. of what ·a 
iiiany-niillion-dolfar defense can accomplish," Reiter told 
the Pal.m Beach Daily News upon his retirement. 
CA/Aro~ft:ffl5?~A~~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 
l 
f i I I 
I 

187 / 278 - Wednesday. January 27, 2010
Edition: FINAL
Section: LOCAL & BUSINESS
Page: 3B
Source: By JANE MUSGRAVE Palm Beach Post Staff Writer
Dateline: WEST PALM BEACH
JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS
In a decision that could spark a constitutional showdown over privacy rights, a judge
Tuesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to
subpoena abortion records from women who are seeking millions in damages from the part-
time Palm Beach resident.
Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut
the women's claims that they suffered psychological ills after being paid to give him
sexually-charged massages at his Palm Beach mansion when they were as young as 14.
Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records,
he said, can't be sought until the women are asked whether they have ever had an abortion,
how many and where. Further, he said, the records would not be made public and might not
be admissible during trial.
But, he said, since the women claim Epstein, now 57, is responsible for their emotional
distress, his attorneys can explore the impact of other events. Medical records, Hafele said,
are a better source of information than a person's memory.
Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palin
Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky
constitutional grounds.
"These records are protected by our constitutional right ofprivacy," he said, referring to the
Florida Constitution.
After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the
records.
In another ruling Wednesday, Hafele also said that videos from depositions in the state cases
can't be released without a court order. The ruling came after Epstein attorney Robert Critton
complained that a video ofEpstein being asked whether he had an "...

A
,
0
Tne Palm Beach Post
HAL HEWS STARE HERE
Epstein Journal’s FindingsMM
Resurrect Base
By Me Musgrave
Posted Sep 17,2019 at 12:01 AM
Updated Oct 1,2019 at 10:51 AM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on March 20, 2010)
A purloined journal that is said to contain the names of
“hundreds” ofvictims ofconvicted sex offenderJeffrey
Epstein could be used to reopen the investigation into the
multi-millionaire’s appetite for teenage girls, an attorney
representing seven ofthe victims said Friday;
New details about the contents of the journal were released
this week when Alfredo Rodriguez, who worked as a
property manager for the Palm Beach resident, pleaded
guilty to obstruction ofjustice for lying to federal agents
when asked ifhe had any information about his former
boss’ criminal activity. He later tried to sell the journal he
stole from Epstein for $50,000 to ah unidentified person,
who alerted authorities, according to court records.
As part of the plea agreement, federal prosecutors said the
journal “contains information material to the Epstein
investigation, including the names of material witnesses
and additional victims.”
“Had the items been produced in response to the inquiries
of state of federal authorities ... the materials would have
been presented to the federal grand jury,”federal
prosecutors wrote.
CA/Arop^^-Og]^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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T1'e Palm Beach Pcft 
REAi. filWS STARTS HERE 
Epstein Jour.ijal's iFh1dlngs loo .. ld: 
iR·esurrect &ase1 
• • 
••> ,• 
• 
• 
• 
~ 
•• 
0 
• • 
•---• I 
• 
,, 0 
• •,, 
0 
By Jane_Mu$grave 
Posted Sep 17, 20.19 at 12:01 AM 
Updated Oct i. 2019 at 1 0:Si AM 
(EDITOR'S NOTE: This story origirially pJ-tblished in The 
Palm Beach Post on March 20, 2010) 
A purloiried journal that is said to contain the names of 
"hundreds" of victims of convicted sex offender Jeffrey 
Epstein could be used to reopen the fovestigation into the 
multi...

Instea^^^jsecutors
short-circuited the grand jury
investigation and cut a deal with Epstein. They agreed hot
to pursue federal charges ifhe didn’t contest prostitution-
related felonies in state court. The money manager pleaded
guilty in July 2008 to procuring a minor for prostitution
and soliciting prostitution. He served 13 months of an 18-
month sentence.
Attorney Adam Horowitz, who represents seven of the
roughly 18 women who have filed civil suits against
Epstein, said the new information could trump the so-
called non-prosecution agreement.
The multifaceted agreement, he said, deals only with a
specific list ofvictims that the U.S. Attorney's Office knew
about when it penned the deal in 2007. Ifadditional victims
are listed in the journal Rodriguez stole, Horowitz said
federal prosecutors could reopen the investigation.
“It opens the door for further prosecution,” he said.
In addition to turning over the journal to federal agents,
Rodriguez told them he knew his former boss was having
sex with underage girls when he worked for him in 2004
and 2005. He had seen naked girls, who looked like minors,
in the pool of Epstein’s $8.6 million mansion. He had seen
pornographic images ofyoung girls on Epstein’s computer,
according to court records.
Neither Epstein’s criminal defense attorney,Jack
Goldberger, nor attorney Robert Crittoh, who represents
Epstein in the civil lawsuits, could be reached. Federal
prosecutors have consistently declined comment.
The wording of the controversial agreement is unclear. It
says federal prosecutors would provide Epstein’s attorneys
“with a list of individuals whom it has identified as victims.”
Miami attorney Robert Josefsberg was appointed to
CA/AroPh?®5??183?i
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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lnstea.secutors short-circuited' the grand jury • 
investig3,tion and cut a deal with Epstein. They a~teed not 
to pursue fed.era! charges ifhe didn't contest pt.6:Stitution,-
related felonies ...

repres®Olny ofthe victims oh the list who wanted™
pursue Epstein in civil court. As part of the agreement,,
Epstein is to pay forJosefsberg to represent the women.
Some of the women, most identified asJane Doe in
'
lawsuits, had already hired attorneys to represent them.
Some have since settled their suits with Epstein, although
terms were not disclosed.
Horowitz said he has filed court papers to get the journal
that Rodriguez stole. “It's another piece of evidence that
shows our clients were at Epstein’s mansion,” he said.
Rodriguez told prosecutors he didn’t turn over the journal
when both FBI and Palm Beach police asked for it because
he wanted money for it. He also said he was afraid Epstein
would make him "disappear.” The information, he told
investigators, was his "insurance policy/’
He faces a maximum 20 years in prison when he is
sentenced on June 18.
jane_musgrave@pbpost.com
@pbpcourts
i
CA/Arof^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 1:04:39 PM
NOT A CERTIFIED COPY
I 
repres&y of the victims on the listwho wanted. 
pursue Epstein in civil court,. A~ part of th.e agreement, 1 
Epstein i~ to pay for J osefsberg to represent the women! 
I 
Some ofthe. women·, most identified as Jane Doe in 
lawsµits, had already hired attorneys toreprese11t them. 
Some have since settled their suits with Epstein, although 
terms were not disclosed .. 
Horowitz said he h~.s filed court papers to get thejourrtal 
thatRodriguez stole. "It'.s another piece of evid~nc,:e that 
shows our clients were at Epstein'~ n;i..tnsion," he said. 
Rodriguez told prosecutors he did,n't tun1 over the journal 
when both. FBI and Palill Beach police asked for it because 
he wanted money for it. He also said he was .afraid Epstein. 
would make him udisappeat." The inforIIiation,.he told 
investigators; was his "insurance policy;" 
He faces a maximwil 20 years in p.r:ison when he is 
sentenced on June 18. 
@pbpcourts 
CA/Ar°fltt~~~M_,¾_ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/20...

•
•
The Palm Beach Post
REALNEWSSTARTSHERE
Epstein paid three women $5.5 million to end underage-
sex lawsuits
By ^ane Musgrave
Posted Oct 3,2017 at 12:01 AM
Updated Oct 4,2017 at 12;46 AM
Ending years of speculation about how much Palm Beach billionaireJeffrey Epstein paid young
women who claimed he used them as sex toys, court documents filed last week show he shelled
out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him.
Responding to requests from Epstein’s attorneys in a complex lawsuit that was spawned by the
sex scandal, attorney Bradley Edwards said the politically-connected 64-year-old Convicted sex
offender paid more than S1 million to each of the three women Edwards represented.
Identified in court papers only by their initials or pseudonyms because of the nature of the
allegations and their youthful ages, L.M. was paid S1 million, E.W. $2 million and Jane Doe
$2.5 million, Edwards said of the settlements he negotiated with Epstein to end the lawsuits.
Jack Goldberger, one of Epstein’s criminal defense attorneys, on Tuesday declined comment on
the revelations, citing confidentiality agreements that were part ofthe settlements. For the
same reason, he declined to say whether Epstein paid similar amounts to settle roughly two
dozen lawsuits filed by other young,women against Epstein, claiming he paid them for sex
when some were as young as 14 years bld.
AttorneyJack Scarola, Who is representing Edwards, said his client was compelled to divulge
the confidential settlements to answer questions posed by Epstein’s attorneys. "Brilliant move
on their part,” he said.
Even ifEpstein’s attorneys hadn't opened the door, Scarola said the information would have
likely come out. He says the information will help him undermine Epstein’s claims that
Edwards “ginned up” the allegations to help his former law partner, imprisoned and disbarred
Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.
CA/Aropj^O^ BEACH...

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e
The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute
between Epstein and Rothstein, both billionaires.
A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a
minor for prostitution, he sued Rothstein and Edwards^ claiming they trumped up the
allegations of sexual molestation to perpetuate the Ponzi scheme.
Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly
successful law firm by forging the names offederal judges and others to persuade investors he
had negotiated settlements in lawsuits against high-profile people. Investors were told they
could get a cut ofthe cash.
One ofthe high-profile people Rothstein used to lure investors was Epstein, according to a
lawsuit West Palm Beach attorney Robert Critton filed on Epstein’s behalf. According to the
lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the lawsuits
with the teens for S200 million — a claim Critton described as “a complete fabrication.”
After Epstein dropped the lawsuitin 2012, Edwards turned the tables on him. Edwards accused
Epstein offiling the lawsuit maliciously to punish him for representing the young women.
Although Edwards was a partner in Rothstein’s now defunct firm, Scarola claims Epstein had
no evidence Edwards was involved in the Ponzi scheme. Federal prosecutors successfully
charged other attorneys and members of the firm, but Edwards was never implicated, Scarola
said in the malicious prosecution lawsuit.
The revelations aboutthe money Epstein paid to three of the young woman came last week in
documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit.
Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay ofthe
trial, in part, because she claimed she has been unable to talk to her client since his estate on his
private island in the U.S. Virgin Islands was devastated last month by ...

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e
Pointing out Epstein’s enormous wealth and his private jet, Palm Beach County CircuitJudge
Donald Hafele rejected her request. While saying he didn’t want to appear insensitive to those
victimized by the storm that hammered the Caribbean and roared through South Florida, he
said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.
Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide
before the case goes to trial.
Despite Scarola’s insistence that Edwards had nothing to do with Rothstein’s Ponzi scheme,
Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein’s
well-known friends, such as now President Donald Trump, former President Bill Clinton and
illusionist David Copperfield, she asked. He used the celebrities as a draw, she said.
"The Epstein cases were used to fleece money and defraud investors,” she said.
Edward’s malicious prosecution case has been difficult for both sides because both Epstein and
Edwards have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked
his Fifth Amendment right against self-incrimination when questioned by Scarola. Edwards
has claimed that much ofthe information Epstein is seeking is protected by attorney-client
privilege.
The malicious prosecution lawsuit is one oftwo hotly-contested lawsuits that continue to pit
Edwards against Epstein. Edwards also is suing the U.S. attorney’s office, claiming it violated
the federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with
Epstein.
Ohly after federal prosecutors agreed to drop their investigation of Epstein, did he agree to
plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court
records, prosecutors claim one ofthe key reasons they agreed to drop their case was Epstein’s
agreement to settle lawsuits filed againsthim by dozens of his underage victims.
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLE...

Palm Beach DailyNews
Judge rifles feds’ agreement with
Jeffrey Epstein pact violated teen
victims’ rights
By Jane Musgrave
Posted Sep 17,2019 at 4:02 PM
Updated Oct 8,2019 at 12:31 PM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on February 22, 2019)
Federal prosecutors violated the rights ofJeffrey Epstein’s
teenage victims by failing to reveal they had dropped plans
to prosecute the billionaire on dozens of federal charges in
connection with the girls’ claims that he paid them for sex
at his Palm Beach mansion, U.S. DistrictJudge Kenneth
Marra ruled on Thursday.
In a,blistering 33-page ruling, Marra meticulously and
methodically detailed the numerous steps federal
prosecutors took to hide the agreement from more than 40
young women who claim Epstein paid them for sex when
they were as young as 14.
“While the government spent untold hours negotiating the
terms and implications of the NPA with Epstein’s attorneys,
scant information was shared with the victims,” Marra
wrote. "Instead, the victims were told to be patient’ while
the investigation proceeded.”
By then, it was too late. A deal had already been cut with
then-South Florida U.S. Attorney Alex Acosta and Epstein’s
attorneys to shelve a 52-page federal indictment against
Epstein, a former math teacher turned money manager
who counts: Presidents Donald Trump and Bill Clinton
among his friends.
CA/Aropp^O^^ BEACH CouNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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-• 
•• 
- • 
Palm Beach Daily News 
Judge ru'le.s feds' ,a.g_r.e«unent with 
Jeffrey,, Ep_stein ;pact vlolated; teen; 
victims' rights:: 
By Jane Musgrave 
Post_ed S~p 17, 2019 at 4:02 PM 
Updated Oct 8, 2019 at 12:31 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm}?each Post on February 22,,2019) 
F ecleral prosecutors violated the tights. of Jeffrey ~pstei,n' s 
teenage victims by failing to reveal thE!y had dropped plans 
to prosecute the bi11iona1re on dozens of federal charges· in...

Prosec^^^’failure to alert the young women about^
deal violated the Crime Victims’ Rights Act, Marra ruled.
“At a bare minimum the (act) required the government to
inform (the young women) that it intended to enter into an
agreement not to prosecute Epstein,” he wrote.
Still, Marra said he wasn’t second-guessing prosecutors'
decision not to pursue Epstein on federal charges ifhe
pleaded guilty to minor state prostitution charges and
agreed to compensate his victims for the trauma he caused.
“The court is not ruling that the decision not to prosecute
was improper," Marra wrote. “The court is simply ruling
that, under the facts of this case, there was a violation under
the CVRA.”
Further, he made no decision about what the remedy
should be. He gave prosecutors and attorneys representing
the young women 15 days to meet to decidehow to unravel
the complex legal web that has been hanging over Epstein
and his young victims for more than a decade.
The chances an accord will be reached are slim, said
attorneyJack Scarola, who is representing the two Jane
Does who challenged.the prosecutors' actions.
Further, he said, there is no road map to follow. The
lawsuit attorney Bradley Edwards filed on behalf ofthe two
unidentified young women, claiming prosecutors violated
the federal act, is unique, he said.
“We are treading on virgin ground, to use what is probably
an inappropriate phrase in this situation,” he said.
Scarola said he and Edwards will ask that the non¬
prosecution agreement be thrown out. That would open
the possibility that the long-shelved federal indictment
could be dusted off and filed against the 66-year-old
Epstein, who spends most of his time on a private island he
owns in the U.S. Virgin Islands.
CA/ArGfte?)P?H^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Prose•• failure to alert the. young women about. 
dealviolatedthe Crime Victims' Rights Act, Marra ruled, 
"At a bare minimum.the (act) required thE! government to 
i...

“I don^^the
government conceding to that remelj|^
Scarola admitted. Further, he said, it is likely Epstein will be
allowed to weigh in. Miami attorney Roy Black years ago
filed papers asking to intervene on Epstein’s behalf.
The U.S. Attorney’s Office said it wouldn’t comment oh
Marra’s ruling. Neither Black nor New York City attorney
Jay Lefkowitz, who led efforts to bury the federal
indictment, responded to emails or phone calls for
comment. West Palm Beach attorneyJack Goldberger, who
represents Epstein, also didn't respond.
Scarola said it is likely Epstein’s star-studded legal team will
argue that.Epstein fully complied with the terms of the
agreement he made in 2007 with federal prosecutors and
therefore the agreement can’t be undone.
As he promised, Epstein pleaded guilty in June 2008 to state
charges of soliciting a minor for prostitution and soliciting
prostitution. He served 13 months of an 18-month jail term
in a vacant wing of the county stockade that he was allowed
to leave 12 hours a day; six days week.
Further, as agreed, he paid settlements to the young women
who sued him. While the settlements were confidential,
court records show he paid three women a total of $5.5
million.
In return, federal prosecutors held up their end of the
bargain. Their investigation Ceased.
Having done all that prosecutors asked of him, Scarola said
Epstein will make a simple argument: “You can’t turn
around and deprive me ofthe benefits I bargained for.”
However, Scarola said, using Marra's ruling, he will counter
that the contract Epstein signed was illegal and therefore
unenforceable.
CA/Arop^^O^^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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"I don.the gqvernment conceding to that reme. 
SC?rola.admitted. Further,.he said, it is likely.Epstein:will b.e 
allowed to weigh in. Miami attorney Roy Blackye~r~ ago 
filed papers asking to intervene on Epstein's behalf 
The U.S. Attorney's Office said itwouldn\ ccmi.ment oh 
Marra's ruling. N...

Even i^^^rra
agrees to toss out the non-prosecutio^j^
agreement, Scarola conceded that doesn’t mean Epstein will
face federal charges.
"The contract can be set aside and the federal government
can attempt to enter into the same agreement," he said.
“Except the spotlight ofpublic attention will be on them
and the 40 victims will be able to explain to the court why
this sweetheart deal should not be approved.”
Scarola said that prosecutors may have had good reason not
to pursue Epstein. "There may be a reasonable explanation
but we don't know what that reason may have been,” he
said.
In court papers, federal prosecutors have said that many of
the young women were afraid to cross the powerful;
politically connected money manager and simply refused to
testify against him.
In other cases, they said, the women changed their stories.
Jane Doe 2, who is trying to have the nOn-prosecution
agreement thrown out, initially described Epstein as “an
awesome man" and told prosecutors she hoped "nothing
happens” to him. While she later agreed to testify against
Epstein, prosecutors said they feared Epstein’s attorneys
would use her words to destroy her if she ever took the
witness stand.
Marra, however, said the young woman’s comments didn’t
mean she wasn’t entitled to know about the prosecutors’
plans to drop the charges. “There is no dispute that Epstein
sexually abusedJane Doe 2 while she was a minor,” he
wrote. “Therefore, regardless of her comments to the
prosecutor, she was a victim.”
Before the case is finally resolved, Scarola predicted that "a
lot of people are going to have to answer a lot ofquestions.”
CA/Aropjj^Op]^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Even i.ra agrees to toss out the non-prosecutio. 
agreement; Scarola conceded that doesn't n1ean Epstein will 
face• federal charges. 
"The contr,!ct can be set asi<le and the federal government 
can a~tempt to enter into the same agreemerit,".lie said. 
"Except the spotlight ...

In his^^^g,
Marra detailed what appeared to be a
relationship between Acosta, his line prosecutors and
Epstein’s team of lawyers. His phalanx oflawyers included
noted Harvard law professor Alan Dershowitz and Kenneth
Starr, the former U.S. solicitor general whose investigation
led to the impeachment of President Clinton.
Marra describes an October 2007 breakfast meeting
between Acosta, who is now U.S. labor secretary, and
Lefkowitz shortly after the nbn-prosecutioh agreement; was
inked.
After the meeting, Lefkowitz sent Acosta a note thanking
him for "the commitment you made to me during our
October 12 meeting in which you assured me that your
Office would notcontact any of the identified
individuals, potential witnesses, or potential civil claimants
arid their respective counsel in this matter.”
Marra quoted an equally pleasant note then-Palm Beach
County State Attorney Barry Krischer sent to Assistant U.S.
Attorney Marie Villafana, who was the lead prosecutor in
Epstein’s case. “Glad We could get this worked out for
reasoris I won’t put in writing,” Krischer wrote, shortly
after the non-prosecution agreement was signed. “After this
is resolved I would love to buy you a cup at Starbucks and
have a conversation.”
Marty of the notes that were exchanged dealt with
prosecutors’ and Epstein’s lawyers' shared desire to keep the
deal secret from Epstein’s accusers. In a September email,
Villafana asked Lefkowitz for guidance about what she
should reveal. "And can we have a conference call to discuss
what I may disclose to ... the girls regarding the
Agreement," she asked.
I
CA/Arop^^O^g^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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In his .g, l\1arra detailed what appeared to be a. 
relationship between Acosta; his line proseClltors and 
Epstein's team of lawyers, His p.halanx Qf}awyers included 
noted Harvard law professorAlan Dersh'owiti and Kenneth 
Starr, the former ffS. solicitor general whose investigation 
led to the impeachmen...

Such c^^pration between prosecutors and defensew
attorneys is unusual, Marra said. “It was a deviation from
the government’s standard practice to negotiate with
defense counsel about the extent of crime victim
notifications,” he wrote.
Further, he noted, that when Edwards and his two young
clients asked for information, they were repeatedly misled.
“The CRVA was designed to protect victims’right and
ensure their involvement in the criminal justice process,”
Marra wrote. "When the government gives information to
victims it cannot be misleading.”
Ultimately, the terms ofthe non-prosecution agreement
were revealed only after Edwards and attorneys fdr the
press successfully sued to make them public.
@pbpcourts
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Such c.ratioii between prosecutors and defense • 
attomeys is unusulll, Marra said. "It was a deviation from 
the government's standard prictice to negotiate with 
defense counsel about the extent of crime victim 
notifications," he wrote, 
Further, he noted, that whe,n Edwards and his two young 
c:lients asked fqr information, they were repeatedly misled. 
UThe CRVA was designed to protect victims' right and 
ensure their involvement in the crimillal justic~ process," 
Marra wrc;>te. "When rh.e government gives information to 
victims, it cannot be misieading.'; 
Uitimately, the terms of the non-prosecution agreement 
wete revealed only after Edwards and attorneys for the 
press successfully sued to m~~ them public. 
jmusgrave@pbpost,cqm 
·-·-···--·-··-·-·--··-····-·······-·-····-············---~---
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76/278 - Tuesday, July 9, 2019
Edition: Final
Section: A Section
Page: 1A
Source: By Jane Musgrave, The Palm Beach Post
Epstein indicted on sex charges
Part-time Palm Beacher pleads not guilty to sex
trafficking, conspiracy charges in federal court in
Manhattan
Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not guilty
to charges accusing him of creating a vast network of girls as young as 14 that he exploited
for his sexual pleasure at his homes in Palm Beach arid Manhattan.
The 66-year-old money manager's appearance in U.S. District Court in New York City
capped more than a decade of recriminations by young women and their attorneys who
claimed Epstein used his money and political influence to avoid federal prosecution.
Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking
charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach
County Jail for 13 months more than a decade ago.
However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to
shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state
prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is
now U.S. labor secretary.
"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey
Berman said at a
morning news conference. "And while the chafged conduct is from a number of years ago, it
is still profoundly important to many ofthe alleged victims, now young women. They
deserve their day in court."
At a detention hearing scheduled for Monday, Berman said he will ask a federal judge to
keep: Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to
commit sex traffickihg. Epstein paid dozens ofyoung women to give him nude massages
that, for most, led to sex, he said.
If convicted of exploiting dozens ofyoung women, including many Palm Beach County girls
who were students at R...

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"We think he's a significant flight risk," Berman said ofthe man who ferried Britain's Prince
Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former
President Bill Clinton on his jet, dubbed the Lolita Express.
Berman's hard-line stance was welcomed by young women, who for years have been told that
Epstein couldn't be touched because Acosta signed offon the nonprosecution agreement,
promising not to charge Epstein in federal court.
Former Palm Beach County resident Virginia Guiffre, who has accused Epstein ofturning
her into his sex slave arid forcing her to have sex with, others, including Dershowitz and
Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she
told the Associated Press. Dershowitz has vehemently denied Guiffre's claims,
New York prosecutors were able to ignore the controversial nonprosecution agreement
because it contained some significant fine print, said former federal Judge Paul Casselk who
for years has fought to get the agreement thrown out. It says only that ho charges could be
filed against Epstein in South Florida, he said.
Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of
Florida," he said. "The Southern District ofNew York.is not bound by that agreement and
wasn't a signatory of it."
That means the sordid allegations that have been leveled at Epstein for years are now part of
a federal indictment.
Contrary to Epstein's claims, he knew the women wild came to his homes in New York and
Palm Beach were minors because they told him their ages, according to the indictment.
Epstein preyed on young girls because he knew they were "vulnerable to exploitation,"
prosecutors added.
As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while
he was in New York so they would be available for sex once he returned to Palm Beach, the
indictment says. The employees weren't named. They were identified only as "Employe...

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o
U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime
Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked.
Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight
Monday, explaining what action Marra should take to redress that wrong.
Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida
victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein’s
victims with attorneys Bradley Edwards and Jack Scarola.
Since it's likely Florida women will get to testify against Epstein in New York, Scarola said
he's not focused on whether Epstein will face charges here. Instead, he said he wants to know
how and why the agreement was reached.
"There's been no explanation as to how a deal like this could have been cut arid how the
federal government could have been involved in a conspiracy to violate federal law," Scarola
said ofhis interest in continuing the legal battle over the nonprosecution agreement.
When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two
prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the
Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He
was also forced to register as a sex offender and settle civil lawsuits more than 30 young
women filed against him.
U.S; Rep. Lois Frankel. D-West Palm Beach, said she shares Scarola’s interest in finding out
how the agreement came to be/T am especially more interested in why Epstein got the deal
he got,” Frankel said. "We need to know why he was given such an easy sentence.
While she has asked the House Oversight Committee to investigate Acosta, Frankel said she
is not sure that will happen. "It just seems to me it was a travesty that this guy got offthe
way he did and. without pre-judging it, let's have a proper court case," Frankel said...

©
"Ifyou believe you are a victim ofthis man. Jeffrey Epstein, we want to hear from you,"
Berman said. A special number, 1-800-CALLFBI. will link victims of authorities.
Bill Sweeney, assistant director ofthe FBI's New York office, said after years of being
ignored by federal agents, the victims' voices will be heard.
"The Jeffrey Epstein matter is No.
1 on the major case list in the country," Sweeney said.
Turning to address Epstein's victims directly, he said: "Your bravery may empower others to
speak out against crimes against them."
jmusgrave@pbpost.com
ft®
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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" 
• 
• 
"ff you believe you are a victim of this man, Jeffrey Epstein, we want to heat from you," 
Bennan said. A Special nurrtber, . .1-800-'CALLFBI, will lin.l( victims of authorities. 
BillSweeney, assistant director of the FBI's New York office; said after years of being 
ignored by federal agents, the victims' voices will be. hea~<i._ 
;The Jeffrey Epstein matter is No. 1 on the major-case list in the countiy;" Sweeney said. 
Turning to address Epstein's victims directly, he said: "Your bravery may empower others to 
speak out ~gainst cijmes against them." 
jm1,15grc1ve@pbposi.com 
CA/Arop~?ixl~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

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o
Def.Ex.A-2
CA/Aro^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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• 
• 
Def.Ex.A-2 
CA/Arop:ll9m:5?~li¾ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

Jacobs Scholz & Wyler, leg.
THE LAW OFFICES OF
JACOBS & ASSOCWTES. PA.
ARTHUR L UACO8S
A UMfTtO LIABILITY COMPANY OF PR0FESSlpNAL ASSOCIATIONS
•
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ATTORNEYS’AT LAW-'
GATEWAY.TO AMELIA
061687 GATEWAY BLVD...SUITE 2014
Fernandina Beach,Florida 38034
RICHARD -U. SCHOLZ, P.A.
WCHARp J. SCHOLZ
TELEPHONE (904) 261*3693
FAX NO. (904) 261-7879
DOUGLAS A. WYLER, P.A.
. DOUGLAS A. WYLCA
November 26,2019
Office of the State Attorney
15th Judicial Circuit
Attn:
JcanneHoward
401 North Dixie Highway
West Palm Beach, FL 33401
Re:
CA Florida Holdings, LLC v. Dave Aronberg et al.
Case No.: 2019-CA-014681
Dear Mrs. Howard:
"
The purpose of this letter is to confirm that Jacobs Scholz & Wyler, LLC will represent you regarding the
above-referenced matter.
Our fees wilt be contingent upon our success in this matfer.-You will not be liable or required to pay any
monies to,our office unless we aresuccessfiil in dur representation ofyou regarding the above-referenced
litigation and receive a court order awarding attorneys’ fees.
Accordingly, should we be successful inthis matter, you agree to be billed.for the time incurred in defending
this action at our current hourly rates.
At this time, our current hourly, rates are:
S475.00/hourfor senior
partners, $425.00/hourfor other partners, $375.00/hour for associate attorneys, and $125.00/hour for
paralegal time.
Furthermore, the attorneys’ fees paid to our firm shall be calculated by the above listed hourly rates
multiplied by the number of hours expended in defending this action or the total fee. mandated and awarded,
by the court order herein, whichever is greater.
By sighing below, you agree to the terms as set forth above.
Please return a signed and dated copy ofthis
letter to our office.
If you have any questions or concerns, please contact our office,
On behalf of the
firm, we are proud to represent you in this matter.
Sincerely,
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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•• ·.·•-· 
. 
. 
J.A.C?-...

Def.Ex.A-3
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Def.Ex.A-3 
CA/Arffl~?~Ai~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

o
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM. BEACH COUNTY. FLORIDA
CA FLORIDA HOLDINGS. LLC,
Publisher of the PALM BEACH POS E
Plaintiff,
y.
CASE NO. : 19-CA-014681
DAVE ARONBERG. as State Attorney of
Palm Beach County, Florida: SHARON R
BOCK, as Clerk and Comptroller of Palm
Beach County, Florida.
Defendants._I
MOTION TO DISMISS
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
through the undersigned counsel, hereby files this Motion to Dismiss Plaintiffs Complaint for failure to
state a cause of action, and in support thereof states:
MOITON TO DISMISS STANDARD
When confronted with a motion to dismiss, the Court must determine whether the Complaint as
phrased vyithm its four. corners sufficiently states a cause of action, whereby relief can be granted. Fox v.
Professional Wrecker Operations. 801 So. 2d 175; 178 (Fla. 5th DCA 2001). A motion to dismiss tests
whether the plaintiff has stated a cause of action. The test for a motion to dismiss under Florida Rule of
Civil Procedure 1.140(b) is whether the pleader could prove any set of facts as alleged in the Complaint to
support his or her claim. See. Connolly v. Sebeco, Inc.. 89 So. 2d 482,.484 (Fla. 1956): Wasua Ins: Co. v.
Havnes, 683 So. 2d 1123 (Fla. 4th DCA 1996),
In order to meet this test, “a complaint must allege sufficient ultimate facts to show that a pleader
is entitled to relief.” W.R Townsend Conti . Inc v. Jensen Civ. Constr., Inc.. 728 So. 2d 297, 300 (Fla.
1st DCA 1999) (quoting Perry v. Cosgrove; 464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla. R. Civ. P.
1.110(b)).
The com! need not accept internally inconsistent factual claims, conclusory allegations,
unwarranted deductions, or mere legal conclusions made by a party. Id. (citing Response Oncology, Inc.
CA/AroPft®^M BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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• 
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IN THE CIRCUIT COURT OF THE FIFTEENTH.ruDICL\L CIRCUIT 
IN N'1D FOR PALM. BEACJ:I COUNTY',...

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v. Metrahealth Insurance Co.. 978 F. Supp. 1052, 1058 (SiD. Fla. 1997)): Oxford Asset Mgmt., v. Jaharis.
297 F.3d 1182. 1188 (11th Cir. 2002) (“[On a motion to dismiss.] the plaintiffs factual allegations are
accepted as true.... However, legal conclusions masquerading as facts will not prevent dismissal.”). To
avoid dismissal, a pleading ‘must allege a cause of action recognized under law” against the defending
party. Kislak v. Kreediah. 95 Sb. 2d 510, 514 (Fla. 1957).
COUNTI
(Florida Statutes Section 905.27)
Plaintiff attempts to assert a cause of action, in the interest of “furthering justice”, under Florida
Statute § 905.27; however, a review of the statute in question reveals that no cause of action is provided
for therein and consequently Plaintiffs Complaint must be dismissed as a matter of law.
Despite
Plaintiff’s extensive recitation of the factual background regarding Jeffery Epstein and the testimony and
evidence presented to the 2006 grand jury in Palm Beach County, Florida, Fla. Stat.
§; 905.27, merely
explains the exceptions to the disclosure of grand jury testimony and does not set forth in any way a cause
of action upon which to initiate a valid law suit.
Moreover, a review of the statute at issue clearly indicates that even if § 905.27, Fla. Stat,
provided a basis for a cause of action. Plaintiff is barred from access to the records it seeks. To wit, in
pertinent part, Fla. Stat. § 905.27(2) states:
When such disclosure is ordered by a court pursuant to subsection (1) for use in a civil
case, it may be disclosed to all parties to the case and to their attorneys and by the latter
to their legal associates and employees. However, the grand jury testimony afforded such
persons by the court can only be used in the defense or prosecution of the civil or
criminal case and for no other purpose whatsoever.
Here, despite the clear statutory guidelines for disclosure of grand jury materials in a civil, case,
Plaintiff is improperly seeking the requested 2...

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Plaintiffs intended purpose for public disclosure of the grand jury evidence.
Fla. Stat. § 905:27(2).
Finally, it is significant to note that despite Plaintiffs allegations to the contrary. Defendant Aronberg is
not in custody or control ofthe records sought and is therefore not a proper party to this action.
WHEREFORE; based on the foregoing argument and supporting authority, Defendant, DAVE
ARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests that this Honorable
Court grant the instant Motion and dismiss Plaintiffs Complaint with prejudice, and grant Defendant
Aronberg all other and further relief deemed just and proper, :including attorney’s fees and costs for
defending this frivolous action.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day of December. 2019, a copy of the foregoing has been
electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
JACOBS SCHOLZ & WYLER, LLC
/s/Douglas A. Wyler
Arthur I. Jacobs, Esq.
Fla. Bar No.: 10249
Richard J. Scholz, Esq.
Fla. Bar No.: 0021261
Douglas A. Wyler, Esq,
Fla. BarNo.: 119979
961687 Gateway Blvd., Suite 201-1
Fernandina Beach, Florida 32034
(904) 261-3693
(904) 261-7879 Fax
Primary: jacobsscholzlaw@comcast.net
General Counselfor the Florida Prosecuting
Attorney’s.Association
CA/Arowm BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Plaintiff's intended purpose for public disclosure of the grand jury evidence. Fla. Stat. § 905:27(2). 
Finally, iris significant to note that despite Plaintiff's allegations to the contrary, Defendant Aronberg is 
not in custody or conu·ol of the records sought andis therefore not a:proper paity to this· action. 
WHEREFORE; based on the fort!goiug argument and -~upporting lluth01ity, Defendant, DAVE 
AR.ONBE'.R.G, as State Attorney of Palm Beach County, Florida: respectfully requests that this Honorable 
Comt grant the instant Motion and dismiss Plaintiff's Compla...

Def.Ex.A-4
CA/Arop^eg^l^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Def.Ex.A-4 
CA/Aropifffl5?iJ\.1_~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

Filing # 101.840557 E-Filedd^/202012:23:06 PM
e
IN
THE
CIRCUIT
COURT
OF
THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY,. FLORIDA
CA FLORIDA HOLDINGS, LLC,
CASE NO.: 50-2019-CA-014681-XXXX-MB
Publisher of THE PALM BEACH POST,
Div.: AG
Plaintiff,
v.
DAVE ARONBERG, as State Attorney of
Palm Beach.County, Florida; SHARON R.
BOCK, as Clerk and Comptroller of Palm
Beach County, Florida,
Defendants.
FIRST AMENDED COMPLAINT
CA Florida Holdings, LLC, publisher of Hie Palm Beach Post, for its First Amended
Complaint against Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his
official capacity (“State Attorney”), and Sharon R. Bock, the Clerk of the Court for Palm Beach
County, Florida, in her official capacity (“Court Clerk”), alleges as follows:
JURISDICTION
1.
This is an action within the exclusive jurisdiction of the Circuit Com! pursuant to
Fla. Stat. Sections 26.012(2)(a) and 86 011 et seq.
PARTIES
2.
The Palm Beach Post is a daily community newspaper published by Plaintiff CA
Florida Holdings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.
3.
Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth,
Judicial Circuit in and for Palm Beach Comity, Florida, pursuant to Fla. Stat. Section 27.01 and
has authority in grand jury proceedings pursuant to Fla, Stat. Section 27.03. He is sued herein in
cA/Ar°pm-°pm BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Fjling# 101_840557 E.;Filed ./2020 12:23-::06 PM 
• 
CA FLORIDA HOLDINGS, LLC, 
Publi~her of IJ[E PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach. County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palin 
Beach County, Florida, 
Defendapts, 
IN Tlffi CIRCUIT COURT 
QF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY,_ FLORIDA 
CASE NO.: 50-2019-CA-014681-XXXX-MB 
Div.~ AG 
FIRSTAlvlENDEDCOMPLAINT 
CA Flo1ida Holdings, LLC, publisher of Tiie Pa/nl ...

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ids official capacity as his office is in possession and/or control of documents that are the subject
of this action.
4.
Defendant Sharon R. Bock is the duly elected Clerk and,Comptroller ofPalm Beach
County, Florida. She is sued herein in her official capacity as her office is in possession and/or
control of documents that are the subject of this action.
INTRODUCTION
5.
In what is now widely ifbelatedly recognized as a colossal miscarriage ofjustice-
which led to the further needless victimization of countless young girls and women - a wealthy,
politically connected, and powerful financier was not held accountable for, nor even forced to
confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein’s 2008
deal with the State of Florida was not consistent with the evidence gathered against him, what
remains shrouded in.mystery is how that evidence was presented- and the extent to which it was
presented - to the grand jury that returned an indictment far more limited in scope than expected
and deserved.
6.
Through this action, Hie Palm Beach Post seeks public access to the testimony,
minutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled
during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for
example, in order to prevent the flight of those whose indictment may be contemplated and their
ability to conceal or destroy evidence; to ensure jurors’ candor in deliberations; and to protect an
accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law
expressly authorizes the disclosure of grand jury proceedings under certain circumstances,
including, as here, in the furtherance ofjustice. Fla. Stat. § 905.27(l)(c).
7.
It can no longer credibly be maintained that continued blanket secrecy over the
proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law.
CA/Arop^e^O^I^ BEACH COU...

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To the contrary', transparency is required to promote public understanding of the criminaljustice
system and public confidence in the fair administration ofjustice. As detailed below, Epstein was
accused of sexually abusing and trafficking dozens of women and girls in south Florida (among
other locations) over a period ofseveral years while exploiting his wealth and political connections
to obstruct the administration ofjustice at every turn. Public disclosmc of the Epstein grand jury
proceedings will shed light on the extent to which those in our government entrusted with the
solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled then’ duties
in this instance. Justice will be furthered where it is either (1) demonstrated thatEpstein was treated
like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those
who chose to give Epstein favorable - “unusual,” in the words of the Town of Palm Beach Police
Chief- treatment, are exposed and held accountable. From what limited information is now in the
public domain, the State Attorney’s referral ofEpstein’s case to the erand jury- which would be
out of the ordinary for this type of case - gives rise to a strong inference of favoritism and
corresponding disregard for the rights of the minor victims ofEpstein’s sex trafficking. Access to
the grand jury materials will allow the public to determine whether the grandjury process, and the
secrecy that comes with it, was used to further justice or, instead, operated to shield Epstein and
his co-conspirators from the consequences of their criminal activities. Accordingly, Fla. Stat.
Section 905.27 authorizes the disclosure ofEpstein’s 2006 grand jury proceedings.
8.
Even in the absence of such a statutory basis, this Court is empowered to order
public disclosure pursuant to its inherent authority and supervisory powers over the grand jury.
Indeed, courts throughout the country in the past several decades ha...

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as here, many of the details of Epstein’s criminal misdeeds have already been made available in
the public domain through extensive news reporting by, among others, The Palm Beach Post} by
the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves.
9.
In recognition ofthe sensitivity of the materials being sought, and in the interest of
protecting any victims who wish to remain anonymous. The Palm Beach Post has no objection to
copies ofthe testimony, minutes, and other evidence presented in 2006 to the Palm Beach Comity
grand jury first being submitted to this Court for in camera review, where they may be redacted,
as appropriate, to protect those who deserve such protection.
FACTUAL BACKGROUND
10.
The following facts were gathered, in large part, from documents obtained by The
Palm Beach Post through various Florida Public Records Law requests, documents unsealed or
publicly available in other related judicial proceedings, and information and documents in the
public record.
A.
First Epstein Sex Crimes Investigation. Indictment, and Plea Agreement;
2005—2008.
11.
The investigation into Epstein’s sex crimes began more than fourteen years ago,
when a 14-year-old girl’s stepmother reported to police in the Town of Palm Beach, Florida, that
Epstein and others who worked for him arranged for her to give Epstein a “massage.” Epstein
required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid
$300. Epstein was 52 years old at the time.
12.
Following this initial report in 2005, the Town of Palm Beach Police, and later, in
2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
disturbingly similar details, with each of the other victims.
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13.
Both the victim/witness interviews, as well as evidence retrieved following a search
of Epstein’s home, showed that some of the girls involved were, under the age of 18. The police
search of Epstein’s residence also found two hidden cameras and, throughout the house, large
number’s of nude photos of girls, including victims whom the police had not interviewed in the
course oftheir investigation.
14.
In March 2006, a State grand jury was scheduled at which all of the victims were
expected to testify. The proceeding was postponed, however, due to meetings between the State
Attorney’s office and Epstein’s prominent criminal defense lawyer and personal friend, Alan
Dershowitz.
15.
Another grandjury was convened in April 2006,,butcanceled the day before it was
to begin receiving evidence.
(1)
Police Chief Reiter’s Letter to the State Attorney.
16.
On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a
“personal and confidential” letter to then Palm Beach County State Attorney, Barry Krischer,
stating:
I must renew my prior observation to you that I continue to find your office’s
treatment of [the Epstein] 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 urgeyou to examine the unusual course thatyour office’s handling ofthis
matter has taken and consider ifgood andsufficient reason exists to requireyour
disqualificationfrom theprosecution ofthese cases. (Emphasis supplied)
17
ChiefReiter’s letter to State Attorney Krischer enclosed the Town of Palm Beach
Police Department’s probable cause affidavits charging Epstein and two of his assistants with
multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested
CA/Arop^r^Opi^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/202...

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that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges
against hiin, which would be public.
(2)
The July 2006 State Grand Jury Presentation.
18.
Instead, State Attorney Krischer elected to refer the case to a grand jury, which is
mandatory for capital cases but rarely used for all other crimes.
According to an official
spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm
Beach County.
19.
In July 2006, after State Attorney Krischer presented testimony and evidence from
one; victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.
There is no mention in the indictment ofthe victim being a minor.
20.
On information and belief, a second of Epstein’s victims was supposed to testify
before the grandjury, but was unable to attend because of a school exam.
21.
No reasonable explanation has been provided as to why the numerous other known
victims were not presented as witnesses and crime victims to the grandjury convened in July 2006.
Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was
initially eager to investigate and prosecute Epstein for his crimes, over time lost tire desire to do
so.
22.
On information and belief, dining: the grand jury appearance of the: single victim
yyho testified, the State Attorney presented evidence that vilified the victim and attacked her
credibility, including soliciting testimony regarding underage:drinking and questionable personal
behavior that was unrelated to the charges against Epstein. Further upon information and belief,
this information was initially brought to the attention of the State Attorney’s office by Epstein’s
defense counsel.
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that either an arrest wamint be issued for Epstein or the State Atto111ey dii:ectly initiate the charges 
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(3)
The FBI’s Investigation and Epstein’s Non-Prosecution
Agreement With Federal Authorities.
23.
On information and belief, following the deficient July 2006 indictment, and with
ChiefReiter’s encouragement, the FBI began its own investigation ofEpstein.
24.
Records unsealed in 2015 revealed that the FBI compiled,reports oh “34 confirmed
minors” that were victims of Epstein’s sexual predations. Based on evidence gathered by the FBI,
a 53-page indictment was prepared by the U.S. Attorney’s Office in June 2007. However, at the
request of Epstein’s lawyers, the indictment was never presented to a federal grand jury.
25.
Instead, then U.S. Attorney for the Southern District ofFlorida. Alexander Acosta,
negotiated a plea deal with Epstein’s team of lawyers to grant immunity to Epstein (along with
four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
charges.
26.
Throughout the remainder of 2007 and through the first half of 2008, Epstein’s
lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
belief. Epstein’s lawyers insisted that (1) the victims not be notified. (2) the deal be kept
confidential and under seal, and (3) all grand jury subpoenas (including one that had already been
issued for Epstein’s computers) be withdrawn,
27.
On June 30,2008, Epstein pled guilty to State charges: one count of solicitation of
prostitution and one count of solicitation ofprostitution with a minor under the age of 18. He was
sentenced to 18 months in jail, followed by a year of community control or house arrest, and was
adjudicated as a convicted sex offender required to register twice: a year in Florida.
28.
The plea deal, called a non-prosecution agreement (“NPA”), allowed Epstein to
receive immunity from federal sex-trafficking charges that could have sent him to prison for life.
CA/ArGfft®BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The FBl'.s Inv...

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On information and belief, based onpublic records. former State Attorney Krischer communicated
with then U.S. Attorney Acosta concerning the NPA’s negotiation with Epstein’s lawyers.
29.
Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for
which he was convicted.
Instead, he was placed in a private wing of the Palm Beach County
Stockade, where, after 3 1/2 months, he was allowed to leave the jail oh “work release” for tip to
12 hours a day, 6 days a week, His private driver provided his transportation to and from “work.”
30.
Epstein was released five months early.
31.
Upon information and belief, Epstein violated the terms of his probation, but was
not prosecuted,
(4)
The Crime Victims’ Rights Act Litigation.
32.
Epstein’s victims only learned after the fact about his plea in State count and filed
an emergency petition to force federal prosecutors to comply with the Crime Victims’ Rights Act
(18 U.S.C. § 3771, ^CVRA”), which mandates certain rights for crime victims, including the right
to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge
Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify
Epstein’s victims before allowing him to plead guilty to only the two State offenses.
33.
The prosecution’s failure to keep the victims apprised, among other things, also
contravenes the Florida Constitution, Article 1, § 16(b) and Fla. Stat. §960.001.
34.
Following publicity exposing the extraordinary leniency ofthe plea deal, dozens of
civil suits were brought against Epstein, most ofwhich Epstein’s lawyers settled out-of-court.
35.
In 2010, Epstein was registered as a “level three” (fa, high risk of repeat offense)
sex offender in New York, a lifelong designation. In 2011, the New York County District
Attorney’s office unsuccessfully sought to lower Ins registration to low-risk “level one.”
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36.
Upon information and belief, during the course ofthe Town ofPalm Beach and FBI
investigations.. Epstein retained private investigators to follow, harass, and photograph his victims
and their families, as well as ChiefReiter and theTown ofPalm Beach detective who investigated
the case against Epstein.
37.
Upon information and belief. Epstein’s victims were threatened against cooperating
with law enforcement and told that theywould be compensated only if they did not cooperate with
law enforcement.
B.
Second Epstein Sex Crimes Investigation. Indictment, Suicide: 2019.
38.
On July 6, 2019, Epstein was arrested on federal sex trafficking charges.
39.
Upon information and belief, the United States government’s investigation ofnew
allegations and charges stemmed, in part, from continued press investigations into and reporting
on the mishandling of the 2006 charges and the civil suits that followed.
40.
In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the
Southern District ofNew York, Epstein was described as “a serial sexual predator who preyed on
dozens ofminor girls over, a period ofyears.” The letter emphasized that “the Government has real
concerns - grounded in past experience with this defendant- that ifallowed 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.”
It also
described the results of the FBI’s search of Epstein’s Manhattan townhouse? evidence of sex
trafficking in the form of“hundreds
and perhaps thousands - ofsexually suggestive photographs
of frilly- or partially-nude females,” including underage females. In a locked safe, compact discs
were found with handwritten labels including the descriptions: “Young [Name] 4 [Name],” “Mise
nudes 1,” and “Girl pics nude.”
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41,
On July 8,2019, prosecutors with the Public Corruption Unit ofthe U.S. Attorney’ s
office for the Southern District ofNew York charged Epstein with sex trafficking and conspiracy
to traffic minors for sex. The grand jury indictment alleges that “dozens” of underage girls were
brought into Epstein’s mansions for sexual encounters. A few days later, owing to public outcry
over the NPA With Epstein entered into by the U.S. Attorney for the Southern District of Florida,
Alexander Acosta, who by then was serving as U S: Secretary of Labor in the Trump
administration, resigned from office.
42.
Epstein was denied bail and was placed into pretrial detention at the federal
Metropolitan Correction Center in lower Manhattan.
43.
On or about August 6, 2019, Florida Gov. Roh DeSantis ordered a state criminal
probe into the actions of the Palm Beach Sheriff and former State Attorney Krischer for their
handling of the Epstein underage sex trafficking case.
44.
Oh August 10, 2019, Epstein was found dead in his cell at the Metropolitan
Correctional Center, His cause of death was determined to be suicide,
C.
The August 27, 2019, SDNY Hearing; Epstein’s Victims Speak.
45.
On account of his death, prosecutor’s sought to dismiss the indictment against
Epstein, while maintaining that they would continue to investigate his co-conspirators.
46.
United States Senior District Judge Richard M. Berman ordered a hearing' on
August 27, 2019, on the prosecutors’ decision to dismiss the indictment and allowed victims to
speak at the hearing.
47.
In the course of the hearing, more than two dozen victims delivered their personal
stories of pain, frustration, and sexual abuse at the hands of Epstein, Several victims spoke of
violent rape by Epstein. Many more victims were present in the courtroom but did not testify.
10
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011 Jllly 8;2019; prosecutors with the Public Conuption Uuitofthe US,...

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48.
While some questioned the reasoning behind the court’s decision to give the victims
voice after Epstein’s death, District Judge Berman noted that “a public hearing is [the] preferred
vehicle of resolution,” emphasizing that “public hearings are exactly what judges do. Hearings
promote transparency and they provide the court with insights and information which the court
may hot otherwise be aiware of.” Indeed, even Epstein’s defense lawyer rioted at the hearing that
the court “is the institution that most people have confidence in, in these very troubled times.”
49.
At the August 27th hearing, the girls, now women, Spoke about their “exploitation
and coercion,” and to tire fact that many ofthem “were in very vulnerable situations and in extreme
poverty, circumstances where [they] didn’t have anyone on [their] side, to speak on [their]
behalf....” One victim lamented that “as a victim, [she] never got to see what the agreementwas
or why the special treatment got approved” in the Florida case years earlier. Another noted how
“completely different” the investigator's leading to the 2019 federal indictment were from the
prosecutors in the Florida case, both in their treatment of her and their investigation of her
victimization by Epstein.
50.
A former federal judge in attendance at the August 27th hearing emphasized that
“transparency is one of the overriding objectives in our criminal justice system.”
51.
Nearly all of the victims expressed the conviction that the secrecy that shielded
Epstein has caused them “irreparable harm” and that an opportunity to address liis criminal
wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
at least some measure ofjustice to be served after his death. Indeed, one victim stated: “Any efforts
made to protect Epstein’s name and legacy send a message to the victims that he wins and that he
is untouchable.” Another victim expressed fear' that this is a world “where there are predators in
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“unusual” treatment Epstein received in Florida in 2006 based on his wealth, social status, and
connections severely eroded the public’s faith in the integrity and impartiality of the criminal
justice system.
D.
The Palm Beach JUsT’s Standing and the Public Interest.
(1)
The Palm Beach Post Has Reported Extensively On Epstein’s
Crimes For Nearly 15 Years.
52.
Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm
Beach County and the Treasure Coast vicinity.
53.
The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist
three other times.
54.
Beginning in 2004, The Palm Beach Post has extensively investigated and reported
on the allegations against, the law enforcement investigation of, and tire crimes committed by,
Epstein and his co-conspiratbrs.
The Newspaper’s reportage has included publication of the
following articles:
•
“The Man Who Had Everything- Jeffrey Epstein Craved Big Homes, Elite Friends
arid, Investigators Say, Underage Girls.,” published oh August 14,2006, reporting that:
Haley Robson, a local community college student, admitted in a sworn statement to
police that “she had taken at least six girls to visit Epstein, all between the ages of 14
and 16;” Palm Beach Police “interviewed five alleged victims and 17 witnesses’”
“Dershowitz, the Harvard law professor, traveled to West Palm Beach with information
about the girls,” inchiding social media discussions about “their use of alcohol arid
marijuana;” after meeting with Epstein’s legal team, “prosecutors postironed their
decision to take the case to a grand jury;” Palm Beach Police subsequently “received
complaints that two of the victims or their families had been harassed or threatened;”
“relations between police and prosecutors were fraying” as the investigation continued;
and “one girl who was subpoenaed- the one who said she had sexual intercourse with
Epstein- never showed up” to testify before the grand jury.
•
“Trump Snags Gosnian Estate for $4...

•
“Indictment: Billionaire Solicited 3 Times” published on July 25, 2006, reporting that
“Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
solicited or procured prostitutes three or more times between.Aug. 1 and Oct. 31 oflast
year, according to an indictment charging him with felony solicitation ofprostitution.”
The article further reported that “Epstein’s case is unusual in that suspected prostitution
johns are usually charged with a misdemeanor, and even a felony charge is typically
made in a criminal information- an alternative to an indictment charging a person with
the cohmiission of a crime.”
•
“After Long Probe, Billionaire Faces Solicitation Charge” published on July 26, 2006,
reporting that “Palm Beach police thought there was probable cause to charge Epstein
with unlawful sex acts with a minor and lewd and lascivious molestation.” The article
further reported that “Police Chief Michael Reiter was so angry' with State Attorney
Barry Krischer’s handling of the case that he wrote a memo suggesting the county’s
top: prosecutor disqualify himself” and identified a 20-year-old on-the-record female
source who said “she gave Epstein a massage in the nude, then brought him six girls,
ages 14 to 16, for massage and sex-tinged sessions at his home.”
•
“Police Say Lawyer Tried to Discredit Teenage Girls” published on July 29, 2006,
reporting that “[f]amed Harvard law professor Alan Dershowitz met with the Palm
Beach Comity State Attorney’s Office and provided damaging information about
teenage girls who say they gave his client. Palm Beach billionaire: Jeffrey Epstein,
sexually charged massages” and that “[t]he state attorney’s office said it presented the
Epstein case to a county grand jury tins month rather than directly charging Epstein
because ofconcerns about the girls’ credibility.”
•
“Expert: Ignorance of Age Isn’t Defense In Sex Cases” published on August 5, 2006,
reporting that “[r]ather than file charges, the state attorney’s offi...

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“Woman Sues Billionaire Investor. Says They Had Sex When She Was 16” published
on October 18, 2007, reporting on a lawsuit brought in New York State court against
Epstein “by a young woman who says he had sex with Iler when she was 16 and had
sought his help becoming a model.”
•
“Palm Beacher Pleads In Sex Case’’ published on July 1, 2008, reporting that “Epstein,
55, pleaded guilty... to felony solicitation ofprostitution andproctiring a person under
the age of 18 for prostitution,” resulting in “a lifelong obligation to register as a sex
offender,5’ and that
-■[a]s part of the plea deal, federal investigators agreed to drop their
investigation of Epstein, which they had taken to a grandjury.”
•
“Jeffrey Epstein: Scientist, Stuntman, ‘Sex Slave’ Visit Jailed Tycoon” published on
August 13,2008, reporting that “[d]uring his first month of confinement” Epstein was
visited by Sarah Kellen, who allegedly escorted victims“upon their arrival at his Palm
Beach waterfront home to an upstairs room, where she prepared the massage table and
provided the oils for their encounters” with Epstein, and by Nadia Marcinkova, “a
young woman whom Epstein purportedly described as his Yugoslavian sex slave.”
•
“Billionaire Sex Offender Leaves Jail Six Days a Week For Work” published on July
1, 2008, reporting that Epstein “is allowed to leave the Palm Beach County Stockade
six days a week on a work-release program,”
•
“Women Want Epstein Sex Plea Deal Unsealed” published on June 10,2009, reporting
that attorneys for women suing Epstein in various courts “want his [hon-prosecution]
agreement [NPA] with federal prosecutors unsealed” and were moving to unseal the
agreement in Circuit Court ofthe Fifteenth Judicial Circuit, and that “Epstein now faces
at least a dozen civil lawsuits in federal and state courts filed by young women who
said they had sex with him and now are seeking damages.” On that date, The Palm
Beach Post moved to intervene in the matter for the purpose ofobtaining pu...

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•
“Epstein Journal’s Findings Could Resurrect Abuse Case” published on March 20.
2010, reporting that “[a] purloined journal that is said to contain the names of
‘hundreds
’ ofvictims ofconvicted sex offender Jeffrey Epstein could be used to reopen
the investigation into the multi-millionaire’s appetite for teenage girls.”
•
‘‘Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits” published
on October 4,2017, reporting that, according to court documents, Epstein “shelled out
$5.5 million to settle lawsuits with three of more than two dozen teens who sued him.”
•
“Judge Rules Feds’ Agreement With Jeffrey Epstein Pact Violated Teen Victims’
Rights” published on February 22, 2019, reporting on a ruling by U.S. District Judge
Kenneth Malta that “Federal prosecutors violated the rights of Jeffrey Epstein’s
teenage victims [under the Crime Victims’ Rights Act] by failing to reveal they had
dropped plans to prosecute the billionaire on dozens of federal charges in connection
with the girls’ claims that he paid them for sex at his Palm Beach mansion.”
•
“Epstein Indicted Oh Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex
Trafficking,, Conspiracy Charges In Federal Court In Manhattan” published on July 9,
2019, reporting on Epstein’s appearance in U.S. District Court for the Southern District
ofNew York inwhich he “pleaded not guilty to charges accusing him ofcreating a vast
network of girls as young as 14 that he exploited for his sexual pleasure at hrs homes
in Palm Beach and Manhattan.”
A true and correct copy ofthe above news articles, in either the computerized format in which they
are maintained in The Palm Beach Post's electronic archives or the news print edition in which
originally published, is annexed hereto as Exhibit 1.
55.
Since the filing ofthe initial Complaint in this matter, The Palm Beach Post- along
with media worldwide
- has continued to report on Epstein’s crimes and the ongoing official
proceedings resulting from those crim...

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Co. y. Lewis, 426 So. 2d1, 6 7 (Fla. 1982) (identifying the news media as a “public surrogate” in
matters concerning the closure ofjudicial proceedings). The press also has a First Amendment
interest in receiving information from willing speakers. See Va. Pharmacy Bd: v. Va. Consumer
Council, 425 U.S. 748, 756-57 (1976) (“Where a speaker exists .
.
. the protection afforded [by
the First Amendment] is to the communication, to its source and to its recipients both.”); Pittman
v. Cole, 267 F.3d ]269, 1283 n, 12 (11th Cir, 2001) (“The Supreme Court has recognized that the
First Amendment offers protection to both speakers and those wishing to receive speech.”); see
also Stephens v. Cty. ofAlbemarle, Va., 524 F.3d 485,492 (4th Cir. 2008) (providing that a plaintiff
has “standing to assert a right to receive speech” by “showfing] that there exists a speaker willing
to convey the information to her”).
57.
Because of the unique role performed by the press as a “public surrogate” (Lewis,
426 So. 2d at 6-7) in protectine the right of access and its interest in reporting information about
criminal proceedings, news organizations “presumptively have a right to access judicial records,”
Comm 'r, Ala. Dep’t ofCorr. y. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11 th Cir. 2019),
and “standing to question the validity of an order restricting publicity because its ability to gather
news is directly impaired or curtailed.” Lewis, 426 So. 2d at 4; see also Carlson v. United States,
837 F.3d 753, 757-58 (7th Cir. 2016) (“[a]s a member of the public, [the Reporters Committee]
has standing to assert [its] claim” to grandjury materials;because such materials are “public records
to which the public may seek access, even ifthat effort is ultimately unsuccessful”).
58.
Here, the continued denial of access to information The Palm.Beach Post seeks on
behalf of its journalists and the public it serves “unquestionably constitutes irreparable injury.”
Gainesville Woman Care, LLC v. State...

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source of informationis weakened whenever the ability of journalists to gather information is
impaired.” as it is by Attorney General’s refusal to disclose unredacted report and underlying grand
jury materials).
59.
The Palm BeachPost has the right to maintain this private right of action because
the furtherance ofjustice, an express legislative exception, to grand jury secrecy., is intended for
the public benefit, and The Palm Beach Post seeks access on behalf of the public. Fla. Stat.
§ 905.27(1 )(c). It is further express in Fla. Stat. § 905.27 that the legislature intended for a court
to be the party to make the determination of disclosure; Fla. Stat. § 905.27(1). In other words, the
legislature intended for recourse to the courts in considering and determining the propriety and
scope of grand jury' secrecy.
E.
The Court’s jurisdiction And Authority.
(1)
The Court’s Supervision of the Grand Jury Process and Its
Authority to Order Public Disclosure of the: Epstein Evidence.
60.
The Florida Supreme Court has noted that “in states such as Florida, where the
grand jury is preserved, it; is an important appendage of the; court which impanels it. At the same
time it should not be forgotten that the judge ofthat court is equally important and he is generally
charged with the supervision of the grand jury’s activities...It is, therefore, ofvital importance to
maintain the dignity and the integrity of both the grand jury and the presiding judge.” State v.
Clemons, 150 So. 2d 231, 233-34 (Fla. 1963).
61.
Chapter 905 of the Florida Statutes governs the empanelment and conduct of
Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury
about its legal duties. Fla, Stat. § 905.18.
62.
Florida Stat. Section 905.27(1) provides that “the testimony of a witness examined
before the grand jury .. . or other evidence received by it” may be disclosed “when required by a
17
CA/ArofteS^M BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1...

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court..
... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by
the witness before the court: (b) Determining whether the Witness is guilty of pcrjiuy; or (c)
Furtheringjustice.” Fla. Stat. § 905.27(l)(a)-(c).
63.
Further, disclosure is appropriate pursuant to this Court’s inherent authority over
grand jury proceedings because of the exceptional public interest in this case and the compelling
circumstances supporting transparency. Carlson v. United States, 837 F.3d at 766 (“a district court
has the inherent power to disclose [grand jury] materials in exceptional circumstances and
.
.
.
historic importance can be a sufficient reason when there is little countervailing need for secrecy”).
64.
The Florida Supreme Court has confirmed that grand jury secrecy is not absolute
and that any “potential harm to public officeholders” from disclosure “will be the product of their
own conduct, and not the consequence of an unrestrained body of misguided citizens.” Miami
Herald Pub Co.
v. Marko, 352 So. 2d 518 (1977) (“The benefits to be derived from this
extraordinary exercise in citizen participation [in the grand jury] would be severely limited if the
fruits ofthat activity were not available to the public on whose behalfit is undertaken. Implicit in
the power ofthe grandjury to investigate and expose official misconduct is the right of the people
to be informed ofits findings. While public disclosure of grandjury findings inevitably entails the
risk of reputational damage, the legislature has ensured that any potential harm to public
officeholders will be the product oftheir own conduct, and not the consequence of an unrestrained
body of misguided citizens.”).
(2)
The Court’s Jurisdiction To Declare Rights And Construe
Statutes.
65.
This Court has jurisdiction to declare rights, status, and other equitable or legal
relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011.
CA/Aro«m BEACH COUNTY, FL, J...

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66.
Florida law specifically provides that a declaration may be sought from the Court
concerning a petitioner’s rights; under a statute. Florida Stat. Section 86.021 (“Anyperson.. .whose
rights, status, or other equitable or legal relations are affected by a statute, or any regulation made
under statutory authority,.. .may have determined any question of construction or validity arising
under such statute,.. .or anypart thereof, and obtain a declaration ofrights, status, or other equitable
or legal relations thereunder.”).
67.
The Court’s exercise of its power to declare rights “is to be liberally administered
and construed.” Florida Stat. Section 86.101.
COUNTI
(Declaratory Relief- Florida Stat. Sections 86.011 et seq)
68.
The allegations set forth in paragraphs 1 through 67 are incorporated by reference
as if fully set forth herein.
69.
This is an action for Declaratory Relief pursuant to Chapter 86, Florida Statutes,
and other supplemental relief.
70.
The Palin Beach Post respectfully requests that the Court declare that pursuant to
Fla. Stat. Section 905.27(1), it is entitled access to the testimony, minutes, and other evidence
presented in 2006 to the Palm Beach County grandjury because such disclosure and access would
be in the furtherance of justice. Fla. Stat. § 905.27(l)(c). Because The Palm Beach Post is not
seeking these materials in connection with either a civil or criminal case, it seeks a declaration that
the scope of its use of the disclosed materials is not limited. See Ela. Stat. § 905.27(2).
71.
The Palm Beach Post further seeks a declaration that disclosme of the testimony,
minutes, and other evidence presented in 2006 to the Palm Beach County grandjury is appropriate
CA/Ar°fft®BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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66. 
Florida law specifically provid~s that !I. declaration may \)e sought froJ;ll the Comt· 
concerning a: petitioner's tights iitideta stah1te. Florida Stat. Section 86.021 {"Aii...

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pursuant to this Court’ s inherent authority over grandjury proceedings because ofthe exceptional
public interest in this case and the compelling circumstances supporting transparency.
72.
ThePalm Beach Post has sought from Defendants, but Defendants have refused to
provide, access to the; testimony, minutes, and other evidence presented in 2006 to the Palm Beach
County grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint arid the
reliefit sought under Fla, Stat, Section 905,27(1). Accordingly, a good-faith dispute exists between
the parties.
73.
Through this Complaint, The Palm Beach Post presently has a justiciable question
concerningits rights to obtain the 2006 grandjury materials pursuant to Fla. Stat, Section 905.27(1)
arid the Court’s inherent authority.
74.
A bona fide, actual, present, and practical need for the declaration exists in that
Defendants have denied to The Palm Beach Post - and to the public at large — the grand jury
materials sought to be disclosed. The reliefsought from the Court is therefore not rnerely the giving
oflegal advice or to answer hypothetical questions.
WHEREFORE, The Palm Beach Post respectfully requests that the Court determine the
rights and obligations of the parties byideclaring thatpursuantto Fla. Stat. Section 905.27(l)(c)
(and the Court’s inherent authority, The' Palm Beach Post may gam access to the testimony!
(minutes,and other evidence presented m 2006 to the Palm Beach Comity grand jury and use those}
(materials for, tire purpose of informing thejpublic.j
COUNTn
(Florida Stat. Section 905.27)
75.
The allegations set forth in paragraphs 1 through 74 are incorporated by reference
as if fully set forth herein.
20
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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pursuant tQ this Court's inherevt authority'over grand jury proceecliugs beQ.allSe of the exceptional 
public interest in this case and the compelling circumstances supporting transparency. 
72....

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76.
Based on information learned by The Palm Beach Post through its Florida Public
Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence
and proceedings, judicial documents obtained from independent but related court proceedings, and
documents otherwise available in the public record, the State Attorney for Palm Beach County
presented truncated evidence ofEpstein’s criminal wrongdoing to the 2006 grand jury in a manner
that precluded his indictment for die serious crimes he committed, including sex trafficking and
sexual assault.
77.
Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein’s
victims and the public, and to provide public disclosure to illuminate whether Epstein received
unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests
immediate access to the testimony, minutes, and other evidence presented in 2006 to die Palm
Beach County grand jury.
78.
In a case ofthis magnitude and importance, where the accused is dead and so many
of his crimes, as well as the identities and crimes of his co-conspirators, and the identities of the
victims have already been exposed, the need for grand jury secrecy is no more. See United States
v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) (“[A]fter the grand jury’s functions are
ended, disclosure is wholly properwhere the ends ofjustice require it.”).
WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla.
Stat: Section 905.27(1) and the Court’s inherent authority, order the State Attorney and the Clerk
of the Court to file with this Court copies of die testimony, minutes, and other evidence presented
in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so
that, following an in camera inspection, it can be made available to The Palm Beach Post and the
CA/ArOftefe°?B^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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public on an expedited basis, and grant any other and further equitable or legal relief the Court
deems just and proper.
Dated: January 17,2020
Respectfully submitted.
GREENBERG TRAURIG, P.A.
Attorneys forCA Florida Holdings, LLC,
Publisher of The Palin Beach Post
Stephen A. Mendelsohn, Esq.
510Q Town Center Circle, Suite 400
Boca Raton, Florida 33486
Telephone: (561) 955-7629
Facsimile: (561) 338-7099
By: A/Stephen A. Mendelsohn_
STEPHEN A. MENDELSOHN
Florida Bar No. 849324
mendelsohns@gtlaw.com
hasenh@gtlaw.com
FLService@gtlaw.com
By: /s/MichaelJGrvsiel_
MICHAEL J GRYGIEL
(Admitted Pro Hac Vice)
54 State St , 6th Floor
Albany, New York 12207
Telephone: (518) 689-1400
Facsimile: (518) 689-1499
grygielm@gtlaw.com
By;
/s/Nina D.Bovajian_
NINA D. BOYAJIAN
(Pro Hac Vice application pending)
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: (310) 586 -7700
Facsimile: (310) 586 -7800
boyajiann@gtlaw.c6m
riveraal@gtlaw.com
22
CA/Arop^jO^I^] BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
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public on an expedit~d basis, and grant any other and finther equitable or l~gal relief the CoUit 
deems j11St and propet. 
Dated: Januaiy 17, 2020 
Respectfully submitted, 
GREENBERG TRA.URIG, 'P.A. 
Attorheys for CA Florida Holdings, LLC, 
Publisher of The Palm Beach Post 
Stephen A Mern;lelsohn, Esq. 
5100 TmV11 Center Cirde, Sltite 400 
Bbca Raton, Florida 33486 
Telephone: (561) 955-7629 
Facsimile: (561) 338~ 7099 
By: Isl Stephen A, Mendelsoh11 
STEPHEN A. (MENDELSOHN 
Fl01ida Bat No. 849324 
111endelsohns@gtlaw.com 
hasenh@gtla,v.com 
FLSeI;Yice@gtl_aw:com 
By: Isl Michael J Grvgiel 
MICHAELJ GRYGIEL 
(Admitted Pro·Hac Vice) 
54 State SL, 6th Floor • 
Albany, New York 12207 
Telephone: (518) 689-1400 
Facsimile: (518) 689-1499 
giy~ielm@itlaw :com 
By: Isl Nina D. Bovahan 
NINA D. BOYAJIAN 
(Pro Hae Vice application.pending) 
i 840 Century Park East, Suite i900 
Los Angeles CA 90067 
Telephone: O 10) 586 -7700 
,Facsimile...

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day ofJanuary, 2020, a copy ofthe foregoing has
been electronically filed with the Florida E-File Portal for e-seivice on all parties ofrecord herein.
/s/ Stevhen A. Mendelsohn_
STEPHEN A. MENDELSOHN
23
CA/AroPteS5°M BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
• 
• 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 17th day of January, 2020, a copy ofthe-fotegoing has 
been electronically filed with the Florida E-File Portal for e-se1vice on all parties.ofrecord herein. 
Isl Stephen A. Mendelsohn 
STEPHEN A. ::tvIENDELSOHN. 
23 
CA/Aro~ffflh?i~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

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EXHIBIT 1
The Newspaper’s Reportage on Jeffrey Epstein
CAWopf^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The Newspaper's Reportage on Jeffrey Epstein 
CA/Arof?fi:m5?~A~¾ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

The Palm Beach Post
_
The Man Who Had Everything: Joffrey Epstein craved big
homes, elite friends and underage girls
By Andrew Marra
Posted Jyl 17,2019 at 6:02 AM
From the archives: When Palm Beach detectives started asking
questions and teenage girls started talking, a wave of legal resistance
followed.
Editor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after
Jeffrey Epstein’s arrest in Palm Beach County on a charge offelony solicitation ofprostitution.
WINGED GARGOYLES guarded the gate at Jeffrey Epstein’s Palm Beach mansion. Inside,
hidden cameras trolled two rooms, while the girls came and went.
For the police detectives who sifted through the garbage outside and kept records ofvisitors, it
was the lair of a troubling target.
Epstein, one ofthe most mysterious ofthe country’s mega-rich, was known as much for his
secrecy as for his love of fine things: magnificent homes, private jets, beautiful women,
friendships with the world’s elite.
But at Palm Beach police headquarters, he was becoming known for something else: the
regular arrival ofteenage girls he hired to give him massages and, police say, perform sexual
favors.
Epstein was different from most sexual abuse suspects; he was far more powerful. He counted
among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
with some of the most prominent legal, scientific and business minds in the country.
When detectives started asking questions and teenage girls started talking, a wave of legal
resistance followed.
CA/Arop^^]^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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The M·an, W,bo l.Had 
1.Eveiyt.hing: .Jeff,rey Epstein icraved b_ig-; 
hontes, ellte ·friends .and underage ;gi·rls 
By Andrew Marrc1 
Po;iefj1Jii7, 20{9 at 6:02AM 
From the archives: When Palm Beach detectives started asking 
questions and teenage girls started talking, a wave of legal resistance 
followed. 
Editor's Note: This artide ap...

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» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work¬
release
If Palm Beach police didn’t know quite who Jeffrey Epstein was, they found out soon enough.
Epstein, now 53, was a quintessential man ofmystery. He amassed his fortune and friends
quietly, always in the background as he navigated New York high society.
When he first attracted notice in the early 1990s, it was on account ofthe woman he was
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
In a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love/ the British
Mail on Sunday tabloid laid out speculative stories that the socialite’s beau was a CIA spook, a
math teacher, a concert pianist or a corporate headhunter.-
"But what is the truth about him?” the newspaper wondered. "Like Maxwell, Epstein is both
flamboyant and intensely private.”
The media frenzy did not begin in full until a decade later. In September 2002, Epstein Was
flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to
Africa on his private jet.
$
Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair
published lengthy profiles. The New York Post listed him as one ofthe city’s most eligible
bachelors and began describing him in its gossip columns with adjectives such as “mysterious”
and “reclusive.”
Although Epstein gave no interviews, the broad strokes ofhis past started to come into focus.
Building a life ofextravagance
He was born blue-collar in 1953, the son of a New York City parks department employee, and
raised in Brooklyn’s Coney Island neighborhood. He left college without a bachelor’s degree
but became a math teacher at the prestigious Dalton School in Manhattan.
The story goes that the father of one of Epstein’s students Was so impressed With the man that
he put him in touch with a senior partner at Bear Stearns, the global investment bank and
securities firm.
CA/Arop^e^0^^^ BEACH COUNTY, ...

In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started}.
Epstein and Co. That is when he began making his millions in earnest.
Little is known or said about Epstein’s business except this: He manages money for the
extremely wealthy. He is said to handle accounts only of SI billion or greater.
It has been estimated he has roughly 15 clients, but their identities are the subject of only
speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a
former Palm Beacher who is said to have been a mentor to Epstein.
Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a
block on Manhattan's Upper East Side. It is reported to have, among its finer features, closed-
circuit television and a heated sidewalk to melt away fallen snow.
That townhouse, thought to be the largest private residence in Manhattan, is only a piece of
the extravagant world Epstein built over time.
In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch
outside Santa Fe. Many believed it to be the largest home in the state.
In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre
private island in the Virgin Islands.
» PHOTOS: The players in the Jeffrey Epstein saga
Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
the highest echelons of power. This includes not only socialites but also business tycoons,
media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often
funds.
"Just like other people collect art, he collects scientists,” said Martin Nowak, who directs the
Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of
a $30 million research donation from Epstein.
Epstein is said to have befriended former Harvard President Larry Summers, prominent law
Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort...

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And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
photographed.
"The odd thing is I never met him,” said Dominick Dunne, the famous chronicler of the trials
and tribulations of the very rich. "I wasn’t even aware of him," except for a Vanity Fair article.;
Epstein’s friendship with Clinton has attracted the most attention.
Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at
an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become
close friends until after Clinton left the Oval Office and moved to New York.
Epstein has donated more than 5100,000 to Democratic candidates’ campaigns, including John
Kerry’s presidential bid, the reelection campaign ofNew Mexico Gov. Bill Richardson and the
Senate bids ofJoe Lieberman, Hillary Rodham Clinton, Christopher Dodd and Charles
Schumer.
Powerful friends and enemies
A Vanity Fair profile found cracks in the veneer of Epstein’s life story. The 2003 article said he
left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange
Commission violation. It also pointed out that Citibank once sued him for defaulting on a S20
million loan.
The article suggested that one of his business mentors and previous employers was Steven
Hoffenberg, now serving a prison term after "bilking investors out ofmore than S450 million
in one ofthe largest Ponzi schemes in American history.”
As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the
man who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less
than Si6,000 in furnishings.
A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
owed him nothing.
» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says
CAZArop^e^O^?^ BEACH COUNTY, FL, JOSEPH ...

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"It’s a bad memory. I would rather not have ever metJeffrey Epstein ,” said Michael Stroll, the
retired former president of Williams Electronics and Sega Corp. “Suffice,it to say I have
nothing good to say about him.”
Among the characteristics most attributed to Epstein is a penchant for women.
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian
model.
"He’s a lot of fun to be with,” Donald Trump told New York magazine in 2002. “It is even said
that he likes beautiful women as much as I do, and many ofthem are on the younger side. No
doubt about it, Jeffrey enjoys his social life.”
Investigation leads to Epstein
Although he was not a frequenter ofthe Palm Beach social scene, he made his presence felt.
Among his charitable donations, he gave $90,000 to the Palm Beach Police Department and
$100,000 to Ballet Florida.
In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a green
Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a
private chef and a small staff stood at the ready. From a window in his mansion, he could look
out on the Intracoastal Waterway and the West Palm Beach skyline; He seemed to be a man
who had everything.
But extraordinary wealth.can fuel extraordinary desires.
» Epstein wants to leaveJail for mansion in sex-trafficking case
In March 2005, a worried mother contacted Palm Beach police. She said another parent had
overheard a conversation between their children.
Now the mother was afraid her 14-year-old daughter had been molested by a man on the
island.
The phone call triggered an extensive investigation, one that would lead detectives to Epstein
but leave them frustrated.
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Palm Beach police and the state attorney’s office have declined to discuss the case. But a Palm
Beach police report detailing the criminal probe offers a window into what detectives faced as
they sought to close in on Epstein.
Detectives interviewed the girl, who told them a friend had invited her to a rich man’s house to
perform a massage. She said the friend told her to say she was 18 if asked. At the house, she
said she was paid $300 after stripping to her panties arid massaging the man while he
masturbated.
Police interview 5 alleged victims
The investigation began in full after the girl identified 'Epstein in a photo as the man who had
paid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift
through it. They set up a video camera to record the comings and goings at his home. They
monitored an airport hangar for signs ofhis private jet’s arrivals and departures.
They quickly learned that the woman who took the 14-year-old girl to Epstein’s house was
Haley Robson, a Palm Beach Community College student from Loxahatchee. Iri a sworn
statement at police headquarters, Robson, then 18, admitted she had taken at least six girls to
visit Epstein, all between the ages of14 and 16. Epstein paid her for each visit, she said.
During the drive back to her house, Robson told detectives, “I’m like a Heidi Fleiss.”
Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls
said they had been instructed to have sex with another woman in front of Epstein, arid one said
she had direct intercourse with him.
In October, police searched the Palm Beach,mansion. They discovered photos ofnaked, young-
looking females, just as several of the girls had described iri interviews. Hidden cameras were
found in the garage area and inside a clock on Epstein’s desk, alongside a girl’s high school
transcript.
Two of Epstein’s former employees told investigators that young-looking girls showed up to
perform massages two...

•
e
One employee told detectives he was told to send a dozen roses to one teenage girl after a high
school drama performance. Others were given rental cars. One, according to police, received a
$200 Christmas bonus.
The cops moved to cement their case. But as they tried to tighten the noose, they encountered
other forces at work.
In Orlando they interviewed a possible victim who told them nothing inappropriate had
happened between her and Epstein. They asked her whether she had spoken to anyone else.
She said yes, a private investigator had asked her the same questions.
» Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal
When they subpoenaed one of Epstein's former employees, he told them the same thing. He
and a private eye had met at a restaurant days earlier to go over what the man would tell
investigators.
Detectives received complaints that private eyes were posing as police officers. When they told
Epstein s local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the
high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
Kennedy Smith.
While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law
professor, traveled to West Palm Beach with information about the girls. From their own
profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
their use of alcohol and marijuana.
He took his research to a meeting with prosecutors in early 2006; where he sought to cast
doubt on the teens’ reliability,
The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
did some of the girls have issues with drugs or alcohol but also some had criminal records and
other troubles, Epstein’s legal team claimed. And at least one ofthem, they said, lied when she
told police she was younger than 18 when she started performing massages for Epstein.
After the meeting, prosecutors postponed their decision to take the case t...

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In the following weeks, police received complaints that two of the victims or their families had
been harassed or threatened. Epstein’s legal team maintains that its private investigators did
nothing illegal or unethical during their research.
By then, relations between police and prosecutors were fraying. At a key meeting with
prosecutors and the defense, Detective Joseph Recarey, the lead investigator, was a no-show,
according to Epsteins attorney.
“The embarrassment on the prosecutor's face was evident when the police officer never
showed up for the meeting," attorneyJack Goldberger said.
Later in April, Recarey walked into a prosecutor’s office at the state attorney’s office and
learned the case was taking an unexpected turn.
The prosecutor, Lanna Belohlavek, told Recarey the state attorneys office had offered Epstein
a plea deal that would not require him to serve jail time or receive a felony conviction.;
Recarey told her he disapproved ofthe plea offer.
The deal never came to pass, however.
Future unclear after charge
On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four
counts ofunlawful sexual activity with, a minor and to charge his personal assistant, Sarah
Kellen, now 27, for her alleged role in arranging the visits. Police .officials also wanted to
charge Robson, the self-described Heidi Fleiss, with lewd and lascivious acts.
By then, the department was frustrated with the way the state attorneys office had handled the
case. On the same day the warrants were requested, Palm Beach Police ChiefMichael Reiter,
wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if
he would not act.
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
the grand jury.
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In the following weeks, police received complaints. that tw() of the victi_nis or thei...

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It is not known how many of the girls testified before the: grand jury. But Epstein’s defense
team said one girl who was subpoenaed - the one who said she had sexual intercourse with
Epstein- never showed up.
The grand jury’s indictment was handed down in July. It was not the one the police
department had wanted.
Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was
charged with one count of felony solicitation of prostitution, which carries a maximum penalty
of five years in prison. He was booked into the Palm Beach. CountyJail earlyJuly 23 and
released hours later.
Epstein’s legal team “doesn’t dispute that he had girls over for massages,” Goldberger said. But
he said their claims that they had sexual encounters with him lack credibility.
“They are incapable of being believed,” he said. “They had criminal records.: They had
accusations of theft made against them by their employers. There was evidence of drug use by
some of them.”
What remains for Epstein is yet to be seen.
The Palm Beach Police Department has asked the FBI to investigate the case. It also has
returned the $90,000 Epstein donated in 2004.
In New York, candidates for governor and state attorney general have vowed to return a total
of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein’s powerful
friends have remained silent as tabloids and Internet blogs feast on the public details ofthe
police investigation.
Goldberger maintains Epstein’s innocence but says the legal team has not ruled out a future
plea deal. He insists Epstein will emerge in the end with his reputation untarnished.
“He will recover from this,” he said.
Staffwriter Larry Keller and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and
Melanie Mena contributed to this story.
amarra@pbpost.com
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It is not known how many of the girls testified before tiie grand...

@AMarraPBPost
KTELUGENT ®MD
i
w«a»ll
CA/Arop$^0^37^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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@AMarra.PBPost 
CA/AropfL~~~A¥M BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

273 / 278 - Tuesday, November 16, 2004
Edition: FINAL
Section: A SECTION
Page: 1A
Source: By PAUL OWERS Palm Beach Post Staff Writer
Illustration: PHOTO (C & 2 B&W) & MAP (B&W)
Memo: Ran all editions.
Dateline: WEST PALM BEACH
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The
Donald was not about to be trumped.
"Nobody was going to outbid me." the brash developer-turned-TV-personality said from his
New York office.
Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot,
seven-bedroom estate on 6 oceanfront acres, along the storied "Raider's Row:."
But Trump, 58, proud possessor ofMar-a-Lago, has no plans to live in the Gosman home at
513 N. County Road. He wants to - what else? - sell it and make more money.
The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super
luxury house" that would be the "finest anywhere in the United States," He might build
another, house before flipping the entire package.
"I've known about this house for quite some time," Trump said. "It's probably the best piece
of land in Florida - and probably the country - for luxury real estate."
Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor
Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith
said she's not worried about Trump's plans.
"He's been a very good property owner in the town of Palm Beach," she said. "He does his
projects very well, He's a perfectionist,"
Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of
Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual
distribution to creditors.
The auction began at exactly noon after Judge Steven Friedman dismissed an objection from
an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully
that Trump was not a qualified bidder because hi...

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But Friedman allowed the offer to stand, and Pulte and Trump went back and forth until
Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at
$38.6 million.
Friedman closed the bidding 10 minutes after it started, leaving Trump with the right to buy
the 29,000-square-foot home (a typical Palm Beach County single-family house is about
2,200 square feet). The property also has a tennis house, a pool house and 193Os-era service
quarters.
The closing could take place within a week but probably won't happen until next month.
Trustee Joe Luzinski and creditors said they were pleased with the outcome.
"We knew we were dealing with some substantial people ... who were going to bid it up a
bit," Luzinski said.
"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.
"In bankruptcy court, the idea is to get the most for creditors, and that's what happened."
The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer
former listing agent Sotheby's International Realty received was $32 million,. Sotheby's won't
receive a commission, he said;
Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday,
"I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said.
Pulte .said Gosman asked him before the auction whether he would be willing to let him stay
in the mansion after the closing until he decides where he wants to move. Trump and
Luzinski said they have had no such discussions with Gosman.
Gosman, 75; had the house built after paying $12.1 million for the land in 1986.
The former health-care magnate declined interview requests before and after the auction
Monday. He was at the courthouse but left before the auction took place.
The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm
Beach home and guest house but fal ls short of the $45 million that Virginia home builder
Dwight Schar pai...

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The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
an ownership interest in his home and other belongings only to avoid losing them in
bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in
1999, well before he filed for bankruptcy.
Lessen is expected to rule in the next two months whether Gosman made improper transfers,
a.decision that will affect how much money will be available to creditors.
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
willing to move forward, in part because the upkeep of the estate now exceeds their means.
"This is hot a happy occasion for them, but at least we're moving to the next.level," Cimo
said. "That's not a house you want to live in unless you're making large amounts of money
like Donald Trump."
paul_bwers@pbpost.com
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The trustee alleged during a week.long trial in May that Gosman fraudulently gave his wife 
an ownership interest in his home and other belongings only-to avoid losing them ih 
bankruptcy. Gosman has denied any wrongdoing, saying he made the pr.operty transfers .in 
1999, well before l1~ filed for bankrµptcy, 
Lessen is, expected to rule in the next two months whether Gosman made improper transfers, 
a.decision that.will affect how much mqney will be availableto creditors. 
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were 
willing to move forward, in part bec~us_e th~ upkeep pfthe est~te IJ.OW e~c~ds their mem_1s. 
"This· is.hot a happy occasion forthem,butat least.we're moving to the next.level," Cimo 
said. "That's nqt a house you want to live in unless you're making largf! amounts ofmoney 
like Donald Trump.'' 
paul ,--owets@pbpost.com 
CNAro-pil,~~~Ai~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 

11/1172019
t: Billionaire Solicited 3 Times - News - The Palm Beach
st Palm Beach, FL
The Palm Beach Post
REALNEWSSTARTSHERE
Indictment: Billionaire Solicited 3 Times
Posted Jul 1, 2008 at 12:01 AM
Updated Oct 2,2019 at 2:30 PM
(EDITOR’S NOTE: This story originally published in The Palm Beach PostonJuly25,
2006)
Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31
of last year, according to an indictment charging him with felony solicitation of
prostitution.
Epstein, 53, was booked at the Palm Beach County jail at 1:45 a.m. Sunday. He
was released on $3,000 bond.
Epstein’s case is unusual in that suspected prostitutionJohns' are usually charged
with a misdemeanor, and even a felony charge is typically made in a criminal
information - an alternative to an indictment charging a person with the
commission of a crime.
His attorney, Jack Goldberger, declined to discuss the charge.
State attorneys office spokesman Mike Edmondson also had little to say.
"Generally speaking, there is a case that has a number of different aspects to it,”
Edmondson said of a prostitution-related, charge-being submitted to a grand jury.
"We first became aware ofthe case months ago by Palm Beach police,”
Prosecutors and police worked together to bring the case to the grand jury, he
said.
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11/1.1/2019 
l.t: 
Billionaire Soliciied 3 Times - News - The Palm Beach .st 
Palm Beach, FL 
lndtctment: Billionaire Solicited 3 Times 
Posted Jul 1, .zoos at 12:01 Afv1 
Updated Oct 2; 2019 at 2:30 PM 
(E.DITORS N.OT.E: This story originczlly published in The Palm Beach Post on July.25, 
2006) 
Billionaire money manager and Palm Beath part-time resident Jeffrey Epstein 
solicited or pro~ured prostitutes three or more dmes b...

11/11/2019
t: Billionaire Solicited 3 Times - News - The Palm Beach P|
fest Palm Beach, FL
Palm Beach police confirmed that and said the department will release a report
today regarding its investigation.
Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a
pool and a boat dock on the Intracoastal Waterway since 1990, according to
property records. A man answering the door there Monday said that Epstein
wasn’t home. A Cadillac Escalade registered to him was parked in the driveway,
which is flanked by two massive gargoyles.
Epstein sued Property Appraiser Gary Nikplits in 2001, contending that the
assessment of his home exceeded its fair market value. He dismissed his lawsuit
in December 2002.
A profile of Epstein in Vanity Fair magazine said he owns what are believed to
be the largest private homes in Manhattan - 51,000 square feet - and in New
Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the
U.S. Virgin Islands and fleet of aircraft.
Epstein's friends and admirers, according to the magazine, include prominent
businessmen, academics and scientists and famed Harvard law professor Alan
Dershowitz.
JarryJcener@pbpost.cQm
https;//www.palmbeachpost.com/news/2008070'l/indictment-billionaire-solicited-3-tirnes
2/2-
CA/ArGffi®
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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11/11/2019 
ln.t: Billionaire Solicjt~d 3 Times-. News - The·PalrTl B_eiic!) P.est Palm Beach, Fl 
Palm Beach police confirmed that and said the department will release a report 
today regarding its investigation. 
Epstein has owned a five..,bedroom, 71/2.C.:bath, 7,234-square-foot home With a 
pool at1d a boat dock on the Intracoastal Waterway since 1990, according to 
property records. A man answering the door there Monday said that Epstein 
wasn't home. A Cadilla<= Escal;i.de registered to him was parked in ~he driyeway, 
which is flanked. by twp massive gargoyles. 
:Ep_stejn sueq. Prop~_rty Apprc!i.ser Gary Nik<:...

11/11/2019
After
billionaire faces solicitation charge - News - The Palm Be
st - West Palm Beach, FL
The Salm Beach Post
WEMME
After long probe, billionaire faces solicitation
charge
Posted Jul 27,2006.at 12:01 AM
Updated Oct 3,2019 at 3:11 PM
(EDITOR’S NOTE: This story originally published in The Palm Beach Post onJuly 26,
2006)
Palm Beach billionaireJeffrey Epstein paid to have underage girls and young
women brought to his home, where he received massages and sometimes sex,
according to an investigation by the Palm Beach Police Department.
Palm Beach police spent months sifting through Epstein's trash and watching his
waterfront home and Palm Beach International Airport to keep tabs on his
private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
him with one count of felony solicitation of prostitution.
Palm Beach police thought there was probable cause to charge Epstein with
unlawful sex acts with a minor and lewd and lascivious molestation.
Police Chief Michael Reiter was so angry with State Attorney Barry Krischer’s
handling of the case that he wrote a memo suggesting the county’s top
prosecutor disqualify himself.
"I must urge you to examine the unusual course that your office’s handling of this
matter has taken and consider if good and sufficient reason exists to require your
disqualification from the prosecution of these cases,” Reiter wrote in a.May 1
memo to Krischer.
While not commenting specifically on the Epstein case, Mike Edmondson,
spokesman for the state attorney, said his office presents cases Other than
murders to a grand jury when there are questions about witnesses’ credibility and
their ability to testify.
https://www.palmbeachpostcom/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
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After Ion.: billionaire faces solicitation·charg_e - News - The Palm B.sl - West Palm Beach, FL 
After tong probe,...

11/11/2019
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billionaire faces solicitation charge - News - The Palm B
st - West Palm Beach, FL
By the nature of their jobs, police officers look at evidence from a "one-sided
perspective,” Edmondson said. “A prosecutor has to look at it in a much broader
fashion,” weighing the veracity ofwitnesses and how they may fare under
defense attorneys' questioning, he said.
Epstein’s attorney, Jack Goldberger, said his client committed no crimes.
"The reports and statements in question refer to false accusations that were not
charged because the Palm Beach County state attorney questioned the credibility
of the witnesses,” Goldberger said., A county grand jury "found the allegations
wholly unsubstantiated and riot credible,” and that’s why his client was riot
charged with sexual activity with minors, he said.
Goldberger said Epstein passed a lie detector test administered by a reputable
polygraph examiner in which he said he did not know the girls were minors.
Also, a search warrant served ori Epstein's home found no evidence to
corroborate the girls' allegations, Goldberger said.
According to police documents:
- A Palm Beach Community College student said she gave Epstein a massage in
the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged
sessions at his home.
- A 27-year-old woman who worked as Epstein's personal assistant also
facilitated the liaisons, phoning the PBCC student to arrange for girls when
Epstein was coming to town. And she escorted the girls upstairs when they
arrived, putting fresh sheets ori a massage table arid placing massage oils nearby.
- Police took sworn statements from five alleged victims arid 17 witnesses. They
contend that on three occasions, Epstein had sex with the girls.
A money manager for the ultra-rich, Epstein was named one of New York’s most
eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with
the likes of former President Clinton, former Harvard University President
Lawrence Summe...

11/11/2019
After Ione
billionaire faces solicitation charge - News - The Palm B©
st - West Palm.Beach, FL
He has contributed tens of thousands ofdollars to Democratic Party candidates
and organizations, including Sen. John Kerry s presidential bid, and the Senate
campaigns ofJoe Lieberman, Hillary Clinton, Christopher Dodd and Charles
Schumer.
Goldberger is one of five attorneys Epstein has retained since he became the
subject of an investigation, Edmondson said. Among the others: Alan
Dershowitz, the well-known Harvard law professor and author, who is a friend
ofEpstein. Dershowitz could not be reached for comment.
Police said the woman who enlisted young girls for Epstein was Haley Robson,
20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in
Wellington and said she was a journalism major at Palm Beach Community
College when she was questioned by police last October. She has an unlisted
phone number and could not be reached for comment.
Robson said she met Epstein when, at age 17 , a friend asked her ifshe would like
to make money giving him a massage, She said she was driven to his five-
bedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs
to a bedroom with a massage table and oils. Epstein and Robson were both naked
during the massage, she said, but when he grabbed her buttocks, she said she
didn't want to be touched.
https://www.paimbeachpost.com/news/20Ci60727/after-long-probe-biillonaire-faces-soiicitation-charge
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After Ion •. 
biilionaire faces· solicitation charge - News - The Palm B.st • West Palm.Beach, FL 
He has contributed.tens of thousandsofdoliars to Democratic Pai;ty candidates 
and organizations, including Sert. John Kerry's presidential bid, and the Senate 
campaigns ofJoe Lieberman; Hillary Clinton, Christopher Dodd and Charles 
Schumer. 
Goldberger is one of five attonieys Epstein has retained...

11/11/2019
After ton.
; billionaire faces solicitation charge - News - The Palm
st - West Palm Beach, FL
Epstein said he’d pay her to bring him more girls - the younger the better,
Robson told police. When she tried once to bring a 23-year-old woman to him,
Epstein said she was too old, Robson said.
Robson, who has not been charged in the case, said she eventually brought six
girls to Epstein who were paid $200 each time, Robson said. ’Till like a Heidi
Fleiss,” police quoted her as saying. The girls knew what to expect when they
were taken to Epstein’s home, Robson said. Give a massage - maybe naked - arid
allow some touching.
One 14-year-old girl Robson took to meet Epstein led police to start the
investigation of him in March 2005. A relative of the girl called to say she
thought the child had, recently engaged in sex with a Palm Beach man. The girl
then got into a fight with a classmate who accused her of being a prostitute, and
she couldn’t explain why she had $300 in her purse.
The girl gave police this account ofher meeting with Epstein:
She accompanied Robson and a second girl to Epstein's house oil a Sunday in
February 2005. Once there,, a woman she thought was Epstein’s assistant told the
girl to follow her upstairs to a room featuring a mural of a naked woman, several
photographs of naked women on a shelf, a hot pink and green sofa and a massage
table.
She stripped to her bra and parities and gave him a massage.
Epstein gave the 14-year-old $300 and she and the other girls left, she said. She.
said Robson told her that Epstein paid her $200 that day.
Other girls told similar stories. In most accounts, Epstein's personal assistant at
the time, Sarah Kellen, now 27, escorted the girls to Epstein’s bedroom.
Kellen, whose most recent known address is in North Carolina, has not been
charged in the case.
Palm Beach police often conducted surveillance of Epstein’s home, and at Palm
Beach International Airport to see if his private jet was there, so they would
kn...

11/11/2019
After Ione
, billionaire faces solicitation charge - News -The Palm B
st - West Palm Beach, FL
from Palm Beach sanitation workers, collecting papers with names and phone
numbers, sex toys and female hygiene products.
One note stated that a female could not come over at 7 p.m. because of soccer.
Another said a girl had to work Sunday - "Monday after school?” And still
another note contained the work hours of a girl, saying she leaves school at 11:30
a.m, and would come oyer the next day at 10:30 a,m.
Only three months before the police department probe began, Epstein donated
$90,000 to the department for the purchase of a firearms simulator, saidJane
Struder, town finance director. The purchase was never made. The money was
returned to Epstein on Monday, she said.
https:7/www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
CA/Ar°Pte?j:TOj?l BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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11/11/2019 
After Ion •. 
billionaire faces solicitation charge - News -The Palm B.st - West Palm Beach, FL 
from Palm Beach s~nitation w9rkers, collecting pa.pers with na111es a_nd phone 
numbers, s~xt9ys and, fema.le hygie_ne pr:oducts. 
One note stated that a female could not come _over at 7 p.m. because of soccer. 
Another said a ~irl had to work Sut1day "" ''Monday after school?" And still 
another note contained the work hours ofa girl, saying she leaves school at 11 :30 
a.m, and would come over the next day at 10:30 a.m. 
Only three months before the police department probe began, Epstein donated 
$90,000 to the dep;3.rtment for th~ purchase of a firearms simlllator, saidja.ne 
Struder, toW11 financ:e directqr, The p~rchase wa.s never ma<ie. The money wa.s 
returned to Epstein on Monday, she said, 
https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge 
CA/Arcpfl~\b?~Ai¾ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1 :04:39 PM 
5/5 

11/11/2019
Poliw
wyer tried to discredit teenage girls - News - Palm BeachV
ews - Palm Beach, FL
Palm Beach DailyNews
Police say lawyer tried to discredit teenage
girts
Posted Jul 29,2006 at 12:01 AM
Updated Oct 3,2019 at 2:00 PM
(EDITORS NOTE: This story originally was published in The Palm Beach Post on July
29, 2006)
Famed Harvard law professor Alan Dershowitz met with the Palm Beach County
State Attorney's Office and provided damaging information about teenage girls
who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually
charged massages, according to police reports.
The reports also state that another Epstein attorney agreed to a plea bargain that
would have allowed Epstein to have no criminal record. His current attorney
denies this happened.
And the documents also reveal that the father of at least one girl complained that
private investigators aggressively followed his car, photographed his home and
chased offvisitors.
Police also talked to somebody who said she was offered money if she refused to
cooperate with the Palm Beach Police Department probe of Epstein.
The state attorney’s office said it presented the Epstein case to a county grand
jury this month rather than directly charging Epstein because of concerns about
the girls’ credibility. The grand jury indicted Epsteihj 53, on a single count of
felony solicitation of prostitution, which carries a maximum penalty of five years
in prison.
Police believed there was probable cause to charge Epstein with the more serious
crimes ofunlawful sex acts with a minor and lewd and lascivious molestation.
Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
Krischer a memo in May suggesting he disqualify himself from the case.
https://www.palrnbeachdailynews.eom/article/20060729/NEWS/190917573
CA/ArOf41WM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
NOT A CERTIFIED COPY
11/i1/2019 
Poli.wyer tried to discredit teenage giris • News - Palm Bea·ch .ews ~ Pc...

11/11/2019
Polia
wyer tried to discredit teenage girls - News - Palm Beach
ews - Palm Beach, FL
The case originally was going to be presented to the grand jury in February, but
was postponed after Dershowitz produced information gleaned from the Web
site myspace.com showing some ofthe alleged victims commenting on alcohol
and marijuana use, according to the police report prepared by Detective Joseph
Recarey.
Haley Robson, a 20-year-old Royal Palm Beach woman who told police she
recruited girls for Epstein, also is profiled on myspace.com. Her page includes
photos of her and her friends, including one using the name ''Pimpin’ Made EZ.”
Robson, who was not charged in the case, is a potential prosecution witness.
According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with
Epstein, accepted the deal, in which Epstein would plead guilty to one count of
aggravated assault with intent to commit a felony, be placed on five years’
probation and have ho criminal record. The deal also called for Epstein to submit
to a psychiatric and sexual evaluation and have no unsupervised visits with
minors, according to Recarey’s report. The plea bargain was made in connection
with only one of the five alleged victims, the report states,
Fronstin - who declined to comment on the case - was subsequently fired and
veteran defense attorneyJack Goldberger was hired. He denies there was any
agreement by any ofEpstein’s attorneys to a plea deal.
“We absolutely did hot agree to a plea in this case,” he said. Neither Belohlavek
nor a state attorney's spokesman could be reached for comment?
The parent or parents of alleged victims who complained of being harassed by
private investigators provided license tag numbers oftwo ofthe men. Police
found the vehicles were-registered to a private eye in West Palm Beach and
another in Jupiter, according to Recarey’s report.
"I have no knowledge of it,” defense, at...

11/11/20,19
Polic^
awyer tried to discredit teenage girts - News - Palm Beach#
ews - Palm Beach, FL
who did talk "will be dealt with,” the woman said she was told. Phone records
show the woman talked with the person who allegedly intimidated her around
the time she said, Recarey reported.
Phone records also show that the person said to have made the threat then
placed a call to Epstein's personal assistant, who in turn called a New York
corporation affiliated with Epstein, the report states.
The issue in the Epstein case is not whether females came to his waterfront
home, but whether he knew their ages.
“He’s never denied girls came to the house,” Goldberger said. But when Epstein
was given a polygraph test, “he passed on knowledge of age,” the attorney said.
After the indictment against Epstein was unsealed this week, Police Chief Reiter
referred the matter to the FBI. "We've received the referral, and were reviewing
it,” said FBI spokeswoman Judy Orihuela in Miami.
The chief himself has come under attack from Epstein s lawyers and friends in
New York, where he has a home. The New York Post quoted Epstein’s
prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
only "because ofthe craziness of the police chief
”
Reiter has declined to comment on the case.
Prosecutors have not presented a sex-related case:like Epstein's to a grand jury
before, said Mike Edmondson, spokesman for the state attorney’s office. “That’s
what you do with a case that falls into a gray area,” he said.
The state attorney’s office did not recommend a particular criminal charge on
which to indict, Epstein, Edmondson said. The grand jury was presented with a
list of charges from highest to lowest, then deliberated with the prosecutor out of
the room, he said.
“People are surprised at the grand jury proceeding,” West Palm Beach defense
attorney Richard Tendler said. “It’s a way for the prosecutor’s office to not take
the full responsibility for hot filing the (charge), and ...

11/11/2019
Polic^^^wy
er tried to discredit teenage girls - News - Palm Beache
ews- Palm Beach, FL
Defense attorney Robert Gershman was a prosecutor for six years. "Those girls
must have been incredible or untrustworthy, I don’t know," he said.
Other attorneys said Epstein’s case raises the issue ofwhether wealthy, connected
defendants like Epstein - whose friends include former President Clinton and
’
Donald Trump - are treated differently from others. Once he knew he was the
;
subject of a criminal probe, Epstein hired a phalanx ofpowerful attorneys such as
i
Dershowitz and Lefcourt, who is a past president of the National Association of
;
Criminal Defense Lawyers.
*
Miami lawyer Roy Black - who became nationally known when he successfully
j
defended William Kennedy Smith on a rape charge in Palm Beach - also was
j
-
4
involved at one point.
j
Said defense attorney Michelle Suskauer: "I think it’s unfortunate the public may
j
get the perception that with power, you may be treated differently than the
i
averagejoe.”
1
I
i
https://wwW.palmbeachdaiiynews.com/article/2b060729/NEVVS/i9d917573
4/4
CA/Arop^e^0^, BEACH C0UNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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1i/ili2019 
Poli.er tried.to ciiscreci1i teenage gfrls - News - Palm Beach .ews•- Palm Beifch, FL 
D.efense attorney Robert Gershman was a prosecutor for six years. "Those girls 
must have. been incredible 6r untrustworthy, I don't know," he said. 
Other attorneys said Epstein's case raises the issue of whether wealthy, connected 
defendants like Epstein - whose friends include former P·resident Clinton ;md 
Donal.cl Trump - are treated dl.fferently from others. Once he knew he was. the 
subject of a. criminal probe, Epstein hired a phalanx of powerful attorneys such as 
Dershowitz and Lefrourt, who is a past president of the National Association of 
Criminal Defense Lawyers. 
Miami lawyer Roy Black - who became nationally known when he successfully 
defended William Kennedy Smith ...

The Palm Beach Post
SEAL NEWSSTARTSHERE
Expert: Ignorance of age isn’t
defense iii sei cases
Posted Aug 5,2006 at 12:01 AM
Updated Oct 3,2019 at 1:38 PM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on Aug. 5,2006)
Even if Palm Beach money managerJeffrey Epstein didn’t
know that girls who police sav gave him sexual massages at
his Intracoastal home were under the legal age, that alone
wouldn’t have exempted him from criminal charges of
sexual activity with minors.
"Ignorance is not a valid defense,” said Bob Dekle, a legal
skills professor who was a Lake City prosecutor for nearly
30 years, half ofthat,time specializing in sex crimes against
children.
"There is no knowledge element as far as the age is
concerned,” Dekle said.
After an 11-month investigation, Palm Beach police .said
there was probable cause to charge Epstein, 53, with
unlawful sex acts with a minor and lewd and lascivious
molestation. They contend that Epstein - friend of the rich
and famous and financial patron of Democratic Party
organizations and candidates - committed those acts with
five underage girls.
In the past week, New York Attorney General and
gubernatorial candidate Eliot Spitzer has returned about
$50,000 in campaign contributions he received from
Epstein, and Mark Green, a candidate to replace Spitzer iri
CA/Arop^jO^^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
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Ji_1n:r.t,: lg11ora.1icJQ of i3gQ;, isutt 
·:delenscr:: ltt se1c eases 
Posted Aug 5, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 1 :38 PM 
(EDiTOR'S NOTE: Thi_s story originaJly publishe_d in The 
Palm Beach Post on Aug. 5; 2006) 
Even if Palm Beach money manager J effre'y Epstein didn't 
know t_hat_ girls whq police say gav~ hi!n- s~xual ma,ssages at 
his Intracoastal home were :under the legaf age, that alone 
wouldn'.t have exempted him from criminal charges of 
sexual activity with minors; 
'!Ignorance is not a v~lid.defense," said Uob Dekle, a iegal 
skills profe...

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