153.pdf

IFiling # 101840557 E-Filed 01/17/2020 12:23:06 PM
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IN
THE
CIRCUIT
COURT
OF
THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC,
Publisher of THE PALMBEACH POST,
CASE NO.: 50-2019-CA-O14681-XXXX-MB
Div.: AG
Plaintiff,
v.
DAVE ARONBERG, as State Attorney of
Palm Beach County, Florida; SHARON R.
BOCK, as Clerk and Comptroller of Palm
Beach County, Florida,
Defendants.
FIRST AMENDED COMPLAINT
CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its First Amended
Complaint against Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his
official capacity (“State Attorney”), and Sharon R. Bock, the Clerk of the Court for Palm Beach
County, Florida, in her official capacity (“Court Clerk”), alleges as follows:
JURISDICTION
L
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 Dave Aronberg is the duly elected State Attorney for the Fifteenth
Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and
has authority in grand jury proceedings pursuant to Fla. Stat, Section 27.03. He is sued herein in
Party
JOINT
.
ID#. J09
EV#Jbq
DATE ADMITTED:
Case No. 2019-CA-014681
JOSEPH ABRUZZO CLERK
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CIRCUIT COURT
—*
Joint Exhibit
J09 -
CA/ArcFiBHgJOMtM BEACH COUNTY, FL, JiBfePH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
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NOT A CERTIFIED COPY
_ IFiling # 101_840557 E-Filed 0l/17/2020 12:23:06 PM 
IN 
THE 
CIRCUIT 
I COURT 
OF 
THE 
FIFTEENTH JUDICIAi, CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HQLDINCrS, LLC, 
Publisher of THE_PAIM BEACH POST, 
CASE NO,: 50-2019-CA-:014681.,XXXX-MB 
Div_.: AG 
Plaintiff, 
v. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R....

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his official capacity as his office is in possession and/or control of documents that are the subject
of this action.
4.
Defendant Sharon R. Bock is the duly elected Clerk and Comptroller ofPalm Beach
County, Florida.
She is sued herein in her official capacity as her office is in possession and/or
control of documents that are the subject ofthis action.
INTRODUCTION
5.
In what is now widely if belatedly recognized as a colossal miscarriage ofjustice -
which led to the further needless victimization of countless young girls and women - a wealthy,
politically connected, and powerful financier was not held accountable for, nor even forced to
confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein’s 2008
deal with the State of Florida was not consistent with the evidence gathered against him, what
remains shrouded in mystery is how that evidence was presented - and the extent to which it was
presented - to the grand jury that returned an indictment far more limited in scope than expected
and deserved.
6.
Through this action, 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 the furtherance ofjustice. Fla. Stat. § 905.27(l)(c).
7.
It can no longer credibly be maintained that continued blanket secrecy over the
proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law.
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To the contrary, transparency is required to promote public understanding of the criminal justice
system and public confidence in the fair administration ofjustice. As detailed below, Epstein was
accused of sexually abusing and trafficking dozens of women and girls in south Florida (among
other locations) over a period of several years while exploiting his wealth and political connections
to obstruct the administration ofjustice 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 ofEpstein’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 ofEpstein’s 2006 grand jury proceedings.
8.
Even in the absence of such a statutory basis, this Court is empowered to order
public disclosure pursuant to its inherent authority and supervisory powers over the grand jury.
Indeed, courts throughout the country in the past several decades ...

as here, many of the details of Epstein’s criminal misdeeds have already been made available in
the public domain through extensive news reporting by, among others, The Palm Beach Post, by
the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves.
9.
In recognition of the sensitivity of the materials being sought, and in the interest of
protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to
copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County
grand jury first being submitted to this Court for in camera review, where they may be redacted,
as appropriate, to protect those who deserve such protection.
FACTUAL BACKGROUND
10.
The following facts were gathered, in large part, from documents obtained by The
Palm Beach Post through various Florida Public Records Law requests, documents unsealed or
publicly available in other related judicial proceedings, and information and documents in the
public record.
A.
First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement:
2005—2008.
11.
The investigation into Epstein’s sex crimes began more than fourteen years ago,
when a 14-year-old girl’s stepmother reported to police in the Town of Palm Beach, Florida, that
Epstein and others who worked for him arranged for her to give Epstein a “massage.” Epstein
required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid
S300. Epstein was 52 years old at the time.
12.
Following this initial report in 2005, the Town of Palm Beach Police, and later, in
2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
disturbingly similar details, with each of the other victims.
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13.
Both the victim/witness interviews, as well as evidence retrieved following a search
of Epstein’s home, showed that some of the girls involved were under the-age of 18. The police
search of Epstein’s residence also found two hidden cameras and, throughout the house, large
numbers of nude photos of girls, including victims whom the police had not interviewed in the
course oftheir investigation.
14.
In March 2006, a State grand jury was scheduled at which all of the victims were
expected to testify. The proceeding was postponed, however, due to meetings between the State
Attorney’s office and Epstein’s prominent criminal defense lawyer and personal friend, Alan
Dershowitz.
15.
Another 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.
16.
On May
1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a
“personal and confidential” letter to then Palm Beach County State Attorney, Barry Krischer,
stating:
I must renew my prior observation to you that I continue to find your office’s
treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to
communicate in this manner, but my most recent telephone calls to you and those
of the lead detective to your assigned attorneys have been unanswered and
messages remain unreturned. After giving this much thought and consideration, I
must urge you to examine the unusual course thatyour office’s handling ofthis
matter has taken and consider ifgood and sufficient reason exists to requireyour
disqualificationfrom theprosecution ofthese cases. (Emphasis supplied)
17.
Chief Reiter’s letter to State Attorney Krischer enclosed the Town of Palm Beach
Police Department’s probable cause affidavits charging Epstein and two of his assistants with
multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested
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that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges
against him, which would be public.
(2)
The July 2006 State Grand Jury Presentation.
18.
Instead, State Attorney Krischer elected to refer the case to a grand jury, which is
mandatory for capital cases but rarely used for all other crimes.
According to an official
spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm
Beach County.
19.
In July 2006, after State Attorney Krischer presented testimony and evidence from
one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.
There is no mention in the indictment of the victim being a minor.
20.
On information and belief, a second of Epstein’s victims was supposed to testify
before the grand jury, but was unable to attend because of a school exam.
21.
No reasonable explanation has been provided as to why the numerous other known
victims were not presented as witnesses and crime victims to the 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.
22.
On information and belief, during the grand jury appearance of the single victim
who testified, the State Attorney presented evidence that vilified the victim and attacked her
credibility, including soliciting testimony regarding underage drinking and questionable personal
behavior that was unrelated to the charges against Epstein. Further upon information and belief,
this information was initially brought to the attention of the State Attorney’s office by Epstein’s
defense counsel.
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that either an arrest warrant be issued for Epstein or the State Attorney direc~ly initiate the charges 
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(3)
The FBI’s Investigation and Epstein’s Non-Prosecution
Agreement With Federal Authorities.
23.
On information and belief, following the deficient July 2006 indictment, and with
Chief Reiter’s encouragement, the FBI began its own investigation of Epstein.
24.
Records unsealed in 2015 revealed that the FBI compiled reports on “34 confirmed
minors” that were victims ofEpstein’s sexual predations. Based on evidence gathered by the FBI,
a 53-page indictment was prepared by the U.S. Attorney’s Office in June 2007. However, at the
request ofEpstein’s lawyers, the indictment was never presented to a federal grand jury.
25.
Instead, then U.S. Attorney for the Southern District ofFlorida, Alexander Acosta,
negotiated a plea deal with Epstein’s team of lawyers to grant immunity to Epstein (along with
four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
charges.
26.
Throughout the remainder of 2007 and through the first half of 2008, Epstein’s
lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
belief, Epstein’s lawyers insisted that (1) the victims not be notified, (2) the deal be kept
confidential and under seal, and (3) all grand jury subpoenas (including one that had already been
issued for Epstein’s computers) be withdrawn.
27.
On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of
prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was
sentenced to 18 months in jail, followed by a year of community control or house arrest, and was
adjudicated as a convicted sex offender required to register twice a year in Florida.
28.
The plea deal, called a non-prosecution agreement (“NPA”), allowed Epstein to
receive immunity from federal sex-trafficking charges that could have sent him to prison for life.
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On information and belief, based on public records, former State Attorney Krischer communicated
with then U.S. Attorney Acosta concerning the NPA’s negotiation with Epstein’s lawyers.
29.
Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for
which he was convicted.
Instead, he was placed in a private wing of the Palm Beach County
Stockade, where, after 3 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.”
30.
Epstein was released five months early.
31.
Upon information and belief, Epstein violated the terms of his probation, but was
not prosecuted.
(4)
The Crime Victims’ Rights Act Litigation.
32.
Epstein’s victims only learned after the fact about his plea in State court and filed
an emergency petition to force federal prosecutors to comply with the Crime Victims’ Rights Act
(18 U.S.C. § 3771, “CVRA”), which mandates certain rights for crime victims, including the right
to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge
Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify
Epstein’s victims before allowing him to plead guilty to only the two State offenses.
33.
The prosecution’s failure to keep the victims apprised, among other things, also
contravenes the Florida Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001.
34.
Following publicity exposing the extraordinary leniency of the plea deal, dozens of
civil suits were brought against Epstein, most of which Epstein’s lawyers settled out-of-court.
35.
In 2010, Epstein was registered as a “level three” (i.e., high risk of repeat offense)
sex offender in New York, a lifelong designation. In 2011, the New York County District
Attorney’s office unsuccessfully sought to lower his registration to low-risk “level one.”
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36.
Upon information and belief, during the course ofthe Town ofPalm Beach and FBI
investigations, Epstein retained private investigators to follow, harass, and photograph his victims
and their families, as well as ChiefReiter and the Town ofPalm Beach detective who investigated
the case against Epstein.
37.
Upon information and belief, Epstein’s victims were threatened against cooperating
with law enforcement and told that they would be compensated only ifthey did not cooperate with
law enforcement.
B.
Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019.
38.
On July 6, 2019, Epstein was arrested on federal sex trafficking charges.
39.
Upon information and belief, the United States government’s investigation of new
allegations and charges stemmed, in part, from continued press investigations into and reporting
on the mishandling of the 2006 charges and the civil suits that followed.
40.
In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the
Southern District ofNew York, Epstein was described as “a serial sexual predator who preyed on
dozens 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 photographs
of fully- or partially-nude females,” including underage females. In a locked safe, compact discs
were found with handwritten labels including the descriptions: “Young [Name] + [Name],” “Mise
nudes 1,” and “Girl pics nude.”
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41.
On July 8,2019, prosecutors with the Public Corruption Unit ofthe U.S. Attorney’s
office for the Southern District ofNew York charged Epstein with sex trafficking and conspiracy
to traffic minors for sex. The grand jury indictment alleges that “dozens” of underage girls were
brought into Epstein’s mansions for sexual encounters. A few days later, owing to public outcry
over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,
Alexander Acosta, who by then was serving as U.S.
Secretary of Labor in the Trump
administration, resigned from office.
42.
Epstein was denied bail and was placed into pretrial detention at the federal
Metropolitan Correction Center in lower Manhattan.
43.
On or about August 6, 2019, Florida Gov. 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.
44.
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.
45.
On account of his death, prosecutors sought to dismiss the indictment against
Epstein, while maintaining that they would continue to investigate his co-conspirators.
46.
United States Senior District Judge Richard M. Berman ordered a hearing on
August 27, 2019, on the prosecutors’ decision to dismiss the indictment and allowed victims to
speak at the hearing.
47.
In the course of the hearing, more than two dozen victims delivered their personal
stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of
violent rape by Epstein. Many more victims were present in the courtroom but did not testify.
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41. 
On July 8, 2019, prosecutors with the Public Cor...

48.
While some questioned the reasoning behind the court’s decision to give the victims
voice after Epstein’s death, District Judge Berman noted that “a public hearing is [the] preferred
vehicle of resolution,” emphasizing that “public hearings are exactly what judges do. Hearings
promote transparency and they provide the court with insights and information which the court
may 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.”
49.
At the August 27th hearing, the girls, now women, spoke about their “exploitation
and coercion,” and to the fact that many ofthem “were in very vulnerable situations and in extreme
poverty, circumstances where [they] didn’t have anyone on [their] side, to speak on [their]
behalf...One victim lamented that “as a victim, [she] never got to see what the 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.
50.
A former federal judge in attendance at the August 27th hearing emphasized that
“transparency is one ofthe overriding objectives in our criminal justice system.”
51.
Nearly all of the victims expressed the conviction that the secrecy that shielded
Epstein has caused them “irreparable harm” and that an opportunity to address his criminal
wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
at least some measure ofjustice to be served after his death. Indeed, one victim stated: “Any efforts
made to protect Epstein’s name and legacy send a message to the victims that he wins and that he
is untouchable.” Another victim expressed fear that this is a world “where there are predators in
power, a worl...

“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.
52.
Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm
Beach County and the Treasure Coast vicinity.
53.
The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist
three other times.
54.
Beginning in 2004, The Palm Beach Post has extensively investigated and reported
on the allegations against, the law enforcement investigation of, and 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
complaints that two of the victims or their families had been harassed or threatened;”
“relations between police and prosecutors were fraying” as the investigation continued;
and “one girl who was subpoenaed - the one who said she had sexual intercourse with
Epstein - never showed up” to testify before the grand jury'.
•
“Trump Snags Gosman Estate for $41 M...

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“Indictment: Billionaire Solicited 3 Times” published on July 25, 2006, reporting that
“Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
solicited or procured prostitutes three or more times between Aug.
1 and Oct. 31 oflast
year, according to an indictment charging him with felony solicitation 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 “[t]he state attorney’s office said it presented the
Epstein case to a county grand jury this month rather than directly charging Epstein
because of concerns about the girls’ credibility.”
•
“Expert: Ignorance of Age Isn’t Defense In Sex Cases” published on August 5, 2006,
reporting that “[r]ather than file charges, the state attorney’s offi...

•
“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 ofprostitution 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
agreement in Circuit Court ofthe Fifteenth Judicial Circuit, and that “Epstein now faces
at least a dozen civil lawsuits in federal and state courts filed by young women who
said they had sex with him and now are seeking damages.”
On that date, The Palm
Beach Post moved to intervene in the matter for the purpose of obtaining pu...

•
“Epstein Journal’s Findings Could Resurrect Abuse Case” published on March 20,
2010, reporting that “[a] purloined journal that is said to contain the names of
‘hundreds’ ofvictims 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
ofNew 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.”
A true and correct copy of the above news articles, in either the computerized format in which they
are maintained in The Palm Beach PosCs electronic archives or the news print edition in which
originally published, is annexed hereto as Exhibit 1.
55.
Since the filing ofthe initial Complaint in this matter, The Palm Beach Post- along
with media worldwide - has continued to report on Epstein’s crimes and the ongoing official
proceedings resulting from those crimes....

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. ofAlbemarle, Va., 524 F.3d 485,492 (4th Cir. 2008) (providing that a plaintiff
has “standing to assert a right to receive speech” by “showing] that there exists a speaker willing
to convey the information to her”).
57.
Because of the unique role performed by the press as a “public surrogate” (Lewis,
426 So. 2d at 6-7) in 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 ofCorr. v. Advance LocalMedia, 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 ultimately unsuccessful”).
58.
Here, the continued denial of access to information The Palm Beach Post seeks on
behalf of its journalists and the public it serves “unquestionably constitutes irreparable injury.”
Gainesville Woman Care, LLC v. State of...

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).
59.
The Palm Beach Post has the right to maintain this private right of action because
the furtherance ofjustice, an express legislative exception to grand jury secrecy, is intended for
the public benefit, and The Palm Beach Post seeks access on behalf of the public. Fla. Stat.
§ 905.27(l)(c). It is further express in Fla. Stat. § 905.27 that the legislature intended for a court
to be the party to make the determination of disclosure. Fla. Stat. § 905.27(1). In other words, the
legislature intended for recourse to the courts in considering and determining the propriety and
scope of grand jury secrecy.
E.
The Court’s Jurisdiction And Authority.
(1)
The Court’s Supervision of the Grand Jury Process and Its
Authority to Order Public Disclosure of the Epstein Evidence.
60.
The Florida Supreme Court has noted that “in states such as Florida, where the
grand jury is preserved, it is an important appendage of the court which impanels it. At the same
time it should not be forgotten that the judge of that court is equally important and he is generally
charged with the supervision of the grand jury’s activities... It is, therefore, of vital importance to
maintain the dignity and the integrity of both the grand jury and the presiding judge.” State v.
Clemons, 150 So. 2d 231, 233-34 (Fla. 1963).
61.
Chapter 905 of the Florida Statutes governs the empanelment and conduct of
Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury
about its legal duties. Fla. Stat. § 905.18.
62.
Florida Stat. Section 905.27(1) provides that “the testimony of a witness examined
before the grand jury ... or other evidence received by it” may be disclosed “when required by a
17
CA/Aronberg-000133
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court... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by
the witness before the court; (b) Determining whether the witness is guilty of peijury; or (c)
Furtheringjustice.” Fla. Stat. § 905.27(l)(a)-(c).
63.
Further, disclosure is appropriate pursuant to this Court’s inherent authority over
grand jury proceedings because of the exceptional public interest in this case and the compelling
circumstances supporting transparency. Carlson v. UnitedStates, 837 F.3d at 766 (“a district court
has the inherent power to disclose [grand jury] materials in exceptional circumstances and
.
.
.
historic importance can be a sufficient reason when there is little countervailing need for secrecy”).
64.
The Florida Supreme Court has confirmed that grand jury secrecy is not absolute
and that any “potential harm to public officeholders” from disclosure “will be the product of their
own conduct, and not the consequence of an unrestrained body of misguided citizens.” Miami
Herald Pub. Co.
v. Marko, 352 So. 2d 518 (1977) (“The benefits to be derived from this
extraordinary exercise in citizen participation [in the grand jury] would be severely limited if the
fruits of that activity were not available to the public on whose behalf it is undertaken. Implicit in
the power of the grand jury to investigate and expose official misconduct is the right ofthe people
to be informed of its findings. While public disclosure of grand jury findings inevitably entails the
risk of reputational damage, the legislature has ensured that any potential harm to public
officeholders will be the product oftheir own conduct, and not the consequence of an unrestrained
body of misguided citizens”).
(2)
The Court’s Jurisdiction To Declare Rights And Construe
Statutes.
65.
This Court has jurisdiction to declare rights, status, and other equitable or legal
relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011.
18
CA/Aronberg-000134
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66.
Florida law specifically provides that a declaration may be sought from the Court
concerning a petitioner’s rights under a statute. Florida Stat. Section 86.021 (“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 ofrights, status, or other equitable
or legal relations thereunder.”).
67.
The Court’s exercise of its power to declare rights “is to be liberally administered
and construed.” Florida Stat. Section 86.101.
COUNT I
(Declaratory Relief - Florida Stat. Sections 86.011 et seq.)
68.
The allegations set forth in paragraphs
1 through 67 are incorporated by reference
as if fully set forth herein.
69.
This is an action for Declaratory Relief pursuant to Chapter 86, Florida Statutes,
and other supplemental relief.
70.
The Palm Beach Post respectfully requests that the Court declare that pursuant to
Fla. Stat. Section 905.27(1), it is entitled access to the testimony, minutes, and other evidence
presented in 2006 to the Palm Beach County grand jury because such disclosure and access would
be in the furtherance of justice. Fla. Stat. § 905.27(l)(c). Because The Palm Beach Post is not
seeking these materials in connection with either a civil or criminal case, it seeks a declaration that
the scope of its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2).
71.
The Palm Beach Post further seeks a declaration that disclosure of the testimony,
minutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate
19
CA/Aronberg-000135
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NOT A CERTIFIED COPY
66. 
Florida law specifically provides that a declaration may be sought from the Court 
I 
concerning a petitioner's rights under a statute. Florida Stat. Sectio...

pursuant to this Court’s inherent authority over grand jury proceedings because of the exceptional
public interest in this case and the compelling circumstances supporting transparency.
72.
The Palm Beach Post has sought from Defendants, but Defendants have refused to
provide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach
County grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint and the
relief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith dispute exists between
the parties.
73.
Through this Complaint, The Palm Beach Post presently has a justiciable question
concerning its rights to obtain the 2006 grandjury materials pursuant to Fla. Stat. Section 905.27(1)
and the Court’s inherent authority.
74.
A bona fide, actual, present, and practical need for the declaration exists in that
Defendants have denied to The Palm Beach Post - and to the public at large - the grand jury
materials sought to be disclosed. The relief sought from the Court is therefore not merely the giving
of legal advice or to answer hypothetical questions.
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. Section 905.27(l)(c)
and the Court’s inherent authority, The Palm Beach Post may gain access to the testimony,
minutes, and other evidence presented in 2006 to the Palm Beach County grand jury and use those
materials for the purpose of informing the public.
COUNT n
(Florida Stat. Section 905.27)
75.
The allegations set forth in paragraphs
1 through 74 are incorporated by reference
as if fully set forth herein.
20
CA/Aronberg-000136
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I 
pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional 
public interest in this case and the compelling circumstances supporti...

76.
Based on information learned by The Palm Beach Post through its Florida Public
Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence
and proceedings, judicial documents obtained from independent but related court proceedings, and
documents otherwise available in the public record, the State Attorney for Palm Beach County
presented truncated evidence ofEpstein’s criminal wrongdoing to the 2006 grand jury in a manner
that precluded his indictment for the serious crimes he committed, including sex trafficking and
sexual assault.
77.
Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein’s
victims and the public, and to provide public disclosure to illuminate whether Epstein received
unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests
immediate access to the testimony, minutes, and other evidence presented in 2006 to the Palm
Beach County grand jury.
78.
In a case of this magnitude and importance, where the accused is dead and so many
of his crimes, as well as the identities and crimes of his co-conspirators, and the identities of the
victims have already been exposed, the need for grand jury secrecy is no more. See United States
v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) (“[A]fter the grand jury’s functions are
ended, disclosure is wholly proper where the ends ofjustice require it.”).
WHEREFORE, The Palm Beach Post respectfully requests that thi s Court, pursuant to Fla.
Stat. Section 905.27(1) and the Court’s inherent authority, order the State Attorney and the Clerk
of the Court to file with this Court copies of the testimony, minutes, and other evidence presented
in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so
that, following an in camera inspection, it can be made available to The Palm Beach Post and the
21
CA/Aronberg-000137
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public on an expedited basis, and grant any other and further equitable of legal relief the Court
deems just and proper.
Dated: January 17, 2020
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
hasenh@gtlaw.com
FLService@gtlaw.com
By: /s/MichaelJGrygiel_
MICHAEL J GRYGIEL
(Admitted Pro Hac Vice)
54 State St., 6th Floor
Albany, New York 12207
Telephone: (518) 689-1400
Facsimile: (518)689-1499
grygielm@gtlaw.com
By: /s/NinaD.Boyajian_
NINA D. BOYAJIAN
(Pro Hac Vice application pending)
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: (310) 586 -7700
Facsimile: (310) 586 -7800
boyaj iann@gtlaw.com
riveraal@gtlaw.com
22
CA/Aronberg-000138
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NOT A CERTIFIED COPY
public on an expedited basis, and grant any other and further equitable or; legal relief the Court 
deems just and proper. 
Dated: January 17, 2020 
Respectfully submitted, 
GREENBERG TRAURIG, P.A. 
Attorneys 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: Isl Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
Florida Bar No. 849324 
mendelsohns@gtlaw.com 
hasenh@gtlaw.com 
FLService@gtlaw.com 
By: Isl Michael J G,ygiel 
MICHAEL J GRYGIEL 
(Admitted Pro Hae Vice) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: (518) 689-1400 
Facsimile: (518) 689-1499 
grygielm@gtlaw.com 
By: Isl Nina D. Boyaiian 
NINA D. BOY AJIAN 
(Pro Hae Vice application pending) 
1840 Century Park East, Suite 1900 
Los Angeles CA 90067 
Telephone: (310) 586 -7700 
Facsimile: (31...

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has
been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
/s/Stephen A.Mendelsohn_
STEPHEN A. MENDELSOHN
CA/Aronberq-000139
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has 
been electronically filed with the Florida E-File Portal fore-service on all parties of record herein. 
Isl Stephen A. Mendelsohn 
STEPHEN A MENDELSOHN 
23 
CA/Aro¥~rms?W1~r~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 

EXHIBIT 1
The Newspaper’ s Reportage on Jeffrey Epstein
CA/Aronberg
FILE!1-000140
): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
The Newspaper's Reportage on Jeffrey Epstein 
CA/AronbeLQ-000140 
FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 

...
.
,
....
...
_
...... I,
TheMm Beach fbst
_
REALNEWSSTARTS HERE
The Man WhoHad Everything: Jeffrey Epstein craved big
homes, elite friends and underage girls
By Andrew Marra
Posted Jul 17; 2019 at 6:02 AM
From the archives: When Palm Beach detectives started asking
questions and teenage girls started talking, a wave of legal resistance
followed,
Editor's Note:, This article appeared in The Palm Beach Post on August 14,2006, three weeks after
Jeffrey Epstein’s arrest in Palm Beach County on a charge offelony solicitation ofprostitution.
WINGED GARGOYLES guarded the gate at Jeffrey Epstein’s Palm Beach mansion. Inside,
hidden cameras trolled two rooms, while the. girls came and went.
For the police detectives who sifted through the garbage outside and kept records ofvisitors, it
was the lair of a troubling target.
Epstein, one ofthe most mysterious of the country’s mega-rich, was known as much for his
secrecy as for his love of fine things: magnificent homes,, private jets, beautiful women,
friendships with the world’s elite.
But at Palm Beach police headquarters, he was becoming known for something else: the
regular arrival ofteenage girls he hired to: give: him massages and, police say, perform sexual
fayprs.
Epstein Was different from most sexual abuse suspects; he was far more powerful. He counted
among his friends former President Bill.Clinton, Donald Truinp and Prince Andrew, along
with some of the most prominent legal, scientific and business minds in the country.
When detectives started asking questions and teenage girls started' talking, a wave of legal
resistance, followed.
CA/Aronberg-000141
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
'The Palm Beach Post 
REAUNEWS{STARTS HERE __ _ . 
.... 
_________ _ 
The\ :M'alJ; Wb.o: lll:all :Eveiyt.hillg_; Je.ffrey: E~p,slbi:n ·orated big, 
h-onles, elite :,friends ,and- u-rad;era'ge::Igi"rls 
B,y. Andrl!W Marrc1 
P9s:t"~d)ui17.,"ii5i9.~16:02 AM 
From the archi...

» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work-
release
’
If Palm Beach police didn’t know quite who Jeffrey Epstein was, they found out soon enough.
Epstein, now 53, was a quintessential man ofmystery. He amassed his fortune and friends
quietly, always in the background as he navigated New York high society.
When he first attracted notice in the early 1990s, it was on account 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 limefight 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 fisted him as one ofthe city’s most eligible
bachelors and began; describing him in its gossip columns with adjectives such as “mysterious”
and “reclusive.”
Although Epstein gave no interviews, the broad strokes of his past started to come into focus;
Building a life ofextravagance
He was born blue-collar in 1953, the son of a New York City parks department employee, and
raised in Brooklyn’s Coney Island neighborhood. He left college without a bachelor’s degree
but became a math teacher at the prestigious- Dalton School, in Manhattan;
The story goes that the father of one of Epsteins students was so impressed with theman that
he put him in touch with a senior partner at Bear Stearns, the global investment bank and
securities firm.
CA/Aronberq-000142
FILED: PALM...

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

And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
photographed.
i
"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
ah 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 ofNew Mexico Gov. Bill Richardson and the
Senate bids ofJoe Lieberman, Hillary Rodham Clinton, Christopher, Dodd and Charles
Schumer.
Powerful friends and enemies
A Vanity Fair profilefound 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 ofthe largest Ponzi schemes in .American history.”
As he amassed his wealth, Epstein made enemies in disputes, both large and small. He sued the
man who in 1990 sold him his
Palm Beach home over a dispute abdut.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 syyept, mopped floors, official says
CA/Aronberg-000144
FILED: PALM BEACH COUNTY, FL, JOSEPH ABR...

“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. “Sufficejit
to say I have
nothing good to say about him.”
j
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.
are said to include a former Ms. Sweden and a Romanian
model.
“He’s a lot offun to be with,” Donald Trump told New York magazine in 2002. “It is even said
that he likes beautiful women as much as I do, and many 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 frequenter1of the Palm Beach social scene, he made his presence felt.
Among his charitable donations, he gave 590,000 to the Palm Beach Police Department and
SI00,000 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.
i
i
i
CA/Aronberq-000145
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. 
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·. 
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"IJ' s :a: b~d roem01:y I woulci rather n.o...

Palm Beach police and the state attorney’s office have declined to discuss the case. But a Palm
Beach police report detailing the criminal probe offers a window into what detectives:faced as
they sought to close in on Epstein.
;
Detectives interviewed the girl, who told them a friend had invited her to a rich man’s house to
perform a massage. She said the friend,told her to say she was 18 if asked. At the house, she
said she was paid $300 after stripping to her panties arid massaging the man while he
masturbated.
Police interview 5 alleged victims
The investigation began in full after the girl identified Epstein in a photo as the man who had
paid her. Police arranged for garbage trucks to set aside Epstein’s trash so police could sift
through it. They set up a video camera to record the comings and goings at his home., They
monitored ait airport'hangar for signs ofhis private jet’s arrivals and departures.
They quickly learned that the woman who took the 14-year-old girl to Epstein’s house was
Haley Robson, a Palm Beach Community College student from Loxahatchee. 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 toher house, Robson told detectives, “I’m like a Heidi Fleiss.”
Police interviewed five alleged victims arid 17 witnesses. Their report.shows some of the girls
said they had been instructed to have sex with another woman in front of Epstein, arid one said
she had direct intercourse with him..
In October,, police searched the Palm Beach mansion. They discovered photos of naked, young-
looking femalesJust 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 girls showed up to
perform massages two ...

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
I
$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 sweethealrt deal
When they subpoenaed one of Epstein's former employees, he told them the same thing. He
and a private eye had met at a restaurant days earlier to go over what the man would tell
investigators.
Detectives received complaints that private eyes were posing as police officers. When they told
Epstein’s local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the
high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
Kennedy Smith.
While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard laiw
professor, traveled to WestPalm Beach with information about the girls. From their own
profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
their use of alcohol and marijuana.
He took his research to a meeting with prosecutors in early 2006, where he sought to cast
doubt on the-teens’ reliability,
The. private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
did some of the girls have issues with drugs or alcohol, but also some had 'criminal, records and
other troubles, Epstein’s legal team claimed. And at least one of them, they said, lied when she
told police she was younger than 18 when she started performing massages for Epstein.
After the meeting, prosecutors postponed their decision to take the ...

In the following weeks, police received complaints that two ofthe victims or their families had
been harassed of threatened. Epstein's legal team maintains that its private’ investigators did
nothing illegal or unethical during their research.
i
By then, relations between, police and.prosecutors were fraying. At a key meeting with
prosecutors and the defense, Detective Joseph Recarey, the lead investigator, was a no-show,
according to Epsteins attorney.
"The embarrassment on the prosecutor's face was evident when the police officer never,
showed up for the meeting,” attorneyJack Goldberger said.
Later in April, Recarey walked into a prosecutor’s office at the state attorney’s office and
learned the case was taking an unexpected turn.
The prosecutor, Lanna Belohlavek, told Recarey the state 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 pass, however,
Future unclear after charge
On May 1, the department asked prosecutors to approve Warrants to arrest Epstein on four
counts ofunlawful sexual activity with a minor and to charge his personal assistant, Sarah
Kellen, now 27, for her alleged role in arranging.the visits. Police officials also wanted to
charge Robson, the self-described Heidi Fleiss, with lewd and lascivious acts.
By then, the, department was frustrated with the way the state attorney’s office had handled the
case. On the same day the warrants were requested, Palm Beach Police ChiefMichael Reiter
Wrote a letter to State Attorney Barry Krischer suggesting hedisqualifyhimselffromthe case if
he would not act.
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
the grand jury.
CA/Aronberq-000148
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In the following weeks, police received,compfaint...

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.
Jnstead ofbeing slapped with a charge ofunlawful sexual activity with a minor, Epstein was
charged with one count of felony solicitation of prostitution, which carries a maximum penalty
of five years inprison, He was booked into the Palm BeachCountyJail earlyJuly 23 and
released hours later.
Epstein’s legal team "doesn’t dispute that he had girls over for massages,” Goldberger said. But;
he said their claims that they had sexual encounters with him lack credibility.
“They are- incapable of being believed," he said, “They had criminal.records. They had
accusations of theft made against them by their employers. There was evidence of drug use by
■some ofthem."
What remains for Epstein is yet to be seen.
The Palm Beach Police Department has asked the FBI to investigate the case. It also has
returned the $90,000 Epstein donated-in 2004.
In New York, candidates for governor and state attorney general have vowed to return a total
of atleast $60)000 in campaign contributions from Epstein. Meanwhile, Epstein’s powerful
friends have remained silent as tabloids and Internet blogs feast on the public details ofthe
police investigation.
Goldberger maintains Epstein’s innocence but says the legal team has riot ruled out a future
plea deal. He insists Epstein will emerge in the end with his: reputation untarnished.
"He will recover from this," he said.
Staffwriter Larry. Keller and staff researchers Bridget Bulger, Angelica Cortez, AmyHanaway and
Melanie Mend contributed id this'story.
amarra@pbpost.com
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His not known hoW:rn:<lny ofthe girls testiJieci bero:...

@AMarraPBPost
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FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 

213 / 278 - Tuesday, November 16, 2004
;
Edition: FINAL
Section: A SECTION
Page: 1A
Source: By PAUL 0WERS 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: Gosmah, 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.Maf-a-Lago, has ho 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 ofthe mega-hit The Apprentice said he intends to redevelop the site into a "super
luxury house" that would be the "finest anywhere in the United States." He might build
another, house before flipping the entire package.
"I've known about this house for quite some time," Trump said. "It's probably the best piece
of land in Florida - and probably the country - for luxury real estate."
Although Trump said he could subdivide the property into nine lots, Palm.Beach Mayor
Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith
said she's not worried about Trump's plans.
"He's been a very good property owner in the town of Palm Beach," she said. "He does his
projects very, well. He's: a perfectionist."
Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of
Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual
distribution to creditors.
The auction began at exactly .noon after Judge Steven Friedman dismissed an objection from
an attorney representing money manager. Jeffrey Epstein. The lawyer argued unsuccessfully
that Trump was not a qualified bidder becau...

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 sajd 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.
T he 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 ofthe $45 million that Virginia home builder
Dwight Schar...

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 Gosmaris but said they were
willingto moye forward, in part because the upkeep ofthe 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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The trustee .alleged during .a weeklong; trial in May that Gos111an: fraudul~rttly gave his wife 
an ownership interest in.his bo1ne and otby~ belongings only to avoid l9s
1ing th~m in 
bankruptcy. Gosman has denied any wrongdoing;; sayirtg he 'made: the :property transfers in 
1999, w.elJ before.h,efjled{o1: banlp-µptcy,_ 
Lessen is expected to rule in the next two. months whether Gosman mad¢ improper transfers, 
a deci~ion that will c1ffect bow much mcmey will be ava,ilahle to creditors. 
Cimo acknowle.dged that Monday wasn't the b,est of days for the Gosmaris but. said they were 
wiJling to ,rn9ye for.ward, ip part ]J.ecal,lse the lJpkeep of the estate-now -~x..c~~~rs their ITiean.s, 
"This:is.not a happy ·occasibn. for them, b:ut atleast. we're moving to the riext level," Cimo 
.s.cUd. ,;That's n_ot a hous~ you want to· live in µ11less you're making large i,im,ounts of money 
like Donald Trump." 
paul ~owets@pbpost.com 
CA/Aronben1-000153 
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FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, C...

11/11/2019
indictment: Billionaire Solicited 3 Times - News - the. Palm Beach Post - West Palm Beach, FL
The Palm Beach Post
~.
■” '■—...
“
■
■n.- -
Indictment: Billionaire Solicited 3 Times
Posted Jul 1,2008 at 12:01 AM
I
Updated Oct 2,2019 at 2:30 PM
i
(EDITOR’S NOTE: This story originally published in The. Palm Beach Post onJuly 25,
2006)
Billionaire money manager and Palm Beach part-time residentJeffrey Epstein
solicited or procured prostitutes three or more times: between Aug. 1 and Oct. 31
of last year, according to an indictment charging him with felony solicitation of
prostitution.
Epstein, 53, was booked at the Palm Beach County jail at 1:45 a.m. Sunday. He
was released on S3,000 bond.
Epstein’s case is unusual in that suspected prostitution johris 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
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: Bi
1Hio.naire Solicited 3. Times 
PQl>Jed J.uJ 1, 2008 at 12:Q1 AM 
Updated Oct 2, 2019 ·at:2:·30 PM 
(ED!TQIJ 'S N.QTE: This storyorigi11ally py~[isheq, iti-' The Palm Bead! Post,on]uly25, 
2006) 
Billionaire money manager and Balm Beach part-time resident Jeffrey Epstein 
solidted or pr.ocured prostitutes three or more times between Aug; 1 and Oct. 31 
of ...

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t
Indictment;Billionaire.Solicited 3 Times.7 News:- The Palm Beach Post
West Palm.Beach, FL.
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Palm Beach police confirmed that and-said the department will release a report
today regarding its investigation.
Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a
pool and a boat dock oh the Intracoastal Waterway since 1990, according to
property records. A man answering the door there Monday said that Epstein,
wasn’t home. A Cadillac Escalade registered to him was parked in the driveway,
which is flanked by two massive gargoyles.
Epstein sued Property Appraiser Gary Nikplits in 2001, contending that the
assessment of his home exceeded its. fair market value. He dismissed his lawsuit
in December 2002.
A profile of Epstein in VanityFair 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@pbppst.cOm
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lr:idJctrnent: .Billion~ire.SoliciJed ~ Tirnes ." News - The paJm Beach Ppst" \(Vest Palin.Beach, .FL 
Palm Beach polic~ confirmed that and.said ·the department will release a report 
today :r~garding •its investigation. 
Ep·steih has owned a five..:.b_edrootn, 7 l/2,..hath, 7,234-square-toot:home with a 
pool artd a bcfat dock o'ii-thelntracoastal Waterway since 1990, actotdingto 
property records. A man answering the door there Monday said that Epstein 
wa,sri't home .. A CaMJ.a~ Escaj.,!d~ r~gi.st~i::~d to hi.m was pai:.k..ecJ i11- ...

11/11/2019
After long probe, billionaire faces solicitation charge - News - TheiPalm Beach Post - West Palm Beach, FL
The Palm Beach Post
REALNEWSSTARTSHERE
:
After longprobe, billionaire faces solicitation
charge
Posted Jul 27,2006 at 12:01 AM
Updated Oct 3,2019 at 3:11 PM
(EDITOR’S NOTE: This story originally published in The Palm Beach Post 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 oh his
private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
him with one count of felony solicitation ofprostitution,
Palm Beach police thought there was probable cause to charge Epstein with
unlawful sex acts with a minor and lewd and lascivious molestation.
Police Chief Michael Reiter was so angry with State Attorney Barry Krischer s
handling ofthe case that he wrote a memo suggesting the county’s top
prosecutor disqualify himself.
“I must urge you to examine the unusual course that your office’s handling ofthis
matter has taken and consider if good and sufficient reason exists to require your
disqualification from the prosecution ofthese 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 arid
their ability to testify.
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After long_ probe, billionaire faces solicitation'.ch...

11/11/2019
After long probe, billionaire faces solicitation charge.<News - The Palm Beach Fjbstjr West Pairri Beach, FL
j
By the nature of their jobs, police officers look at evidence from a
‘ one-sided
perspective,” Edmondson said. “A prosecutor has to look at it in a much broader
fashion,” weighing the veracity ofwitnesses; and how they may fare under
defense attorneys’ questioning, he said.
Epstein’s attorney, Jack Goldberger, said his client committed no crimes.
“The reports and statements in question refer to false accusations that were not
charged because the Palm Beach County state attorney questioned the credibility
of the witnesses,” Goldberger said. A county grand jury “found the allegations
wholly unsubstantiated and 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 BeachCommunity 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 sexwith the girls.
A money manager for the ultra-rich, Epstein was named one of New York’s most
eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with
the likes of former President Clinton, former Harvard University President
La...

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 ofJoe. Lieberman, Hillary Clinton, Christopher Dodd and Charles
Schumer.
Goldberger is one of five attorneys Epstein has retained since he became the
subject of an investigation, Edmondson said. Among the others: Alan
Dershowitz, the well-known Harvard law professor and author, who is a friend
of Epstein. Dershowitz could not be reached for comment.
Police said the woman who enlisted young girls for Epstein was Haley Robson,
20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in
Wellington and said she was a journalism major at Palm Beach Community
College when she was questioned by police last October. She has ail unlisted
phone number and could not be reached for comment.
Robson said she met Epstein when, at age 17, a friend askedher 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 Ihtracoastal 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://wvjvApalmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
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After long probe, b-illionaire:faces solicitation ·cliarge'- News - The Palm Beach Post - West Palm Beach, FL 
He hc,1s contributed teI_ls ofthousc,1nds o(do1iars to Democratic- Pa;ty rnndidates 
I 
arid otga11izations1 induding Sen. John Kerry's presidential bid, a1d the Senate 
campaigns of Joe, Lieberman, Hillary Clinton, Christopher Dodd ~n:d Charles 
Sch...

11/11/2019
After long probe, billionaire faces solicitation charge - News- The Palm Beach Post r 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; “I’m like a Heidi
Fleiss,” police quoted her as saying. The girls knew what to expect:when they
were taken to Epstein’s home, Robson said. Give a massage - maybehaked - and
allow some touching.
One 14-year-old girl Robson took to meet Epstein led police to start the
investigation ofhim in March 2005. A relative ofthe girl called to say she
thought the child had recently engaged in sex with a Palm Beach man. The girl
then got into a fight with a classmate who accused her of being a prostitute, and
she couldn’t explain why she had $300 in her purse.
The .girl gave police this account ofher meeting with Epstein:
She accompanied Robson and a second girl to Epstein’s house 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 ofa naked woman, several
photographs ofnaked 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 Airport to see ifhis private jet was there, so they woul...

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 ofsoccer.
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.
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" 
After long probe, billionaire faces solicitation charge - liiews - The Palm Beach Post - West Palm Beach, FL 
from Palm B¢ac:h ?ariitc1,tiozy w9rkers, collectipg papers with nc11n~~ a_nd p_hone 
'numbers, s_ex toys a11d %m~l~ ·hygiene produc:ts. 
One note stated that a female could not cpmeoverat 7 p.ni. becau,se ots_occer. 
Another said a girl had to work Sunday - ,;Monday after school?" And still 
another note contained the workhours ofa girl, saying she lea.ves: school at 11:30 
c1.m. and would come over the next day at 10:30 a,m. 
Only three months before the. police ·departrneht probe began, Epstein donated 
$90~000 tp the depa_rtnu~nt for the
0purchase of a fireafl1ls s_imµla.tor:, saidJane 
$trud~r, town fina_n<:~ di_r~c:t9ri J:he purQhase wc1.s JJ~Y~r ma_de. Th~ money was 
r_eturned to Epstein on Monday, she· said. 
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CA/Aronberg~000160 
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11/11/2019
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Pajrn Beach, FL
Palm Beach DailyNews
Police say lawyer tried to discredit teenage
girls
Posted Jul 29, 2006 at 12:01 AM
Updated Oct 3, 20.19 at 2:00 PM
(EDITOR’S NOTE: This story originally was published in The Palm Beadi Post on July
29, 2006)
Earned 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 billionaireJeffrey Epstein, sexually
charged massages, according to police reports.
Thereports 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 s'omebddy 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, ofconcerns about
the girls’ credibility. The grand jury indicted Epstein, 53, on a single count of
felony solicitation ofprostitution, which carries a maximum penalty offive 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.
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Police say lawyer tried t...

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
i
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 "Pimpin’ Made EZ/’
Robson, who was not charged in the case, is a potential prosecution witness.
According to Recarey, prosecutor Lanna Belohlavek offered Epstein, attorneys
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with
Epstein, accepted the deal, in which Epstein would plead guilty to one count of
aggravated assault with intent to commit a felony, be placed on five years’
probation and have ho criminal record. The deal also called for Epstein to submit
to a psychiatric and sexual evaluation and have no unsupervised visits with,
minors, according to Recarey’s report. The plea bargain was made in connection
with only one of the five alleged victims, the. report states.
Fronstin - who declined to comment on the case - was subsequently fired and
veteran defense" attorneyJack Goldberger was hired. He denies there was any
agreement by any 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 ofthe men. Police
found the vehicles were registered to a private eye in West Palm Beach and
another in Jupiter, according to Recarey’s report.
"I have no knowl...

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.
Afterthe 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. TheNew York Post quoted Epstein’s
prominent New York lawyer, Gerald Lefcourt, as saying-his client:was indicted
only "because ofthe craziness ofthe police chief.”
Reiter has declined to comment on the: case...
Prosecutors have not presented a sex-related'case,like Epstein’sto 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 grandjury proceeding,’’ West Palm Beach defense
attorney Richard Tendler said. “It’s a way for the prosecutor’s office to not take
the full responsibility for not filing th...

11/11/2019
Police say lawyer tried to discredit teenage girls - News - Paim 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 ofwhether wealthy, connected
defendants like Epstein - whose friends- include former President Clinton and
Donald.Trump - are treated differently from others. Once he knew he was the
subject of a criminal probe, Epstein hir.ed 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.”
https://www:pairribeachdailynews:com/article/20060729/NEWS/i 90917573
4/4
CA/Aronbera-000164
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11/11/2019 
Police say lawyer trfed to discredit teenage girls - News - Paim Beach DaHy ~ews - Paim Beach, FL 
Defense attorney Robert Gershman was'. a prosecutor for six yea:rs. "Those .girls 
i 
rtm·st have been.ihctedible or tinttuStW.orthy, I don'tkhow/' he sai'd. 
Other attorneys said Epstein'.s case raises the .issue of whether wealthy, connected 
defendant~ like Epstein -·whose .friends-include former President Ch11tQn anc:i 
Donald.Trump - are treated differe_ntly frQm_ others. Onc:e he knew he,was the 
subject ofa criminal probe, Epstein hir.eda· phalanx of powerful.attorneys such as 
Dershowitz: and Leftourt; who is a past president ·of the National Association of 
Criminal Defense Lawyers. 
Miami lawyer Rox Black ~ who became nationally known when he successfully 
de...

The Palm Beach Post
REALNEWSSTARTSHERE
Expert: Ignorance of age isn1
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. 5j 2006)
Even if Palm Beach money managerJeffrey 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
S50,000 in campaign contributions he received from
Epstein, and Mark Green, a candidate to replace Spitzer in
CA/Aronberg-000165
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SEi~p,grt,: lgo.oia,llCQ :qf 11g1\ is11l't 
:defense: ln: stx)ca:s:es 
Posted Aug 5, 2006 at 12:0l AM 
Updated O~t ~. 2Ql9 atl :3~PM 
(EDITOR'S NOTJ:: This_ stqry origino.lly pitbJi.s_h._e,fi11 The 
Palm Beath Post on Aug. 5; 2006). 
Even if Palm Beach money manager Jeffrey Epstein didn't 
kn9wth;i.t_ grrls wh_o poHc~ say gave, hi111 sexµaJ massage,s ~l 
his Intra.coastal home were under the legal a·ge, that alone 
wouldn't have exempted him from criminal.charges of 
sexµal activity with,rrii_no_rs. 
,;Ignorance is not a valid',defense," said Bob Dek...

his current job, has returned Si0,000 to him because ofthe
Palm Beach scandal, the New York Daily News has
reported.
i
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. Arid 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 fnet Epstein when she was 15 said he
told her ifshe 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 knowwhether
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 attorneyJack Goldberger maintains that not only
did Epstein pass a polygraph test showing he did not know
the girls were minors, but their stories weren’t credible.
The state attdrriey’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.
i
CA/Aronbera-000166
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his currentjob, has ret:um:ed $10,000 to him because ·of the 
Palm Beach scandal, the New York Daily News has 
re...

“A prosecutor has to look at it in a much broader fashion,” a
state attorney’s spokesman said last-week.
■
rtTKWQENT
0
EL-'1
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 arid
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.
CA/Aronberg-000167
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CA/Aronberg~000167 
''.A prosecutor has to look atit in a much broader fashion/ a 
state attorney's spokesman said last'week. 
Epstein hi'r.ed Haivatdlaw ProfessorAlanDershowitz 
whe1Jlte ):,e~ru.ne: awa.re. he was under investigation, and 
Dershowitz,.gave prosecut0,rs information. that sorpg of the 
allegedvittims had sI5oke ofusing alcohol and marijuana on 
a pop11lar Web site, according;toa Palm Beachpolice 
report. 
Prosecutors:typi,caily,c.onsider two ,things in deciding 
'whether to charge somebody with sex-related offenses 
a,ga.inst mipop; -whether there is sufficient evide·nce an:d 
whether iliere is 'a public in_teresti:n d.oiI1g so, Dekle said, 
If two teens are in a s~xµal relationship anc:l the :bpytµrns 
1 S before tli:e girl, he could be, chatged With a sex <:time if 
the: sex condnues,. Then~ w9uld:be no publ...

Still there is a "universal constant” in prosecuting these
j
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.
1
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 ofthe alleged victims in the Epstein case returned to
his home multiple times for the massage sessions and the
S200 to S300 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 againstyou in a child
sex abuse case. Prosecutors normally try to be very Careful
in filing those cases because they know what they’re getting
into. There is no such thing as an iron-clad child sexual
abuse case.”
CA/Aronberg-000168
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Still there is a ''universal constarit" in prosecµting th,ese1 
. 
. . 
. . 
J 
cases, Dekle said. Men who ,exploit underage children for 
-
I 
sex often carefully choose their victims irt ways that will 
minimize the risk to them,...

The Palm Beach Post
REALNEWSSTARTSHERE
'
i
Epstein camp calls female accusers
liars
Posted Aug 8,2006 at 12:01 AM
Updated Oct 3, 2019 at 3:35 PM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on Aug. 8, 2006).
Attorneys and publicists for Palm Beach financierJeffrey
Epstein went on the offensive Monday, contending that
teenage girls who have accused Epstein of sexual
shenanigans at his Waterfront home are liars and saying
that the Palm Beach Police Department is 'childish.”
"There never was any sex between Jeffrey Epstein arid any
underage women," his lead attorney, Jack Goldberger, said
frbiri 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 arid surveilling his home, Palm Beach police
concluded there was enough evidence to charge him with
sexual activity with minors. When the. grand jury indicted
CA/Aronberg-000169
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I 
. . 
I 
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Epstein on the less serious charge, Police ChiefMichael
Reiter referred the case to the FBI to determine whether
there "were federal law violations.
After a spate of stories about the case last week, New York
publicist Dan Klores - whose client list has included Paris
Hilton and Jennifer Lopez - said on Saturday that Epstein’s
camp was ready “to get their story out."
They did that Monday via Goldberger and a Los Angeles
publicist for Miami criminal defense attorney Roy Black,
who also has represented Epstein in the case.
"We just think there has been a distorted view of this case
in the media presented by the Palm Beach police,”
Goldberger said.
Reiter has consistently declined to comment on the case
arid 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.
CA/Aronberq-000170
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Epstein on the'Ie~s serfous charge,-Pohce Chief Michael 
Reiter referred the ,case to the FBI to, determine wheth~r 
there were federal law violations; 
After a spate of stories· about the case last week, New York 
publicist Da11 Kl ores - whose client 11st has :included· P.aris 
Hilton andJenniferLopez - s_aid on. Saturday that Epstein's 
camp was ready "to ·~et their story out.'; 
They did that Mondayvia Goldberger and a Los Angeles 
publicist for Miami .criminal :pefense attorney Roy Slack, 
who .also has represented Epstein in the case. 
"We just-think ther.e has been a: .distorted view·of tliis .case 
in,the media presented by the Palm Beach police;" 
Goldberger said. 
Reiter has consist:entiy dedined to comment on the case 
artd did not respond to·a request for corn:ment Monday: 
The implitat'ioh tharState Attorney Barry Kristhetwas 
ea,_sy on Epstein by presendng the case to a grand jury 
r_ather than tiling charges...

The Palm Beach Police Department was "happy and
[
ecstatic” that the panel was going to review the evidence. T
think what happened is they weren’t happy with the. result.
They decided to use the press to embarrass Mr. Epstein.”
i
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 ro
require your disqualification from the prosecution ofthese
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 ofthe 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 histori es of drug abuse and thefts. “These women are
liars. We’ve established that.”
But why would they all invent their stories about meeting
Epstein for sexual massages?
“I don’t have an answer as to what was the motivation for
these women to come forward and make these allegations,"
Goldberger said.
I
I
CA/Aronbera-000171
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
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i 
The Pafm Beach Polii;:e bepartment was "happy and i 
. 
I 
ecstatid' that the ·p:anel was going to review the evidence. ''I 
think wha:r happened.is they were:n\ happy with the tefult. 
--
- --
I 
They decided to use the press to embarrass Mr. Epsteil" 
I 
But records show ihat Reiter wrote Krischer on May 1 :-
--
I 
we...

Newspapers'
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•
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Reiter focus of fire in Epstein case
Clipped By:
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reiter_m
Sat, Apr 22. 2017
Copyright © 2019 Newspapersicom. All Rights Reserved.
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CA/Aronberg-000172
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
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News p,9(:)e_t§-
b,;~1!10~·es1!):' 
The Palm Beach Post ('Nest Palm Beach, Flonda) • 14 Aug 2006, Mon• Page 7 
Reiter focu~ of fire in Epstein case 
Clipped By. 
reiter;.m 
Sat',_ Apr 22, 2017 
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CA/Aronberg..-000172 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 

The Palm Beach Post
REALNEWSSTARTSHERE
r
i
Delays in Epstein case unusual,
i
lawyers say
Posted Mar 13, 2007 at 12:01 AM
Updated Oct 3,2019 at 3:48 PM
(EDITOR'SNOTE: 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 Beachcr’s solicitation case:
Nearly eight months after Palm Beach tycoon Jeffrey
Epstein was charged with felony solicitation ofprostitution,
there has been no. discernible progress in his case. No
witnesses deposed. No trial date set. Nothing, save for
routine court hearings reset without explanation.
"Usually that would be unusual/’ said criminal defense
attorney Glenn Mitchell, who has no involvement in the
case.
"As a general rule, it would be unusual for nothing to have
happened,” agreed Michael Dutko, a criminal defense
attorney in Fort Lauderdale. He represents Haley Robson,
20, of Royal Palm Beach, potentially a key witness in the
case.
A routine hearing for Epstein was pulled from the court
docket last week and reset for May 16. The delays and
inaction could be due to a potential federal probe 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.
,
CA/Aronbera-000173
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM
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... - l 
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:•. ., ',• 
,.• '' ·.·' ', .... ' '', ,.,. ·. '' ., I 
I 
e ay.s n1 . ,p_s e:i1un .case~ unusua , 
lai:yets say: 
Posted Mar 13,2007 at 12:01 AM 
Updated bet 3, 2019 at3:48. PM 
(EDITORSNaTE:: This story originally published in The Palm 
Beach Post Ma.rch f:t 2007) 
A federal probe or a plea deal .could explain the wait in the 
Palm Beacher's solicitation case; 
Nearly eight months after Falm Beach tycoon Jeffrey 
Epstefo was charge.d with folony solicitation ofprostituti...

"Highly unusual” is how Palm Beach Police Chief Michael
.r
Reiter described State Attorney Barry Krischer’s handling
•
v
•
.
.
.
.
I
ofthe case in a bluntly critical letter to Krischer last year
before Epstein was indicted;
I
I
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.
Reiters department investigated Epstein for 11 months;
Police sifted repeatedly through his trash and conducted
surveillance on his five-bedroom, 7 1/2-batb, 7,234-square-
foot home oh the Intfacoastal Waterway.
Police said Epstein paid women and girls as young, as 1.4 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 ofthe girls who said
they were with Epstein.
Prosecutors then referred the case to the grand jury rather
than file charges directly against Epstein.
Epstein’s attorneys deny he had sex with underage girls.
The:lawyers say .the girls’ stories' are not credible. But if the
court file is any indicator, ’they’ve made no effort to depose
the girls.
Neither prosecutors: nor defense attorneys have sought to
question Robson, said Dutko, her attorney. She recruited
teenage girls to visit Epstein for massages and sexual
activity,. Palm Beach police said, and presumably would be a
key witness.
CA/Aronbera-000174
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' 
"Highly unusual" is how Palm Beach Police Chief Mic:b:4(;1 
• 
I 
Reiter d~_scdb(;dState _A.tt91;neyJ3;irry Kdscher's handli"hg 
-
. 
. 
. . 
. 
I 
ofl:he c:as_e in a bhmtly critical leuert:o Krischer la.st ye·ar 
before Epstein was indicted, ...

Epstein’s attorneyJack 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 spokeswomanJudy
■
Orihuela said Monday.
State Attorney Krischer did not return a call for comment.
His spokesman, Mike Edmondson, declined to say whether
federal investigators are delaying the Epstein case. But, he
added, “if another agency is looking at something, we
wouldn’t want to step on their toes.”
Attorneys say inertia in a criminal case often points to a
pending plea deal,
“It would not. surprise me 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
maybe ordered to undergo a psychological evaluation,
counseling or other conditions in return for dropping the
charge.
CA/Aronberg-000175
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_Epste1n'' s .attorney Jack Goldberger did not return phorte 
messages. 
A sourc·e dose to. the case :suggested it ·is lantuishing 
pendin~ a decis'ic>ii bytheFBI chi whetherto refer itto 
federal pr9secµtors. 
"Westillhave.a,.pe_nd.ing case/ FBI spokeswomanJudy, 
Orihuela said Monday. 
State Attorney Krisclier did not return a call for comment....

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,.
CA/Aronbera-000176
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Edmondson, spokesman for Stat~ Attorney Krischer,, said 
there is no plea offer and' no request for t:he prose-cutio~ to 
show its ta:tds. 
"To my knowledg~, it's never: happened before on a filed 
ca_se/ he s.aiq_. 
CA/ Aronberg-000176 
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252 / 278 - Thursday, October 18, 2007
;
I
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 hisLeip 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 1.6 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 I6-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 Lcfcourt, said, "The girl has admitted she is insane, but she can
re...

The Palm Beach Pest
REALNEWSSTARTSHERE
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
Paint Beach Post onJuly 1, 2008)
Jeffrey Epstein will serve 1 1/2 years on teen solicitation
charges.
He lives:in a Palm Beach waterfront mansion and has kept
company with the: likes of President Clinton, Prince
Andrew and Donald Trump, but investment bankerJeffrey
Epstein will call the Palm Beach CountyJail home for the
next 18 months.
Epstein, 55, pleaded,guilty Monday to felony solicitation of
prostitution and procuring a person under the age of 18 for
prostitution. After serving 18 months in jail, he will be
under house arrest for a year. And he. will have a lifelong
obligation to register as a sex offender; He must submit to
an HIV test within 48 hours, with the results being
provided to his victims or their parents.
As part of the plea deal, federal investigators agreed to drop
their investigation of Epstein, which they had taken to a
grandJury, 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, 38; 5 million Intracoastal home.
Police concluded that there were several other girls brought
in 2004 and 2005 to an upstairs room at the home for
similar massages and sexual touching.
CA/Aronberq-000178
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.. 
ltaltn :B·e.·a:cbe,r: p_l~ads ln sti '.;~~ie~ 
Po:st~d Jul 1, 20Q8 at 1_2:01 AM 
Updated Oct 3, 2019 at 1:47 PM 
(EDITOR'S NOTE; This ~_tory originally published in Th~ 
Palm Beach. Post onjuly-1, -2008) 
Jeffrey Epstein will serve J 1 /2 years on teen solicitation 
charge,s. 
He Hv~s:in a PalmBeachwat~.r_fr9~t rnansiQn: ~9 J:.ia,~ kept 
companywith ·the· iikes of President C...

The indictment charged Epstein only with felony
;
solicitation ofprostitution. The state attorney’s office later
added the charge ofprocuring underage girls for that
'
purpose.
Prosecutor Lanna Belohlavek said 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 ho criminal record and hot 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 sneaker's. 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
uhsupervised contact with anyone younger than 18 and
neither own nor possess pornographic or sexual materials
"that are relevant to your deviant behavior,” the judge said.
Epstein will be allowed to leave home for work. The New
York-based money manager told the judge he has formed
the not-for-profit Florida Science Foundation to finance
scientific research. "I’m there every day,” Epstein said.
The foundation was incorporated in November. Epstein
said he already has awarded money to Harvardand MIT.
CA/Aronberg-000179
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The. indictment charged:Epstein only with felony 
solicitation ofprostitution. The state attorney's office l~te:t 
a,dded the chc1.rge of procuring underage: girls for that 
1 
purpose. 
ProsecJ.1tQr La·nna B:efohfa...

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
Manhattan
mansion.
“It’s validation ofwhat we’re saying; in the civil cases,” said
Miami attorneyJeffrey Herman, who represents the alleged
victims in the federal lawsuits. West Palm Beach attorney
Ted Leopold.represents one alleged victim in a civil suit in
state court. He 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 Palin 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
sessions.
Tm like a Heidi Fleiss,” Haley Robson, now 22, told police
about her efforts, in recruiting girls for Epstein.
There was probable cause to charge Epstein with unlawful
sex acts' with a minor arid lewd arid lascivious rnolestation,
police concluded.
CA/Aronbera-000180
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When he is released.from jail, there is a chance that Epstein 
will be forced to move. Sex offenders ·are hot allowed to live 
within 1,900 f~~t qfa s_c)109l, P?-fk qr ()tll,~r are?-s·where 
children may gather-. No· determination has been made as to 
whether Epstein'...

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 Reiterwas 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 ofhigh-priced lawyers - including
Harvard law professor and author Alan Dershowitz - and
public, relations, people who questioned Reiter's competence
and the yictims’ 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 Goy. 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.
Staffwriter Eliot Kleinberg arid foririer.staff researcher'
Michelle Quigley contributed to this story.
CA/Aronbera-000181
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The state attorney's office. sa.id q:uestions about the _girls' 
credibility l~d it to take the unprecedented step of 
presend.ng the e_vid~nc:e'. ;igiJcins,t Epsteh1 to a ,g_rMcl jll_ry, 
rather than-directly chargi'n:g him. 
Pa.Im Beach Police Chief Michael Reiter-was flirioµs_ with 
State Attorney'Barry Krischer,saying ina May 2006 le~tet 
that the prqsecutor sholJ}d d1squ;ilify himself "I c::ontimie to 
find yout office's treatment c>fthese cases highly unusual'," 
he wrote. He then asked fonmd got a..federa.l investigation. 
...

'The Bata Beach Post
REALNEWSSTURTSHERE
Jeffrey Epstean: Scientist,
Stuntman, ‘sex shve’ visit jailed
tycoon
By LARRY KELLER / Palm Beach Post Staff Writer
Posted Aug 13,2008 at 12:01 AM
Updated Jul 16.2019 at 4:54 PM
TycoonJeffrey Epstein, mingled with ah 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 how 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 onJune 30 to two prostitution-
related charges and was sentenced .to 18 months in jail,
followed by a year of house arrest'. Epstein paid teenage
CA/Aronberg-000182
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lef:fre·-; E' :slein: Scienlisl 
. 
' )J ·- p ... -· --. -.. - . -- . .. ' 
stuntm-an', '·stot slalltf visit j'.a'iled: 
ty1;0-0J.l, 
ey· LARRY KELLER/ Palm Beach Post Staff Write'r 
Postea Aug 13, 2008-at 12:01 AM 
Updated Jul 16, 2019 .at 4:54 PM 
Tycoon Jeffrey Epstein mingled with ah eclectic mix of 
people1 including beautiful young women! before he got 
into trouble for paying teenage: girls to give him s_exual 
massages at his Palm. Beach mansioh., 
Not much has changed; ever...

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 Julyincluded:
- 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 telephone, she declined to discuss Epstein.
- Nadia Marcinkova, 23, whose family in Yugoslavia
Epstein paid money to so that he could bring her to the
United States to be his “sex slave,” two teenage girls told
police. One. girl told police that Epstein instructed
Marcirikova arid 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 tirries in 13 days. She lists her address as on the
Upper East side of Manhattan, not far from Epstein's
enormous apartment.
- Roger Schank, 62, founder of the Institute for Learning
Sciences at Northwestern University and art expert On
artificial intelligence, paid one visit to Epstein. Schank has
written numerous books on that subject and has a doctorate
degree fforri 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 Stuart, and records show he also owns a home
in Lake Worth.
CA/Aronberg-000183
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.;-
girls $200 to $300 irt 2004 and 2005 for massages in his 
home. that sometimes included sexual touc:hing, Palm Beach 
pol_ice. s~id. 
Bis. ja,jl vis_itors jn,Jµly{nclu.qecl: 
- Sarah Kellen, 29, wh_...

Epstein has financed a number of scientists over the years,
including Nobel Prize winners. He gave $30 million to
Harvard University in 2Q03. In November, he: formed the
not-for-profit Florida Science Foundation, which he said
finances scientific research.
- Igor Zinoviev, a Russian mixed martial arts fighter, who
coaches a Chicago team in the International Fight League,
He also has worked as a personal trainer,, celebrity
bodyguard and movie stuntman, according to the league’s
Web site, The NewJersey resident visited Epstein seven
times in July.
Zinoviev, Schank and Marcinkova could not be reached for
comment,
Staff researcher Niels Heimeriks. contributed to this stoty:
CA/Aronberg-000184
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Epstein has financed a number of scientists over the years, 
including Nobel Prtze winners. H~ gave$30 IIlillJon to: 
Harvard University in 2003. In November, he: formed tpe 
hot-for-profit Florida Science Foundation, which he said 
finances scientific research. 
- lgpr Zinpviev, a Ru~sian .mixed rnartial arts fighter, who 
coaches a Chicago· teaITI in the Inte:rn:atio_nal Fight L!;!agµ,e. 
He also has worked as a personal trainer,. celebrity 
body,g\lard and 111ovie stuntman1 according to the league's 
Web site. Th!;! New J~r~ey resident: yi~itedEp~t~in seven 
times irtJuly. 
Zinoviev, Stharik and Marcinkova could rtot be r.eached for 
c.omrne_nt. 
Staffresearcher Niels Heim~riks. contdbut_ed to this ~tory: 
CA/ Aronberg-000184 
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Palm Beach DailyNews
Billionaire sex offender leaves jail
six days a week for work
Posted Jul i, 20,08 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 attorneyJeffrey Herman represents six young
women who’ve sued Epstein, claiming he sexually abused
them at his Palm Beach home when they were minors.
Herman said he received a letter about the work-release
program from the U.S. Attorney’s Office within the past
few days. But Herman says Epstein had,been, out on work-
release for several weeks before the notification.
“My clients expressed shock and disappointment,” Herman
said. “I find it incredible that he’s on work-release in the
community and my clients aren’tnotified ofthis and we get
this letter weeks after the fact.”
Jack Goldberger, Epstein’s criminal attorney, said the
CA/Aronberq-000185
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BUlbuiair, s111 offPnd:Q~ .IQa.v,sJa:il 
six :da .. s a;··wee:kJrir \w_ork 
................... ¥ ........... .' .............. ·--
-····· , ....... . 
Posted Jul 1, 20.08 at 12:01 AM 
Updated Oct 4, 2019 at 9:27 AM 
Palm ~ea,ch bi.1Honc1ire Jeffrey J;pstein,. who's serving 18 
months.'in jail for soliciting an underage girl for 
prostitution, .is allowed to leave the Palm Beach Cou,11ty 
StocJ<,ade s....

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 guiltyJune 30 to two felony counts:
soliciting prostitution and procuring a person under 18 for
prostitution. As part ofthe plea agreement, Epstein must
serve one year Of house arrest and register as a lifelong sex
offender.
CA/Aronberg-000186
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arrangement is not unusual. 
"He goes to work every single, day an-d goes back to ja,il at 
ni~ht, justlike everybody else (in the pro~tam}," 
Goldberger said. 
Epstein pleaded g_uiltyJune 30 to two felony cotlilts: 
soliciting prostitution and procuring a: person U;I1der 18 for· 
prostitution. As part of the plea agreement, Epstein must 
setve·oneyeat of house arrest and register as a lifelong sex 
of{en<:le.r. 
CA/ Aronberg-000186 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 

The Palm Beach Post
REALNEWSSTARTSHERE
Women want; Epstein sax plea deal
unsealed'
Posted Jul 1, 2008 at 12:01 AM
Updated Oct 2,2019 at 2:23 PM
(EDITORS NOTE: This story originally published in The
Palm Beach PostJune 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 ofjudicial 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 dr a compelling government
interest.
Yet no notification or reason occurred in Epstein’s case,
according to court records.
CA/Aronberg-000187
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:women.1 w;anl Epsl1ih s~lt ple_a. dtal 
unseaJed' 
Posted Jul 1, 2'008 at 12:01· AM 
Updated Oct 2, 2019 at.2:23 PM 
(EDITOR'$_ NOTE: This story originally publishe,d in The 
Palm Beach Post June 10, 2009)' 
Their: attorneys will ~s,k a jµdge to open Jeffrey Eps.tein's. 
records. 
When wealthy money manager Jeffrey Epstein of Paim 
Beach pleaded guih:ylast year to procuring teens for 
pros_titution, h1s. case d_etour~d aro:µ»dJq<:al a,ndstate rules 
regarding tne ;sfaling of court do_cume·nts. 
At a: plea conference on the state chars.es, a judge, a defense 
lawyer and.a prosecutor huddled at the bench and decided 
that a, dgal Epste111 ha:d stru<:k wifu federal pro...

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,
Countyjudge Deborah Dale Pucillo.
Epstein,now faces at least a dozencivil 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 CircuitJudge Bill Berger, now in
private practice arid representing one of the women.
The Palm Beach Post also will ask Colbath to unseal the
agreement., Post attorney Deanna Shullmari 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.
CA/Aronberg-000188
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Epst~in's own atto_rneys,. in .federai filings, have·referred to 
his contide-ntial deferred prosecution a~teertieht with·the 
U.S. attorney's office; struck in Septerriber 2007, as 
"unprecedented"...

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 activity,
and then being paid afterward.
At Epstein's plea conference last year, his attorney, Jack
Goldberger, and then-Assistant State Attorney Lanna
Belohlavek approached Pucillo in a sidebar conference.
Pucillo, who had left the bench nine years earlier, was
filling in temporarily as a senior judge.
According to a transcript, Goldberger told Pucillo: that
Epstein had entered a confidential agreement with the. U.S.
attorney’s office in which federal prosecutors brokered not
pursuing charges against him 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"
arid launched an all-out inquiry into, sealirig 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, arid this court is fully cornrhitted 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.
CA/Aronbera-000189
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During a Palm Beach .Polite Department investigation/ five 
victims and. 17 wit11esses gave stateinents, T~ey fol~ qf 
young wpmen brollghtby his assis_ta,11ts to EP,stein's 
mansion on 'El Brillo Way for massages and sexual activity, 
and thert being paid afterward. 
At Epstein's plea conference last year! his attorney,Jack 
Golq.berger,, and then-Assistant St~te Atto.rney Lanna 
Belohlavekapptoached Pu...

The Mm Beach Post
MkIwWe
I
Epstein secret,pact withMs
reveals “highly unusual” terms
Posted Jun 10,2009 at 12:01 AM
Updated Oct 4,2019 at 9:23 AM
(EDITOR S NOTE: T7iis story originally published in The
Palm Beach Post on September 19, 2009)
A secret non-prosecution agreement multimillionaire
financierJeffrey Epstein struck with federal prosecutors is
being called “highly unusual” by former federal prosecutors
and downright outrageous by attorneys now representing
young women who serviced him.
The deal reveals that the FBI and the. U.S. Attorneys Office
investigated him for several federal crimes, including
engaging minors in commercial sex. The crimes are
punishable by anywhere from 10 years to life in prison.
But federal prosecutors backed down and agreed to recall
grand jury subpoenas if Epstein pleaded guilty to
felonies in state court, which he
ultimately did. He received an 18-month jail sentence, of
which he served 13 months.
The U.S. Attorney’s Office also'agreed not to charge any of
Epstein’s possible co-conspirators: Sarah Kellen, Adriana
Ross, Lesley 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.
CA/Aronberg-000190
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.Ep:sfdirt se.9};ret.i.Plf;l wil.hA ff)d'.s 
teveals "hJ 'ht·; :un11,stud" terms 
.. - -
g _y -
-
---
-
--
-
Posted Jun 10, 2009 at 12:01 AM 
Update_d Oct 4, 2019 at 9~23 AM 
(EDITORjs: NOTE: This story originaJly p_ublfsbe_d {n 'fh_e 
Palm Beach Postiin September 19, 2009) 
A sec:ret n_qn-prosec;utiqn a_greement multimillionaire 
financier Jeffrey Epstein struck ·with federal prqsectttor~ is 
being_ called "highly unusual"· hy fohn.er federal :prosecutors 
~ng do...

MarkJohnson of Stuart, a former federal prosecutor.,
described the disparity in potential sentences as unusual,
But even more so; a provision bn attorney payment.
The first draft of the agreement in September 2007
required that Epstein pay an attorney -- tapped by the U.S,
Attorneys Office and approved by Epstein -- to represent
some of the victims. That attorney is prominent Miami
lawyer Bob Josefsberg.
But an addendum to the agreement Signed the following
month struck Epstein’s duty to payJosefsberg 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, Tve 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
of 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 ofit,” 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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Mark Johnson ofSt:uart, a former federa:lprosecutor., ' 
I 
aesttibed the. disparity in:poterttial se...

other young women to lure them to his Palm Beach
mansion. They walked away with between $200 and
$1,000.
Former CircuitJudge Bill Berger, also representing victims,
called the agreement a "sweetheart deal."
“Why was it so important for the government to make this
deal?” Berger asked rhetorically. “We have not yet had ari
honest explanation by any public official as to why it was
made ... and why the victims were sold down the; river.”
Former federal prosecutor Ryon McCabe described the.
agreement as “very unorthodox:” Such agreements, he said,
are; usually reserved for corporations, not individuals.
“It’s very, very rare. I’ve never seen or heard of the
procedure that was set up here,” said McCabe, who has no
involvement in any Epstein litigation.
“He’s essentially avoiding federal prosecution because he
can afford to pay that many lawyers to help those victims
review their cases..;. If a person has no money, he couldn’t
be able to strike a deal like this and avoid federal
prosecution.”
The backroom deal with federal prosecutors'is all the more
interesting in light ofthe legal powerhouses who have
worked for Epstein, including Harvard professor Alan
Dershowitz and Bill Clinton investigator Kenneth Starr.
Lefcourt is a past president of the National Association of
Criminal Defense Lawyers.
Epstein’s local, defense attorney, jack Goldberger, issued a
statement Friday saying he had fought the release of the
sealed agreement to protect the third parties named there.
“Mr. Epstein has fully abided by all of its terms and
conditions. He is looking forward to putting this difficult
period in his lifebehind him. He is continuing his long¬
standing history of science philanthropy.”
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other yo:u,.ng wome-n to lure them tQ his Palm Beach 
mansion. They walked away with between $200 and 
$1;000. 
Fornier Circuit Judge Bill Berg¢r, also representing victims, 
c;illec;l ...

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..
"1 continue to find your office's treatment ofthese cases
highly unusual,” Reiter wrote. He then asked for and got
the federal investigation that ended in the sealed deal.
"The Jeffrey Epstein matter was an experience ofwhat a
many-million-dollar defense can accomplish,” Reiter told
the Palm Beach Daily News upon his retirement.
CA/Aronberg-000193
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The iI1vestigation trigge_r_ed teil~ions between polic;e and 
·prosecutors I with then-Palm B.each Chief Michael. Reitrr 
saying in a: May 2006 letter to then ~Sta:te Attorney Ba.try: 
Krischer that the chief prosecutor should disqualify himself., 
"I .c9:rjtinue to find. yo.ur qffice's treatment of these cases 
highly unusual," Reiter wr.ote. ,He then asked for ,md.got 
the federal ,investigation that ended in the sealed deal. 
"TheJeffrey Epstein.mattet:was ah experience ofwha:t a 
many-milHon-clollar defonse· can accomplish," Reiter told 
the Palm Beach Daily News upon his retirement. 
CA/ Aronberg-000193 
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187 / 278 - Wednesday, January 2-7, 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
Tn a decision that could spark, a constitutional, showdown over privacy fights, ajudge
Tuesday gave lawyers representing multimillionaire sex offenderJeffrey 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 a video of Epstein being asked whether he ...

The Mm Beach Post
REALNEWSSTARTSHERE
Epstein Journals FindingsCould
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 Poston March 20, 2010)
A purloined journal that is said to 'contain the names' of
"hundreds” ofvictims of convicted sex offenderJeffrey
Epstein could be used to,reopen the investigation into the
multi-millionaire’s appetite for teenage girls, an attorney
representing seven of the victims said Friday.
New details about the contents of the journal were released
this week when.Alfredo Rodriguez,,who worked as a
property manager for the Palm Beach resident, pleaded
guilty to obstruction ofjustice for lying to federal agents:
when asked if he had any information about.his former
boss’ criminal activity. He later tried to, sell the journal he
stole from Epstein for $50,000 to an unidentified person,
who alerted authorities, according to court records.
As part of the plea agreement, federal prosecutors said the
journal "contains:information material to the Epstein
investigation,, including the names ofmaterial witnesses
and additional victims.”
"Had theitems 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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By .JCln~MusgrClv.e: 
Posted Sep 17, 2019 at 12:01 AM 
Updc;iteg 0Gt 1, 20l9 at 1 Q:51 AM 
(EDITOR'S N'PTE: This story originczlly pukl~she<J-frz J]w 
Palin Beach Poston March-20; 2010) 
A purloined journal that is said to contain the n:am:es· of 
"lrnndreds" qfvjc;tims of convic;ted se~ offender Jeffrey 
Epstein could be, used to ,reop·en the investigation in to the. 
multi-millionaire's appetite for teenage girls, art attorney 
rep.r:e.senti11,g s_eye.11 of.the victim~ said Friday. 
New de...

Instead, prosecutors short-circuited the grand jury
investigation and cut a deal with Epstein. They agreed hot
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 ofthe
roughly 18women who have filed civil suits against
Epstein, said the new information could trump the so-
called non-prosecution agreement.
The multifaceted agreement, he said, deals only with a
specific list ofvictims that the U.S. Attorneys 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- oyer the journal to federal agents,
Rodriguez told them he knew his former boss was haying
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 $8.6 million mansion. He had seen
pornographic images of young girls on Epstein’s computer,
according to court records'.
Neither Epstein’s criminal defense attorney, Jack
Goldberger, riof attorney Robert Critton, who represents
Epstein in the civil lawsuits, could be reached. Federal
prosecutors have consistently declined comment.
The wording ofthe controversial agreement is: unclear. It
says federal prosecutors would provide Epstein’s attorneys
“with a: list of individuals whom it has identified as victims."
Miami attorney Robert Josefsberg was. appointed to
CA/Aronberq-000196
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Instead, prosecutors short-circuited the grand' jufy 
investi_gati6n arid cut a deal with Epstein. They agreed iiot 
tQ pµr.stH~ (ec:ie:ral ~tu1rge$ ifhe didn't contest pr...

represent any of the victims on the list who wanted to
pursue Epstein in civil court-. As part of the agreement,
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@pbp.ost.com
@pbpcourts
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represent any of the victims on the list who wanted to; 
pursue Epstein in .civii court, As pI1.rt of the agreement;: 
I 
Epstein is to pay for Josefsbetg to represent the women, 
Some of the women; most identified as Jane Doe in 
law~uits, h;id :ah:eady hired attorneys to r~present 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 RQdriguez stole. "It's another piece of evidence that 
shows our clients were at Epstein;s fnansion/"he said. 
Rodriguez told ptos·etutofs he didn't turn over the journal 
when both FBI and Palm Beachpolic;:e c1sked for it becal.}se 
he wanted money for it. He a]so sa:id he was afraid Epstein 
would make him iidisappear.;'·The information, he told 
investigators~ was his "insurance poli_cy." 
He faces ama,ximum td·years fn pri,5Qnwhen he is 
sentenced on June 18. 
jane_musgrave@pbp.ost.com 
CA/ Aronberg-000197 
FILED: PA...

The Palm Beach Post
Ml. NEWSSTARTSHERE.~
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 suedhim.
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 St million to each of the three women Edwards represented.
Identified in court papers only by their initials or pseudonyms because of the nature ofthe
allegations and their youthful, ages, L.M. Was paid $1 million, E.W. $2 million andJane Doe
$2.5 million, Edwards said ofthe 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 byother young women against Epstein, claiming he paid them for sex
when some were as young as 14 years old.
AttorneyJack Scarola, who is representing Edwards, said his client was compelled to divulge
the confidential settlements to answer questions posed byEpstein’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
Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.
CA/Aronberg-000198
FI...

The revelations’of the settlements came as part of an ongoing lawsuit that started as a dispute
between Epstein and Rothstein, both billionaires.
i
A year after Epstein in 2008 pleaded guilty to solicitation ofprostitution- 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 fold they
could get a cut of the cash.
One ofthe high-profile people Rothstein used tolure 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 ofthe
trial, in part, because she claimed she has been unable to talk to her client since his estate on his
private island in the;U.S. Virgin Islands was devastated last month...

t
Pointing out Epstein’s enormous wealth and his private jet, 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 proof, such as an affidavit from Epstein, to shore up her claims.
Still,. Hafele gave Coleman extra time to respond to various motions that he will have to decide
before the case goes to trial.
DespiteScarOlas insistence that Edwards had nothing to do>with.Rothstein's Ponzi scheme,
Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein's
well-known friends, such as now President Donald Trump, former President Bill Clinton and
illusionist David Copperfield, she asked. He used the celebrities as a draw, she said.
“The Epstein cases were used to fleece money and defraud investors,” she said.
Edward’s malicious prosecution case has been difficult for both sides because bdth.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 victims,
CA/Aronbera-000200
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Palm fetch DailyNews
t
Judge rules feds’ agreement with!
Jeffrey Epstein past violated teen
victims’ rights
By Jane Musgrave
Posted Sep 17,2019 at 4:02 PM
Updated Oct 8,2019 at 12:31 PM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on February, 22, 2019)
Federal prosecutors violated the rights ofJeffrey Epstein’s
teenage victims by failing to reveal they had dropped plans
to prosecute the billionaire on dozens of federal charges in
connection with the girls’ claims that he paid them for sex
at his Palm Beach mansion,, U.S. Districtjudge Kenneth
Marra ruled on.Thursday.
In a blistering 33-page ruling, Marra meticulously and
methodically detailed the numerous steps federal
prosecutors took to hide the agreement from, more than 40
young women who claim Epstein paid them for sex when
they were as young as 14.
“While the government'spent untold hours negotiating the
terms and implications of the NPA with Epstein's attorneys,
scant information was shared with the victims," Marra
wrote. “Instead,;the victims were told to be patient’ while
the investigation proceeded.”
By then, it was too late. A deal had already been cut with
then-South Florida U.S. Attorney Alex Acosta and Epstein’s
attorneys to shelve a. 52-page federal indictment against
Epstein, a former math teacher turned money manager
who counts Presidents Donald Trump and, Bill Clinton
among his friends.
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CA/Aronberg-000201 
Jud ei' rule.s Je'ds' ]1 • reaiment. withi 
- _g ········- ,. ·---·· 
__ g _ - -·· .,,, ... , .. 
Je_ff~ey: iEpsteUt: p:a·cf vi:olate'd leeri 
\vi.c:tiJ1ls' ,r,lghls 
ey J.!l~~.M·µ~gr,~~e 
Posted Sep 17, 20·19 at 4:02 PM 
Updated Oct 8; 2019 at 12:31 PM 
(EDITOR'S NOTE: This story ori.ginally publishfd in The 
Pqlm B~qc:h, Post 9n F~b~ciry 22, 2019) 
Federal prosecutors violated the rights ofJe{frey Epstdn!s 
teenage victims byfailihg to reveal they had dropp...

Prosecutors’ failure to alert the young women about the
deal,violated the Crime Victims’ Rights Act, Marra ruled.
“At a bare minimurn the (act) required the government'to
inform,(the young women) that it intended to enter into an
agreement riot to prosecute Epsteiri,” 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' arid
agreed to corriperisate 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, urider 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 Epsteiri
and his young victims for more than a decade.
The chances an accord will be reached are slim, said
attorneyJack Scarola, who is representing the two Jane
Does who challenged the; prosecutors’ actions.
Further, he said, there is no road map to follow, The
lawsuit attorney Bradley Edwards filed on behalf of the two
unidentified young women, clairning prosecutors violated
the federal act, is unique, he said,
“We are: treading on virgin ground, to use what is probably
aft inappropriate phrase in this situation,” he said.
Scarola said he and Edwards will ask that the riori-
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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Prosecutors' failure-to alert the young women about the 
. 
. 
. 
. 
- .. 
. 
. 
. 
-
. 
. I 
deal.violatedtheCrime Victims' Ri...

"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 Rov Black years ago
filed papers asking to intervene on Epstein’s behalf.
The U.S. Attorney’s Office said it wouldn’t comment oh
Marra’s ruling. Neither Black nor New York City attorney
Jay Lefkowitz,,who led efforts to bury the federal
indictment, responded to emails or phone calls for
comment. West Palm Beach attorneyJack Goldberger, who
represents Epstein, also didn’t respond.
Scarola said it is likely Epstein’s star-studded legal team will
argue that Epstein fully complied with the terms of the
agreement he made in 2007 with federal prosecutors and
therefore the agreement can’t be undone.
As he promised,,Epstein pleaded guilty in June 2008 to state
charges of soliciting a minor for prostitution and soliciting
prostitution. He served 13 months of an 18-month jail term
in a vacant wing of the county stockade that he was allowed
to leave 12 hours a day, six days week.
Further, as agreed, he paid settlements to the young women
who sued him. While the settlements were confidential,
court records show he paid three women a total of $5.5
■rnillio'il.
In return, federal prosecutors held up their end of the
bargain. Their investigation ceased.
Haying done all that prosecutors, asked of him, Scarola said
Epstein will make a simple argument: “YOii 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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"I don\ see the gover:tnnerit conceding to that r,emedy,": 
I 
Scarola admitted. Further, he sard, it 1s likely.Epste1n wµl be 
aJloweq to w~igh 1n, Miami .J.ttomey Roy :Black years ago 
fHeci papers asking to intervene: oh Epstein's·behalf. 
The: U.S. Attorney's Offi...

Even if Marfa agrees to toss out the non-prosecution
!
agreement, Scarola conceded that doesn’t mean Epstein' will
I
face federal charges.
'
“The contract can be set aside and the federal government
can attempt to enter into the same agreement,” he said.
“Except the spotlight ofpublic attention, will be on them
and the. 40 victims will be able to explain to the court why
this sweetheart deal should not be approved.”
Scarola said that,prosecutors may have had good reason not
to pursue’Epstein. "There:maybe 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-prpsecution
agreement thrown out, initially described Epstein as "an
awesome man" arid told prosecutors she hoped “nothing
happens” to him. While she later agreed to testify against
Epstein, prosecutors said they feared Epstein's attorneys
would use her words to destroy her if she ever took the
witness stand.
Marra, however, said the young woman’s comments didn’t
mean she wasn't entitled to know about the prosecutors’
plans to drop the charges. “There is no dispute that Epstein
sexually abusedJane Doe 2 while she was a minor,” he
Wrote. “Therefore, regardless of her comments to the
prosecutor, she was a victim.”
Before the case is finally resolved, Scarola predicted that “a
lot of people, are going to have to answer a lot ofquestions.”
CA/Aronberg-000204
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Even if Marra: agrees to toss outthe,non-J_)r.osecution 
1 
I 
agreement, Scarola conceded that doesn't mean Epstein; will. 
face, fedgral cha.rges. 
' 
"The contra_ct c_an he s.et asid¢ an:d the fe:deral gQvernmJnt 
ca.Ii attempt to enter into the sa...

In his ruling, Marfa detailed what appeared to be a cozy
relationship between Acosta, his line prosecutors and
;
Epstein’s team of lawyers. His phalanx of lawyers included
noted Harvard law professor Alan Dershowitz and Kenneth
Starr, the former U.S. solicitor general whose investigation
led to; the impeachment ofPresident Clinton.
Marra describes an October 2007 breakfast meeting
between Acosta, who,is now U.S; labor secretary, and
Lefkowitz shortly after the noh-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 ofthe 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 sighed. "After this
is resolved I would love to buy you a cup at Starbucks .and
have a conversation.”
Many ofthe 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 wehave a conference call to discuss
what I may disclose to ... the girls regarding, the
Agreement,” she asked.
CA/Aronbera-000205
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In his ruling, Marra detailed what appeared to be.a cozy 
relationship between.Acosta, his line prosecutors and ; 
EpsteJ:n's t~am ofla:wyer~. Hi.~ P,ha};in,x of l:1wy~rs i:ndu<led 
note:d Harvard law professor Alan Detshowitz ·and Ken'neth 
I 
Starr, the former U.S. solicitor gene...

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 CRVA was designed to protect victims’ right arid
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.
@pbpcourts
i
CA/Aronberg-000206
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i 
• 
Such cooperation between prosecutors and defens,e 
att_orneys: is unllS\lal, _M,;m::a sa_id. "It wa.s a deviation froµi 
the government's standard practice to negotiate with 
defense counsel abo.uttheextent of crime vic:tiin 
notifications," he wrote. 
Fµrthe_r, he noted, th.at w4en Edwards and hi.s two young 
clients ,asked for: information, they were repeate:dly misled; 
'The. CRV A was designed to protec:t'-vic:tims' tight and 
ensure: thei:r.involvei:n.eIJ.t fo the cdminal justke process," 
Marra wrote .. "When the government giv.es information to 
vittims it c:an11ot be misleading." 
Ultimately; the terms of the non-prosecution.agreement 
were Teve~led only afte.r; Edwards a;id attorn~ys for the 
press suq:::essfully s.ued to make them public. 
jin usgrave@pbp·ost;com 
@pbptotirts 
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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-timeAWBeadier pleads not guilty to sex
trafficking, conspiracy charges in Bderal court in
Ifanhattan
Dressed in a.blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded,riot 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 oh 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 ofyoung women, including many Palm Beach County girls
who were students at...

"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 nonprosecutibn agreement,
promising not to charge Epstein in federal court.
Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning
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 nonprosecutibn agreement
because it contained some significant fine print; said former federal Judge Patil Cassell, who
for years has fought to get the agreement thrown.but. It says only that ho charges could be
filed.against Epstein in South Florida, he said.
Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of
Florida," he said. "The Southern District ofNew York is not bound by that, agreement and
wasn't a signatory of it."
Thatmeans 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 Ting, Epstein or his associates would Call girls while
he was in New York so they would be available for sex once he returned to Palm Beach, the
indictment says. The employees weren't named. They were identified, only as. "Emp...

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 arid 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 getto 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 ah 18-inonth sentence in a vacant wing of the
Palm Beach County Jail - a ceil 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, let's have a proper court case," Frankel s...

"If you believe you arc 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 ofthe FBI's New York office, said after years of being
ignored by federal agents, the victims7 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."
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"If you believe you are a victim of this,iii.an, Jeffrey Epstein, we want.to.he-at from you,"' 
BeIT11~n sai_d.. A specJ,al oumber, l_-8Q0~CALLFBtwill Hnkvictims of al)thorities. 
Bill Sweeney, assistant director of the FBI's New York office, said after years of being 
ignored by federaJ agents, tl)e victims' voic~s will be b~ard. 
• 
• 
·"The Jeffrey Epstein matter is No. 1 ort the major case list in the country," Sweeney said. 
Tumi.ngtp a4ch:ess EpsteiJJ.'.s victims dih:ctly1 he said: "Your bravery may empower others to 
speak out against crimes against them." 
jmusgrave@pbpost.com 
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