146.pdf

Unknown Volume 92 pages

PDF Page
Page 1
Page 1
Page 2
Page 2
Page 3
Page 3
Page 4
Page 4
Page 5
Page 5
Page 6
Page 6
Page 7
Page 7
Page 8
Page 8
Page 9
Page 9
Page 10
Page 10
Page 11
Page 11
Page 12
Page 12
Page 13
Page 13
Page 14
Page 14
Page 15
Page 15
Page 16
Page 16
Page 17
Page 17
Page 18
Page 18
Page 19
Page 19
Page 20
Page 20
Page 21
Page 21
Page 22
Page 22
Page 23
Page 23
Page 24
Page 24
Page 25
Page 25
Page 26
Page 26
Page 27
Page 27
Page 28
Page 28
Page 29
Page 29
Page 30
Page 30
Page 31
Page 31
Page 32
Page 32
Page 33
Page 33
Page 34
Page 34
Page 35
Page 35
Page 36
Page 36
Page 37
Page 37
Page 38
Page 38
Page 39
Page 39
Page 40
Page 40
Page 41
Page 41
Page 42
Page 42
Page 43
Page 43
Page 44
Page 44
Page 45
Page 45
Page 46
Page 46
Page 47
Page 47
Page 48
Page 48
Page 49
Page 49
Page 50
Page 50
Page 51
Page 51
Page 52
Page 52
Page 53
Page 53
Page 54
Page 54
Page 55
Page 55
Page 56
Page 56
Page 57
Page 57
Page 58
Page 58
Page 59
Page 59
Page 60
Page 60
Page 61
Page 61
Page 62
Page 62
Page 63
Page 63
Page 64
Page 64
Page 65
Page 65
Page 66
Page 66
Page 67
Page 67
Page 68
Page 68
Page 69
Page 69
Page 70
Page 70
Page 71
Page 71
Page 72
Page 72
Page 73
Page 73
Page 74
Page 74
Page 75
Page 75
Page 76
Page 76
Page 77
Page 77
Page 78
Page 78
Page 79
Page 79
Page 80
Page 80
Page 81
Page 81
Page 82
Page 82
Page 83
Page 83
Page 84
Page 84
Page 85
Page 85
Page 86
Page 86
Page 87
Page 87
Page 88
Page 88
Page 89
Page 89
Page 90
Page 90
Page 91
Page 91
Page 92
Page 92
Page 1 100% OCR confidence
'***" CASE NUMBER: 502019CA014681XXXXMB Div. AG ***
Fifing # 98869063 E-Filed 11/14/2019 11:06:37 AM
IN THE CIRCUIT COURT. 15th
JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO.:
CA FLORIDA HOLDINGS, LLC,
Publisher ofTHE PALM BEACH POST
Plaintiff
v.
DAVE ARONBERG, as State Attorney of
Palm Beach County, Florida, SHARON R
BOCK, as Clerk and Comptroller ofPalm
Beach County, Florida,
Defendants.......
/
SUMMONS
DEFENDANT:
Dave Aronberg, as State Attorney of
Palm Beach County, Florida
401 N. Dixie Highway
West Palm Beach, Florida 33401
//MM
A lawsuit has been filed against you. You have 20 calendar days after this summons is
served on you to file a written response to the attached Complaint with the Clerk of this
Court.
A phone call will not protect you. Your written response, including the case
number given above and the names of die parties, must be filed if you want the Court to
hear your side of the case. If you do not file your response on time, you may lose the
case, and your wages, money, and property may thereafter be taken without further
warning from the Court. There are other legal requirements. You may want to call an
attorney right away. If you do not know an attorney, you may call an attorney referral
service or a legal aid office (listed in the phone book). If you choose to file a written
response yourself, at the same time you file your written response to the Court you must
also mail or take a copy of your written response to the:
Stephen A. Mendelsohn,
Esquire, Greenberg Traurig, P.A., 5100 Town Center Circle, Suite 400, Boca Raton,
Florida 33486, Telephone: (561)955-7600.
Party
JOINT
ID#. J04
EV#Jq4
DATEadmitted:
Case No. 2019-CA-O14681
JOSEPH ABRUZZO CLERK
CIRCUIT COURT
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/14/2019 11:06:37 AM
*.
Joint Exhibit
J04
C/MArcfWEgJODMQQ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
i 
f ✓....,,, CASE NUMBER: 502019CA014681XXXXMB Div: AG -kttl, 
Filing # ...
Page 2 100% OCR confidence
THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and
a copy ofthe Complaint in this lawsuit on the above named Defendant
DATED on November
,2019
NOV 15 2019
Sharon R. Bock
As Clerk & Comptroller of the Court
IMPORTANTE
Deputy Clerk
DOILY GARCIA
listed ha sido demandado Icgalmente.
Tiene 20 Dias, contados a partir del recibo de esta
notificacion, para contestar la demanda adjunta, por escrito, y presentaria ante este tribunal.
Una Hamada
telefonica no 16 protegera, Si usted desea que el tribunal considere su defcnsa, debe presenter su respueste
por escrito, incluyendo el numero del caso y los nombres de las partes interesadas.
Si usted no contesta la
demanda a tiempo, pudiese perder el.caso y podria.ser despojado de sus ingresds y propiedades, o privado
de sus derechos, sin previo aviso del tribunal Existen otros requisites legales.
Si lo desea, puede usted
consultar.a un abogado inmediatemente. Si no conoce a un abogado, puede llamar a una de las oficinas^de:
asistericia legal que aparecen en la guia telefonica.
Si desea responder a la demanda por su cucnta, al mismo tiempo en que presenta su respueste ante
el tribunal, debcra usted enviar por correo o entregar una copia de su respueste a la persona denominada
abajo coma "Plaintiff/Plaintiffs Attorney" (Demandante o Abogado del Demandante).
IMPORTANT
Des poursuites judiciaries ont etc entreprises contre vous. Vous avez 20 jours consecutifs a partir
de la date de fassignation de cette citation pour deposef une reponse ecrite a la plainte ci-jqinte aupres de ce
tribunal.
Un simple coup de telephone est insuffisant pour vous proteger. Vous etes oblige de deposer
votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties nommees ici, si
vous spuhaitez que le tribunal entende votre cause.
Si vous ne deposez pais votre reponse ecrite dans le
relai requis, vous risquez de perdre la cause ainsi que votre salairc, votre argent, et vos biens peuvent etre
s...
Page 3 100% OCR confidence
’
Filing # 98869063 E-Filed 11/14/2019 11:06:37 AM
;
3
i
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC,
CASE NO.:
Publisher of THE PALM BEACH POST,
Plaintiff,
v.
DAVE ARONBERG, as State Attorney of
Palm Beach County, Florida; SHARON R.
BOCK, as Clerk and Comptroller of Palm
Beach County, Florida,
Defendants.
COMPLAINT
CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Complaint against
Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his official capacity (“State
Attorney”), and Sharon R. Bock, the Clerk of the Court for Palm Beach County, Florida, in her
official capacity (“Court Clerk”), alleges as follows:
JURISDICTION
1.
This is an action within the exclusive jurisdiction of the Circuit Court pursuant to
Fla. Stat. Section 26.012(2)(a).
PARTIES
2.
The Palm Beach Post is a daily community newspaper published by Plaintiff CA
Florida Holdings, LLC, with offices located at 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
CA/Aronberg-000010
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
~Filing# 98869063 E-Filed l l/14/2019 11:06:37 AM 
1 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIATI CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 
COMPLAINT 
CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Complaint against 
Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his official capacity ("State 
Attorney"), and Sharon R. Bock, the Clerk of the Court for Palm Beach Cou...
Page 4 100% OCR confidence
0
I
has authority in grand jury proceedings pursuant to Fla. Stat, section 27.03; He is sued herein in
his official capacity as his office is in possession of documents that are the subject of this action.
4.
Defendant Sharon R. Bock is the duly elected Clerk and Comptroller ofPalm Beach
County, Florida.
She is sued herein in her official capacity as her office is in possession of
documents that are the subject of this action.
INTRODUCTION
5.
In what is now widely if belatedly recognized as a colossal miscarriage ofjustice -
which led to the further needless victimization of countless young girls and women - a wealthy,
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...
Page 5 100% OCR confidence
0
To the contrary, transparency is required to promote public understanding of the criminal justice
1
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 to the grand jury - which would be out ofthe ordinary
for this type of case - gives rise to a strong inference of favoritism and corresponding disregard
for the rights of the minor victims 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 have ordered th...
Page 6 100% OCR confidence
a
i
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
$300. Epstein was 52 years old at the time.
12.
Following this initial report in 2005, the Town of Palm Beach Police, and later, in
2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
disturbingly similar details, with each of the other victims.
4
;
i
CA/Aronberg-000013
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED ...
Page 7 100% OCR confidence
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 of their 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 urgeyou 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
5
CA/Aronberg-000014
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZ...
Page 8 100% OCR confidence
I
that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges
i
against him, which would be public.
I
(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.
6
:
!
CA/Aronbera-000015
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM
NOT A CERTIFIED COPY
that either an arrest warrant be issued for Epstein or the State Attorney direc~ly initiate the charges 
I 
I ...
Page 9 100% OCR confidence
j
(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 of Epstein’s sexual predations. Based on evidence gathered by the FBI,
a 53-page indictment was prepared by the U.S. Attorney’s Office in June 2007. However, at the
request of Epstein’s lawyers, the indictment was never presented to a federal grand jury.
25.
Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta,
negotiated a plea deal with Epstein’s team of lawyers to grant immunity to Epstein (along with
four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
charges.
26.
Throughout the remainder of 2007 and through the first half of 2008, Epstein’s
lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
belief, Epstein’s lawyers insisted that (l)the victims 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.
7
CA/Aronbera-000016
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
(...
Page 10 100% OCR confidence
I
On information and belief, based on public records, former State Attorney Krischer communicated
i
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.”
8
I
CA/Aronberg-000017
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZ...
Page 11 100% OCR confidence
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 of Palm Beach detective who investigated
the case against Epstein.
37.
Upon information and belief, Epstein’s victims were threatened against cooperating
with law enforcement and told that they would be compensated only ifthey did not cooperate with
law enforcement.
B.
Second Epstein Sex Crimes Investigation, Indictment. Suicide: 2019.
38.
On July 6, 2019, Epstein was arrested on federal sex trafficking charges.
39.
Upon information and belief, the United States government’s investigation of new
allegations and charges stemmed, in 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.”
9
,
i
CA/Aronberg-000018
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
N...
Page 12 100% OCR confidence
41.
On July 8, 2019, prosecutors with the Public Corruption Unit ofthe U.S. Attorney’s
office for the Southern District of New York charged Epstein with sex trafficking and conspiracy
to traffic minors for sex. The grand jury indictment alleges that “dozens” of underage girls were
brought into Epstein’s mansions for sexual encounters. A few days later, owing to public outcry
over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,
Alexander Acosta, who by then was serving as U.S.
Secretary of Labor in the Trump
administration, resigned from office.
42.
Epstein was denied bail and was placed into pretrial detention at the federal
Metropolitan Correction Center in lower Manhattan.
43.
On August 10, 2019, Epstein was found dead in his cell at the Metropolitan
Correctional Center. His cause of death was determined to be suicide.
C.
The August 27, 2019, SDNY Hearing: Epstein’s Victims Speak.
44.
On account of his death, prosecutors sought to dismiss the indictment against
Epstein, while maintaining that they would continue to investigate his co-conspirators.
45.
United States Senior District Judge Richard M. Berman ordered a hearing on
August 27, 2019, on the prosecutors’ decision to dismiss the indictment and allowed victims to
speak at the hearing.
46.
In the course of the hearing, more than two dozen victims delivered their personal
stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of
violent rape by Epstein. Many more victims were present in the courtroom but did not testify.
47.
While some questioned the reasoning behind the court’s decision to give the victims
voice after Epstein’s death, District Judge Berman noted that “a public hearing is [the] preferred
vehicle of resolution,” emphasizing that “public hearings are exactly what judges do. Hearings
promote transparency and they provide the court with insights and information which the court
10
CA/Aronberq-000019
FILED: PALM BEACH...
Page 13 100% OCR confidence
may not otherwise be aware of.” Indeed, even Epstein’s defense lawyer noted at the hearing that
I
the court “is the institution that most people have confidence in, in these very troubled times.”
48.
At the August 27th hearing, the girls, now women, spoke about their “exploitation
and coercion,” and to the fact that many of them “were in very vulnerable situations and in extreme
poverty, circumstances where [they] didn’t have anyone on [their] side, to speak on [their]
behalf....” One victim lamented that “as a victim, [she] never got to see what the agreement was
or why the special treatment got approved” in the Florida case years earlier. Another noted how
“completely different” the investigators leading to the 2019 federal indictment were from the
prosecutors in the Florida case, both in their treatment of her and their investigation of her
victimization by Epstein.
49.
A former federal judge in attendance at the August 27th hearing emphasized that
“transparency is one of the overriding objectives in our criminal justice system.”
50.
Nearly all of the victims expressed the conviction that the secrecy that shielded
Epstein has caused them “irreparable harm” and that an opportunity to address his criminal
wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
at least some measure ofjustice to be served 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 world where people can avoid justice if their pockets run deep enough.” In short, the
“unusual” treatment Epstein received in Florida in 2006 based on his wealth, social status, and
connections severely eroded the public’s faith in the integrity and impartiality of the criminal
justice system.
CA/Aronbero-000020
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2...
Page 14 100% OCR confidence
D.
The Palm Beach Post’s Standing and the Public Interest.
51.
Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm
Beach County and the Treasure Coast vicinity.
52.
The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist
three other times.
53.
Beginning in 2004, The Palm Beach Post has extensively investigated and reported
on the allegations against, the law enforcement investigation of, and the crimes committed by,
Epstein and his co-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 Million” published on November 16, 2004,
reporting on the bidding war between Donald Trump and Jeffrey Epstein for the
purchase of a
seven-bedroom estate on 6 oceanfront acres along
the storied ‘Raider’s Row’ ” in Palm Beach.
•
“Indictment: Billionaire Solicited 3 Times” published on July 25, 2006, r...
Page 15 100% OCR confidence
•
“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 office presented the case
to a county grand jury” which “indicted Epstein last week on a single, less serious
charge of felony solicitation of prostitution,” and that “[t]he case raised eyebrows
because the state attorney’s office rarely, if ever, kicks such charges to a grand jury.”
•
“Epstein Camp Calls Female Accusers Liars” published on August 8, 2006, reporting
that “[a] state attorney’s spokesman would say only that the office refers cases to the
grand jury when there are issues with the viability of the evidence or witnesses’
credibility.”
•
“Palm Beach Chief Focus of Fire In Epstein Case” published on August 14, 2006,
repor...
Page 16 100% OCR confidence
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 public access
to the NPA, which was ordered disclosed by this Court on June 25, 2009.
•
“Epstein’s Secret Pact With Feds Reveals ‘Highly Unusual’ Terms” published on
September 19, 2009, reporting that, owing to Epstein’s non-prosecution agreement,
“federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein
pleaded guilty to
felonies in state court” and “also agreed not.to
charge any of Epstein’s possible co-conspirators: Sarah Kellen, Adriana Ross, Lesley
Groff and Nadia Marcinkova.”
The article further reported that,...
Page 17 100% OCR confidence
■
I
i
I
•
“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 ofthe above news articles, in either the computerized format in which they
are maintained in The Palm Beach Posfs electronic archives or the news print edition in which
originally published, is annexed hereto as Exhibit 1.
54.
The press has a constitutional right of access to criminal proceedings, see, e.g.,
Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal
proceedings. Newman v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, “the integrity of the
judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in
proceedings of this kind [pre- and post-trial] as at trial.” Id. at 801; see also Miami HeraldPubl.
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)...
Page 18 100% OCR confidence
has “standing to assert a right to receive speech” by “showing] that there exists a speaker willing
to convey the information to her”).
55.
Because of the unique role performed by the press as a “public surrogate” (Lewis,
426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about
criminal proceedings, news organizations “presumptively have a right to access judicial records,”
Comm’r,Ala.Dep’tofCorr. v. Advance LocalMedia, LLC, 918F.3d 1161,1166(llth Cir. 2019),
and “standing to question the validity of an order restricting publicity because its ability to gather
news is directly impaired or curtailed.” Lewis, 426 So. 2d at 4; see also Carlson v. United States,
837 F.3d 753, 757-58 (7th Cir. 2016) (“[a]s a member of the public, [the Reporters Committee]
has standing to assert [its] claim” to grandjury materials because such materials are “public records
to which the public may seek access, even ifthat effort is ultimately unsuccessful”).
56.
Here, the continued denial of access to information The Palm Beach Post seeks on
behalf of its journalists and the public it serves “unquestionably constitutes irreparable injury.”
Gainesville Woman Care, LLC v. State ofFlorida, 210 So. 3d 1243, 1263 (Fla. 2017); see also
Zerilli v. Smith, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that “the press’ function as a vital
source of information is weakened whenever the ability of journalists to gather information is
impaired,” as it is by Attorney General’s refusal to disclose unredacted report and underlying grand
jury materials).
E.
The Court’s Supervision of the Grand Jury Process and Its Authority to Order
Public Disclosure of the Epstein Evidence.
57.
The Florida Supreme Court has noted that “in states such as Florida, where the
grand jury is preserved, it is an important appendage of the court which impanels it. At the same
time it should not be forgotten that the judge of that court is equally important and he is generally
charged with ...
Page 19 100% OCR confidence
maintain the dignity and the integrity of both the grand jury and the presiding judge.” State v.
Clemons, 150 So. 2d 231, 233-34 (Fla. 1963).
58.
Chapter 905 of the Florida Statutes governs the empanelment and conduct of
Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury
about its legal duties. Fla. Stat. § 905.18.
59.
Florida Stat. Section 905.27(1) provides that “the testimony of a witness examined
before the grand jury ... or other evidence received by it” may be disclosed “when required by a
court... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by
the witness before the court; (b) Determining whether the witness is guilty of peijury; or (c)
Furthering justice.” Fla. Stat. § 905.27(l)(a)-(c).
60.
Further, disclosure is appropriate pursuant to this Court’s inherent authority over
grand jury proceedings because of the exceptional public interest in this case and the compelling
circumstances supporting transparency. Carlson v. United States, 837 F.3d at 766 (“a district court
has the inherent power to disclose [grand jury] materials in exceptional circumstances and
.
.
.
historic importance can be a sufficient reason when there is little countervailing need for secrecy”).
COUNTI
(Florida Stat. Section 905.27)
61.
Based on information learned by The Palm Beach Post through its Florida Public
Records Law requests, law enforcement sources with direct knowledge 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
17
CA/Aronberg-000026
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
maintain the dignity and the integrity of both the grand jury and the pres,iding judge." State v....
Page 20 100% OCR confidence
that precluded his indictment for the serious crimes he committed, including sex trafficking and
sexual assault.
62.
Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein’s
victims and the public, and to provide public disclosure to illuminate whether Epstein received
unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests
immediate public access to the testimony, minutes, and other evidence presented in 2006 to the
Palm Beach County grand jury. In a case of this magnitude and importance, where the accused is
dead and so many 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 this Court, pursuant to Fla.
Stat. Section 905.27(1) and the Court’s inherent authority, order the State Attorney and the Clerk
of the Court to file with this Court copies of the testimony, minutes, and other evidence presented
in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so
that, following an in camera inspection, it can be made available to The Palm Beach Post and the
public on an expedited basis, and grant any other and further equitable or legal relief the Court
deems just and proper.
18
CA/Aronberq-000027
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
that precluded his indictment for the serious crimes he committed, includihg sex trafficking and 
I 
sexual assault. 
62. 
Pursuant to Florida Stat. Section 905.27, in order to furthe~ justice for Epstein's 
victims and the public, and to provide public disclosure to illuminate whether Epstein received 
unreasonably...
Page 21 100% OCR confidence
Dated: November 1'4, 2019
ACTIVE 45678709v3
Respectful ly submitted,
i
GREENBERG TRA UR IG PA.
Attorneysfor CA Florida Holdings, LLC,
Publisher of The Palm BeachPost
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
mendel sohns@gtlaw.com
.hasenh@gtlaw.com
FLSefvice@gtlaw.com
By; h!MichaelJGrygiel_
MICHAEL J GRYGIEL
(Pro Hac Vice application forthcoming)
54 State St., 6th Floor
Albany, New York 12207
Telephone: (518) 689-1400
Facsimile: (518) 689-1499
grvgielm@gtlaw;Com
By:
/s/ Vincent H.Chieffo_
VINCENT H CH1EFFO
(Pro Hac Vice application forthcoming)
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: (310) 586 7700
Facsimile: (310 586 7800
chieflfov@gtlaw.com
rivcraai@gtlaw.com
By:
/s/ Nina 1).Boyajian_
Nina d boyajian
(Pro Hac Vice application forthcoming)’
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: (310) 586 7700
Facsimile:. (310) 586 7800
riveraal@.gtiaw.com
19
CA/Aronbera-000028
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Dated: November I4~ 2019 
ACTIVE 45678709v3 
Respe:ctfully submitted, 
I 
. 
, 
I 
GREENBERGTRAURIG; P.A. 
Attorneysfor CA Florida Holdings, LLC, 
.Puhlis.f1er of Th? Palm Be(ff:hPost 
Stephen A. Mendelsohn, Esq. 
5100 Town Center Circle, Suite400 
Boca Ra1ort,Florida 33.486 
T<dephone: (561)955-7629 
Ff_lcs{mile; (Sql) 338-7099 
By: Isl Stepheh A. Meildelsohii 
STEPHEN A. MENDELSOHN 
Ffqri(ia Bar ~o. 849324 
mendeisohnslahrtlaw.com 
J;iasenh@gtlaw.com 
FLService@gtlaw:com 
By: isl WchaeiJ Grygiel 
MICBAELJ GRYGIEL 
(Pro Hae Vite application forthcoming) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: (518) 689-1400 
Facsimile.: (51 S) 689-J 4.9_9 
.grvgielm@2:tlaw,com 
By'. ./s/ Vii1tentH ,Chieffo 
VINCENTH CHIEFFO 
(Pro Hae Vice appilcati on f o,rthcorn ing) 
184Q Century Pa...
Page 22 100% OCR confidence
EXHIBIT 1
The Newspaper’s Reportage on Jeffrey Epstein
CA/Aronbera-000029
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
EXHIBIT 1 
The Newspaper's Reportage_on Jeffrey Epstein 
CA/Aronberg-000029 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 23 100% OCR confidence
The ManWho Had Everything: Jeffrey Epstein craved big homes, elite friends'and tinder... Page 1 of 10
I
The Palm Beach Post
REALNEWSSTARTSHERE
-
The Man Who Had Everything: Jeffrey Epstein craved big
homes, elite friends and underage girls
By Andrew Marra
Posted JuH 7,2019 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.
Editors Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after
Jeffrey Epstein’s arrest in Palm Beach County on a charge offelony solicitation ofprostitution.
WINGED GARGOYLES guarded the gate atJeffrey Epstein’s Palm Beach mansion. Inside,
hidden cameras trolled two rooms, while the girls came and went.
For the police detectives:who sifted through the;garbage outside; and kept records ofvisitors, it
was the lair of a troubling target.
Epstein, one ofthe most mysterious of the country’s mega-rich, was known as much for his
secrecy as for his love offine things:- magnificent homes, private jets, beautiful women,
friendships with the world’s elite.
But at Palm Beach police headquarters, he was becoming known for something else: the
regular arrival ofteenage girls he hired to give him massages and, police say, perform sexual
favors.,
Epstein was different from most sexual abuse suspects; he Was far more powerful. He counted
among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
with some of the most prominent legal, scientific and business minds in the country.
When detectives started asking questions and teenage girls started talking, a wave of legal
resistance followed.
I
j
https://www.palmbeachpost.com/news/201907177man-who-had-everything-jefirey-epstei...
11711/2019
CA/Aronberq-000030
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
The Man'Who Had Evetythirtg: Jeffrey Epstein cra:ved big homes~ elite friendsjand under... Page 1 ofl...
Page 24 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 2 of 10
» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work¬
release
IfPalm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.
Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends
quietly, always in the background as he navigated New York high society.
When he first attracted notice in the early 1990s, it was on account of the woman he was
dating: Ghislaine Maxwell, daughter ofthe late British media tycoon Robert Maxwell.
In a lengthy article, headlined “The Mystery of Ghislaine Maxwell’s Secret Love,” the British
Mail on Sunday tabloid laid out speculative stories that the socialite’s beau was a CIA spook, a
math teacher, a concert pianist or a corporate headhunter.
“But what is the truth about him?” the newspaper wondered. “Like Maxwell, Epstein is both
flamboyant and intensely private.”
The media frenzy did not begin in full until a decade later. In September 2002, Epstein was
flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to
Africa on his private jet.
Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair
published lengthy profiles. The New York Post listed him as one ofthe city’s most eligible
bachelors and began describing him in its gossip columns with adjectives such as “mysterious”
and “reclusive.”
Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
Building a life of extravagance
He was born blue-collar in 1953, the son of a New York City parks department employee, and
raised in Brooklyn’s Coney Island neighborhood. He left college without a bachelor’s degree
but became a math teacher at the prestigious Dalton School in Manhattan.
The story goes that the father of one of Epstein’s students was so impressed with the man that
he put him in touch with a senior part...
Page 25 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends1 and under... Page 3 of 10
In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had startedJ.
Epstein and Co. That is when he began making his millions in earnest.
Little is known or said about Epstein’s business except this: He manages money for the
extremely wealthy. He is said to handle accounts only of $1 billion or greater.
It has been estimated he has roughly 15 clients, but their identities are the subject of only
speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a
former Palm Beacher who is said to have been a mentor to Epstein.
Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a
block on Manhattan’s Upper East Side. It is reported to have, among its finer features, closed-
circuit television and a heated sidewalk to melt away fallen snow.
That townhouse, thought to be the largest private residence in Manhattan, is only a piece of
the extravagant world Epstein built over time.
In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch
outside Santa Fe. Many believed it to be the largest home in the state.
In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre
private island in the Virgin Islands.
» PHOTOS: The players in the Jeffrey Epstein saga
Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
the highest echelons of power. This includes not only socialites but also business tycoons,
media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often
funds.
“Just like other people collect art, he collects scientists,” said Martin Nowak, who directs the
Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of
a $30 million research donation from Epstein.
Epstein is said to have befriended former Harvard President Larr...
Page 26 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends jand under... Page 4 of 10
I
i
i
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 ofthe trials
and tribulations of the very rich. T 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 ofthousands of dollars to join him at
an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become
close friends until after Clinton left the Oval Office and moved to New York.
Epstein has donated more than $100,000 to Democratic candidates’ campaigns, includingJohn
Kerry’s presidential bid, the reelection campaign ofNew Mexico Gov. Bill Richardson and the
Senate bids ofJoe Lieberman, Hillary Rodham Clinton, Christopher Dodd and Charles
Schumer.
Powerful friends and enemies
A Vanity Fair profile found cracks in the veneer of Epstein’s life story. The 2003 article said he
left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange
Commission violation. It also pointed out that Citibank once sued him for defaulting on a $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 multimillion-dollar Palm Beach home over a dispute about less
than $16,000 in furnishings.
A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
owed him nothing.
» Jeffrey E...
Page 27 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friendsland under... Page 5 of 10
I
i
“It’s a bad memory. I would rather not have ever metJeffrey Epstein,” sai<d Michael Stroll, the
retired former president of Williams Electronics and Sega Corp. “Sufficejit
to say I have
nothing good to say about him.”
;
Among the characteristics most attributed to Epstein is a penchant for women.
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian
model.
“He’s a lot of fun to be with,” Donald Trump told New York magazine in 2002. “It is even said
that he likes beautiful women as much as I do, and many of them are on the younger side. No
doubt about it, Jeffrey enjoys his social life.”
Investigation leads to Epstein
Although he was not a frequenter ofthe Palm Beach social scene, he made his presence felt.
Among his charitable donations, he gave $90,000 to the Palm Beach Police Department and
$100,000 to Ballet Florida.
In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a green
Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a
private chef and a small staff stood at the ready. From a window in his mansion, he could look
out on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man
who had everything.
But extraordinary wealth can fuel extraordinary desires.
» Epstein wants to 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
https://www. palmbeachpost,com/news/20190717/man-who-had-everything-j...
Page 28 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friendsjand under... Page 6 of 10
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.
[
I
Detectives interviewed the girl, who told them a friend had invited her to a rich man s house to
perform a massage. She said the friend told her to say she was 18 if asked: At the house, she
said she was paid $300 after stripping to her panties and massaging the man while he
masturbated.
Police interview 5 alleged victims
The investigation began in full after the girl identified Epstein in a photo as the man who had
paid her. Police arranged for garbage trucks to set aside Epstein’s trash so police could sift
through it. They set up a video camera to record the comings and goings at his home. They
monitored an airport hangar for signs of his private jet’s arrivals and departures.
They quickly learned that the woman who took the 14-year-old girl to Epstein’s house was
Haley Robson, a Palm Beach Community College student from Loxahatchee. In a sworn
statement at police headquarters, Robson, then 18, admitted she had taken at least six girls to
visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said.
During the drive back to her house, Robson told detectives, “I'm like a Heidi Fleiss.”
Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls
said they had been instructed to have sex with another woman in front of Epstein, and one said
she had direct intercourse with him.
In October, police searched the Palm Beach mansion. They discovered photos of naked, young-
looking females, just as several of the girls had described in interviews. Hidden cameras were
found in the garage area and inside a clock on Epstein’s desk, alongside a girl’s high school
transcript.
Two of Epst...
Page 29 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends 'and under... Page 7 of 10
!
i
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 sweetheart deal
When they subpoenaed one of Epstein’s former employees, he told them the same thing. He
and a private eye had met at a restaurant days earlier to go over what the man would tell
investigators.
Detectives received complaints that private eyes were posing as police officers. When they told
Epstein’s local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the
high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
Kennedy Smith.
While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law
professor, traveled to West Palm Beach with information about the girls. From their own
profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
their use of alcohol and marijuana.
He took his research to a meeting with prosecutors in early 2006, where he sought to cast
doubt on the teens’ reliability.
The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
did some ofthe 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 ...
Page 30 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friendsland under... Page 8 of 10
i
i
In the following weeks, police received complaints that two of the victims or their families had
been harassed or threatened. Epstein’s legal team maintains that its private investigators did
nothing illegal or unethical during their research.
'
By then, relations between police and prosecutors were fraying. At a key meeting with
prosecutors and the defense, Detective Joseph Recarey, the lead investigator, was a no-show,
according to Epstein’s attorney.
“The embarrassment on the prosecutor’s face was evident when the police officer never
showed up for the meeting,” attorneyJack Goldberger said.
Later in April, Recarey walked into a prosecutor’s office at the state attorney’s office and
learned the case was taking an unexpected turn.
The prosecutor, Lanna Belohlavek, told Recarey the state attorney’s office had offered Epstein
a plea deal that 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 of unlawful sexual activity with a minor and to charge his personal assistant, Sarah
Kellen, now 27, for her alleged role in arranging the visits. Police officials also wanted to
charge Robson, the self-described Heidi Fleiss, with lewd and lascivious acts.
By then, the department was frustrated with the way the state attorney’s office had handled the
case. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter
wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if
he would not act.
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
the grand jury.
'
I
i
I
https://www.palmbeachpost.com/news/20190717/man-who-had-everything-jeffrey-...
Page 31 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 9 of 10
I
I
It is not known how many ofthe girls testified before the grand jury. But Epstein’s defense
team said one girl who was subpoenaed - the one who said she had sexual intercourse with
Epstein - never showed up.
The grand jury’s indictment was handed down in July. It was not the one the police
department had wanted.
Instead ofbeing slapped with a charge of unlawful sexual activity with a minor, Epstein was
charged with one count of felony solicitation ofprostitution, which carries a maximum penalty
of five years in prison. He was booked into the Palm Beach CountyJail earlyJuly 23 and
released hours later.
Epstein’s legal team “doesn’t dispute that he had girls over for massages,” Goldberger said. But
he said their claims that they had sexual encounters with him lack credibility.
“They are incapable of being believed,” he said. “They had criminal records. They had
accusations oftheft made against them by their employers. There was evidence of drug use by
some of them.”
What remains for Epstein is yet to be seen.
The Palm Beach Police Department has asked the FBI to investigate the case. It also has
returned the $90,000 Epstein donated in 2004.
In New York, candidates for governor and state attorney general have vowed to return a total
of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein’s powerful
friends have remained silent as tabloids and Internet blogs feast on the public details of the
police investigation.
Goldberger maintains Epstein’s innocence but says the legal team has not ruled out a future
plea deal. He insists Epstein will emerge in the end with his reputation untarnished.
“He will recover from this,” he said.
Staffwriter Larry Keller and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and
Melanie Mena contributed to this story.
amarra@pbpost.com
https://www.palmbeachpost.com/news/20190717/man-who-had-everything-...
Page 32 100% OCR confidence
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends, and und. ..
Page 10 of 10
@AMarraPBPost
1
LEARN MORE
https://www.palmbeachpost.com/news/20190717/man-who-had-everything-j effrey-epstei...
11711/2019
CA/Aronberg-000039
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends\nd und. .. Page lQ of lO 
TI 
httJ?s:l/www.palmbeachpost.com/news/201907l1/man-who-had-everything-jeffrey-epstei. .. 
11/11/2019 
CA/ Aronbern __ -000039 
FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 33 100% OCR confidence
273 / 278 - Tuesday, November 16, 2004
!
i
Edition: FINAL
'
Section: A SECTION
Page: 1A
Source: By PAUL OWERS Palm Beach Post Staff Writer
Illustration: PHOTO (C & 2 B&W) & MAP (B&W)
Memo: Ran all editions.
Dateline: WEST PALM BEACH
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The
Donald was not about to be trumped.
"Nobody was going to outbid me," the brash developer-turned-TV-personality said from his
New York office.
Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot,
seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row."
But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at
513 N. County Road. He wants to - what else? - sell it and make more money.
The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super
luxury house" that would be the "finest anywhere in the United States." He might build
another house before flipping the entire package.
"Fve known about this house for quite some time," Trump said. "It's probably the best piece
of land in Florida - and probably the country - for luxury real estate."
Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor
Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith
said she's not worried about Trump's plans.
"He's been a very good property owner in the town of Palm Beach," she said. "He does his
projects very well. He's a perfectionist."
Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of
Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual
distribution to creditors.
The auction began at exactly noon after Judge Steven Friedman dismissed an objection from
an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully
that Trump was not a qualified bidder because...
Page 34 100% OCR confidence
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 (atypical Palm Beach County single-family house is about
2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service
quarters.
The closing could take place within a week but probably won't happen until next month.
Trustee Joe Luzinski and creditors said they were pleased with the outcome.
"We knew we were dealing with some substantial people
.
.
. who were going to bid it up a
bit," Luzinski said.
"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.
"In bankruptcy court, the idea is to get the most for creditors, and that's what happened."
The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer
former listing agent Sotheby's International Realty received was $32 million. Sotheby's won't
receive a commission, he said.
Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday.
"I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said.
Pulte said Gosman asked him before the auction whether he would be willing to let him stay
in the mansion after the closing until he decides where he wants to move. Trump and
Luzinski said they have had no such discussions with Gosman.
Gosman, 75, had the house built after paying $12.1 million for the land in 1986.
The former health-care magnate declined interview requests before and after the auction
Monday. He was at the courthouse but left before the auction took place.
The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm
Beach home and guest house but falls short of the $45 million that Virginia home builder
Dwight Schar paid ...
Page 35 100% OCR confidence
The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
an ownership interest in his home and other belongings only to avoid losing them in
bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in
1999, well before he filed for bankruptcy.
Lessen is expected to rule in the next two months whether Gosman made improper transfers,
a decision that will affect how much money will be available to creditors.
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
willing to move forward, in part because the upkeep of the estate now exceeds their means.
"This is not a happy occasion for them, but at least we're moving to the next level," Cimo
said. "That's not a house you want to live in unless you're making large amounts of money
like Donald Trump."
paul_owers@pbpost.com
CA/Aronbera-000042
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
' 
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 lo~ing them in 
bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in 
1999, well before he filed for bankruptcy. 
Lessen is expected to rule in the next two months whether Gosman made improper transfers, 
a decision that will affect how much money will be available to creditors. 
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were 
willing to move forward, in part because the upkeep of the estate now exceeds their means. 
"This is not a happy occasion for them, but at least we're moving to the next level," Cimo 
said. "That's not a house you want to live in unless you're making large amounts of money 
like Donald Trump." 
paul _ owers@pbpost.com 
CA/Aronbem-000042 
FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 36 100% OCR confidence
11/11/2019
Indictment: Billionaire Solidted3 Times - News - The Palm Beach Post - West Palm Beach,.FL
i
'
’
The Palm Beach Post
REALNEWSSTARTSHERE
;
Indictment: Billionaire Solicited 3 Times
Posted Jul 1,2008 at 12:01. AM
Updated Oct 2,2019 at 2:30 PM
(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 25,
2006)
Billionaire money manager and Palm Beach part-time residentJeffrey Epstein
solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31
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 Johns are usually charged
with a misdemeanor, and even a felony charge is typically made in a criminal
information - an alternative to an indictment charging a person with the:
commission of a crime.
His attorney, jack Goldberger, declined to discuss, the. charge.
State.attorney’s office spokesman Mike Edmondson also had little to say.
“Generally speaking, there is a case that has a number of different aspects to it,”
Edmondson said of a prostitution,-related charge being submitted to a grand jury.
“We first became aware of the case,months ago by Palin Beach police.”
Prosecutors and police worked together to bring: the case to the grand jury, he
said.
https://www.palmbeachpost:com/news/20080701/indictment-billionaire-solicited-3-times
T/2
CA/Aronberg-000043
FILW: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
ff/11/2019 
I 
. 
lndjctmE!nl: Billionaire! Spliciled'3 Times- N~w.s-The Palm B_e_ach Post-.West PallTI BE!a9h,.FL 
I 
. 
I 
The Palm Beach Post 
REAL NEWS STARTS HERE 
lndictm:ent: Billionaire SolJcited 3 Time:s 
P9§te9 Jul 1,.2008 at 12:01AM 
,Updated 0ct2; 20,19 at 2:3.0PM 
(EDITOR'S'NOTE: This story originally published in-The,Palm Beam Poston]uly25; 
2006) 
Billionaire mon...
Page 37 100% OCR confidence
11/11/2019
Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West Palm Beach, FL
I
i
i
I
Palm Beach police confirmed that and said the department will release a report
today regarding its investigation.
Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a
pool and a boat dock on the Intracoastal Waterway since 1990, according to
property records. A man answering the door there Monday said that Epstein
wasn’t home. A Cadillac Escalade registered to him was parked in the driveway,
which is flanked by two massive gargoyles.
Epstein sued Property Appraiser Gary Nikolits in 2001, contending that the
assessment of his home exceeded its fair market value. He dismissed his lawsuit
in December 2002.
A profile of Epstein in Vanity Fair magazine said he owns what are believed to
be the largest private homes in Manhattan - 51,000 square feet - and in New
Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the
U.S. Virgin Islands and fleet of aircraft.
Epstein’s friends and admirers, according to the magazine, include prominent
businessmen, academics and scientists and famed Harvard law professor Alan
Dershowitz.
larry keller@pbpost.com
https://www.palmbeachpost.com/news/20080701/indictment-billionaire-solicited-3-times
2/2
CA/Aro nberg-000044
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
11/11/2019 
Indictment: Billionaire Solicited 3 1imes - News - The Palm Beach Post - vyest Palm Beach, FL 
Palm Beach police confirmed that and said the department will release a report 
today regarding its investigation. 
Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a 
pool and a boat dock on the Intracoastal Waterway since 1990, according to 
property records. A man answering the door there Monday said that Epstein 
wasn't home. A Cadillac Escalade registered to him was parked in the driveway, 
which is flanked by two massive gargoyles. 
Epstein s...
Page 38 100% OCR confidence
I
11711/2019
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
The Palm Beach Post
REALNEWSSTARTSHERE
;
After long probe, billionaire faces solicitation
charge
Posted Jul 27,2006 at 12:01 AM
Updated Oct 3,2019 at 3:11 PM
(EDITOR’S NOTE: This story originally published in The Palm Beadi Post on July 26,
2006)
Palm Beach billionaireJeffrey Epstein paid to. have underage girls andyoung
women brought to his home, where he received massages andsometimes 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 keeptabs on his
private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
him with one count of felony solicitation of prostitution.
Palm Beach police thought there was .probable cause to charge Epstein with
unlawful sex acts;with,a minor and lewd and lascivious molestation.
Police Chief Michael Reiter was so angry with State Attorney Barry Krischers
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 of this
matter- has taken and consider if good and sufficient reason exists to require your
disqualification from the prosecution of these cases/' Reiter wrote in a May 1
memo to Krischer.
While not commenting specifically on the Epstein case, Mike Edmondson,
spokesman for the state attorney, said his office presents cases other than
murders to a grand jury when there are questions about witnesses’ credibility and
their ability to testify.
https:7/www.palmbeachpost.com/news/26060727/after-iong-probe-billionaire-faces-solicitation-charge
175
CA/Aronberg-000045
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
11/11/2019 
. 
. 
. 
. 
I 
. 
. 
. 
.After long probe,.billionajre f!lce...
Page 39 100% OCR confidence
they may fare under
11/11/2019
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
l(
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
defense attorneys’ questioning, he said.
Epstein’s attorney, Jack Goldberger, said his client committed no crimes.
“The reports and statements in question refer to false accusations that were not
charged because the Palm Beach County state attorney questioned the credibility
of the witnesses,” Goldberger said. A county grand jury “found the allegations
wholly unsubstantiated and not credible,” and that’s why his client was not
charged with sexual activity with minors, he said.
Goldberger said Epstein passed a lie detector test administered by a reputable
polygraph examiner in which he said he did not know the girls were minors.
Also, a search warrant served on Epstein’s home found no evidence to
corroborate the girls’ allegations, Goldberger said.
According to police documents:
- A Palm Beach Community College student said she gave Epstein a massage in
the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged
sessions at his home.
- A 27-year-old woman who worked as Epstein’s personal assistant also
facilitated the liaisons, phoning the PBCC student to arrange for girls when
Epstein was coming to town. And she escorted the girls upstairs when they
arrived, putting fresh sheets on a massage table and placing massage oils nearby.
- Police took sworn statements from five alleged victims and 17 witnesses. They
contend that on three occasions, Epstein had sex with the girls.
A money manager for the ultra-rich, Epstein was named one ofNew 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
Lawre...
Page 40 100% OCR confidence
11/11/2019
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
I
He has contributed tens ofthousands of dollars to Democratic Party candidates
and organizations, including Sen. John Kerry’s presidential bid, arid the Senate
campaigns ofJoe Lieberman, Hillary Clinton, Christopher Dodd arid Charles
Schumer.
Goldberger is one offive attorneys Epstein has retained since he became the
subject of an investigation, Edmondson said. Among the others: Alan
Dershowitz, the well-known Harvard law professor and author, who is a friend
of Epstein. Dershowitz could not be reached for comment.
Police said the woman who enlisted young girls for Epstein was Haley Robson,
20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in
Wellington and said she was a journalism major at Palm Beach Community
College when she was questioned by police last October. She has an unlisted
phone number and could not be reached for comment.
Robson said she met Epstein when, at age 17, a friend asked her if she would like
to make money giving him a massage. She said she was driven to his five-
bedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs
to a bedroom with a massage table and oils. Epstein and Robson were both naked
during the massage, she said, but when he grabbed her buttocks, she said she
didn’t want to be touched.
https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
3/5
CA/Aro^O^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
11/1112019 
I 
I 
After long probe, billionaire faces solicitation charge - News - The Palm Beach P.ost - West Palm Beach, FL 
I 
He has contributed tens of thousands of dollars to Democratic Pam candidates 
I 
and organizations, including Sen. John Kerry's presidential bid, add the Senate 
I 
campaigns of Joe Lieberman, Hillary Clinton, Christopher Dodd ~nd Charles 
Schumer. 
Goldberger is one...
Page 41 100% OCR confidence
11/11/2019
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
i
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 ^oman 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 - maybe naked - and
allow some touching.
One 14-year-old girl Robson took to meet Epstein led police to start the
investigation of him in March 2005. A relative 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 ofbeing a prostitute, and
she couldn’t explain why she had $300 in her purse.
The girl gave police this account of her meeting with Epstein:
She accompanied Robson and a second girl to Epstein’s house on a Sunday in
February 2005. Once there, a woman she thought was Epstein’s assistant told the
girl to follow her upstairs to a room featuring a mural of a naked woman, several
photographs of naked women on a shelf, a hot pink and green sofa 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 if his private jet was there, so they...
Page 42 100% OCR confidence
11/11/2019
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
I
from Palm Beach sanitation workers, collecting papers with names and phone
numbers, sex toys and female hygiene products.
]
i
I
i
One note stated that a female could not come over at 7 p.m. because of soccer.
i
Another said a girl had to work Sunday - “Monday after school?” And still
another note contained the work hours of a girl, saying she leavesjschool 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
S90,000 to the department for the purchase of a firearms simulator, said Jane
Struder, town finance director. The purchase was never made. The money was
returned to Epstein on Monday, she said.
https://wvAv.palmbeachpost.com/nevzs/20060727/after-long-probe-billionaire-faces-solicitationcharge
5/5
CA/Aronberg-000049
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
11/11/2019 
After long probe, billionaire faces solicitation charge - News - The Palm Beach P~st - West Palm Beach, FL 
I 
from Palm Beach sanitation workers, collecting papers with name~ and phone 
i 
numbers, sex toys and female hygiene products. 
i 
I 
! 
I 
One note stated that a female could not come over at 7 p.m. becau~e of soccer. 
I 
Another said a girl had to work Sunday - "Monday after school?" And still 
I 
another note contained the work hours of a girl, saying she leaves;school at 11:30 
a.m. and would come over the next day at 10:30 a.m. 
Only three months before the police department probe began, Epstein donated 
$90,000 to the department for the purchase of a firearms simulator, said Jane 
Struder, town finance director. The purchase was never made. The money was 
returned to Epstein on Monday, she said. 
https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge 
CA/AronbeLCJ.:-000049 
. 
FILb1J: PALM...
Page 43 100% OCR confidence
.1'1/11/2019
Police say-lawyer tried to discredit teenage/girls - News - Palm Beach Daily News -:Palm Beach, FL
i
Palm Beach DailyNews
Police say lawyer tried to discredit teenage
girls
Posted Jul 29,2006 at 12:01 AM
Updated Oct 3,2019 at 2:00 PM
(EDITOR’S NOTE: This story originally was published in The Palm Beach Post on July
29, 2006)
Famed Harvard law professor Alan Dershowitz met with the Palm Beach, County
State Attorney’s Office and provided damaging information about teenage girls
who say they gave his client, Palm Beach billionaire JeffreyEpstein, sexually
charged massages, according to police reports.
The reports also state that another Epstein attorney agreed to a plea bargain that
Would have allowed Epstein to have no criminal record. His current attorney
denies this happened.
And the documents also reveal that the father of at least one girl, complained that
private investigators aggressively followed his car, photographed his home arid
chased offvisitors.
Police alsotalked to somebody who said she was offered moriey if she refused to
cooperate:with the Palm Beach Police:Department:probe of Epstein.
The state attorney’s office said it presented the Epstein case to a county grand
jury this month rather than directly charging Epstein because of concerns about
the girls’ credibility. The grand jury indicted Epstein, 53, on a single, count,of
felony solicitation ofprbstitutiori, which carries a maximum penalty offive years
iri prison.
Police believed there Was probable cause to charge Epstein with the more serious
crifties of unlawful sex acts with a rriiftor and lewd arid lascivious molestation.
Police ChiefMichael Reiter was so angry that he wrote State Attorney Barry
Krischer a memo in May suggesting he disqualify himself from the case.
https:7/www.palmbeachdailynews.com/article/200607297NEWSZ190917573
1/4
CA/Aronberg-000050
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
ff/11/2019 
Police say.lawyer Irie.c...
Page 44 100% OCR confidence
11/11/2019
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily flews - Palm Beach, FL
The case originally was going to be presented to the grand jury in [February, but
was postponed after Dershowitz produced information gleaned from the Web
site myspace.com showing some of the alleged victims commenting on alcohol
and marijuana use, according to the police report prepared by DetectiveJoseph
Recarey.
Haley Robson, a 20-year-old Royal Palm Beach woman who told police she
recruited girls for Epstein, also is profiled on myspace.com. Her page includes
photos of her and her friends, including one using the name “Pimpin’ Made EZ.”
Robson, who was not charged in the case, is a potential prosecution witness.
According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with
Epstein, accepted the deal, in which Epstein would plead guilty to one count of
aggravated assault with intent to commit a felony, be placed on five years’
probation and have no criminal record. The deal also called for Epstein to submit
to a psychiatric and sexual evaluation and have no unsupervised visits with
minors, according to Recarey’s report. The plea bargain was made in connection
with only one 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 ofbeing harassed by
private investigators provided license tag numbers of two of the men. Police
found the vehicles were registered to a private eye in West Palm Beach and
another inJupiter, according to Recarey’s report.
“I have no knowledge of ...
Page 45 100% OCR confidence
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.
J
Phone records also show that the person said to have made the threat then
placed a call to Epstein’s personal assistant, who in turn called a New York
corporation affiliated with Epstein, the report states.
The issue in the Epstein case is not whether females came to his waterfront
home, but whether he knew their ages.
“He’s never denied girls came to the house,” Goldberger said. But when Epstein
was given a polygraph test, “he passed on knowledge of age,” the attorney said.
After the indictment against Epstein was unsealed this week, Police Chief Reiter
referred the matter to the FBI. “We’ve received the referral, and we’re reviewing
it,” said FBI spokeswoman Judy Orihuela in Miami.
The chiefhimself has come under attack from Epstein’s lawyers and friends in
New York, where he has a home. The New York Post quoted Epstein’s
prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
only “because of the craziness of the police chief.”
Reiter has declined to comment on the case.
Prosecutors have not presented a sex-related case like Epstein’s to a grand jury
before, said Mike Edmondson, spokesman for the state attorney’s office. “That’s
what you do with a case that falls into a gray area,” he said.
The state attorney’s office did not recommend a particular criminal charge on
which to indict Epstein, Edmondson said. The grand jury was presented with a
list of charges from highest to lowest, then deliberated with the prosecutor out of
the room, he said.
i
“People are surprised at the grand jury proceeding,” West Palm Beach defense
attorney Richard Tendler said. “It’s a way for the prosecutor’s office to not take
the full responsibility for not filing the ...
Page 46 100% OCR confidence
11/11/2019
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
Defense attorney Robert Gershman was a prosecutor for six years: “Those girls
must have been incredible or untrustworthy, I don’t know,” he saiid.
Other attorneys said Epstein’s case raises the issue ofwhether wealthy, connected
defendants like Epstein - whose friends include former President Clinton and
Donald Trump - are treated differently from others. Once he knew he was the
subject of a criminal probe, Epstein hired a phalanx 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
averageJoe.”
https://www.palmbeachdailynews.eom/article/20060729/N EWS/190917573
4/4
CA/Aronbera-000053
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
11/11/2019 
I 
I 
I 
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily ~ews - Palm Beach, FL 
Defense attorney Robert Gershman was a prosecutor for six yearsl "Those girls 
must have been incredible or untrustworthy, I don't know," he saib. 
I 
Other attorneys said Epstein's case raises the issue of whether wealthy, connected 
I 
defendants like Epstein - whose friends include former President Clinton and 
I 
Donald Trump - are treated differently from others. Once he kne~ he was the 
subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as 
Dershowitz and Lefcourt, who is a past president of the National Association of 
Criminal Defense Lawyers. 
Miami lawyer Roy Black - who became nationally known when he successfully 
defended...
Page 47 100% OCR confidence
The Palm Beach Post
REAL NEWSSURIS HERE
Expert: Ignorance of age isn’t
defense in sex cases
Posted Aug 5,2006 at 12:01 AM
Updated Oct 3; 2019 at 1:38 PM
(EDITORS NOTE: This story originally published in The,
Palm.Beach Post on Aug. 5^ 2006)
Eyen ifPalm Beach money managerJeffrey Epstein didn’t
know that girls who police jsay gave him sexual massages at
his Intracoastal home were under the legal age, that alone
wouldn’t have exempted him from criminal charges of
sexual activity with minors.
“Ignorance is not a valid defense,” said Bob Dekle, a legal
skills professor who was a Lake City prosecutor for nearly
30 years, half ofthat time specializing in sex crimes-against
children.
“There is no knowledge element as far as the age is
concerned,” Dekle said,
After an 11 -month investigation, Palm Beach police said
there was probable cause to charge Epstein, 53, with
unlawful sex acts with a minor and lewd and lascivious
molestation.-They contend that Epstein - friend of the rich
and famous and financial patron of Democratic Party
organizations and candidates - committed those acts with
five underage girls.
In the past week, New York Attorney General and
gubernatorial candidate Eliot Spitzer has returned about
$50,000 in. campaign contributions he received from.
Epstein, and Mark Green, a candidate to replace Spitzer in
CA/Aronberq-000054
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
The Palm Beach Post 
REAL NEWS STARTS HERE 
Expert:- Ignorance of age isn't 
defense in sex cases 
Posted Aiig 5,.2@6 at 12:0i AM 
Updated Oct 3; 2019 at 1 :38 PM 
I 
(EDITOR;S NOTE: This story originally published in The. 
Palm.Beach Post on Aug. 5; 2006) 
Eyen if P.alJn Be~chrnoney manag~r Jeffrey Epstein didn't 
know th_a.t girls who poli<:_e ·say gave him sexllai mfl,ss_age_s at 
his liitracoastal home wete undet the legal age,- that alohe 
wouldn't ·have exempted hllll from criminal charge~ of 
sexu_aJ aot1v1ty WI(h rninors. 
"Ignorance is n...
Page 48 100% OCR confidence
I
his current job, has returned $10,000 to him because ofjthe
Palm Beach scandal, the New York Daily News has
reported.
Rather than file charges, the state attorney’s office
presented the case to a county grand jury. The panel
indicted Epstein last week on a single, less serious charge of
felony solicitation of prostitution.
The case raised eyebrows because the state attorney’s office
rarely, if ever, kicks such charges to a grand jury. And it
increases the difficulty of prosecuting child sex abuse cases,
especially when the defendant is enormously wealthy and
can hire high-priced, top-tier lawyers.
At least one of Epstein’s alleged victims told police he knew
she was underage when the two of them got naked for
massages and sexual activity. She was 16 years old at the
time and said Epstein asked her questions about her high
school, according to police reports.
A girl who said she met Epstein when she was 15 said he
told her if she told anybody what happened at his house,
bad things could happen, the police reports state.
Epstein’s youngest alleged victim was 14 when she says she
gave him a massage that included some sexual activity. She
is now 16. The girl’s father says he doesn’t know whether
she told Epstein her age.
“My daughter has kept a lot ofwhat happened from me
because of sheer embarrassment,” he said. “But she very
much looked 14. Any prudent man would have had second
thoughts about that.”
Defense attorneyJack Goldberger maintains that not only
did Epstein pass a polygraph test showing he did not know
the girls were minors, but their stories weren’t credible.
The state attorney’s office also implied that their credibility
was an issue when it decided not to charge Epstein directly,
but instead give the case to the grand jury.
|
CA/Aronbera-000055
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
his current job, has returned $10,000 to him because 0£ the 
Palm Beach scandal, the New York Daily News has 
repor...
Page 49 100% OCR confidence
“A prosecutor has to look at it in a much broader fashion,” a
i
state attorney’s spokesman said last week.
'
Epstein hired Harvard law Professor Alan Dershowitz
when he became aware he was under investigation, and
Dershowitz gave prosecutors information that some of the
alleged victims had spoke of using alcohol and marijuana on
a popular Web site, according to a Palm Beach police
report.
Prosecutors typically consider two things in deciding
whether to charge somebody with sex-related offenses
against minors - whether there is sufficient evidence and
whether there is a public interest in doing so, Dekle said.
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 ofsex with minors.
CA/Aronberg-000056
FILW: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
"A prosecutor has to look at it ma mtith broader fashioirt," a 
• 
i 
state attorney's spokesman said last week. 
' 
Epstein. hired JI~rvard faw Professor Alan Dershowitz 
when he,becafue aware he was u-rtdet,irivestigation, and 
Dershowitz gave,prosecutor~ 1.nformation that some ofthe 
~lieged victims had spoke of using alcphol anq. ·nrarijuana .<:>:n 
a poJ5ula:t Web site, atcordihg: to a Palm Beach police 
report. 
Prosecutors typically consider two things in -deciding 
wllether to ·charge somebody with sex-rela,ted Qffenses 
against minors - whether there is sufficient evidence and 
whether there is a. :publicinterestin doing so, Dekle said. 
If two teens are in a sexual relationship and the boy turns 
) 8 be{ore·the girJ, he could be charged with -a,. sex crime-if 
the sex continues. There wcmldbe hb public: intete-st in 
pursuing that, Dekle...
Page 50 100% OCR confidence
Still there is a “universal constant” in prosecuting these!
cases, Dekle said. Men who exploit underage children for
. i
sex often carefully choose their victims in ways that will
I
minimize the risk to them, he said.
Victims usually are from a lower social status, and they'may
suffer from psychological problems, Dekle said.
“Lots of child sexual abuse victims have been victimized by
multiple people over a period of time. Then the act of abuse
produces behavior in the victims that further damages their
credibility.” Examples include promiscuous behavior and
drug abuse.
Some of the alleged victims in the Epstein case returned to
his home multiple times for the massage sessions and the
$200 to $300 he typically paid them per visit. “That would
be a definite problem for the prosecutor,” said Betty Resch,
who prosecuted crimes against children in Palm Beach
County for five years and now is in private practice in Lake
Worth.
“The victim becomes less sympathetic” to a jury, Resch said.
“But she’s a victim nevertheless. She’s a kid.”
Most men charged with sex crimes against minors look
normal, Dekle said. A jury expecting to see a monster
seldom will. And the victims’ ages work against them and in
favor of the defendant in a trial, Dekle said.
If a child and an adult tell different stories and both swear
they’re telling the truth, adult jurors are more likely to
believe the adult, Dekle said.
“You have all these things working against you in a child
sex abuse case. Prosecutors normally try to be very careful
in filing those cases because they know what they’re getting
into. There is no such thing as an iron-clad child sexual
abuse case.”
CA/Aronberg-000057
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
I 
I 
I 
Still there is a "universal constant" in prosecuting these! 
I 
cases, Dekle said. Men who exploit underage children fpr 
I 
sex often carefully choose their victims in ways that will 
I 
minimize the risk to them, ...
Page 51 100% OCR confidence
The Palm Beach Post
REAL NEWSSTARTSHERE
!
i
Epstein camp calls female accusers
liars
Posted Aug 8,2006 at 12:01 AM
Updated Oct 3,2019 at 3:35 PM
(EDITORS 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 water-front home are liars and saying
that the.Palm Beach Police Department is “childish.”
“There never was any sex betweenJeffrey Epstein and any
underage women,” his lead attorney, Jack Goldberger, said
from Idaho where he was vacationing with his family.
Epstein did have young women cornerto 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 nd 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
oh a charge offelony solicitation of prostitution. After an
11-month investigation that included sifting through
Epstein’s, trash and surveilling his home, Palm Beach police
concluded there was enough evidence to charge him with
sexual activity with minors. When the grand jury indicted.
CA/Aronberg-000058
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
-
-
I 
The Palm Beach Post 
REAL NEWS STARTS HERE 
I 
I 
I 
I 
Epstei_n camp cal.ls female accus~rs 
liars 
Posted Aug 8, 20·06,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} 
.Att<:>rneys a,nd pul:>H.cists for Palm: Beach finalld~r Jeffrey 
...
Page 52 100% OCR confidence
Epstein on the less serious charge, Police ChiefMichael
Reiter referred the case to the FBI to determine whether
there were federal law violations.
'
I
i
After a spate ofstories about the case last week, New York
publicist Dan Klores - whose client list has included Paris
Hilton andJennifer Lopez - said on Saturday that Epstein’s
camp was ready “to get their story out.”
They did that Monday via Goldberger and a Los Angeles
publicist for Miami criminal defense attorney Roy Black,
who also has represented Epstein in the case.
“We just think there has been a distorted view of this case
in the media presented by the Palm Beach police,”
Goldberger said.
Reiter has consistently declined to comment on the case
and did not respond to a request for comment Monday.
The implication that State Attorney Barry Krischer was
easy on Epstein by presenting the case to a grand jury
rather than filing charges directly against him is wrong;
Goldberger said.
CA/Aronbera-000059
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
I 
I 
Epstein on the less serious charge, Police Chief Michael 
Reiter referred the case to the FBI to determine whethJr 
I 
I 
there were federal law violations. 
, 
I 
After a spate of stories about the case last week, New Ybrk 
I 
publicist Dan Klores - whose client list has included Patis 
Hilton and Jennifer Lopez - said on Saturday that Epstein's 
camp was ready "to get their story out." 
They did that Monday via Goldberger and a Los Angeles 
publicist for Miami criminal defense attorney Roy Black, 
who also has represented Epstein in the case. 
"We just think there has been a distorted view of this case 
in the media presented by the Palm Beach police," 
Goldberger said. 
Reiter has consistently declined to comment on the case 
and did not respond to a request for comment Monday. 
The implication that State Attorney Barry Krischer was 
easy on Epstein by presenting the case to a grand jury 
rather than filing ch...
Page 53 100% OCR confidence
The Palm Beach Police Department was “happy and
|
ecstatic” that the panel was going to review the evidence. “I
think what happened is they weren’t happy with the result.
They decided to use the press to embarrass Mr. Epstein'.”
i
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 to
require your disqualification from the prosecution of these
cases.”
Rather than flat-out decline to charge Epstein, Krischer
referred the case to the grand jury to “appease” the chief,
Goldberger said.
A state attorney’s spokesman would say only that the office
refers cases to the grand jury when there are issues with the
viability of the evidence or witnesses’ credibility.
Both the state attorney and the grand jury concluded there
was not sufficient evidence that Epstein had sex with
minors, according to Goldberger. “It was just a childish
performance by the Palm Beach Police Department,”
Goldberger said.
The defense attorney said one of the alleged victims who
claimed she was a minor was in fact over the age of 18.
Another alleged victim who was subpoenaed to testify to
the grand jury failed to do so. Epstein’s accusers, he added,
have histories of drug abuse and thefts. “These 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
CA/Aronbera-000060
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
The Palm Beach Police Department was "happy and 
ecstatic" that the panel was going to review the evidence. "I 
think what happened is they weren't happy with the reLlt. 
I 
They decided to use the press to embarrass Mr. Epsteid." 
! 
I 
I 
But records show that Reiter wrote Krischer on May 1 :-
1 
well before the case we...
Page 54 100% OCR confidence
Newspapers
ancestry
The Palm Beach Rost (West Palm Beach, Florida)
■
14 Aug 2006, Mon
■Page 7
Downloaded on Npv:11.2019
Palm Beach chief focus
of fire in Epstein case
-• «F>'tLu'
»
,
- pH friMiWul ■
“ *
“}kjvfrf*3rr*braintpr~i-«’’»: Mffjr
bthtcavcfFsinlfesAiBianaerJeirrT
pKfrs'JvtuhtdttndL'kadt-nhip.
E>4?a. i;
in
s* Btw ram art-
Urcotn.
«ibt Lmcim Irfc*
f-s<zw*d•:wmscttocur.-Epstrin sb^ < Pains® tnethod a. Paint Bearh Can?*:eastor,
hi a kilt-
hir«brt »ti t
i Hk> 1 &
t
>^t- arfferfsi® .sliont. tf* Aerkjnitsn > ca^f-i
MwgWyunaraaLTHr adckil*Iinm4 ttryr vtwis
Irl <:2H'OCSt^K■,if £,xjd rs«i SKtScWEl
’
^^flypiiEfiriKS-r.' IrSta s
-Ike pmcesttjcn cl trese a*n-'::
iwiRni^irsx fh?past 13 yean thathe flugh?3i
■w
«fthe.ow.’-Jt boss l&ea Aianur?^
ir-dpn»frFS»oa2^n.‘ Mann-Dadestale Ak:s
<Kiiikizw Rstuadca: SmdJc sod efy
i man nxaaxeArvexpmrnt front r^kn Ikach:-
'Aitanc l-BMTWtr.alsot»*a:irn4‘d Ae FBI ■
s Natucr-aliAadectynn s QwKdK-^Va;^ and
>
’niafE^ieircOTnivrtiir^
.»r «> '
< fOTtrateni crtpsriiTatidns aid
■hat ajmp w-
,
?ott* resiarcd seaiiiiy
^5-'Heh£rt«TspSH5&ti&'£^
"
tjui’aJdresMiF the herdsjjf fh'etuwh.r;5air
,Tu-Ai?Mau««'P«iT Elw'clV.wbu'pnuiiotcd^
? Keaer friira’assisS^
Reiter focus of fire in Epstein case
Clipped By:
reiter_m
Sat, Apr 221 2017
Copyright © 2019 Newspapers.com. All Rights Reserved.
Newspapers
CA/Arop^C^ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
.Newspapers-
½' sBJ aricestry'-
I 
I 
. . . . . . . 
. I 
. . . 
. 
The Palm Beach P.os.t (West Palm Beach .. Florida) • .14 Aug 2006; Mon, Page 7 
I 
• 
I 
D9wnlo.adedon Npv·ll,2019 
Reiter focus of fire in Epstein case 
Clipped By: 
~1 relter m 
~ 
s~t. Apr 22: 2017 
CopyrigtJ1 © 2019 N~papers.c9m. All Rjghts R~1?rved. 
Newtpapers"' 
CA/Aroppffils?Wl~K-1 BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 55 100% OCR confidence
The Palm Beach Post
MALNEWSSIMnSHERE
'
Delays in Epstein case unusual,
lawyers say
Posted Mar 13,2007 at 12:01 AM
Updated Oct 3,2019 at 3:48 PM
(EDITOR’S NOTE: This story originally published in The Palm
Beach Post March 13, 2007)
A federal probe or a plea deal,could explain the wait in the
Palm Beachers 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 potentialfederal 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.
l
CA/Aronberg-000062
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
The Palm Beach Post 
REAL NEWS STARTS HERE 
Delays i_n Epstein case unusual, 
lawyers say 
Posted Mar 13, 2007 at 12:01 AM 
Updatea Dot 3; 2019 at 3:48 PM 
(EDITOR'S NaTE: This story originally published in- The Palm 
Beach Post-March n 2007) 
A federal probe Qr a. plea d~a.J, c:oll)d e~pla.in the wa.it in the 
Pal.In. Eea.cher;s solicitation c_a.se. 
Nearly eighnnonths afterPafm Beach tycoon.Jeffrey 
Epstein was charged with felony solicitation of prostittiti6h, 
th~re:h.as beep no discemi,ble progress in,his ...
Page 56 100% OCR confidence
“Highly unusual” is how Palm Beach Police Chief Michael
i
Reiter described State Attorney Barry Krischer’s handling
i
of the case in a bluntly critical letter to Krischer last year
before Epstein was indicted.
Reiter referred the matter to the FBI to determine whether
any federal laws had been violated. Epstein’s allies
countered by attacking the chief personally and
professionally.
Reiter's department investigated Epstein for 11 months.
Police sifted repeatedly through his trash and conducted
surveillance on his five-bedroom, 7 1/2-bath, 7,234-square-
foot home on the Intracoastal Waterway.
Police said Epstein paid women and girls as young as 14 to
give him erotic massages at his home. Police thought there
was probable cause to charge him with unlawful sex acts
with a minor and lewd and lascivious molestation.
Epstein responded by hiring a phalanx of lawyers. One of
them, Harvard law professor and author Alan Dershowitz,
provided the state attorney’s office with information about
alcohol and marijuana use by some of the girls who said
they were with Epstein.
Prosecutors then referred the case to the grand jury rather
than file charges directly against Epstein.
Epstein's attorneys deny he had sex with underage girls.
The lawyers say the girls' stories are not credible. But ifthe
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/Aronberg-000063
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
i 
"Highly unusual" is how Palm Beach Police Chief MichJel 
I 
Reiter described State Attorney Barry Krischer's handlip.g 
I 
of the case in a bluntly critical letter to Krischer last ye~r 
before Epstein was indicted. 
Reiter referred the matter to the FBI to determine...
Page 57 100% OCR confidence
I
Epstein's attorneyJack Goldberger did not return phone
I
messages.
[
A source close to the case suggested it is languishing
j
pending a decision by the FBI on whether to refer it to
'
federal prosecutors.
“We still have a pending case/' FBI spokeswoman Judy
Orihuela said Monday.
State Attorney Krischer did not return a call for comment.
His spokesman, Mike Edmondson, declined to say whether
federal investigators are delaying the Epstein case. But, he
added, “if another agency is looking at something, we
wouldn’t want to step on their toes.”
Attorneys say inertia in a criminal case often points to a
pending plea deal.
“It would not surprise me if something has happened that’s
not reflected in the court file,” said Dutko, such as an
agreement that will be formalized later.
Defense attorney Marc Shiner said defense attorneys
sometimes put off overtly conducting discovery -- deposing
witnesses, requesting documents and the like -- because
doing so creates more work for harried prosecutors who
may become angry and not offer a plea deal.
“Sometimes defense lawyers, knowing that, will try and do
discovery without taking depositions,” said Shiner, a former
prosecutor for 13 years.
Instead, they may conduct a below-the-radar probe such as
having a private investigator check out leads, he said.
Shiner and others say a plea deal for Epstein probably
would result in pretrial intervention, in which a defendant
may be ordered to undergo a psychological evaluation,
counseling or other conditions in return for dropping the
charge.
CA/Aronberq-000064
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Epstein's attorney Jack Goldberger did not return phone 
messages. 
A source close to the case suggested it is languishing 
I 
I 
I 
I 
pending a decision by the FBI on whether to refer it to : 
federal prosecutors. 
"We still have a pending case," FBI spokeswoman Judy 
Orihuela said Monday. 
State Attorney Krischer did not return a call for...
Page 58 100% OCR confidence
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/Aronberq-000065
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM
NOT A CERTIFIED COPY
I I 
Edmondson, spokesman for State Attorney Krischer, Jid 
there is no plea offer and no request for the prosecutio~ to 
I 
show its cards. 
I 
"To my knowledge, it's never happened before on a file~ 
I 
case," he said. 
CA/Aronbern.:-000065 
FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 59 100% OCR confidence
252 / 278 - Thursday, October 18, 2007
I
1
Edition: FINAL
I
Section: LOCAL
!
Page: 5B
:
Source: The Associated Press
Illustration: PHOTO (B&W)
Memo: Ran all editions.
Dateline: NEW YORK
WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16
A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage
prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had
sought his help becoming a model.
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had
the teen perform a sex act when she brought photographs of herself for him to review in his Upper
East Side mansion sometime in 2000.
Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get
you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice"
included massages and other favors.
When the girl told Epstein, "lam 16 years old and just want to model," he replied, "Don't worry, I
won't tell anybody," court papers say.
Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been
indicted in Palm Beach on charges of soliciting underage prostitutes. That case is pending.
The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural
sex acts" while she was a minor, the lawsuit says.
Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends,
stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her
40s). I love girls your age.'
"
The young woman, now 23, kept returning to Epstein because she has "mental issues," said her
lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result
of severe mental disease and defect."
Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she c...
Page 60 100% OCR confidence
The Palm Beach Post
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
Palm Beach Post on July 1, 2008)
Jeffrey Epstein will serve 1 1/2 years on teen solicitation
charges.
He lives in a Palm Beach waterfront mansion and has kept
company with the likes of President Clinton, Prince
Andrew and Donald Trump, but investment bankerJeffrey
Epstein will call the Palm Beach CountyJail home for the
next 18 months.
Epstein, 55, pleaded guilty Monday to felony solicitation of
prostitution and procuring a person under the age of 18 for
prostitution. After serving 18 months in jail, he will be
under house arrest for a year. And he will have a lifelong
obligation to register as a sex offender. He must submit to
an HIV test within 48 hours, with the results being
provided,to his victims or their parents.
As part ofthe plea deal, federal investigators agreed to drop
their investigation of Epstein, which they had taken to a
grand jury, two law enforcement sources said.
Epstein was indicted two years ago after an 11 -month
investigation byPalm 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-fobt, $8.5 million Intracoastal home.
Police concluded that there were several other girls brought
in 2004 and 2005 to an upstairs room at the home for
■
1
similar massages and sexual touching.
CA/Aronberg-000067
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
The Palm Beach Post 
REAL NEWS STARTS HERE 
• : 
! 
Palm Beacher pleads-.in sex. case, 
pqsteg Jul l, 2Q08 . .it 12:()J AM 
Updated bet 3, 2019 at 1 :47 PM 
(EDITOR'S NOTE: This story orig(nally publishe.d •fo Th.e 
PalmB~ac;h fQ$ton]u)y 1, 2008) 
Jeffrey Epstein will,setve l 1/2 years on teen.solicitation 
charges; 
He hves in a Palm'Beachwaterfront mansion and has kept 
com...
Page 61 100% OCR confidence
The indictment charged Epstein only with felony
|
solicitation of prostitution. The state attorney’s office later
added the charge of procuring underage girls for that
[
I
purpose.
]
Prosecutor Lanna Belohlavek said of the plea: “I took into
consideration the length the trial would have been and
witnesses having to testify” about sometimes embarrassing
incidents.
Epstein may have made a serious mistake soon after he was
charged. He rejected an offer to plead guilty to one count of
aggravated assault with intent to commit a felony,
according to police documents. He would have gotten five
years’ probation, had no criminal record and not been a
registered sex offender, the documents indicate.
Epstein arrived in court Monday with at least three
attorneys. He wore a blue blazer, blue shirt, blue jeans and
white and gray sneakers. After CircuitJudge Deborah Dale
Pucillo accepted the plea, he was fingerprinted. Epstein
then removed his blazer and was handcuffed for the trip to
jail while his attorneys tried to shield him from
photographers’ lenses.
When he eventually is released to house arrest, Epstein will
have to observe a 10 p.m. to 6 a.m. curfew, have no
unsupervised contact with anyone younger than 18 and
neither own nor possess pornographic or sexual materials
“that are relevant to your deviant behavior,” the judge said.
Epstein will be allowed to leave home for work. The New
York-based money manager told the judge he has formed
the not-for-profit Florida Science Foundation to finance
scientific research. “I’m there every day,” Epstein said.
The foundation was incorporated in November. Epstein
said he already has awarded money to Harvard and MIT.
CA/Aronberg-000068
FILET): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
The indictment charged Epstein only with felony 
i 
solicitation of prostitution. The state attorney's office llter 
I 
added the charge of procuring underage girls for that 
purpose. 
Prosecutor Lanna Belohlav...
Page 62 100% OCR confidence
When he is released from jail, there is a chance that Epstein
will be forced to move. Sex offenders are not allowed to live
I
within 1,000 feet of a school, park or other areas where
children may gather. No determination has been made as to
whether Epstein’s home complies, but attorneys said it
likely does.
Sex offenders also typically must attend counseling sessions.
Belohlavek said that was waived for Epstein because his
private psychiatrist is working with him. The judge was
skeptical but agreed to it.
Epstein’s legal woes don’t end with Monday’s plea. There
are four pending federal civil lawsuits and one in state court
related to his behavior. At least one woman has sued him in
New York, where he owns a 51,000-square-foot Manhattan
mansion.
“It's validation 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 Palm Beach International
Airport, where they watched for his private jet so they
would know when he was in town. They concluded that
Epstein paid girls $200 to $300 each after the massage
sessions.
“I’m like a Heidi Fleiss,” Haley Robson, now 22, told police
about her efforts in recruiting girls for Epstein.
There was probable cause to charge Epstein with unlawful
sex acts with a minor and lewd and lascivious molestation,
police concluded.
i
!
I
CA/Aronbera-000069
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
I 
When he is released from jail, there is a chance that Ephein 
will be forced to move. Sex offenders are not allowed td live 
I 
within 1,000 feet of a school, park or other areas where
1 
I 
children may gather. No determination has been made ...
Page 63 100% OCR confidence
The state attorney’s office said questions about the girls'
credibility led it to take the unprecedented step of
J
i
presenting the evidence against Epstein to a grand jury;
rather than directly charging him.
•
I
I
Palm Beach Police Chief Michael Reiter was furious with
State Attorney Barry Krischer, saying in a May 2006 letter
that the prosecutor should disqualify himself. "I continue to
find your office’s treatment of these cases highly unusual,”
he wrote. He then asked for and got a federal investigation.
Epstein hired a phalanx of high-priced lawyers - including
Harvard law professor and author Alan Dershowitz - and
public relations people who questioned Reiter’s competence
and the victims’ truthfulness.
In addition to mansions in Palm Beach and Manhattan,
Epstein owns homes in New Mexico and the Virgin Islands.
He’s a frequent contributor to Democratic Party candidates.
He also donated $30 million to Harvard in 2003.
Former New York Gov. Eliot Spitzer returned a $50,000
campaign contribution from Epstein after his indictment,
then resigned this year during his own sex scandal. And the
same Palm Beach Police Department that vigorously
investigated Epstein returned his $90,000 donation for the
purchase of a firearms simulator.
Staffwriter Eliot Kleinberg and former staff researcher
Michelle Quigley contributed to this story.
CA/Aronbero-000070
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
The state attorney's office said questions about the girls' 
I 
credibility led it to take the unprecedented step of 
~ 
I 
presenting the evidence against Epstein to a grand jury~ 
rather than directly charging him. 
I 
I 
I 
Palm Beach Police Chief Michael Reiter was furious with 
State Attorney Barry Krischer, saying in a May 2006 letter 
that the prosecutor should disqualify himself. "I continue to 
find your office's treatment of these cases highly unusual," 
he wrote. He then asked for and got a federal investigation. 
Epste...
Page 64 100% OCR confidence
The Palm Beach Post
REAL NEWSSIAIHS HERE
Jeffrey Epstein: Scientist,
stuntman, ‘sex slave’ visit jailed
tycoon
By LARRY KELLER / Palm Beach Post Staff Writer
Posted Aug 13,2008 at 12:01 AM
Updated Jul 16,2019 at 4:54 PM
Tycoon Jeffrey,Epstein mingled with an eclectic mix of
people, including: beautiful young women, before he got
into trouble for paying teenage girls to give him sexual
massages at his Palm Beach mansion.
Not much has changed, even though he now resides in a
dorm at the Palm Beach County Sheriffs Office’s 17-acre,
967-bed stockade near the fairgrounds.
During his first month of confinement, Epstein was'visited
by the female assistant who, girls told police,had escorted
them to the room at his mansion where they gave him
naked massages.
Also trekking to the jailwas 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 arid sometifrie
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 Palfri 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-000071
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
The Palm Beach Post 
REAL NEWS STARTS HERE 
Jeffrey Epstein: Scientist, 
stuntman; 'sex slave' visit jaited 
tycoon 
By LARRY KELLER/ Paint Beach Post,StaffWriter 
Posted Aug 1°3; 2008 at 12:01 AM 
Up~a1~d J_ull6; 2019 at4;q4 PM 
Tyc_oon Jeffrey.Epstein mingled with a,n ecfoc:tic; mix of 
' 
people, including beautiful young women, before he got 
into trouble for paying teenage girls to give him sexual 
roa,ssa,ges a,t his Palm Beac:h mans.ion. 
Not much has changed, even though h...
Page 65 100% OCR confidence
girls $200 to $300 in 2004 and 2005 for massages in hisi
home that sometimes included sexual touching, Palm Beach
police said.
His jail visitors in July included:
- Sarah Kellen, 29, who some of the teen masseuses said
phoned them when Epstein was in town and escorted them
upon their arrival at his Palm Beach waterfront home to an
upstairs room, where she prepared the massage table and
provided the oils for their encounters with him. Kellen
visited Epstein three times in July, according to a jail
visitor’s log. Kellen lists a Manhattan home address.
Reached by telephone, she declined to discuss Epstein.
- Nadia Marcinkova, 23, whose family in Yugoslavia
Epstein paid money to so that he could bring her to the
United States to be his “sex slave,” two teenage girls told
police. One girl told police that Epstein instructed
Marcinkova and her to kiss and have sex while he watched
and masturbated. Another said she engaged in sex with
Marcinkova at Epstein’s urging. Marcinkova visited Epstein
in jail four times in 13 days. She lists her address as on the
Upper East side of Manhattan, not far from Epstein’s
enormous apartment.
- Roger Schank, 62, founder of the Institute for Learning
Sciences at Northwestern University and an expert on
artificial intelligence, paid one visit to Epstein. Schank has
written numerous books on that subject and has a doctorate
degree from Yale University in linguistics. He was one of 19
people who applied to be president of Florida Atlantic
University in 2003. He became “chief learning officer” at the
online Trump University in 2005. Schank listed his address
as being in Stuart, and records show he also owns a home
in Lake Worth.
CA/Aronbera-000072
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
J
J
J
(
NOT A CERTIFIED COPY
girls $200 to $300 in 2004 and 2005 for massages in his i 
I 
home that sometimes included sexual touching, Palm B'.each 
police said. 
His jail visitors in July included: 
- Sarah Kellen, 29, who so...
Page 66 100% OCR confidence
Epstein has financed a number of scientists over the years,
including Nobel Prize winners. He gave $30 million to j
Harvard University in 2003. In November, he formed the
not-for-profit Florida Science Foundation, which he said
finances scientific research.
- Igor Zinoviev, a Russian mixed martial arts fighter, who
coaches a Chicago team in the International Fight League.
He also has worked as a personal trainer, celebrity
bodyguard and movie stuntman, according to the league’s
Web site. The NewJersey resident visited Epstein seven
times in July.
Zinoviev, Schank and Marcinkova could not be reached for
comment.
Staff researcher Niels Heimeriks contributed to this story.
CA/Aronbero-000073
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Epstein has financed a number of scientists over the yedrs, 
including Nobel Prize winners. He gave $30 million to j 
Harvard University in 2003. In November, he formed t~e 
not-for-profit Florida Science Foundation, which he said 
l 
finances scientific research. 
- Igor Zinoviev, a Russian mixed martial arts fighter, who 
coaches a Chicago team in the International Fight League. 
He also has worked as a personal trainer, celebrity 
bodyguard and movie stuntman, according to the league's 
Web site. The New Jersey resident visited Epstein seven 
times in July. 
Zinoviev, Schank and Marcinkova could not be reached for 
comment. 
Staff researcher Niels Heimeriks contributed to this story. 
CA/Aronbern:000073 
. 
FILb1J: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 67 100% OCR confidence
Palm Beach DailyNews
I
Billionaire sex offender leaves jail
six days a week for work
Posted Jul 1,2008 at 12:01 AM
Updated Oct 4,2019 at 9:27 AM
Palm Beach billionaire Jeffrey Epstein, who's serving 18
months in jail for soliciting an underage .girl for
prostitution, is allowed to leave the Palm Beach County
Stockade six days a week on a work-release program.
Teri Barbera, spokeswoman for the Palm Beach County
Sheriffs Office,, confirmed that Epstein, 55, has been in the
work-release program since Oct. 10.
“He works six days a week:. Friday through Wednesday 10
a.m. to 10 p.m.,” Barbera said via e-mail; “(He) works at his
local West Palm Beach office, monitored,on an active GPS
system (he wears an ankle bracelet),. Mr. Epstein hires a
permit deputy, at his expense, for his own. security at his
workplace during the time he is out.”
Miami,attorneyJeffrey Herman fepfesents six young
women who’ye sued Epstein, claiming he sexually-abused
them at his Palm Beach home when they were minprs.
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 oh work-
release for several weeks before the notification.
“My clients expressed shock and disappointment,” Herman
said. “I find it incredible that he’s' on work-release in the
community and my clients,aren’t notified of this and we get
this letter weeks after the fact.”
Jack Goldberger, Epstein’s criminal attorney, said the
-
CA/Aronberq-000074
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I I 
Palm Beach Daily Ne\Ns 
I 
BiHJonaire sex, offender lea.ves jaU 
six days a week for work 
Posted-Jul 1, 2008at 12:0.1 AM 
Updated Oct 4; 2019 at 9:27 AM 
Pa:lril Beach. billicniaife Jeffrey Ep:stein,, who; s servih$ 18 
months in jaiLfor soliciting arr underage ,girl for 
prosthutiop, is a_llowed to _kayeth~: Pa1m Beach Coti_nfy 
Stockade six d_ays a we¢k on a w01:k-reiea,se pro·gra:m. 
Te...
Page 68 100% OCR confidence
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 of the plea agreement, Epstein must
serve one year of house arrest and register as a lifelong sex
offender.
CA/Aronberq-000075
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
arrangement is not unusual. 
"He goes to work every single day and goes back to jail ~t 
night, just like everybody else (in the program)," 
Goldberger said. 
Epstein pleaded guilty June 30 to two felony counts: 
soliciting prostitution and procuring a person under 18 for 
prostitution. As part of the plea agreement, Epstein must 
serve one year of house arrest and register as a lifelong sex 
offender. 
CA/Aronbem:,000075 
FILETI: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 69 100% OCR confidence
X
I
The Palm Beach Post
REALNEWSSTARTSHERE
[
Women want Epstein sex plea deal
unsealed
Posted Jul 1,2008 at 12:01 AM
Updated Oct 2,2019 at 2:23 PM
(EDITOR’S NOTE: This story originally published in The.
Palm Beach PostJune 10, 2009)
Their attorneys will ask a judge to open Jeffrey Epstein's
records.
When wealthy money managerJeffrey Epstein of Palm
Beach,pleaded guilty last year to procuring teens for
prostitution, his case detoured around local and state rules
regarding the sealing of court documents.
At a plea conference on the state charges, a judge, a defense
lawyer and a prosecutor huddled at the bench and decided
that a deal Epstein had struck with federal prosecutors to
avoid charges should be sealed, according to a transcript of
the hearing.
And sb 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 or a compelling government
interest.
Yet no notification Or reason occurred in Epstein’s case,
according to court records.
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
! 
The Palm Beach Post 
REAL NEWS STARTS HERE 
I 
Women wa.nt Epstein sex plea dea __ l 
unsealed 
PostedJul 1, 2008 at 12:01 AM 
Updatea Oct 2; 2019 at 2:23 PM 
(EDITOR'S NOTE: This story originally published in The. 
Palm.Beach Post June 10; 2009) 
Thefr atto_111ey~ will ~le a jµdg~ to·openJeffrey Epstein's 
records. 
When wealthymonermana:get Jeffrey Epstein of Palm 
Beach. pleaded guilty last year to- ptocufin$ teens for 
p:i;ostitution, hi~ case detoured around Iocal anq staJ~ .rules· 
regarding the seahng of coµrt do~uments_, 
At ,a plea conference on the s.tate charges, a judge, a defense 
lawyer and a prosecutor huddled at the bendi and _decided 
that a deal 'Epstein had struck WJ.th fede...
Page 70 100% OCR confidence
Epstein’s own attorneys, in federal filings, have referred to
i
his confidential deferred prosecution agreement with the
U.S. attorney’s office, struck in September 2007, as
,
“unprecedented” and “highly unusual.” And it was “a
;
significant inducement” for Epstein to accept the state’s^
deal, observed the state judge who accepted his plea,
CountyJudge Deborah Dale Pucillo.
Epstein now faces at least a dozen civil lawsuits in federal
and state courts filed by young women who said they had
sex with him and now are seeking damages.
Attorneys for some of those women want his agreement
with federal prosecutors unsealed and will ask 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 and representing one of the women.
The Palm Beach Post also will ask Colbath to unseal the
agreement. Post attorney Deanna Shullman will argue that
the public has a right to know the specifics of Epstein’s deal.
According to various media accounts, Epstein moved in
circles that included President Clinton, Donald Trump and
Prince Andrew. “International Moneyman of Mystery,”
declared a 2002 New York magazine profile of Epstein.
Epstein, 56, is in the Palm Beach County Stockade, serving
an 18-month sentence after pleading guilty nearly a year
ago to felony solicitation ofprostitution 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/Aronbera-000077
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Epstein's own attorneys, in federal filings, have referred to 
I 
his confidential deferred prosecution agreement with the 
U.S. attorney's office, struck in September 2007, as 
"unprecedented" and ...
Page 71 100% OCR confidence
During a Palm Beach Police Department investigation, five
i
victims and 17 witnesses gave statements. They told of*
young women brought by his assistants to Epstein’s
i
mansion on El Brillo Way for massages and sexual activity,
and then being paid afterward.
i
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”
and launched an all-out inquiry into sealing procedures
across the state following media reports in 2006 of entire
cases being sealed and disappearing from court records.
“The public’s constitutional right of access to court records
must remain inviolate, and this court is fully committed to
safeguarding this right,” justices wrote in their final report.
Epstein’s office on Tuesday referred any questions to
Goldberger, who declined to comment. Pucillo also has
declined to comment.
CA/Aronberq-000078
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
During a Palm Beach Police Department investigation, 'five 
I 
victims and 17 witnesses gave statements. They told of: 
young women brought by his assistants to Epstein's 
I 
mansion on El Brillo Way for massages and sexual actiJity, 
I 
and then being paid afterward. 
: 
At Epstein's plea conference last year, his attorney,Jack 
Goldberger, and then-Assistant State Attorney Lanna 
Belohlavek approached Puci...
Page 72 100% OCR confidence
The Palm Beach Post
REAL NEWSSTARTSHERE
,
i
Epstein secret pact with Feds
reveals “highly unusual” terms
Posted Jun 10,2009 at 12:01 AM
Updated Oct 4; 2019 at 9:23 AM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on September 19, 2009)
A secret non-prosecution agreement multimillionaire
financierJeffrey Epstein struck with federal prosecutors is
being called “highly unusual” by former federal prosecutors
and downright outrageous by attorneys now representing
young women who serviced him.
The deal reveals that the FBI and the U.S. Attorney’s Office
investigated him for several federal crimes, including
engaging minors in commercial sex. The crimes are
punishable by anywhere from 10 years to life in prison.
But federal prosecutors backed down and agreed to recall
grand jury Subpoenas if Epstein pleaded guilty to
felonies in state court, which he
ultimately did. He received an 18-mpnth 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 Epsteins
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-000079
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
: 
The Palm Beach PoJt 
REAL NEWS STARTS HERE 
Epstei_n secret pact with Feds 
reveals "highly unusual" terms 
PostedsJun 10, 2009-at 12:0i AM 
Updateo Oct 4, 2'0'19 at 9:23 AM 
(~DITOR/S NOTE: This story originally fiiblished in The, 
Palm.Beach Post on September 19, 2009) 
.A se<;:r~t _nQI):'pros~q1tion a.gre~ment mµldrnJlliqn_?-ir~ 
financier Jeffrey Epstein ·s.truck with federal prosec:t1tor~ is 
hein·g called ''highly un usuat by form et fe...
Page 73 100% OCR confidence
MarkJohnson of Stuart, a former federal prosecutor, j
described the disparity in potential sentences as unusual,
but even more so a provision on attorney payment.
The first draft ofthe agreement in September 2007
required that Epstein pay an attorney — tapped by the U.S.
Attorney’s Office and approved by Epstein — to represent
some of the victims. That attorney is prominent Miami
lawyer Bob Josefsberg.
But an addendum to the agreement signed the following
month struck Epstein’s duty to 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. “I’ve never, ever seen anything
like that in my life,” he said. “It’s highly unusual.”
The deal does not say whether any victims were contacted
or consulted before the deal was made.
Attorney Brad Edwards of Fort Lauderdale, who represents
three of the young women, believes that none ofthe 30 to
40 woman identified as victims in the federal investigation
were told ahead of time. Edwards said his clients received
letters from the U.S. Attorney’s Office months after the deal
was signed, assuring them Epstein would be prosecuted.
“Never consulting the victims is probably the most
outrageous aspect of it,” Edwards said. “It taught them that
someone with money can buy his way out of anything. It’s
outrageous and embarrassing for United States Attorney’s
Office and the State Attorney’s Office.”
Epstein now faces many civil lawsuits filed by the women,
who are represented by a variety of attorneys. In many,, the
allegations are the same: that Epstein had a predilection for
teenage girls, identified poor, vulnerable ones and used!
CA/Aronbera-000080
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Mark Johnson of Stuart, a former federal prosecutor, 
I 
described the disparity in potential sentences a...
Page 74 100% OCR confidence
other young women to lure them to his Palm Beach
:
I
mansion. They walked away with between S200 and
SI,000.
I
i
Former CircuitJudge Bill Berger, also representing victims,
called the agreement a “sweetheart deal.”
“Why was it so important for the government to make this
deal?” Berger asked rhetorically. “We have not yet had an
honest explanation by any public official as to why it was
made ... and why the victims were sold down the river.”
Former federal prosecutor Ryon McCabe described the
agreement as “very unorthodox.” Such agreements, he said,
are usually reserved for corporations, not individuals.
“It’s very, very rare. I’ve never seen or heard of the
procedure that was set up here,” said McCabe, who has no
involvement in any Epstein litigation.
“He’s essentially avoiding federal prosecution because he
can afford to pay that many lawyers to help those victims
review their cases. ... If a person has no money, he couldn’t
be able to strike a deal like this and avoid federal
prosecution.”
The backroom deal with federal prosecutors is all the more
interesting in light of the 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 life behind him. He is continuing his long¬
standing history of science philanthropy.”
CA/Aronberg-000081
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
other young women to lure them to his Palm Beach 
mansion. They walked away with between $200 and 
$1,000. 
i 
Former Circuit Judge Bill Berger, also representing victims, 
called...
Page 75 100% OCR confidence
The investigation triggered tensions between police and
prosecutors, with then-Palm Beach ChiefMichael Reiter
I
saying in a May 2006 letter to then-State Attorney Barry
Krischer that the chiefprosecutor should disqualify himself.
“I continue to find your office’s treatment ofthese cases
highly unusual,” Reiter wrote. He then asked for and got
the federal investigation that ended in the sealed deal.
“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-000082
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
! 
The investigation triggered tensions between police ana 
prosecutors, with then-Palm Beach Chief Michael Reit~r 
I 
saying in a May 2006 letter to then-State Attorney Barry 
Krischer that the chief prosecutor should disqualify hiJself. 
I 
"I continue to find your office's treatment of these cases 
highly unusual," Reiter wrote. He then asked for and got 
the federal investigation that ended in the sealed deal. 
"The Jeffrey Epstein matter was an experience of what a 
many-million-dollar defense can accomplish," Reiter told 
the Palm Beach Daily News upon his retirement. 
CA/Aronbern:000082 
• 
FILblJ: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 76 100% OCR confidence
187 / 278 - Wednesday, January 27, 2010
|
Edition: FINAL
Section: LOCAL & BUSINESS
Page: 3B
Source: By JANE MUSGRAVE Palm Beach Post Staff Writer
Dateline: WEST PALM BEACH
JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS
In a decision that could spark a constitutional showdown over privacy rights, a judge
Tuesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to
subpoena abortion records from women who are seeking millions in damages from the part-
time Palm Beach resident.
Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut
the women's claims that they suffered psychological ills after being paid to give him
sexually-charged massages at his Palm Beach mansion when they were as young as 14.
Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records,
he said, can't be sought until the women are asked whether they have ever had an abortion,
how many and where. Further, he said, the records would not be made public and might not
be admissible during trial.
But, he said, since the women claim Epstein, now 57, is responsible for their emotional
distress, his attorneys can explore the impact of other events. Medical records, Hafele said,
are a better source of information than a person's memory.
Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm
Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky
constitutional grounds.
"These records are protected by our constitutional right of privacy," he said, referring to the
Florida Constitution.
After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the
records.
In another ruling Wednesday, Hafele also said that videos from depositions in the state cases
can't be released without a court order. The ruling came after Epstein attorney Robert Cntton
complained that a video of Epstein being asked whether he had an...
Page 77 100% OCR confidence
The Palm Beach Post
REAL NEWS STARTSHERE_i
Epstein Journal’s Findings Could
'
Resurrect Case
By Jane Musgrave
Posted Sep 17,2019 at 12:01 AM
Updated Oct 1,2019 at 10:51 AM
(EDITOR S NOTE: This story originally published in The
Palm Beach Post on March 20, 2010)
A purloined journal that is said to contain the names of
“hundreds” ofvictimsof 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 ofthe journal were released
this week when Alfredo Rodriguez, who worked as a
property manager for the Palm Beach resident, pleaded
guilty to obstruction ofjustice for lying to federal agents
when asked ifhe had any information about his former
boss’ criminal activity. He later tried to sell the journal he
stole from Epstein for §50,000 to 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 the items been produced in response to the inquiries
of state or federal authorities ... the materials would have
been presented to the federal grand jury,” federal
prosecutors wrote.
CA/Aronberg-000084
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
I 
The Palm Beach Post 
REAL NEWS STARTS HERE 
Epstei.n _Journal's Findi.ngs Could. 
Resurrect Case 
By Jan_e_M!,lsgrave: 
Posted Sep 17,_ 2019 at 12:01 AM 
Updated Oct 1, 2019 :at i 0:51 AM 
(EDITOR'S NOTE: This story originally published in The, 
Palm Beqch_ Post on Afqrcb 29; 20i0) 
A p:urloinedjoumal that is said to contain the names or 
"hundte·ds'.' ofvictims ofconvicte'd sex, offender Jeffrey 
Epstein co.uld be, used to reopen the investigation into ·the 
mµlti-piilliona_ir~' s appetit~ f9r teen~...
Page 78 100% OCR confidence
Instead, prosecutors short-circuited the grand jury
investigation and cut a deal with Epstein. They agreed not
to pursue federal charges if he didn't contest prostitution-
related felonies in state court. The money manager pleaded
guilty inJuly 2008 to procuring a minor for prostitution
and soliciting prostitution. He served 13 months of an 18-
month sentence.
Attorney Adam Horowitz, who represents seven of the
roughly 18 women who have filed civil suits against
Epstein, said the new information could trump the so-
called non-prosecution agreement.
The multifaceted agreement, he said, deals only with a
specific list ofvictims that the U.S. Attorney’s Office knew
about when it penned the deal in 2007. If additional victims
are listed in the journal Rodriguez stole, Horowitz said
federal prosecutors could reopen the investigation.
“It opens the door for further prosecution,” he said.
In addition to turning over the journal to federal agents,
Rodriguez told them he knew his former boss was having
sex with underage girls when he worked for him in 2004
and 2005. He had seen naked girls, who looked like minors,
in the pool of Epstein’s $8.6 million mansion. He had seen
pornographic images ofyoung girls on Epstein’s computer,
according to court records.
Neither Epstein’s criminal defense attorney, Jack
Goldberger, nor attorney Robert Critton, who represents
Epstein in the civil lawsuits, could be reached. Federal
prosecutors have consistently declined comment.
The wording of the controversial agreement is unclear. It
says federal prosecutors would provide Epstein’s attorneys
“with a list of individuals whom it has identified as victims.”
Miami attorney Robert Josefsberg was appointed to
CA/Aronbero-000085
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Instead, prosecutors short-circuited the grand jury 
I 
investigation and cut a deal with Epstein. They agreed not 
I 
to pursue federal charges if he didn't contest prostitutio...
Page 79 100% OCR confidence
represent any ofthe 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 women1.
i
Some of the women, most identified as Jane Doe in
lawsuits, had already hired attorneys to represent them.
Some have since settled their suits with Epstein, although
terms were not disclosed.
Horowitz said he has filed court papers to get the journal
that Rodriguez stole. “It’s another piece of evidence that
shows our clients were at Epstein’s mansion,” he said.
Rodriguez told prosecutors he didn’t turn over the journal
when both FBI and Palm Beach police asked for it because
he wanted money for it. He also said he was afraid Epstein
would make him “disappear.” The information, he told
investigators, was his “insurance policy.”
He faces a maximum 20 years in prison when he is
sentenced on June 18.
jane_musgrave@pbpost.com
@pbpcourts
CA/Aronberq-0Q0086
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
represent any of the victims on the list who wanted to j 
pursue Epstein in civil court. As part of the agreement,: 
I 
Epstein is to pay for Josefsberg to represent the womeri. 
I 
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_m usgrave@pbpost.com 
@pbpcourts 
····························...
Page 80 100% OCR confidence
Epstein paid three women $5.5 million to end underage-sex lawsuits - News - The Palm B... Page 1 of 3
i
i
The Palm Beach Post
REALNEWSSTARTSHERE
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 billionaireJeffrey Epstein paid young
women who claimed he used them as sex toys, court documents filed last week show he shelled
out $5.5 million,to settle lawsuits with three ofmore than two dozen teens who sued him.
Responding to requests from Epstein’s attorneys in a complex lawsuit that was spawned by the
sex scandal, attorney Bradley Edwards said the politically-connected 64-year-old convicted sex
offender paid more than $1 million to each of the three women Edwards represented.
Identified in court papers only by their initials or pseudonyms because of the nature of the
allegations and their youthful ages, L.M. waspaid $1 million,E.W. $2million andJane Doe
$2.5 million, Edwards said of the settlements he negotiated with Epstein to end the lawsuits.
Jack Goldberger, One of Epstein’s criminal defense attorneys, on Tuesday declined comment.On
the revelations, citing confidentiality agreements that were part of the settlements. For the
same reason, he declined to. say whether Epstein paid similar amounts to settle roughly two
dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex
when some were as young as 14 years old.
Attorneyjack Scarola, who is representing.Edwards, said his client Was compelled to divulge
the confidential settlements to answer questions posed by Epstein’s attorneys. “Brilliant move
on their part,” he said.
Even if Epstein’s attorneys hadn’t opened the door, Scarola said the information would have
likely come out. He says the information Willhelp him undermine Epstein’s claims that
Edwards “ginned up” the allegations to help his former law partner, imprisoned and disbarr...
Page 81 100% OCR confidence
Epstein paid three women $5.5 million to end underage-sex lawsuits - News - The Palm B... Page 2 of 3
i
i
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 of prostitution and procuring a
minor for prostitution, he sued Rothstein and Edwards, claiming they trumped up the
allegations of sexual molestation to perpetuate the Ponzi scheme.
Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly
successful law firm by forging the names of federal judges and others to persuade investors he
had negotiated settlements in lawsuits against high-profile people. Investors were told they
could get a cut of the cash.
One ofthe high-profile people Rothstein used to lure investors was Epstein, according to a
lawsuit West Palm Beach attorney Robert Critton filed on Epstein’s behalf. According to the
lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the lawsuits
with the teens for $200 million — a claim Critton described as “a complete fabrication.”
After Epstein dropped the lawsuit in 2012, Edwards turned the tables on him. Edwards accused
Epstein of filing the lawsuit maliciously to punish him for representing the young women.
Although Edwards was a partner in Rothstein’s now defunct firm, Scarola claims Epstein had
no evidence Edwards was involved in the Ponzi scheme. Federal prosecutors successfully
charged other attorneys and members of the firm, but Edwards was never implicated, Scarola
said in the malicious prosecution lawsuit.
The revelations about the money Epstein paid to three of the young woman came last week in
documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit.
Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the
trial, in part, because she claimed she has been unable to ...
Page 82 100% OCR confidence
Epstein paid three women $5.5 million to end underage-sex lawsuits - News - The Palm B... Page 3 of 3
l
i
Pointing out Epstein’s enormous wealth and his private jet, Palm Beach County CircuitJudge
Donald Hafele rejected her request. While saying he didn’t want to appear insensitive to those
victimized by the storm that hammered the Caribbean and roared through South Florida, he
said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.
Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide
before the case goes to trial.
Despite Scarola’s insistence that Edwards had nothing to do with Rothstein’s Ponzi scheme,
Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein’s
well-known friends, such as now President Donald Trump, former President Bill Clinton and
illusionist David Copperfield, she asked. He used the celebrities as a draw, she said.
“The Epstein cases were used to fleece money and defraud investors,” she said.
Edward’s malicious prosecution case has been difficult for both sides because both Epstein and
Edwards have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked
his Fifth Amendment right against self-incrimination when questioned by Scarola. Edwards
has claimed that much of the information Epstein is seeking is protected by attorney-client
privilege.
The malicious prosecution lawsuit is one oftwo hotly-contested lawsuits that continue to pit
Edwards against Epstein. Edwards also is suing the U.S. attorney’s office, claiming it violated
the federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with
Epstein.
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 ...
Page 83 100% OCR confidence
Palm Beach DailyNews
Judge rules feds’ agreement with
Jeffrey Epstein pact violated teen
victims’ rights
By Jane Musgrave
Posted Sep 17,2019’ at 4:02 PM
Updated Oct 8,2019 at 12:31 PM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on February 22, 2019)
Federal prosecutors violated the rights ofJeffrey Epstein’s
teenage victims by failing to reveal they had dropped plans
to prosecute the billionaire on dozens, offederal 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.
;
i
I
CA/Aronberg-000090
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
I 
! 
Palm Beach Daily Ne~s 
I 
i 
Judge rules feds~ agreement with_: 
Jeffrey Epstein pact vi·olated teen 
victims' rights 
ey·.~-~:~-~--~~-~9.-~-~~-
Posted Sep 17-, 2019' at 4:02 PM 
UjJd_ajed Oct 8, 2019 at 12;31 PM 
(:EDITOR'S NOTE: This story. originally puhlished in The 
Palm Beach Post onFebrua,:y 22, 2019) 
Federal prosecutors violated the rigli:ts of Jeffrey Epstein1s 
teenage y_ictims py failing to reve~l they ha9.<Jroppe{l plan;s 
fo prosecute the billionaire on d...
Page 84 100% OCR confidence
Prosecutors’ failure to alert the young women about the
i
deal violated the Crime Victims’ Rights Act, Marra ruled,
i
‘‘At a bare minimum the (act) required the government Jo
inform (the young women) that it intended to enter into an
agreement not to prosecute Epstein,” he wrote.
J
Still, Marra said he wasn’t second-guessing prosecutors’
decision not to pursue Epstein on federal charges if he
pleaded guilty to minor state prostitution charges and
agreed to compensate his victims for the trauma he caused.
“The court is not ruling that the decision not to prosecute
was improper,” Marra wrote. “The court is simply ruling
that, under the facts of this case, there was a violation under
the CVRA.”
Further, he made no decision about what the remedy
should be. He gave prosecutors and attorneys representing
the young women 15 days to meet to decide how to unravel
the complex legal web that has been hanging over Epstein
and his young victims for more than a decade.
The chances an accord will be reached are slim, said
attorney Jack Scarola, who is representing the two Jane
Does who challenged the prosecutors' actions.
Further, he said, there is no road map to follow. The
lawsuit attorney Bradley Edwards filed on behalf of the two
unidentified young women, claiming prosecutors violated
the federal act, is unique, he said.
“We are treading on virgin ground, to use what is probably
an inappropriate phrase in this situation,” he said.
Scarola said he and Edwards will ask that the non¬
prosecution agreement be thrown out. That would open
the possibility that the long-shelved federal indictment i
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.
;
I
I
CA/Aronberg-000091
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Prosecutors' failure to alert the young women about th~ 
i 
deal violated the Crime Victims' Rights Act, Marra rule~. 
I 
"At ...
Page 85 100% OCR confidence
“I don’t see the government conceding to that remedy/’'
I
Scarola admitted. Further, he said, it is likely Epstein will be
allowed to weigh in. Miami attorney Roy Black years ago
filed papers asking to intervene on Epstein’s behalf.
i
The U.S. Attorney’s Office said it wouldn’t comment oh
Marra’s ruling. Neither Black nor New York City attorney
Jay Lefkowitz, who led efforts to bury the federal
indictment, responded to emails or phone calls for
comment. West Palm Beach attorneyJack Goldberger, who
represents Epstein, also didn’t respond.
Scarola said it is likely Epstein’s star-studded legal team will
argue that Epstein fully complied with the terms of the
agreement he made in 2007 with federal prosecutors and
therefore the agreement can’t be undone.
As he promised, Epstein pleaded guilty in June 2008 to state
charges of soliciting a minor for prostitution and soliciting
prostitution. He served 13 months of an 18-month jail term
in a vacant wing of the county stockade that he was allowed
to leave 12 hours a day, six days week.
Further, as agreed, he paid settlements to the young women
who sued him. While the settlements were confidential,
court records show he paid three women a total of $5.5
million.
In return, federal prosecutors held up their end of the
bargain. Their investigation ceased.
Having done all that prosecutors asked ofhim, Scarola said
Epstein will make a simple argument: “You can’t turn
around and deprive me of the benefits I bargained for.”
However, Scarola said, using Marra’s ruling, he will counter
that the contract Epstein signed was illegal and therefore
unenforceable.
C/VAronbe^
BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
... 
" 
"I don't see the government conceding to that remedy," 1 
I 
Scarola admitted. Further, he said, it is likely Epstein wtll be 
I 
allowed to weigh in. Miami attorney Roy Black years ago 
filed papers asking to intervene on Epstein's behalf. 
I 
I 
The U.S. Attorney's Office said ...
Page 86 100% OCR confidence
Even if Marra agrees to toss out the non-prosecution
agreement, Scarola conceded that doesn’t mean Epstein will
face federal charges.
I
“The contract can be set aside and the federal government
can attempt to enter into the same agreement,” he said.
“Except the spotlight of public attention will be on them
and the 40 victims will be able to explain to the court why
this sweetheart deal should not be approved.”
Scarola said that prosecutors may have had good reason not
to pursue Epstein. “There may be a reasonable explanation
but we don't know what that reason may have been,” he
said.
In court papers, federal prosecutors have said that many of
the young women were afraid to cross the powerful,
politically connected money manager and simply refused to
testify against him.
In other cases, they said, the women changed their stories.
Jane Doe 2, who is trying to have the non-prosecution
agreement thrown out, initially described Epstein as “an
awesome man” and told prosecutors she hoped “nothing
happens” to him. While she later agreed to testify against
Epstein, prosecutors said they feared Epstein’s attorneys
would use her words to destroy her if she ever took the
witness stand.
Marra, however, said the young woman’s comments didn’t
mean she wasn’t entitled to know about the prosecutors’
plans to drop the charges. “There is no dispute that Epstein
sexually abused Jane Doe 2 while she was a minor,” he
wrote. “Therefore, regardless of her comments to the
prosecutor, she was a victim.”
Before the case is finally resolved, Scarola predicted that “a
lot of people are going to have to answer a lot of questions.”
I
CA/Aronberg-000093
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
Even if Marra agrees to toss out the non-prosecution I 
agreement, Scarola conceded that doesn't mean Epstein! will 
face federal charges. 
I 
I 
I 
"The contract can be set aside and the federal governm~nt 
can attempt to enter into the same agreement," ...
Page 87 100% OCR confidence
In his ruling, Marra detailed what appeared to be a cozy
relationship between Acosta, his line prosecutors and
|
i
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 of President Clinton.
Marra describes an October 2007 breakfast meeting
between Acosta, who is now U.S. labor secretary, and
'
Lefkowitz shortly after the non-prosecution agreement was
inked.
After the meeting, Lefkowitz sent Acosta a note thanking
him for “the commitment you made to me during our
October 12 meeting in which you assured me that your
Office would not... contact any of the identified
individuals, potential witnesses, or potential civil claimants
and their respective counsel in this matter.”
Marra quoted an equally pleasant note then-Palm Beach
County State Attorney Barry Krischer sent to Assistant U.S.
Attorney Marie Villafana, who was the lead prosecutor in
Epstein’s case. “Glad we could get this worked out for
reasons I won’t put in writing,” Krischer wrote, shortly
after the non-prosecution agreement was signed. “After this
is resolved I would love to buy you a cup at Starbucks and
have a conversation.”
Many of the notes that were exchanged dealt with
prosecutors’ and Epstein’s lawyers’ shared desire to keep the
deal secret from Epstein’s accusers. In a September email,
Villafana asked Lefkowitz for guidance about what she
should reveal. “And can we have a conference call to discuss
what I may disclose to ... the girls regarding the
Agreement,” she asked.
!
i
CA/Aronbera-000094
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
i 
In his ruling, Marra detailed what appeared to be a cozy 
I 
relationship between Acosta, his line prosecutors and I 
I 
Epstein's team oflawyers. His phalanx oflawyers included 
noted Harvard law professor Alan Dershowitz and Ken!neth 
l 
Starr, the former U.S. solicito...
Page 88 100% OCR confidence
Such cooperation between prosecutors and defense
attorneys is unusual, Marra said. “It was a deviation from
t
i
the government s standard practice to negotiate with
■
defense counsel about the extent of crime victim
i
I
notifications,” he wrote.
I
Further, he noted, that when Edwards and his two young
clients asked for information, they were repeatedly misled.
“The CRVA was designed to protect victims' right and
ensure their involvement in the criminal justice process,”
Marra wrote. “When the government gives information to
victims it cannot be misleading.”
Ultimately, the terms of the non-prosecution agreement
were revealed only after Edwards and attorneys for the
press successfully sued to make them public.
@pbpcourts
CA/Aronbero-000095
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
.,; 
Such cooperation between prosecutors and defense 
I 
attorneys is unusual, Marra said. "It was a deviation frohi 
I 
the government's standard practice to negotiate with 
defense counsel about the extent of crime victim 
notifications," he wrote. 
Further, he noted, that when Edwards and his two young 
clients asked for information, they were repeatedly misled. 
''The CRVA was designed to protect victims' right and 
ensure their involvement in the criminal justice process," 
Marra wrote. "When the government gives information to 
victims it cannot be misleading." 
Ultimately, the terms of the non-prosecution agreement 
were revealed only after Edwards and attorneys for the 
press successfully sued to make them public. 
jm usgrave@pbpost.com 
@pbpcourts 
CA/Aronbem:-000095 
. 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
Page 89 100% OCR confidence
76/278-Tuesday, July 9, 2019
|
i
Edition: Final
Section: A Section
Page: 1A
Source: By Jane Musgrave, The Palm Beach Post
Epstein indicted on sex charges
Part-time Palm Beacher pleads not guilty to sex
trafficking, conspiracy charges in federal court in
Manhattan
Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not guilty
to charges accusing him of creating a vast network of girls as young as 14 that he exploited
for his sexual pleasure at his homes in Palm Beach and Manhattan.
The 66-year-old money manager's appearance in U.S. District Court in New York City
capped more than a decade of recriminations by young women and their attorneys who
claimed Epstein used his money and political influence to avoid federal prosecution.
Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking
charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach
County Jail for 13 months more than a decade ago.
However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to
shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state
prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is
now U.S. labor secretary.
"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey
Berman said at a
morning news conference. "And while the charged conduct is from a number ofyears 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 Roya...
Page 90 100% OCR confidence
I
I
I
I
I
"We think he's a significant flight risk," Berman said of the man who ferried Britain's Prince
Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former
President Bill Clinton on his jet, dubbed the Lolita Express.
|
Berman's hard-line stance was welcomed by young women who for years have been told that
Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement,
promising not to charge Epstein in federal court.
Former Palm Beach County resident Virginia Guiffre, who has accused Epstein 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 nonprosecution agreement
because it contained some significant fine print, said former federal Judge Paul Cassell, who
for years has fought to get the agreement thrown out. It says only that no charges could be
filed against Epstein in South Florida, he said.
Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of
Florida," he said. "The Southern District ofNew York is not bound by that agreement and
wasn't a signatory of it."
That means the sordid allegations that have been leveled at Epstein for years are now part of
a federal indictment.
Contrary to Epstein's claims, he knew the women who came to his homes in New York and
Palm Beach were minors because they told him their ages, according to the indictment.
Epstein preyed on young girls because he knew they were "vulnerable to exploitation,"
prosecutors added.
As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while
he was in New York so they would be available for sex once he returned to Palm Beach, the
indictment says. The employees weren't named. They were identified only as ...
Page 91 100% OCR confidence
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 agreementlbefore it was inked.
Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight
Monday, explaining what action Marra should take to redress that wrong.
Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida
victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein's
victims with attorneys Bradley Edwards and Jack Scarola.
Since it's likely Florida women will get to testify against Epstein in New York, Scarola said
he's not focused on whether Epstein will face charges here. Instead, he said he wants to know
how and why the agreement was reached.
"There's been no explanation as to how a deal like this could have been cut and how the
federal government could have been involved in a conspiracy to violate federal law," Scarola
said of his interest in continuing the legal battle over the nonprosecution agreement.
When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two
prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the
Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He
was also forced to register as a sex offender and settle civil lawsuits more than 30 young
women filed against him.
U.S. Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out
how the agreement came to be. "I am especially more interested in why Epstein got the deal
he got," Frankel said. "We need to know why he was given such an easy sentence.
While she has asked the House Oversight Committee to investigate Acosta, Frankel said she
is not sure that will happen. "It just seems to me it was a travesty that this guy got off the
way he did and, without pre-judging it, let's have a proper court case," Frankel said....
Page 92 100% OCR confidence
I
I
I
I
i
i
"Ifyou believe you are a victim of this man, Jeffrey Epstein, we want to|hear from you,"
Berman said. A special number, 1-800-CALLFBI, will link victims of authorities.
Bill Sweeney, assistant director of the FBI's New York office, said after years of being
ignored by federal agents, the victims' voices will be heard.
;
"The Jeffrey Epstein matter is No.
1 on the major case list in the country'," Sweeney said.
Turning to address Epstein's victims directly, he said: "Your bravery may empower others to
speak out against crimes against them."
CA/Aronberg-000099
J
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
NOT A CERTIFIED COPY
I 
I 
"If you believe you are a victim of this man, Jeffrey Epstein, we want to)hear from you," 
Berman said. A special number, 1-800-CALLFBI, will link victims of authorities. 
Bill Sweeney, assistant director of the FBI's New York office, said after 1years of being 
ignored by federal agents, the victims' voices will be heard. 
, 
"The Jeffrey Epstein matter is No. 1 on the major case list in the country'," Sweeney said. 
Turning to address Epstein's victims directly, he said: "Your bravery may empower others to 
speak out against crimes against them." 
j musgrave@p bpost. com 
CA/Aronberg-000099 
: 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/27/2023 2:57:43 PM 
Extracted image

Page 1
document
2544 x 3289

Objects: Page, Text, Letter | Text: ***** CASE NUMBER: 502019CA014 4681XXXXMB Div: AG **** | Filing

Extracted image

Page 1
document
383 x 313

Objects: Handwriting, Text, Machine, Wheel, Animal, Kangaroo, Mammal

Extracted image

Page 2
document
2544 x 3290

Objects: Page, Text, Letter | Text: THE STATE OF FLORIDA | TO EACH SHERIFF OF THE STATE: You are com

Extracted image

Page 2
document
512 x 210

Objects: Text | Text: Des poursuites judiciares | de la date de l'assignation de cette: | tribunal.

Extracted image

Page 2
photo
310 x 281

Objects: Logo, Badge, Symbol, Emblem, Bread, Food

Extracted image

Page 3
document
2544 x 3291

Objects: Page, Text, Letter | Text: Filing # 98869063 E-Filed 11/14/2019 11:06:37 AM | IN THE CIRCUI

Extracted image

Page 4
document
2544 x 3287

Objects: Page, Text, Letter | Text: has authority in grand jury proceedings pursuant to Fla Stat. se

Extracted image

Page 5
document
2544 x 3293

Objects: Page, Text, Letter | Text: To the contrary, transparency is required to promote public unde

Extracted image

Page 6
document
2544 x 3289

Objects: Page, Text, Letter | Text: as here, many of the details of Epstein's criminal misdeeds have

Extracted image

Page 7
document
2544 x 3291

Objects: Letter, Text, Page | Text: 13. | Both the victim/witness interviews, as well as evidence re

Extracted image

Page 8
document
2544 x 3293

Objects: Page, Text, Letter | Text: that either an arrest warrant be issued for Epstein or the State

Extracted image

Page 9
document
2544 x 3287

Objects: Page, Text, Letter | Text: (3) | The FBI's Investigation and Epstein's Non-Prosecution | Ag

Extracted image

Page 10
document
2544 x 3292

Objects: Page, Text, Letter | Text: On information and belief, based on public records, former State

Extracted image

Page 11
document
2544 x 3290

Objects: Page, Text, Letter | Text: 36 | Upon information and belief, during the course of the Town

Extracted image

Page 12
document
2544 x 3292

Objects: Page, Text, Letter | Text: 41. | On July 8, 2019, prosecutors with the Public Corruption Un

Extracted image

Page 13
document
2544 x 3295

Objects: Page, Text, Letter | Text: may not otherwise be aware of." Indeed, even Epstein' S defense

Extracted image

Page 14
document
2544 x 3285

Objects: Page, Text, Letter | Text: D. | The Palm Beach Post's Standing and the Public Interest. | 5

Extracted image

Page 15
document
2544 x 3291

Objects: Page, Text, Letter | Text: "After Long Probe, Billionaire Faces Solicitation Charge" publis

Extracted image

Page 16
document
2544 x 3288

Objects: Page, Text, Letter | Text: offender," and that "[a]s part of the plea deal, federal investi

Extracted image

Page 17
document
2544 x 3290

Objects: Page, Text, Letter | Text: "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated

Extracted image

Page 18
document
2544 x 3291

Objects: Page, Text, Letter | Text: has "standing to assert a right to receive speech" by "show[ing]

Extracted image

Page 19
document
2544 x 3291

Objects: Page, Text, Letter | Text: maintain the dignity and the integrity of both the grand jury an

Extracted image

Page 20
document
2544 x 3294

Objects: Page, Text, Letter | Text: that precluded his indictment for the serious crimes he committe

Extracted image

Page 21
document
2544 x 3293

Objects: Page, Text, Chart, Plot, Diagram, Plan, Menu | Text: Dated: November 14; 2019 | Respectfull

Extracted image

Page 21
document
442 x 223

Objects: Text, Head, Person | Text: Telephone: (310) 586 | boyajiann@gtlaw. com

Extracted image

Page 21
document
499 x 220

Objects: Text, Face, Head, Person | Text: Telephone. (310) 586 770 | Facsimile: (310 586 7800 | chie

Extracted image

Page 21
document
427 x 218

Objects: Text, Alphabet, Person | Text: Albany, New York 12 | Telephone: (518) 689- | grygielm@gtlaw

Extracted image

Page 21
document
675 x 332

Objects: Text, Letter, Handwriting | Text: Respectfully submitted, | GREENBERG TRAURIG, P.A. | Attor

Extracted image

Page 22
document
2544 x 3294

Objects: Page, Text | Text: EXHIBIT 1 | The Newspaper's Reportage on Jeffrey Epstein | CA/Aronberg-0

Extracted image

Page 23
document
2544 x 3296

Objects: Page, Text, Advertisement, Poster | Text: The Man Who Had Everything: Jeffrey Epstein crave

Extracted image

Page 23
document
480 x 447

Objects: Text, Page, Number, Symbol, Device, Grass, Lawn, Lawn Mower, Plant, Tool | Text: elite frie

Extracted image

Page 24
document
2544 x 3285

Objects: Page, Text, Letter | Text: The Man Who Had Everything: Jeffrey Epstein craved big homes, el

Extracted image

Page 25
document
2544 x 3289

Objects: Page, Text, Letter | Text: The Man Who Had Everything: Jeffrey Epstein craved big homes, el

Extracted image

Page 26
document
2544 x 3288

Objects: Page, Text, Letter | Text: The Man Who Had Everything: Jeffrey Epstein craved big homes, el

Extracted image

Page 27
document
2544 x 3289

Objects: Page, Text, Letter | Text: The Man Who Had Everything Jeffrey Epstein craved big homes, eli

Extracted image

Page 28
document
2544 x 3291

Objects: Page, Text, Letter | Text: The Man Who Had Everything: Jeffrey Epstein craved big homes, el

Extracted image

Page 28
document
218 x 517

Objects: Text, Alphabet | Text: friendsland | discuss the | into what d

Extracted image

Page 29
document
2544 x 3288

Objects: Page, Text, Letter | Text: The Man Who Had Everything: Jeffrey Epstein craved big homes, el

Extracted image

Page 29
document
292 x 391

Objects: Page, Text, Chart, Plot, Number, Symbol | Text: to one teenage | according to P

Extracted image

Page 30
document
2544 x 3292

Objects: Page, Text, Letter | Text: The Man Who Had Everything: Jeffrey Epstein craved big homes, el

Extracted image

Page 31
document
2544 x 3290

Objects: Page, Text, Letter | Text: The Man Who Had Everything: Jeffrey Epstein craved big homes, el

Extracted image

Page 32
document
2544 x 3293

Objects: Page, Text | Text: The Man Who Had Everything: Jeffrey Epstein craved big homes, elite frie

Extracted image

Page 33
document
2544 x 3294

Objects: Page, Text, Letter | Text: 273 8 / 278 - Tuesday, November 16, 2004 | Edition: FINAL | Sect

Extracted image

Page 34
document
2544 x 3291

Objects: Page, Text, Letter | Text: But Friedman allowed the offer to stand, and Pulte and Trump wen

Extracted image

Page 35
document
2544 x 3295

Objects: Page, Text, Letter | Text: The trustee alleged during a weeklong trial in May that Gosman f

Extracted image

Page 36
document
2544 x 3294

Objects: Page, Text, Advertisement, Poster | Text: 11/11/2019 | Indictment: Billionaire Solicited 3

Extracted image

Page 37
document
2544 x 3295

Objects: Page, Text, Letter | Text: 11/11/2019 | Indictment: Billionaire Solicited 3 Times - News -

Extracted image

Page 38
document
2544 x 3296

Objects: Page, Text | Text: 11/11/2019 | After long probe, billionaire faces solicitation charge - N

Extracted image

Page 39
document
2544 x 3288

Objects: Page, Text, Letter | Text: 11/11/2019 | After long probe, billionaire faces solicitation ch

Extracted image

Page 40
document
2544 x 3291

Objects: Page, Text, Letter | Text: 11/11/2019 | After long probe, billionaire faces solicitation ch

Extracted image

Page 41
document
2544 x 3289

Objects: Page, Text, Letter | Text: 11/11/2019 | After long probe, billionaire faces solicitation ch

Extracted image

Page 42
document
2544 x 3290

Objects: Page, Text, Letter | Text: 11/11/2019 | After long probe, billionaire faces solicitation ch

Extracted image

Page 43
document
2544 x 3290

Objects: Page, Text | Text: 11/11/2019 | Police say lawyer tried to discredit teenage.girls - News -

Extracted image

Page 44
document
2544 x 3288

Objects: Page, Text, Letter | Text: 11/11/2019 | Police say lawyer tried to discredit teenage girls

Extracted image

Page 44
document
492 x 332

Objects: Text, Handwriting | Text: and jury in February, bu | 1 gleaned from the Web | commenting on

Extracted image

Page 45
document
2544 x 3292

Objects: Page, Text, Letter | Text: 11/11/2019 | Police say lawyer tried to discredit teenage girls

Extracted image

Page 45
document
291 x 413

Objects: Page, Text | Text: m Beach Daily News | as told. Phone | intimidated he

Extracted image

Page 46
document
2544 x 3290

Objects: Page, Text, Letter | Text: 11/11/2019 | Police say lawyer tried to discredit teenage girls

Extracted image

Page 46
document
258 x 581

Objects: Text | Text: he said. | r wealthy, со | dent Clinton | e knew he wa

Extracted image

Page 47
document
2544 x 3293

Objects: Page, Text, Advertisement, Poster | Text: The Palm Beach Post | REAL NEWS STARTS HERE | Exp

Extracted image

Page 48
document
2544 x 3293

Objects: Page, Text, Letter, Advertisement | Text: his current job, has returned $10,000 to him beca

Extracted image

Page 49
document
2544 x 3288

Objects: Page, Text, Letter, Advertisement | Text: "A prosecutor has to look at it in a much broader

Extracted image

Page 50
document
2544 x 3293

Objects: Page, Text, Letter | Text: Still there is a "universal constant" in prosecuting these | cas

Extracted image

Page 51
document
2544 x 3290

Objects: Page, Text, Advertisement, Poster | Text: The Palm Beach Post | REAL NEWS STARTS HERE | Eps

Extracted image

Page 52
document
2544 x 3291

Objects: Page, Text, Letter | Text: Epstein on the less serious charge, Police Chief Michael | Reite

Extracted image

Page 53
document
2544 x 3293

Objects: Page, Text, Letter | Text: The Palm Beach Police Department was "happy and | ecstatic" that

Extracted image

Page 53
document
234 x 474

Objects: Text, Page | Text: and | evidence. "I | h the result. | Epstein. | "

Extracted image

Page 54
document
2544 x 3287

Objects: Page, Text, Person, Newspaper | Text: Newspapers | The Palm Beach Post (West Palm Beach, "F

Extracted image

Page 54
document
813 x 1346

Objects: Newspaper, Text, Adult, Male, Man, Person, Face, Head, Page | Text: Palm Beach chief focus

Extracted image

Page 55
document
2544 x 3292

Objects: Page, Text, Advertisement, Poster | Text: The Palm Beach Post | REAL NEWS STARTS HERE | Del

Extracted image

Page 56
document
2544 x 3290

Objects: Page, Text, Letter | Text: "Highly unusual" is how Palm Beach Police Chief Michael | Reiter

Extracted image

Page 57
document
2544 x 3293

Objects: Page, Text, Letter | Text: Epstein's attorney Jack Goldberger did not return phone | messag

Extracted image

Page 58
document
2544 x 3295

Objects: Page, Text, Letter | Text: Edmondson, spokesman for State Attorney Krischer, said | there i

Extracted image

Page 58
document
280 x 318

Objects: Page, Text | Text: Krischer, said | prosecution t

Extracted image

Page 59
document
2544 x 3288

Objects: Page, Text, Letter | Text: 252 / 278 - Thursday, October 18, 2007 | Edition: FINAL | Sectio

Extracted image

Page 60
document
2544 x 3292

Objects: Page, Text, Advertisement, Poster | Text: The Palm Beach Post | REAL NEWS STARTS HERE | Pal

Extracted image

Page 61
document
2544 x 3291

Objects: Page, Text, Letter | Text: The indictment charged Epstein only with felony | solicitation o

Extracted image

Page 62
document
2544 x 3291

Objects: Page, Text, Letter | Text: When he is released from jail, there is a chance that Epstein |

Extracted image

Page 63
document
2544 x 3295

Objects: Page, Text, Letter | Text: The state attorney's office said questions about the girls | cre

Extracted image

Page 64
document
2544 x 3289

Objects: Page, Text, Advertisement, Poster | Text: The Palm Beach Post | REAL NEWS STARTS HERE | Jef

Extracted image

Page 65
document
2544 x 3293

Objects: Page, Text, Letter | Text: girls $200 to $300 in 2004 and 2005 for massages in his | home t

Extracted image

Page 66
document
2544 x 3290

Objects: Page, Text, Letter | Text: Epstein has financed a number of scientists over the years, | in

Extracted image

Page 67
document
2544 x 3292

Objects: Page, Text, Advertisement, Poster | Text: Palm Beach Daily News | Billionaire sex offender

Extracted image

Page 68
document
2544 x 3293

Objects: Page, Text, Letter | Text: arrangement is not unusual. | "He goes to work every single day

Extracted image

Page 69
document
2544 x 3286

Objects: Page, Text, Advertisement, Poster | Text: The Palm Beach Post | REAL NEWS STARTS HERE | Wom

Extracted image

Page 70
document
2544 x 3292

Objects: Page, Text, Letter | Text: Epstein's own attorneys, in federal filings, have referred to |

Extracted image

Page 71
document
2544 x 3289

Objects: Page, Text, Letter | Text: During a Palm Beach Police Department investigation, five | vict

Extracted image

Page 72
document
2544 x 3292

Objects: Page, Text, Advertisement, Poster | Text: The Palm Beach Post | REAL NEWS STARTS HERE | Eps

Extracted image

Page 73
document
2544 x 3293

Objects: Page, Text, Letter | Text: Mark Johnson of Stuart, a former federal prosecutor, | described

Extracted image

Page 74
document
2544 x 3289

Objects: Page, Text, Letter | Text: other young women to lure them to his Palm Beach | mansion. They

Extracted image

Page 75
document
2544 x 3294

Objects: Page, Text, Letter | Text: The investigation triggered tensions between police and | prosec

Extracted image

Page 76
document
2544 x 3291

Objects: Letter, Text, Page | Text: 187/278 - Wednesday, January 27, 2010 | Edition: FINAL | Section

Extracted image

Page 77
document
2544 x 3294

Objects: Page, Text, Advertisement, Poster, Letter | Text: The Palm Beach Post | REAL NEWS STARTS HE

Extracted image

Page 78
document
309 x 306

Objects: Text | Text: prostitution- | Lanager pleaded | prostitution | nths of an 18-

Extracted image

Page 78
document
2544 x 3295

Objects: Page, Text, Letter, Advertisement, Poster | Text: Instead, prosecutors short-circuited the

Extracted image

Page 79
document
2544 x 3287

Objects: Page, Text, Letter | Text: represent any of the victims on the list who wanted to | pursue

Extracted image

Page 80
document
2544 x 3290

Objects: Page, Text, Newspaper | Text: Epstein paid three women $5.5 million to end underage-sex law

Extracted image

Page 80
document
291 x 302

Objects: Text, Logo, Number, Symbol, Animal, Kangaroo, Mammal | Text: Post

Extracted image

Page 81
document
2544 x 3289

Objects: Page, Text, Letter | Text: Epstein paid three women $5.5 million to end underage-sex lawsui

Extracted image

Page 82
document
2544 x 3295

Objects: Page, Text, Letter | Text: Epstein paid three women $5.5 million to end underage-sex lawsui

Extracted image

Page 83
document
2544 x 3294

Objects: Page, Text, Advertisement, Poster | Text: Palm Beach Daily News | Judge rules feds' agreeme

Extracted image

Page 84
document
2544 x 3286

Objects: Page, Text, Letter | Text: Prosecutors failure to alert the young women about the | deal vi

Extracted image

Page 84
document
307 x 336

Objects: Text | Text: en about the | t, Marra rule'd. | | d to enter into a

Extracted image

Page 85
document
2544 x 3290

Objects: Page, Text, Letter, Advertisement | Text: "I don't see the government conceding to that rem

Extracted image

Page 86
document
2544 x 3289

Objects: Page, Text, Letter | Text: Even if Marra agrees to toss out the non-prosecution | agreement

Extracted image

Page 86
document
255 x 393

Objects: Page, Text, Book, Publication | Text: ecution | an Epstein | wi | government

Extracted image

Page 87
document
2544 x 3290

Objects: Page, Text, Letter | Text: In his ruling, Marra detailed what appeared to be a cozy | relat

Extracted image

Page 87
document
284 x 488

Objects: Text | Text: tors and | ers included | investigation

Extracted image

Page 88
document
2544 x 3291

Objects: Page, Text, Letter | Text: Such cooperation between prosecutors and defense | attorneys is

Extracted image

Page 89
document
2544 x 3290

Objects: Page, Text, Letter, Advertisement | Text: 76 6/278-Tuesday, July 9, 2019 | Edition: Final |

Extracted image

Page 90
document
2544 x 3292

Objects: Page, Text, Letter | Text: "We think he's a significant flight risk," Berman said of the ma

Extracted image

Page 90
document
309 x 413

Objects: Text | Text: ho for years ha | nonprosecution

Extracted image

Page 91
document
2544 x 3292

Objects: Letter, Page, Text | Text: U.S. District Judge Kenenth Marra has already ruled that Acosta

Extracted image

Page 91
document
350 x 561

Objects: Text, Page, Person | Text: sta violated the fe | 0 file papers by m | that wrong. | n West

Extracted image

Page 92
document
2544 x 3296

Objects: Page, Text, Letter | Text: "If you believe you are a victim of this man, Jeffrey Epstein, w

People Mentioned
Places Mentioned
Document Info
File Path
additional_files/146.pdf
File Size
5,087 KB
Processed
2025-12-21 03:23
Status
completed