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ACTIVE 696232185v3 
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. 
JOSEPH ABRUZZO, as Clerk and 
Comptroller of Palm Beach County, Florida, 
Defendant. 
CASE NO.: 50-2019-CA-014681-XXXX-
MB Div.: AG 
SECOND AMENDED COMPLAINT 
CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Second Amended 
Complaint against Joseph Abruzzo, the Clerk of the Court and Comptroller for Palm Beach 
County, Florida, in his official capacity (“Court Clerk”), alleges as follows: 
JURISDICTION 
1.
This is an action within the exclusive jurisdiction of the Circuit Court 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 Joseph Abruzzo is the duly elected Clerk and Comptroller of Palm
Beach County, Florida.  He is sued herein in his official capacity as his office is in possession 
and/or control of documents that are the subject of this action. 
Filing # 198551891 E-Filed 05/17/2024 11:40:36 AM
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 05/17/2024 11:40:36 AM 
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INTRODUCTION 
4. 
In what is now widely if belatedly recognized as a colossal miscarriage of justice – 
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.  
5. 
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 
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 furthering justice, which can encompass furthering a public interest. Fla. Stat. 
§ 905.27(1)(c). 
6. 
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.  
To the contrary, transparency is required to promote public understanding of the criminal justice 
system and public confidence in the fair administration of justice. As detailed below, Epstein was 
accused of sexually abusing and trafficking dozens of women and girls in south Florida (a...

 
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to obstruct the administration of justice at every turn. Public disclosure 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 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 Beach Police 
Chief – treatment, are exposed and held accountable. From what limited information is now in the 
public domain, the State Attorney’s referral of Epstein’s case to the grand 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 of Epstein’s sex trafficking.  Access to 
the grand jury materials will allow the public to determine whether the grand jury 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 of Epstein’s 2006 grand jury proceedings. 
FACTUAL BACKGROUND 
7. 
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. 
8. 
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...

 
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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. 
9. 
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. 
10. 
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 
numbers of nude photos of girls, including victims whom the police had not interviewed in the 
course of their investigation. 
11. 
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. 
12. 
Another grand jury 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. 
13. 
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 
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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. (Emphasis supplied) 
14. 
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, and requested 
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 Jury Presentation. 
15. 
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. 
16. 
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. 
17. 
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.  
18. 
No reasonable explanation has been provided as to why the numerous other known 
victims were not presented as witnesses and crime victims to the grand jury 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. 
19. 
On information and belief, during the grand jury appearance of the single victim 
who testified, the State Attorney presented evidence that vilified the v...

 
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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.  
(3) 
The FBI’s Investigation and Epstein’s Non-Prosecution 
Agreement With Federal Authorities. 
20. 
On information and belief, following the deficient July 2006 indictment, and with 
Chief Reiter’s encouragement, the FBI began its own investigation of Epstein.   
21. 
Records unsealed in 2015 revealed that the FBI compiled reports on “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. 
22. 
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.  
23. 
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. 
24. 
On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of 
prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was 
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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. 
25. 
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.  
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. 
26. 
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 on “work release” for up to 
12 hours a day, 6 days a week. His private driver provided his transportation to and from “work.”  
27. 
Epstein was released five months early. 
28. 
Upon information and belief, Epstein violated the terms of his probation, but was 
not prosecuted. 
(4) 
The Crime Victims’ Rights Act Litigation. 
29. 
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. 
30. 
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. 
31. 
Following publicity exposing the extraordinary leniency of the plea deal, dozens of 
civil suits ...

 
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32. 
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.”  
33. 
Upon information and belief, during the course of the Town of Palm Beach and FBI 
investigations, Epstein retained private investigators to follow, harass, and photograph his victims 
and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated 
the case against Epstein.  
34. 
Upon information and belief, Epstein’s victims were threatened against cooperating 
with law enforcement and told that they would be compensated only if they did not cooperate with 
law enforcement. 
B. 
Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019. 
35. 
On July 6, 2019, Epstein was arrested on federal sex trafficking charges.  
36. 
Upon information and belief, the United States government’s investigation of new 
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. 
37. 
In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the 
Southern District of New 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 if allowed to remain out on bail, 
the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this 
case, including victims and their families, and otherwise attempt to obstruct justice.”  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 p...

 
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were found with handwritten labels including the descriptions: “Young [Name] + [Name],” “Misc 
nudes 1,” and “Girl pics nude.” 
38. 
On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney’s 
office for the Southern District of New 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. 
39. 
Epstein was denied bail and was placed into pretrial detention at the federal 
Metropolitan Correction Center in lower Manhattan.  
40. 
On or about August 6, 2019, Florida Gov. Ron 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. 
41. 
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: Epstein’s Victims Speak. 
42. 
On account of his death, prosecutors sought to dismiss the indictment against 
Epstein, while maintaining that they would continue to investigate his co-conspirators. 
43. 
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. 
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44. 
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. 
45. 
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 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.” 
46. 
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.  
47. 
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.” 
48. 
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 racket...

 
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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.” In 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. 
D. 
The Palm Beach Post’s Standing and the Public Interest. 
(1) 
The Palm Beach Post Has Reported Extensively On 
Epstein’s Crimes For Nearly 15 Years. 
49. 
Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm 
Beach County and the Treasure Coast vicinity. 
50. 
The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist 
three other times. 
51. 
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-conspirators.  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 
complain...

 
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• 
“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 “43,000-square-foot, 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, 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 of last 
year, according to an indictment charging him with felony solicitation of prostitution.”  
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 commission 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 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 “[...

 
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• 
“Delays In Epstein Case Unusual, Lawyers Say” published on March 13, 2007, 
reporting that “[n]early eight months after Palm Beach tycoon Jeffrey Epstein was 
charged with felony solicitation of prostitution, there has been no discernible progress 
in his case.” 
• 
“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 her 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 of prostitution and procuring a person under 
the age of 18 for prostitution,” resulting in “a lifelong obligation to register as a sex 
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 grand jury.” 
• 
“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 [non-prosecution] 
agreement [NPA] with federal prosecutors unsealed” and were moving to unseal the 
agreeme...

 
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• 
“Judge Rules Epstein Attorneys Can Subpoena Abortion Records” published on 
January 27, 2010, reporting that “a judge . . . gave lawyers representing multi-
millionaire 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.” 
• 
“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’ of victims of convicted 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 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 the Southern District 
of New York in which he “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 and Manhattan.” 
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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 of judicial 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 1269, 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. of Albemarle, Va., 524 F.3d 485, 492 (4th Cir. 2008) (providing that a plaintiff 
has “standing to assert a right to receive speech” by “show[ing] that there exists a speaker willing 
to convey the information to her”).  
54. 
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’t of Corr. 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 grand jury materials because such materials are “public records 
to which the public may seek access, even if that effort is ultim...

 
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Gainesville Woman Care, LLC v. State of Florida, 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). 
56. 
The Palm Beach Post has the right to maintain this private right of action because 
the furtherance of justice, 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 expressed in Fla. Stat. § 905.27 that the legislature in amending Fla. 
Stat. § 905.27(1)(c) and (2)(c) in 2024, intended for this to disclose the Jeffrey Epstein grand jury 
materials. In other words, the legislature cleared all arguments against release of the Jeffrey Epstein 
grand jury materials.  
(3) 
The Court’s Jurisdiction To Declare Rights And 
Construe Statutes. 
57. 
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.  
58. 
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 (“Any person…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 any part thereof, and obtain a declaration of rights, status, or other equitable 
or legal relations thereunder.”). 
59. 
The Court’s exercise of its power to declare rights “is to be liberally administered 
and construed.” Florida Stat. Section 86.101. 
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COUNT I 
(Declaratory Relief - Florida Stat. Sections 86.011 et seq.) 
60. 
The allegations set forth in paragraphs 1 through 59 are incorporated by reference 
as if fully set forth herein. 
61. 
This is an action for Declaratory Relief pursuant to Chapter 86, Florida Statutes, 
and other supplemental relief. 
62. 
The Palm Beach Post respectfully requests that the Court declare pursuant to Fla. 
Stat. Sections 905.27(1) and (2)(c) that it is entitled access to the testimony, minutes, and other 
evidence presented in 2006 to the Palm Beach County grand jury because such disclosure and 
access would be furthering justice in the public interest. Fla. Stat. § 905.27(1)(c).  
63. 
The Palm Beach Post has sought access to the testimony, minutes, and other 
evidence presented in 2006 to the Palm Beach County grand jury. A good-faith dispute exists. 
64. 
Through this Complaint, The Palm Beach Post presently has a justiciable question 
concerning its rights to obtain the 2006 grand jury materials pursuant to Fla. Stat. Sections 
905.27(1) (c) and (2)(c).  
65. 
In an appeal from the final judgment entered on December 21, 2022 in this case, 
the Fourth District Court of Appeal reversed the trial court’s decision that Florida courts lack 
authority to order the release of grand jury materials. Rejecting the trial court’s determination, the 
appellate court held that trial courts have inherent authority over grand juries and have the right to 
order release of grand jury materials if such would further justice as defined in Fla. Stat. section 
905.27. CA Fla. Holdings, LLC v. Aronberg, 360 So. 3d 1149 (Fla. 4th DCA 2023). Therefore, this 
court has inherent authority to release the Epstein grand jury materials in addition to the statutory 
authority granted by the 2024 amendments to Fla. Stat. section 905.27.     
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66. 
A bona fide, actual, present, and practical need for the declaration exists in order to 
further justice in the public interest by the release of the 2006 Epstein grand jury materials. 
WHEREFORE, The Palm Beach Post respectfully requests that the Court determine the 
rights and obligations of the parties by declaring that pursuant to Fla. Stat. Sections 905.27(1)(c) 
and (2)(c). The Palm Beach Post and the public may gain access to the testimony.  
COUNT II 
(Florida Stat. Section 905.27) 
67. 
The allegations set forth in paragraphs 1 through 66 are incorporated by reference 
as if fully set forth herein. 
68. 
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 2006 State Attorney for Palm Beach 
County, Barry Krischer, presented truncated evidence of Epstein’s criminal wrongdoing to the 
2006 grand jury in a manner that precluded Epstein’s indictment for the serious crimes he 
committed, including sex trafficking and sexual assault. 
69. 
Pursuant to Florida Stat. Section 905.27, as amended in 2024, in order to further 
justice for Epstein’s victims and the public, and to provide public disclosure to illuminate whether 
Epstein received unjustifiably lenient treatment based on the available evidence, The Palm Beach 
Post requests that it and the public be granted immediate access to the testimony, minutes, and 
other evidence presented in 2006 to the Palm Beach County grand jury.  
70. 
In 2024, the Florida legislature amended Fla. Stat. Sections 905.27 (1)(c) and (2)(c) 
for the express purpose of removing all legal impediments to the release of the Jeffrey Epstein 
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grand jury materials. Therefore, other than for limited redactions to protect witness and victim 
identities, Fla. Stat. Sections 905.27 (1)(c) and (2)(c) compel disclosure of the Epstein 2006 grand 
jury materials.  
WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla. 
Stat. Sections 905.27(1)(c) and (2)(c), as amended, order the Clerk of the Court to provide 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, 
these materials are immediately disclosed to the newspaper, and grant any other and further 
equitable or legal relief the Court deems just and proper. 
Dated: May 17, 2024 
Respectfully submitted, 
GREENBERG TRAURIG, P.A. 
Attorneys for 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/ Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
Florida Bar No. 849324 
mendelsohns@gtlaw.com   
rita.curran@gtlaw.com 
FLService@gtlaw.com 
By: /s/ Michael J Grygiel 
MICHAEL J GRYGIEL 
(Pro Hac Vice application forthcoming) 
54 State Street, 6th Floor 
Albany, New York 12207 
Telephone: (518) 689-1400 
Facsimile: (518) 689-1499 
grygielm@gtlaw.com 
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Nina D. Boyajian 
NINA D. 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.com  
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The Palm Beach Post 
REAL NEWS STARTS HERE 
The Man Who Had Everything: Jeffrey Epstein craved big 
homes, elite friends and underage girls 
By Andrew ~~E~~ 
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 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 of felony solicitation of prostitution. 
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 of visitors, 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 of teenage 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. 

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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 of mystery. 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 of the 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 of extravagance 
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 
...

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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 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. 
W exner 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, Dona...

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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 $100,000 to Democratic candidates' campaigns, including John 
Kerry's presidential bid, the reelection campaign of New Mexico Gov. Bill Richardson and the 
Senate bids of Joe 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 $20 
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 of more than $450 million 
in one of the 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 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, officia...

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"It's a bad memory. I would rather not have ever met Jeffrey 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 of them 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 $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 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. 

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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 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, 'Tm 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, 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 of Epstein's former employees told investigators that young-looking gi...

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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 
•••••••--••-· .. ••••u••••-•-.. ·-·•••••••• •••--•••-··- ••••••- ·••-•••••••••••••- •• 
' •••• •••••·•·•·••--•·-•·-••••••••·•• .. ••-•O-••·••H·• •••••·••••••-•+0-00 J•·•••••·••·••••-••-•••-- ••00-fl-••••••••••-.•••-••••-••-• 
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 r...

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In the following weeksi 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 theni relations between police and prosecutors were fraying. At a key meeting with 
prosecutors and the defensei Detective Joseph Recarey, the lead investigator, was a no-showi 
according to Epstein's attorney. 
"The embarrassment on the prosecutor's face was evident when the police officer never 
showed up for the meeting/' attorney Jack Goldberger said. 
Later in Aprili Recarey walked into a prosecutor's office at the state attorney's office and 
learned the case was taking an unexpected turn. 
The prosecutori Lanna Belohlaveki told Recarey the state attorney's 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 of the plea offer. 
The deal never came to passi however. 
Future unclear after charge 
On May 1 i 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 assistanti Sarah 
Kellen, now 27i for her alleged role in arranging the visits. Police officials also wanted to 
charge Robsoni the self-described Heidi Pleiss, with lewd and lascivious acts. 
By theni 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 lateri Recarey was told that prosecutors had decided once again to take the case to 
the grand jury. 

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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 County Jail early July 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 tl}e public details of the 
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. 
Staff writer 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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@AMarraPBPost 
LEARN MORE 

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273 I 278 - Tuesday, November 16, 2004 
Edition: FINAL 
Section: A SECTION 
Page: lA 
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 of Mar-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 unsuccessfull...

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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 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, 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 falls short of the $45 million th...

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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 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 of money 
like Donald Trump." 
paul_ owers@pbpost.com 

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11/11/2019 
Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post- West Palm Beach, FL 
The Palm Beach Post 
REAL NEWS STARTS HERE 
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 Post on July 25, 
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 
oflast 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 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 of different aspects to it," 
Edmondson said of a prostitution-related charge being submitted to a grand jury. 
"We first became aware of the 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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Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West 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 Nikolits 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. 
larry _keller@pbpost.com 
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11/11/2019 
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL 
The Palm Beach Post 
REAL NEWS STARTS HERE 
After Io n g p r o be, b i 11 ion air e faces so Ii c it at i o n 
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 Beadi Post on July 26, 
2006) 
Palm Beach billionaire Jeffrey 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. 
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After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - 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 of witnesses 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-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 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 of former President Cl...

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11/11/2019 
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL 
He has contributed tens of thousands of dollars to Democratic Party candidates 
and organizations, including Sen. John Kerry's presidential bid, and the Senate 
campaigns of Joe 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. 
https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge 
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After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - 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. 'Tm like a Heidi 
Pleiss," 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-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 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 and 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 Airpo...

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11/11/2019 
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - 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 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, said Jane 
Struder, town finance director. The purchase was never made. The money was 
returned to Epstein on Monday, she said. 
https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge 
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Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL 
Palm Beach Daily News 
Police say lawyer tried to discredit teenage 
girls 
Posted Jul 29, 2006 at 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 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 off visitors. 
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 Epstein, 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 of unlawful 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.palmbeachdailynews.com/article/20060729/NEWS/190917573 
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11/11/2019 
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - 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 of the 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 "Pim pin' 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 of the five alleged victims, the report states. 
Fronstin - who declined to comment on the case - was subsequently fired and 
veteran defense attorney Jack 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, acco...

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11/11/2019 
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - 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 we're 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 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 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 ta...

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11/11/2019 
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - 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 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 of powerful attorneys such as 
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 
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." 
htlps://www.palmbeachdailynews.com/article/20060729/NEWS/190917573 
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The Palm Beach Post 
REAL NEWS STARTS HERE 
Expert: Ignorance of age isn't 
defense in sex 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 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 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 in 

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his current job, has returned $10,000 to him because of the 
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 of prostitution. 
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 of prosecuting child sex abuse cases, 
especially when the defendant is enormously wealthy and 
can hire high-priced, top-tier lawyers. 
At least one of Epstein's alleged victims told police he knew 
she was underage when the two of them got naked for 
massages and 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 happen, 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 of what 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 attorney Jack 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. 

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"A prosecutor has to look at it in a much broader fashion," a 
state attorney's spokesman said last week. 
MlithlhM·1ilM 
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. 
If two 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. 

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Still there is a "universal constant" in prosecuting these 
cases, Dekle said. Men who 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 of child sexual abuse victims have been victimized by 
multiple people over a period of time. 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 
$200 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 telling the 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." 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
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 financier Jeffrey 
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 between Jeffrey 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 not 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 of felony solicitation of prostitution. 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 

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Epstein on the less serious charge1 Police Chief Michael 
Reiter referred the case to the FBI to determine whether 
there were federal law violations. 
After a spate of stories about the case last week1 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 not respond to a request for comment Monday. 
The implication that State Attorney Barry Krischer was 
easy on Epstein by presenting the case to a grand jury 
rather than filing charges directly against him is wrong, 
Goldberger said. 

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The Palm. Beach Police Department was "happy and 
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 if good and sufficient reason exists to 
require your disqualification from. the prosecution of these 
" 
cases. 
Rather than flat-out 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 of drug abuse and thefts. "These worn.en 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 worn.en to com.e forward and m.ake these allegations," 
Goldberger said. 

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The Palm Beach Post (West Palm Beach, Florida)· 14 Aug 2006, Mon· Page 7 
Downloaded on Nov 11, 2019 
Reiter focus of fire 1n Epstein case 
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The Palm Beach Post 
REAL NEWS STARTS HERE 
Delays in 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 of prostitution, 
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 of Epstein 
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. 

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"Highly unusual" is how Palm Beach Police Chief Michael 
Reiter described State Attorney Barry Krischer' s handling 
of the 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 chief personally 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 attorney's 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. 

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Epstein's attorney Jack Goldberger did not return phone 
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 spokeswoman Judy 
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 if something 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-radar probe such as 
having a private investigator check out leads, he said. 
Shiner and 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. 

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Edmondson, spokesman for State Attorney Krischer, said 
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. 

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252 I 278 - Thursday, October 18, 2007 
Edition: FINAL 
Section: LOCAL 
Page: 5B 
Source: The Associated Press 
Illustration: PHOTO (B& W) 
Memo: Ran 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 on 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, "I 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 on charges of soliciting underage prostitutes. That case is pending. 
The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural 
sex acts" while she was 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...

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The Palm Beach Post 
REAL NEWS STARTS HERE 
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 banker Jeffrey 
Epstein will call the Palm Beach County Jail 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 
an HIV test within 48 hours, with the results being 
provided to his victims or their parents. 
As part of the plea deaii 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 of a 14-year-old girl who had 
given Epstein a naked massage at his five-bedroom, 7,234-
square-foot, $8.5 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. 

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The indictment charged Epstein only with felony 
solicitation of prostitution. The state attorney's office later 
added the charge of procuring underage girls for that 
purpose. 
Prosecutor Lanna Belohlavek said of the 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 Circuit Judge 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. 'Tm there every day," Epstein said. 
The foundation was incorporated in November. Epstein 
said he already has awarded money to Harvard and MIT. 

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When he is released from jail, there is a chance that Epstein 
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. No 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 51,000-square-foot Manhattan 
mansion. 
"It's validation of what we're saying in the civil cases," said 
Miami attorney Jeffrey 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 said he 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 $200 to $300 each after the massage 
sess10ns. 
'Tm like a Heidi Pleiss," 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. 

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The state attorney's office said questions about the girls' 
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 Chief Michael 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 of these 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 $30 million to Harvard in 2003. 
Former New York Gov. Eliot Spitzer returned a $50,000 
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 $90,000 donation for the 
purchase of a firearms simulator. 
Staff writer Eliot Kleinberg and former staff researcher 
Michelle Quigley contributed to this story. 

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The Palm Beach Post 
REAL NEWS STARTS 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 
Tycoon Jeffrey 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 Sheriffs Office's 17-acre, 
967-bed stockade near the fairgrounds. 
During his first month of confinement, 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 an 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 the jail, according to 
records, are a Singer Island man and an individual who 
listed Epstein's Palm 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 of house arrest. Epstein paid teenage 

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girls $200 to $300 in 2004 and 2005 for massages in his 
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 and 
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 telephone1 she declined to discuss Epstein. 
- Nadia Marcinkova1 23 1 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 Manhattan1 not far from Epstein's 
enormous apartment. 
- Roger Schank1 62 1 founder of the Institute for Leaming 
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 of Florida Atlantic 
University in 2003. He became "chieflearning officer" at the 
online Trump University in 2005. Schank listed his address 
as being in Stuart1 and records show he also owns a home 
in Lake Worth. 

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Epstein has financed a number of scientists over the years, 
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 New Jersey resident visited Epstein seven 
times injuly. 
Zinoviev, Schank and Marcinkova could not be reached for 
comment. 
Staff researcher Niels Heimeriks contributed to this story. 

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Palm Beach Daily News 
Billionaire sex offender leaves jail 
six days a week for work 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 4, 2019 at 9:27 AM 
Palm Beach billionaire Jeffrey 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 attorney Jeffrey 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. "I find it incredible that he's on work-release in the 
community and my clients aren't notified of this and we get 
this letter weeks after the fact." 
Jack Goldberger, Epstein's criminal attorney, said the 

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arrangement 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 guilty June 30 to two felony counts: 
soliciting prostitution and procuring a person under 18 for 
prostitution. As part of the plea agreement, Epstein must 
serve one year of house arrest and register as a lifelong sex 
offender. 

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The Palm Beach Post 
REAL NEWS STARTS 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 Post June 10, 2009) 
Their attorneys will ask a judge to open Jeffrey Epstein's 
records. 
When wealthy money manager Jeffrey 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 of judicial administration, as well as rules 
of the Palm 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 no notification or reason occurred in Epstein's case, 
according to court records. 

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Epstein's own attorneys, in federal filings, have referred 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, 
County Judge 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 Circuit Judge 
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 
of the public, E.W. has a right to have these documents 
unsealed," wrote former Circuit Judge 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 know the 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 of Mystery," 
declared a 2002 New York magazine profile of Epstein. 
Epstein, 56, is in the Palm 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 a.m. to 11 p.m., escorted by a 
deputy, said Palm Beach County Sheriffs Office 
spokeswoman Teri Barbera. 

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During a Palm Beach Police Department investigation, five 
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 activity1 
and then being paid afterward. 
At Epstein's plea conference last year1 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 if he 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 off on 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 of entire 
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. 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
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 
financier Jeffrey 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 
prostitution-related 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 Groff and 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. 

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Mark Johnson of Stuart, a former federal prosecutor, 
described the disparity in potential sentences as unusual, 
but even more so a provision on attorney payment. 
The first draft of the agreement in September 2007 
required that Epstein pay an attorney -- tapped by the U.S. 
Attorney's 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 pay Josefsberg if he 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. ''I've never, ever seen anything 
like that in my life," he said. "It's highly unusual." 
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. Attorney's Office months after the 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 

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other young women to lure them to his Palm Beach 
mansion. They walked away with between $200 and 
$1,000. 
Former Circuit Judge 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 of the legal powerhouses who have 
worked for Epstein1 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 of its 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." 

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The investigation triggered tensions between police and 
prosecutors, with then-Palm Beach .Chief Michael 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 of these cases 
highly unusual," Reiter wrote. He then asked for and got 
the federal investigation that ended in the sealed deal. 
"The Jeffrey Epstein matter was an experience of what a 
many-million-dollar defense can accomplish/' Reiter told 
the Palm Beach Daily News upon his retirement. 

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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 Palm 
Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky 
constitutional grounds. 
"These records are protected by our constitutional right of privacy," 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...

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Epstein Journal's Findings Could 
Resurrect Case 
By Jane.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" of victims of convicted sex offender Jeffrey 
Epstein could be used to reopen the investigation into the 
multi-millionaire's appetite for teenage girls1 an attorney 
representing seven of the victims said Friday. 
New details about the contents of the journal were released 
this week when Alfredo Rodriguez1 who worked as a 
property manager for the Palm Beach resident, pleaded 
guilty to obstruction of justice for lying to federal agents 
when asked if he had any information about his former 
boss' criminal activity. He later tried to sell the journal he 
stole from Epstein for $501000 to an unidentified person1 
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 or federal authorities ... the materials would have 
been presented to the federal grand jury," federal 
prosecutors wrote. 

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Instead, prosecutors short-circuited the grand jury 
investigation and cut a deal with Epstein. They agreed not 
to pursue federal charges if he 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 of victims that the U.S. Attorney's Office knew 
about when it penned the deal in 2007. If additional 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 of young girls on Epstein's computer, 
according to court records. 
Neither Epstein's criminal defense attorney, Jack 
Goldberger, nor attorney Robert Critton, 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 

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represent any of the victims on the list who wanted to 
pursue Epstein in civil court. As part of the agreement1 
Epstein is to pay for Josefsberg to represent the women. 
Some of the women, most identified as Jane 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 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Epstein paid three women $5.5 million to end underage-
sex lawsuits 
By Jane.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 billionaire Jeffrey 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 $1 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 $1 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 of the 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 old. 
Attorney Jack 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 if Epstein'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 
For...

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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 of federal judges and others to persuade investors he 
had negotiated settlements in lawsuits against high-profile people. Investors were told they 
could get a cut of the cash. 
One of the 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 $200 million - a claim Critton described as "a complete fabrication." 
After Epstein dropped the lawsuit in 2012, Edwards turned the tables on him. Edwards accused 
Epstein of filing 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 about the 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 of the 
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....

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Pointing out Epstein's enormous wealth and his private jet1 Palm Beach County Circuit Judge 
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 proof1 such as an affidavit from Epstein1 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 1 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 of the information Epstein is seeking is protected by attorney-client 
privilege. 
The malicious prosecution lawsuit is one of two 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. 
Only 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 of the key reasons they agreed to drop their case was Epstein's 
agreement to settle lawsuits filed against him by dozens of his underage...

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Palm Beach Daily News 
Judge rules 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 of Jeffrey 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. District Judge 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. 

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Prosecutors' failure to alert the young women about the 
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 decide how 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 
attorney Jack 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 of the 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. 

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"I don't see the government conceding to that remedy," 
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 on 
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 attorney Jack 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 of the benefits I bargained for." 
However, Scarola said, using Marra's ruling, he will counter 
that the contract Epstein signed was illegal and therefore 
unenforceable. 

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Even if Marra agrees to toss out the non-prosecution 
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 of public 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 abused Jane 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 of questions." 

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In his ruling, Marra detailed what appeared to be a cozy 
relationship between Acosta, his line prosecutors and 
Epstein's team oflawyers. 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 non-prosecution 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 not ... contact any of the identified 
individuals, potential witnesses, or potential civil claimants 
and 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 
reasons 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." 
Many 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. 

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Such cooperation between prosecutors and defense 
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 CR VA 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 of the non-prosecution agreement 
were revealed only after Edwards and attorneys for the 
press successfully sued to make them public. 
jmusgrave@pbpost.com 
@pbpcourts 

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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 and 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 charged conduct is from a number of years ago, it 
is still profoundly important to many of the 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 trafficking. Epstein paid dozens of young women to give him nude massages 
that, for most, led to sex, he said. 
If convicted of exploiting dozens of young women, including ...

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"We think he's a significant flight risk," Berman said of the 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 off on 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 and 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 Cassell, who 
for years has fought to get the agreement thrown out. It says only that no 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 who 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 nam...

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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 and how the 
federal government could have been involved in a conspiracy to violate federal law," Scarola 
said of his 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. "I 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 off the 
way he did and, without pre-judging it, le...

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"If you believe you are a victim of this 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 of the 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