171.pdf

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relatively straightforward.
In
my view,
a public hearing
clearly is nevertheless the preferred vehicle for its
resolution.
Incidentally, while I'm on this subject,
I got some
help today from the New York Law Journal from two professors
who write that a hearing is — let
me tell you exactly what
they said.
They say, in part, that this is an odd moment for
transparency in a criminal case.
I think that is an odd
sentence to hear about, transparency in a criminal case.
They go on to say that normally, if a prosecutor seeks
to dismiss an indictment for such an obviously worthy reason,
the court would simply grant the request.
As to that
statement,
I respectfully say it is incorrect as a matter of
law.
They go on to say the judge would not schedule a
hearing and he definitely would not allow the victims to speak.
If he did hold a hearing, whatever informational interests the
victims may have would be served by affording them a chance to
attend the hearing, not by giving them a speaking role.
I read it.
It was incredulous.
I'm still
incredulous.
I don't quite understand at all.
There is a
suggestion in the article that the reason they are making these
suggestions has to do with minimization of drama in this case.
In the Jeffrey Epstein case, there has not been much a
minimization of drama,
and what little drama might happen
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000923
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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relatively straightforward. 
In my view, a public hearing 
clearly is nevertheless the preferred vehicle f~r its 
resolution. 
Incidentally, while I'm on this subject, I got some 
help today from the New York Law Journal from two professors 
who write that a hearing is -- let me tell you exactly what 
they sai...

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today,
I don't think it would be very significant.
On a somewhat more serious note, don't; quote me on
this, but it is my understanding that one of this authors of
that article is himself counsel in one of the Epstein-related
cases.
I was surprised to learn that very recently.
I'm
certain it is true.
I was also surprised that that aspect was
not disclosed in the Law Journal.
But in any event,
I think you know where I'm heading.
I respectfully disagree with the Law Journal piece.
I was
saying that the government's motion is relatively
straightforward,
and in my view,
a public hearing is clearly,
nevertheless, the preferred vehicle for its resolution.
I'm
still convinced of that.
A few may differ on this, but public hearings are
exactly what judges do.
Hearings promote transparency and they
provide the court with insights and information which the court
may not otherwise be aware of.
The victims have been included in the proceeding today
both because of their relevant experiences and because they
should always be involved before rather than after the fact.
Indictment 19
CR 490 charges Jeffrey Epstein with sex
trafficking and with conspiracy to commit sex trafficking.
The
U.S. Attorney,
on August 19,
2019, requested that the court
approve the government's proposed order of nolle prosequi.
I
think that's a rough justice.
That means nolle prosequi,
SOUTHERN DISTRICT REPORTERS, P.O.
(212)
805-0300
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CA/Aronberg-000924
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
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today, I don't think it would be very significa~t. 
On a somewhat more serious note, don't: quote me on 
I 
this, but it is my understanding that one of the authors of 
i 
' 
5 
that article is himself counsel in one of the Epstein-related 
cases. 
I was surprised to learn that ve...

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discontinuance by the prosecutor of all or of a part of the
i
case that he or she has commenced.
;
i
The government in its motion concludes' that Epstein's
death abates these proceedings.
In accordance with Federal
Rule of Criminal Procedure 57(b),
I determined to hold a public
hearing and I notified the victims that they would be given the
opportunity to be heard before any final action on the motion.
That is the purpose also of today's proceeding.
I would do
that every time.
Also, recognized that Epstein,
Mr. Epstein died before
any judgment of conviction against him had been obtained, and
that the government's proposed order appears, in form and
substance, to be appropriate.
Federal Rule of Criminal Procedure 48(a) codifies the
nolle prosequi process.
It is entitled dismissal, and it
states in relevant part that the government may, with leave of
the court, dismiss an indictment, information, or complaint,
and that leave of the court proviso,
you should know,
was added
as an amendment to the original draft of Rule 48, which had
originally provided for automatic dismissal upon the motion of
the government.
This proviso, in my judgment, is clearly directed
toward an independent judicial assessment of the public
interest in dismissing the indictment.
Thus, even whereas, in
this case, the standard of court review is deferential, the
SOUTHERN DISTRICT REPORTERS, P.O.
(212)
805-0300
CA/Aronberg-000925
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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discontinuance by the prosecutor of all or of a, part of the 
I 
case that he or she has commenced. 
6 
The government in its motion concludesi that Epstein's 
death abates these proceedings. 
In accordance with Federal 
Rule of Criminal Procedure 57(b), I determined to hold a public 
hearing and I ...

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court must still make its own independent determination.
A
conclusory statement from the government that dismissal is
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appropriate does not satisfy the court's obligations.
It is also, in my view, required that the court
consider the views of the victims in the case at the hearing
and before deciding whether to grant the motion.
This is being
done here both as a matter of law and as a measure of respect
that we have for the victims' difficult decisions to come
forward in this matter.
In a case called United States v. Heaton,
H-e-a-t-o-n-, the government filed a Rule 48 motion for leave
to dismiss a charge against a defendant who allegedly committed
a sexual offense against a young victim.
Although I should
point out, very importantly, that that defendant was still
alive, which distinguishes it from our case.
Nevertheless,
I think it is irrelevant because in
evaluating the Rule 48 motion, then district Judge Paul G.
Cassell — who is now a law professor at the University of Utah
and is regarded to be a noted expert in victims' rights —
concluded that under the Crime Victims' Rights Act, victims
have broad rights that extend to a court's decision whether to
grant a government motion to dismiss under Rule 48.
I completely share that viewpoint in these
circumstances, even though the facts of our case, as I said,
are somewhat different from those in Heaton.
I believe it is
SOUTHERN DISTRICT REPORTERS, P.O.
(212)
805-0300
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CA/Aronberg-000926
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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court must still make its own independent determination. 
A 
' 
conclusory statement from the government that dismissal is 
I 
appropriate does not satisfy the court's 
I 
obliga;tions. 
It is also, in my view, required that the court 
consider the vi...

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the court's responsibility, and manifestly within its purview,
to ensure that the victims in this case are treated fairly and
with dignity.
The fundamental substantive principle which applies in
considering the government's motion is termed the rule of
abatement.
This principle originated in the English common
law.
It was adopted by most U.S. federal courts, but more
recently, it has faced some appropriate criticism.
The rule of
abatement is best explained in the Second Circuit case of
U.S, v. Wright.
In that Wright case,
two defendants had pled guilty to
embezzlement and tax evasion.
Both defendants appealed, but
one of the defendants died while his appeal was pending in the
Second Circuit.
The Court of Appeals rule that under the rule
of abatement, the judgment of conviction against the deceased
defendant was required to be vacated and the indictment was to
be dismissed.
The Wright court held that when a convicted
defendant dies while his direct appeal as of right is pending,
his death abates not only the appeal, but also proceedings had
during the course of the prosecution.
The Second Circuit incidentally has also held that
when a criminal conviction abates upon the death of a
defendant,
any restitution ordered as a result of that
conviction must also abate, and it is also ruled the same with
respect to associated forfeiture orders.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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CA/Aronberg-000927
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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the court's responsibility, and manifestly with~n its purview, 
to ensure that the victims in this case are treated fairly and 
I 
with dignity. 
The fundamental substantive principle which applies in 
considering the government's motion is termed the rule of 
abatement. 
This principle or...

J8RsEPSl
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This latter application of the rule
of1 abatement
regarding forfeiture has not been universally accepted among
federal courts, but it certainly is the law in this circuit.
Some of you may be interested to know that some United States
courts, state courts, have criticized the rule of abatement,
particularly in the face of growing recognition of victims'
rights in the criminal justice system, including the Crime
Victims' Rights Act.
It has been written and contended in the Brooklyn Law
Review — I can give you the cite later — that when courts
abate criminal convictions, they reimpose a burden on victims
that legislatures intended to alleviate through these victim
rights statutes.
The state Supreme Court has even concluded
that the expansion and codification of victims' rights provides
the changed conditions needed for overruling the rule of
abatement.
It has also been stated that Alaska's statute and
its constitution now require the criminal justice system to
accommodate the rights of crime victims.
Further, that the
abatement of criminal convictions has important implications
for these rights.
But coming back to our case, which is what you are
concerned about and I
am as well, it is appropriate to conclude
that if the rule of abatement applies to a convicted defendant
as in the Wright case, it should also apply a fortiori in the
Epstein case, which was still in the pretrial phase when
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000928
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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This latter application of the rule of: abatement 
regarding forfeiture has not been universally accepted among 
federal courts, but it certainly is the law in this circuit. 
Some of you may be interested to know that some United States 
courts, sta...

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Mr. Epstein died,
when there had been no conviction.
So that's just some background I wanted to share with
you.
At this point in time,
I would like to turn to the
government prosecutors to hear from them in support of their
Rule 48 application to dismiss the Epstein indictment.
MS.
COMEY:
Thank you, your Honor.
Would you like me to address the court from the
podium?
THE COURT:
If you wouldn't mind.
MS.
COMEY:
Thank you, your Honor.
I believe your Honor has accurately summarized the
state of the law, as set forth in our papers, in light of the
clear Second Circuit law, that upon the death of a defendant
before a final entry of a judgment of conviction, all
proceedings must be abated.
In light of that clear law, the government is legally
obligated to seek dismissal of the pending indictment against
Jeffrey Epstein, and we respectfully submit, likewise, that the
entry of the proposed order is similarly required by law.
A few notes to make about that, though, your Honor.
To be very clear, dismissal of this indictment as to Jeffrey
Epstein in no way prohibits or inhibits the government's
ongoing investigation into other potential coconspirators, nor
does it prevent the bringing of a new case in the future or the
prosecution of new defendants.
10
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000929
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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Mr. Epstein died, when there had been no convic~ion. 
So that's just some background I wanted to share with 
I 
you. 
At this point in time, I would like to turn to the 
government prosecutors to hear from them in support of their 
Rule 48 application to dismiss the Epstein indictment. 
podium? 
MS. COMEY: 
Thank you, your Honor. 
Would you like me to address the court from t...

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It also does nothing to prevent the government from
continuing to explore the possibility of seeking civil
forfeiture of any assets that were used to facilitate the
crimes charged in this indictment.
Indeed, as has been stated
publicly, investigations into those matters have been ongoing,
remain ongoing,
and will continue following dismissal of the
indictment here.
I would also like to note that, as the government has
previously mentioned, this dismissal in no way lessens the
government's resolve to stand up for the victims in this case,
both those who have come forward and those who have yet to do
so.
We agree with your Honor's sentiment that those victims
should be respected, and we appreciate your Honor's recognition
of that.
One housekeeping matter that I did want to reference
for your Honor.
The protective order in this case requires
destruction or return of any and all discovery material upon
conclusion of the case.
We have been in communication with
defense counsel,
who have confirmed that they have returned all
physical copies that they have of discovery that the government
has produced to date, and they are in the process of deleting
any copies that they may have made.
So the parties are in
compliance with the protective order.
Finally,
I just wanted to say a word about the victims
in this case, and particularly those who are here in court
SOUTHERN DISTRICT REPORTERS, P.O.
(212)
805-0300
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CA/Aronbe rg-000930
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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It also does nothing to prevent the government from 
continuing to explore the possibility of seeking civil 
forfeiture of any assets that were used to facilitate the 
crimes charged in this indictment. 
Indeed, as has been stated 
publicly, investigations into those matte...

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today. I'll note that in light of the court's order indicating
that the victims and their counsel would be permitted to be
heard in court here today, the government has endeavored to
provide notice to all known victims of today's proceeding.
We
did so either directly where a victim was not represented by
counsel or through counsel where a victim is represented by an
attorney.
The government does not know exactly how many victims
or their attorneys are here today and we do not know how many
of them or their counsel would like to speak.
To the extent
any individuals do wish to speak,
we do not know the substance
of what they would like to say.
We have left that entirely up
to the individual decisions of the victims and their attorneys.
I will note, though, that throughout this case, the
government has endeavored and done our utmost to fulfill our
obligations under the Crimes Victims' Rights Act.
We have done
so by trying to keep as many victims as we are aware of up to
date about the ongoing case and about any developments in the
case.
We will continue to provide services and offer
services to any of the victims in this case, even after the
indictment is dismissed.
Both the U.S. Attorney's office and
the FBI have been in touch with all known victims or have
attempted to be in touch with all known victims, either again
directly where victims are not represented by counsel or
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000931
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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today. 
I 
I'll note that in light of the court's prder indicating 
that the victims and their counsel would be permitted to be 
heard in court here today, the government has endeavored to 
provide notice to all known victims of today's pro...

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through counsel where they have attorneys.
We have expressed
I
to them that services are available for those who wish to take
advantage of them.
Unless the court has any questions for me, the
government will otherwise rest on its papers.
THE
COURT:
I just have one question.
The protective order, is that self-executing or do I
need to do something?
MS .
COMEY:
It is self-executing, your Honor
THE COURT:
Thanks very much,
Ms.
Comey.
MS.
COMEY:
Thank you, your Honor.
THE COURT:
Yes.
I'll turn to counsel for the defense at this time.
Mr. Weingarten, I'm happy to hear from you.
MR.
WEINGARTEN:
Thank you.
Your Honor,
I think it is an understatement of the
year to say the world looks and feels differently today than it
did the last time I was before you.
For us, the elephant in
the room is what happened to our client.
I would like to tell
you how we see the world and where we are on that subject.
We start with the Attorney General's statements,
public statements, that there were very serious improprieties
in the jail.
We obviously read the press.
We see that the
warden has been taken out.
We see that the guards on duty at
the time have been put on leave.
We understand guards are
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000932
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RsEPS1 
through counsel where they have attorneys. 
We rave expressed 
to them that services are available for those who wish to take 
advantage of them. 
Unless the court has any questions for me, the 
government will otherwise rest on its papers. 
THE COURT: 
I just have one question. 
The protective order, is that self-executing or do I 
need to do something? 
MS. COMEY: 
It is self-executing, your Honor. 
THE COURT: 
Thanks very much, Ms. Corney. 
MS. COME...

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refusing to cooperate with the investigation.
We have heard
allegations that people at the time who had responsibility for
protecting our client falsified information.
We understand
that there were orders out there that Jeffrey Epstein was never
to be left alone and that the orders were ignored by many of
the employees of the prison.
In a word, yikes.
In addition, obviously we followed
the medical examiner's report, or we haven't followed the
report,
we haven't seen it, but heard conclusions, initially
not enough evidence to come to a conclusion, wanted to see
more.
We assumed she was talking about the videotapes, but
then came to the conclusion that it was suicide.
We report to the court that —
THE
COURT:
Suicide by hanging —
MR.
WEINGARTEN:
Yes.
THE
COURT:
— was her conclusion?
MR.
WEINGARTEN:
Yes.
And we report to the court that we had a doctor there
at the time, and we also have been in receipt of a tremendous
amount of medical and scientific evidence volunteered to us
opining that the injuries suffered, as reported, were far more
consistent with assault than with suicide,
and we are happy to
supply the court with all the information that we have.
Now, in addition, as the court noted,
we were underway
with our pretrial motions, and as the court obviously
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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CA/Aronberg-000933
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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refusing to cooperate with the investigation. 
We have heard 
allegations that people at the time who had responsibility for 
protecting our client falsified information. 
We understand 
that there were orders out there that Jeffrey Epstein was never 
to be left alone and that the orders were ignored by many of 
the employees of the prison. 
In a word...

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understands, the NPA and the role of the NPA was going to be
critically important.
And I would simply like to report that
we went pretty far along.
We interviewed all of the relevant lawyers on the
defense side who participated in the NPA, and we were satisfied
that we had a very strong argument that every one of those
lawyers believed with an objective basis that the deal was
global.
That is, at the time —
THE COURT:
I'm sorry, that?
MR.
WEINGARTEN:
The deal of the
NPA was global.
That
is,
more specifically, at the time, the Florida prosecutors and
agents knew of conduct in New York,
and that no competent
defense counsel negotiating in good faith with the prosecutors
would have ever agreed to a deal back then that allowed New
York prosecutors to indict for precisely the same conduct in
the future, which, of course, is what happened.
In addition,
we have come up with very powerful
evidence,
we believe, that Florida prosecutors,
who
participated in the deal, steered the victims and the alleged
victims to New York on more than one occasion because they did
not want to suffer the sleights of attacks against them.
So we
have advanced the ball on this very subject and we are prepared
to completely report to the court as to where we are and what
we've done.
Another point.
We obviously had contact with our
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000934
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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understands, the NPA and the role of the NPA was going to be 
critically important. 
And I would simply like to report that 
we went pretty far along. 
15 
We interviewed all of the relevant lawyers on the 
defense side who participated in the NPA, and we were satisfied 
that we had a very strong argument that every one of tho...

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client at or around the time of his death, and obviously the
attorney-client privilege survives death and we; are not going
to forfeit the privilege, but we will report to the court, with
as much specificity as the court may want, that at or around
the time of his death,
we did not see a despairing, despondent
suicidal person.
Details to follow, if the court wishes.
The 800-pound gorilla, for us, of course, are the
video surveillance tapes.
Obviously we assume there is a tape
that leads directly to the door where Jeffrey Epstein was
housed.
If that tape reports for 12 hours before his death
that no one went in and out of that room, then the suggestion
that there was something other than a suicide seems
preposterous.
But there is no such evidence that has surfaced to
date.
Just the opposite.
We have heard, and we actually read
in the press, that the tapes were either corrupted or not
functioning.
Talk about a yikes.
If, in fact, the system was
broken for six months before Jeffrey Epstein was housed,
I
mean, that would be stunning incompetence.
If it was allowed
to continue to be inoperative when Jeffrey Epstein was housed,
it would be incompetence times ten.
But what if the tapes only
broke down or were inoperative or were corrupted on the day he
was killed or the day he died?
Then we're in a completely
different situation.
So where does this lead?
I think where it leads,
SOUTHERN DISTRICT REPORTERS, P.d.
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805-0300
CA/Aronberg-000935
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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' I 
client at or around the time of his death, and bbviously the 
attorney-client privilege survives death and we are not going 
to forfeit the privilege, but we will report to the court, with 
as much specificity as the court may want, that at or ar...

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Judge, is there are incredibly important questions that remain
open.
The public interest in this matter is obvious from this
courtroom.
There are conspiracy theories galore.
We are all
for finding the truth.
We believe this court has an
indispensable role to play.
Whether or not this indictment is dismissed,
I think
this court has the inherent authority to find out what happened
on its watch.
Obviously,
when the court detained Jeffrey
Epstein, the court did not anticipate that weeks later he would
be dead in his cell.
I think given the inherent authority of
the court, the court should make inquiry.
This could come in many forms.
Obviously the court
made inquiry as to what happened in the first incident.
When
there was an allegation of an attempted suicide, the court made
inquiry.
The court obviously was interested.
I recall your language.
You talked about that being
one of the several open questions indicating an interest on the
court for the others as well.
Obviously, the ultimate question
is what happened to the client.
THE COURT:
You're talking about the July 23,
2019
incident?
MR.
WEINGARTEN:
Yes.
The court obviously could hold hearings.
The court
could assign a lawyer to help the court.
I think this is an
area where there is intense public interest.
We have complete
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SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
CA/Aronberg-000936
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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Judge, is there are incredibly important questions that remain 
open. 
The public interest in this matter is obvious from this 
courtroom. 
There are conspiracy theories galore. 
We are all 
for finding the truth. 
We believe this court has an 
indispensable role to play. 
Whether or not this indictment is dismissed, I think 
this court has the inher...

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confidence in the prosecutors in the Southern District and the
FBI to do a competent investigation.
But these are allegations
I
against serious components of the United States1 Department of
Justice.
Sometimes the appearance of justice is just as
important as justice itself.
I think the court supervising, or at least keeping an
interest in this proceeding, is incredibly important for the
public to have confidence in the ultimate findings, and
certainly for us to have confidence in the ultimate findings.
One more issue, Judge.
The conditions of the jail, in
a word, they were dreadful.
Not just for Jeffrey Epstein, but
for many of the prisoners over there.
This is a prison within
the shadows of this courthouse.
The situation is rife with
vermin.
The abuse and the conditions in that prison, in a
word, are a disgrace and everybody knows it.
A person with authority told us,
someone with
knowledge, that the prisoners in Guantanamo — and he spoke
with personal knowledge — are treated better than the
prisoners right across the way.
The feds certainly know how to
run a disciplined, clean prison.
I've been in 20 of them.
They know how to do it just fine.
And the question is,
why in
the world does it not happen down the road?
I think that is a
perfectly legitimate subject for the court to make inquiry.
In a word,
we want the court to help us find out what
happened.
The court has a role to play.
It is the institution
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CA/Aronberg-000937
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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confidence in the prosecutors in the Southern Dlstrict and the 
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FBI to do a competent investigation. 
But thes~J are allegations 
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against serious components of the United Statesl Department of 
Jus...

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that most people have confidence in in these very troubled
times.
;
So whether or not you dismiss the indictment, to us,
is beside the point.
We want you to stay on the case,
we want
you to conduct an investigation, and we want to know what
happened here.
Thank you, your Honor.
THE COURT:
Just so it is clear,
so your view on the
motion directly on its merits of the nolle prosequi order and
application by the U.S. Attorney,
do you have a view on that?
MR.
WEINGARTEN:
I think if the court felt that the
case had to stay alive for the court to continue,
we would
oppose it.
I think —
THE COURT:
I'm sorry, if what?
MR.
WEINGARTEN:
If the issue, if you took the
position for you to conduct the investigation or lead the
investigation or participate in the investigation, then we
want, the role
we want you to play, if the indictment has to be
alive,
we would oppose the motion.
I don't think you need to do that.
I think you can
dismiss the indictment.
THE
COURT:
So you're suggesting that you support the
government's motion, just viewed in the context of —
MR.
WEINGARTEN:
Yes, of course.
THE
COURT:
Great.
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SOUTHERN DISTRICT REPORTERS, P.G.
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805-0300
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CA/Aronberg-000938
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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that most people have confidence 
times. 
• 
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in in these very troubled 
! : 
So whether or not you dismiss the indictment, to us, 
is beside the point. 
We want you to stay on the case, we want 
you to conduct an investigation, and we want to know what 
happened here. 
Thank you, your Honor. 
THE COURT: 
Just so it is clear, so your view on the 
motion directly on its merits of the nolle prosequi order and 
application by the U.S. Attorney, do you have a view on that? 
MR. WEINGARTEN: 
I think if the court felt that the 
case had...

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MR.
WEINBERG:
Judge, if I can just supplement?
THE COURT:
Absolutely.
’
MR.
WEINBERG:
Thank you, sir.
Thank you, as an out-of-town lawyer for the privilege
to appear in front of you, your Honor.
THE COURT:
It's
my pleasure.
MR.
WEINBERG:
First, as to the conditions,
we think
your Honor trusted the government, the Bureau of Prisons, to
keep our client safe and keep him in civilized conditions.
The
government will again ask, as to other defendants, that they be
detained at the
MCC,
some subset of them will end up in the
SHU
unit.
It is a horrific.
I've called it medieval.
There's
vermin on the floor.
There is wet from the plumbing.
There is
no sunlight.
There is limited exercise.
It is simply
conditions that no pretrial detainee — and I would go farther
as a criminal defense lawyer — no United States defendant
should be subjected to.
Certain judges have taken views of the conditions.
We
would urge your Honor, the government talks about and we talk
about transparency, to see what kind of conditions there exist
within 50 or 100 yards of one of the great United States
district courts.
Second, in terms,
we have a profound problem with the
conclusions of the medical examiner.
There are for three
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
CA/Aronberg-000939
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RsEPS1 • 
• 
' 
' 
MR. WEINBERG: 
Judge, if I can just 
! ! 
supplement? 
! 
THE COURT: 
Absolutely. 
MR. WEINBERG: 
Thank you, sir. 
20 
Thank you, as an out-of-town lawyer for the privilege 
to appear in front of you, your Honor. 
THE COURT: 
It's my pleasure. 
MR. WEINBERG: 
First, as to the conditions, we think 
your Honor trusted the government, the Bureau of Prisons, to 
keep our client safe and keep him in civilized conditions. 
The 
gover...

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reasons, your Honor.
One is the timing of Mr. Epstein's demise.
It was on
I
August 10.
On August 12,
a bail pending appeal motion was
being filed in the Second Circuit.
On August
12 or 13, the
United States Attorneys were going to respond to our request
for the preservation and production of documents that would
have facilitated and furthered our efforts to demonstrate
communications between the Southern District of Florida, the
Northern District of Georgia, which was standing in the shoes
of the Southern District of Florida main justice and the
Southern District.
In other words,
we were beginning the process
discharging our responsibilities.
There had been no new
evidence that Mr. Epstein had committed any offense against a
minor after 2005.
The subject matter of the New York
prosecution was squarely within the heartland of the Florida
NPA.
We had a significant motion to dismiss.
This was not a
futile,
you know, defeatist attitude.
Third,
we had all the discovery motions that your
Honor had scheduled.
So the timing for a pretrial detainee to
commit suicide on August 10,
when his bail pending appeal
motion is being filed on August 12, strikes us as implausible.
Second,
we had an independent doctor who was present
at the autopsy which occurred on August 11.
On August 11, the
city medical examiner's findings were inconclusive.
We are
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
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CA/Aronberg-000940
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RsEPS1 
reasons, your Honor. 
One is the timing of Mr. Epstein's demise. 
It was on 
I 
August 10. 
On August 12, a bail pending appeal motion was 
being filed in the Second Circuit. 
On August 12 or 13, the 
United States Attorneys were going to respond to our request 
for the preservation and ...

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told by a very experienced forensic pathologist that the broken
bones in Mr. Epstein's neck, in his larynx, are more consistent
with external pressure, with strangulation, with homicide, if
you will, than with suicide.
It doesn't exclude suicide, but
the pure medical forensic evidence creates profound issues
about what happened to him.
Also the time of death.
Our medical examiner's
opinion is it occurred at least 45 minutes and probably hours
before 6:30 a.m.
on August 10,
when he was first found, if you
will, according to the reports.
Yet he was moved, something
that is not ordinary in these circumstances.
I would also —
THE
COURT:
Excuse me.
He was moved?
MR.
WEINBERG:
Instead of having the cell in the
condition it was found, if he had been dead for
45 minutes or
two hours or four hours, there were efforts to move him and,
therefore,
make it more difficult to reconstruct whether or not
he died of suicide or some other cause.
I spoke to Stacey Richmond,
who is a responsible
member of this court who represents the family of Mr. Epstein.
She spoke to the medical examiner on the Friday after
Mr. Epstein's death and asked why, if the conclusion was made
late in the afternoon on Friday that week.
She specifically
asked about what extrinsic nonmedical evidence caused the
medical examiner to go from uncertain to suicide, and she was
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
CA/Aronberg-000941
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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told by a very experienced forensic pathologist that the broken 
bones in Mr. Epstein's neck, in his larynx, are more consistent 
with external pressure, with strangulation, with homicide, if 
you will, than with suicide. 
It doesn't exclude suicide, but 
the pure medical forensic evidence creates ...

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told that the medical examiner had seen nine minutes of one
video which was on a stairwell between floors at the MCC.
She
i
was told that the principal video that would have showed the
whole hall was corrupted.
It was in
DC with the FBI to see if
they can reconstruct it.
And I asked the same questions that my co-counsel did,
you know,
was the dysfunction of the critical pivotal video, in
the most secure prison east of Florence, out in Colorado known
to the
MCC before August 10, or was this corruption occurring
on August 10, which would again cause us to be skeptical of the
servitude of the medical examiner's conclusions that this was
suicide rather than some other cause.
So with my co-counsel,
we ask your Honor, it is not a
question of trust or not trust.
They ask you to detain people
and you trust the Bureau of Prisons.
And it is within your
inherit authority, your Honor, to find out what happened to our
client.
We are angry about the conditions he was held in.
And
we're also angry, quite frankly, your Honor, that the only
source of information that we get as to what happened to him is
through the media rather than through the United States
Attorney's office.
We've made requests informal.
We have
made Touhy requests.
We've been told there is a pending
investigation.
But we trust your Honor and the judiciary, and with
SOUTHERN DISTRICT REPORTERS, P.O.
(212)
805-0300
i
CA/Aronberg-000942
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RsEPS1 
told that the medical examiner had seen nine miputes of one 
video which was on a stairwell between floors at the MCC. 
She 
I 
was told that the principal video that would haye showed the 
whole hall was corrupted. 
It was in DC with the FBI to see if 
they can reconstruct it. 
And I asked the same q...

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all due respect,
we believe there is an inherent and central
role,
a pivotal role in your Honor to find out what happened to
a defendant in a case before the court, whether or not the
court grants the nolle pros today or whether it holds it
pending an investigation into Mr. Epstein's death.
We're not here without significant doubts regarding
the conclusion of suicide.
We are not here to say what
happened.
We don't know what happened.
But
we deeply want to
know what happened to our client.
Thank you, sir.
THE COURT:
And you, as Mr. Weingarten, have the same
view of the nolle prosequi motion?
MR.
WEINBERG:
Yes, your Honor.
THE COURT:
OK.
MS.
COMEY:
Your Honor,
may I respond to some of those
points?
THE COURT:
Sure.
MS.
COMEY:
Thank you, your Honor.
Just briefly.
With the exception of the noting that
the defense does not have an objection to the government's
motion, virtually everything else that defense counsel just
argued, respectfully is completely irrelevant to the purposes
of today's proceeding and to the motion that is pending before
your Honor.
As an initial matter, the question —
24
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
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CA/Aronberg-000943
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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all due respect, we believe there is an • I 
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inherent and central 
I 
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24 
role, a pivotal role in your Honor to find out what happened to 
a defendant in a case before the court, whether or not the 
court grants the nolle pros today or whether it holds it 
pending an investigation into Mr. Epstein's death. 
We're not here without significant doubts regarding 
the conclusion of suicide. 
We are not here to say what 
happened. 
We don't know what happened. 
But we deeply want to 
know what happened to our client. 
Thank you, sir. 
THE ...

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{
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THE COURT:
Well, it may be.
Well,
I ‘don't know.
You
say irrelevant.
;
i
It is a public hearing,
and I think it, is fair game
for defense counsel to raise its concerns.
MS.
COMEY:
Certainly, your Honor.
But it is
irrelevant to whether or not the motion should be granted.
THE COURT:
Right.
I get that.
MS.
COMEY:
I would also note that the question of
Mr. Epstein's death is the subject of an ongoing and active
investigation, as has been publicly noted,
by a separate team
of Assistant United States Attorneys from the Southern District
of New York, separate from the team who is handling this
prosecution, as well as a separate team of FBI agents.
There is an ongoing and active grand jury
investigation into the circumstances surrounding Mr. Epstein's
death.
It is the function of a grand jury and of the Federal
Bureau of Investigation to investigate crimes in the federal
court system.
It is not the purview, respectfully, of the
court to conduct an investigation into uncharged matters.
So respectfully,
we disagree with defense counsel's
suggestion that the court has some authority to conduct an
independent investigation.
To the extent any other defendants
who are detained in the
MCC have concerns about the conditions
or believe that the conditions are relevant to a future or
current bail determination, it is for those defendants and
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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CA/Aronberg-000944
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
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THE COURT: 
Well, it may be. 
Well, I ~on't know. 
You 
say irrelevant. 
It is a public hearing, and I think it! is fair game 
for defense counsel to raise its concerns. 
MS. COMEY: 
Certainly, your Honor. 
But it is 
irrelevant to whether or not the motion should be granted. 
THE COURT:...

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their counsel to raise those arguments and for the judges
hearing those arguments to evaluate those claims.
It is not
I
relevant to today's proceedings.
Thank you, your Honor.
THE COURT:
In those other cases,
Ms.
Comey, judges do
have authority to investigate, but don't here?
MS.
COMEY:
Not to investigate, your Honor, but to
hear arguments about the conditions of confinement in the
MCC
as they may relate to any bail determination.
I believe that
was the argument that was made.
The bigger picture here, your Honor, is that the focus
of today's proceeding, as
we understand it, is to allow the
victims who have gathered here today to be heard and to comment
upon the case and to comment upon the motion that is pending,
and to bring this case to a close.
THE COURT:
Got it.
MR.
WEINGARTEN:
May I?
THE COURT:
Sure.
MR.
WEINGARTEN:
We obviously saw this as, perhaps,
the last opportunity to be before you, and we wanted to take
advantage of the opportunity to say our peace and thank you for
allowing us.
There is precedent here.
Ted Stevens, the Senator
from Alaska case in Washington,
DC, Judge Emmet Sullivan
ordered an independent investigation by a private lawyer when
I
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(212)
805-0300
CA/Aronberg-000945
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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their counsel to raise those arguments and for the judges 
I 
I 
hearing those arguments to evaluate those 
relevant to today's proceedings. 
Thank you, your Honor. 
l 
. 
I 
c aims. 
I 
I 
It is not 
26 
THE COURT: 
In those other cases, Ms. Corney, judges do 
have authority to investigate, but don't here? 
MS. COMEY: 
Not to investigate, your Honor, but to 
hear arguments about the conditions of confinement in the MCC 
as they may relate to any bail determ...

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he was deeply troubled by the alleged Brady violations.
I
represented the prosecutors in that case, so I'm very, very
I
familiar with it.
It is analogous.
It is a situation where there was
tremendous controversy over what happened in the case and
whether or not the prosecutors went off the reservation.
Judge
Sullivan — and there were three or four independent — not
independent,
DOJ inquiries into the very same matter.
But
Judge Sullivan wanted his own opportunity to make a judgment
with his own independent investigation.
THE
COURT:
OK.
MR.
WEINBERG:
If I could just add one precedent, your
Honor.
The Chief judge in the District of Massachusetts or
the Chief Judge at the time, Judge Wolf, in a case called
U.S, v. Fleming,
when the conditions at Walpole,
which is a
state prison where federal prisoners were being held — we
don't have a federal
MCC in Boston — went to the prison,
stayed in the prison to determine whether or not the complaints
about the conditions were authentic.
I think your Honor has the inherent authority to go to
the ninth floor and see how the
MCC houses pretrial detainees.
Thank you.
THE COURT:
Are you saying that whether or not the
motion is granted that is pending before us?
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he was deeply troubled by the alleged Brady vioiations. 
I 
I 
represented the prosecutors in that case, so I'm very, very 
familiar with it. 
27 
It is analogous. 
It is a situation where there was 
tremendous controversy over what happened in the case and 
whether or not the prosecutors went off the reservation. 
Judge 
Sullivan -- and there were three or four independent -- not 
independent, DOJ inquiries into the very same ma...

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MR.
WEINBERG:
Yes, your Honor.
'
I think, like when appeals are taken, bail issues
I
remain before the district court.
Jurisdiction! is not
completely divested.
Your Honor issued a pretrial detention
order and your Honor has the power, the inherent authority,
they are not going to refuse to allow you to go look at the
ninth floor.
They are going to count on you to make decisions
in the future.
I just trust that the executive branch is not going to
prevent the judicial branch from looking into the death of
Jeffrey Epstein or the conditions in the
SHU unit at the
MCC,
sir.
THE COURT:
Great.
Thank you.
MS.
COMEY:
May I, your Honor?
Just very briefly, your Honor.
I would note that upon
the dismissal of the indictment, which I believe the parties
agree is appropriate in this case, there would be no case.
There would be no jurisdiction for the court to conduct any
sort of inquiry, even if the court had such authority.
THE COURT:
Right.
OK.
I think we've heard enough.
It is at this point in the hearing that I would like
to call upon victims' counsel, plural, for any remarks they may
have and they may wish to make.
Also, to introduce their
clients, those of them who wish to be heard.
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• 
MR. WEINBERG: 
Yes, your Honor. 
I think, like when appeals are taken, bail issues 
I 
remain before the district court. 
Jurisdiction! is not 
28 
completely divested. 
Your Honor issued a pretrial detention 
order and your Honor has the power, the inherent authority, 
they are not going to refuse to allow you to go look at the 
ninth floor. 
They are going to count on you to make decisions 
in the future. 
I just trust that the executive branch is ...

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J8RsEPSl
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It would be helpful if, in doing that,1 if counsel —
I
Mr. Edwards and I see and I see Mr. Boise as well — I know
they are counsel to several, at least several of the victims.
It would be helpful if whoever is speaking, both Mr. Edwards
and Mr. Boise,
would indicate to the court whether or not they
have discussed the pending motion with their clients, that is
to say and the rule of abatement, etc., etc. with them prior to
today's hearing.
Are we going to hear from Mr. Edwards first, is that
right?
MR.
EDWARDS:
Thank you, your Honor.
THE
COURT:
You bet.
It would be helpful,
Mr. Edwards, if you would state
and spell your name for the court reporter.
If you are going to introduce someone else, which I
trust that you are, if you could state and spell their name as
well.
MR.
EDWARDS:
Yes, your Honor.
May it please the court.
Brad Edwards, B-r-a-d
E-d-w-a-r-d-s, with the law firm of Edwards Pottinger.
I have in the courtroom today 15 victims that I
represent and have represented over the years.
There are at
least 20 more who didn't make this hearing today for a
multitude of reasons,
some out of fear of public exposure,
others because the way in which this case ended will never
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J8RsEPSl • 
It would be helpful if, in doing that,
1 if counsel --
1 
Mr. Edwards and I see and I see Mr. Boise as well -- I know 
they are counsel to several, at least several of the victims. 
29 
It would be helpful if whoever is speaking, both Mr. Edwards 
and Mr. Boise, would indicate to the court whether or not they 
have discussed the pending motion with their clients, that is 
to say and the rule of abatement, etc., etc. with them prior to 
today's hearing. 
Are we g...

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,
bring full justice, and they decided it was best for them not
to talk today.
I
Some of my clients are going to address the court that
are here today.
Others are not.
Some are going to use their
names, and have in the past, and others wish to remain
anonymous.
And I have instructed each of them to inform the
court reporter that they will be proceeding as Jane Doe so that
the court reporter can take them down.
THE COURT:
For those who wish to remain anonymous?
MR.
EDWARDS:
Exactly, your Honor.
THE COURT:
And that is satisfactory, as far as I am
concerned.
MR.
EDWARDS:
Before we do that,
I would like to
address a couple of the things that have occurred this morning.
First of all, whether relevant or not,
I personally,
and on behalf of
my clients,
do appreciate the presentation
that Mr. Weingarten made and Mr. Marty Weinberg made.
I have tremendous respect for Mr. Weinberg.
I've
worked with him through this and related cases for years, and I
understand the reason why they made the presentation that they
made.
There is two things of interest to our clients in that
respect.
One is, because of the tragic ending, that none of
my
clients wanted, nor did I, nor did anyone else,, if there is
some civil rights violation and there is some civil remedy for
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bring full justice, and they decided it was best for them not 
to talk today. 
30 
Some of my clients are going to address the court that 
are here tod~y. 
Others are not. 
Some are going to use their 
n~mes, and have in the past, and others wish to remain 
anonymous. 
And I have instructed each of them to inform the 
court reporter that they will be proceeding as Jane Doe so that...

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Mr. Epstein that goes to the estate, certainly the victims are
I
interested in that as they might help to repair, the damage
done.
Second,
Mr. Epstein's untimely death, the timing is
curious to us.
But more so, it makes it absolutely impossible
for the victims to ever get the day in court that they wanted
in court and to get full justice.
That now can never happen.
I know that Mr. Epstein's attorneys say he wanted it, and they
know,
we did too.
And there are a lot of people here today
that are very sad by the way that this ended for both
Mr. Epstein and the fact that full justice was robbed from
them, once again.
The second issue I wanted to address was the Law
Review or the Law Journal article that your Honor referenced,
which is troubling because the opinion seems to say that
transparency is not appropriate in the criminal system and is
not appropriate at this point in time.
That's tough to swallow, especially in this case,
given the long history of this case.
Personally, it is tough
to swallow, and on behalf of
my clients,
I can say that is very
concerning.
Transparency is the only way that the justice
system works.
We know this because there was a similar
investigation of Mr. Epstein many years ago, from 2005 to 2008.
My personal involvement in this case was because a
young female came into my office named Courtney Wild, and she
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J8RsEPS1 
Mr. Epstein that goes to the estate, certainly the victims are 
interested in that as they might help to repair! the damage 
done. 
Second, Mr. Epstein's untimely death, the timing is 
curious to us. 
But more so, it makes it absolutely impossible 
for the victims to ever get the day i...

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i
came to me not asking to file a lawsuit against|Jeffrey
I
Epstein, but simply asking for the government to talk to her.
She was cooperating in an FBI investigation and wanted the
government to speak with her, and I thought that was going to
be an easy task.
It was only a few months later that we learned that
this investigation that was represented to my client in written
form, that it would be a long investigation, and to be patient.
Basically, to hang tight.
It was resolved by way of a secret
deal that never allowed any of the more than 30 victims who had
been identified of Mr. Epstein's abuse in Florida to ever
participate in a single hearing.
There was a hearing.
They
were never notified.
I then went on to represent many of them in civil
cases and also in extensive pro bono work.
And I can tell your
Honor that while Jeffrey Epstein's abuse of them hurt them and
harmed them for many years, the feelings they had was
aggravated exponentially by the facts that they had no rights
in the criminal justice system,
by the fact that they were
treated as if they didn't matter.
They were not allowed their
rights under the Crime Victims' Rights Act to meaningfully
confer with prosecutors, to be treated with fairness, to be
treated with dignity.
That is what this is supposed to be
about,
and to have notice of hearings.
So I do want to thank your Honor,
and 'especially the
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' 
' 
came to me not asking to file a lawsuit againstiJeffrey 
I 
Epstein, but simply asking for the government to talk to her. 
She was cooperating in an FBI investigation and wanted the 
government to speak with her, and I thought that was going to 
be an easy task. ...

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prosecutors who have worked this investigation and this case,
which is very different in experience for all of
my clients and
the other Epstein victims in this case, because they were
allowed to be a part of the process.
While some of them
elected not to be here today, that opportunity should always be
allowed for them.
In 2008,
we filed that case under the Crime Victims'
Rights Act because our clients' rights were violated, and as
your Honor knows,
a federal judge has ruled in our clients'
favor that their rights were violated.
So this hearing today
means a lot to them.
The fact that they may never get their
chance to speak in court, they may never get complete closure,
and all of us have to wonder, if their rights had been afforded
them the first time, would any of us be here right now.
Or
wouldn't it more likely be the case that everyone, including
Jeffrey Epstein, would have turned out better for it?
Today,
I have not only represented, but met and become
very close with many of these victims.
Many of these
survivors.
They are very strong people.
They are people who
have persevered through a lot of adversity.
It's been a roller
coaster of emotions that has led us to where we are today.
And
while they have all been cast over the years because of the
secrecy of the first investigation, in the shadow as victims,
you can't put them all in one bucket and say one size fits all.
They are each individual people who were harmed differently and
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J8RsEPSl 
prosecutors who have worked this investigation and this case, 
which is very different in experience for all of my clients and 
the other Epstein victims in this case, because they w...

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i
distinctly through not only the abuse, but the system.
And on behalf of all of them,
I would like to thank
your Honor for the fairness with which they've been treated,
and the United States Attorney's office for the way in which
you have handled this investigation, and especially how you
have treated the victims in this case.
Like I said,
I have many who want to speak.
Some that
can't.
This is a very difficult day for them.
But we
appreciate the opportunity and the invitation.
The first client that I have that is going to address
your Honor is the one who walked into my office in 2008 asking
just to be heard, Courtney Wild.
THE COURT:
Hold on one second.
Did you all want to
be seated?
You don't need to be standing.
Whatever is more
comfortable until you're ready to give some comments.
It's up
to you.
Ms. Wild, if you could spell your name for the court
reporters, please.
MS.
WILD:
Courtney, C-o-u-r-t-n-e-y, last name Wild,
W-i-l-d.
(Continued on next page)
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distinctly through not only the abuse, but the system. 
I 
And on behalf of all of them, I would like to thank 
I 
your Honor for the fairness with which they've been treated, 
and the United States Attorney's office for the way in which 
you have handled this investigation, and especially how you 
have treated the victims in this case. 
34 
Like I said, I have many who want to speak. 
Some that 
can't. 
This is a very difficult day for them. 
But we 
appreciate the opportunity and the invitation. 
The first client that I have that is going to address 
your Honor is the one who walked into my office in 2008 asking 
just to be heard, Courtney Wild. 
THE COURT: 
...

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MS.
WILD:
My name is Courtney Wild, and I'm a victim
of Jeffrey Epstein.
Jeffrey Epstein sexually abused me for
I
years, robbing me of
my innocence and mental health.
Jeffrey
Epstein has done nothing but manipulate our justice system,
where he has never been held accountable for his actions, even
to this day.
Jeffrey Epstein robbed myself and all the other
victims of our day in court to confront him one by one, and for
that he is a coward.
I want to thank the U.S. Attorney's for seeking
justice that has been long over due,
and most importantly,
given us, the victims, our day in court to speak our peace and
find some sort of closure.
I feel very angry and sad that
justice has never been served in this case.
Thank you.
THE COURT:
Thanks very much.
MR.
EDWARDS:
I believe my next client who is going to
speak is probably going to speak as Jane Doe.
JANE
DOE NO.
1:
Yes, Jane Doe.
THE
COURT:
We'll say Jane Doe No.
1, just for the
record.
JANE
DOE NO.
1:
Okay.
Thank you for allowing us to
speak today.
I've shifted what I want to say in hearing
what's already been said, and just about the question of
Jeffrey's death.
I don't know what the relevance is to this
hearing, but I do know that it is profoundly relevant to my
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J8RPEPS2 
MS. WILD: 
of Jeffrey Epstein. 
My name is Courtney Wild, ahd I'm a victim 
Jeffrey Epstein sexually abused me for 
I 
I 
years, robbing me of my innocence and mental health. 
Jeffrey 
Epstein has done nothing but manipulate our justice system, 
where he has never been held accountable for his actions, even 
to this day. 
Jeffrey Epstein robbed myself and all the other 
victims of our day in court to confront h...

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life, as a victim.
I don't like that word, but' I still feel
like I
am learning the ways that he's impacted me as a complex
I
situation, but he was also a major part of my life.
As
destructive as that relationship was and as much of a villain
as we have created him to be — based on facts we've created
him to be a villain — he's a complex villain and actually all
of that is irrelevant.
Anybody deserves — an investigation is
the right thing to do.
Like,
we do need to know how he died.
It felt like a whole new trauma all over again, and I
don't know why,
you know, because I — I'm trying to defend
myself against him at this point in my life, but it still does
not feel good.
It didn't feel good to wake up that morning and
find out that he had allegedly committed suicide.
Okay.
But I
also wanted to say to the press, I'm reading — I read my story
in the paper.
I read so many other girls' stories that are so
similar to my own, and everything that's been focused on is not
the most important part of it.
There was — the problem with focusing on these, the
facts of the situation, that were out of the ordinary and like
because he was such a grand person, and it was just a unique
situation.
I know that that's the more interesting side of the
story, but I don't want to be used as entertainment.
And the
problem, the fundamental problem of the whole situation is the
element of exploitation and coercion, and these are things that
so many girls can relate to.
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J8RPEPS2 
i 
life, as a victim. 
I don't like that word, but; I still feel 
like I am learning the ways that he's impacted me as a complex 
! 
situation, but he was also a major part of...

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;
And even though this Jeffrey Epstein brought it to a
grand scale,
on some level,
a lot of girls could relate to the
trauma that we are talking about, and even though this whole
situation sucks,
I would like to think that it may be possibly
a catalyst for change because, obviously, as we're seeing with
the
"Me Too" movement, change needs to happen and it's — what
I'm seeing in the papers is not a common story, but it's so
much more common than you realize.
That's all.
Thank you.
THE COURT:
Thank you very much.
MR.
EDWARDS:
I believe that the next client is going
to also be a Jane Doe; so I think for the purposes of the
record it will be Jane Doe 2.
THE COURT:
Yes.
JANE
DOE NO.
2:
Good morning, your Honor.
THE COURT:
Good morning.
How are you?
JANE
DOE NO.
2:
Doing okay.
I hadn't prepared any
words to speak today, but there is something that was on my
mind this morning when I got here.
It's been on
my mind in
reading through the press and through the people that I've
spoken to about it, friends, family.
It's something that's
bothered me because I think it has a lot of blame in it, as
well,
a little bit of what my friend,
who was up here,
was
speaking about.
I think that a lot of people asked why we spent so
much time,
why we stayed.
It's an experience that's really
37
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
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CA/Aronberg-000956
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
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J8RPEPS2 
And even though this Jeffrey Epstein brought it to a 
grand scale, on some level, a lot of girls could relate to the 
trauma that we are talking about, and even though this whole 
situation sucks, I would like to think that it may be possibly 
a catalyst for change because, obviously, as we're seeing with 
the "Me Too" movement, change needs to happen and ...

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hard to explain to people who haven't gone through it.
I think
there's a writer,
Thomas Nagel,
who wrote an essay called "What
is it like to be a bat?"
And.I think that he touches on it
pretty strongly and if you haven't experienced something, it's
very hard to fully understand why someone makes the decisions
they do and what the circumstances were.
I don't want to speak for all of the victims.
I think
each of us has a different story and different circumstances
for why we stayed in it, but for me,
I think he was really
strategic in how he approached each of us.
Things happened
slowly over time.
We didn't — it almost was like, putting it
like that analogy of a frog being in a pan of water and slowly
turning the flame up.
You didn't realize it was happening, and
it just — I don't think anyone can fully understand the
experience, but I just — the blame feels very strong.
There's a lot of support as well, but I just want
people to try and understand that we aren't bad people.
We
weren't trying to — it wasn't a situation where we were trying
to extort money from someone.
A lot of us were in very
vulnerable situations and in extreme poverty, circumstances
where we didn't have anyone on our side, to speak on our
behalf, and that's really scary.
You start to blame yourself because, at first,
you
don't tell anyone what's happening, and it becomes your deep,
dark secret that you tried to keep from everyone.
And I didn't
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hard to explain to people who haven't gone through it. 
I think 
there's a writer, Thomas Nagel, who wrote an es~ay called "What 
is it like to be a bat?" 
And.I think that he touches on it 
pretty strongl...

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even know I was a victim until I spoke with my lawyers.
I had
i
no idea.
I had so much self-hatred and doubt and just guilt
1
for everything.
I still do.
I still don't feel like I deserve
to say I'm a victim, and I think that's a big problem with our
society right now, that people are still blaming victims, and I
think that does need to change.
I hope that today people understand that each of us
has a story, has a past, has a family and just give us a chance
to — you know, that's basically all I just wanted to say.
THE COURT:
Thank you so much.
JANE
DOE NO.
2:
Thank you so much.
THE COURT:
Okay.
MR.
EDWARDS:
Okay.
I think that the next person who
is going to speak is also going to be speaking as Jane Doe; so
for the purpose of the record, Jane Doe No. 3.
JANE
DOE NO. 3:
Thank you for allowing us to speak
today.
I came to New York City 15 years ago to pursue modeling
from a small town.
I signed on with an agency and was excited
to pursue my passion and my dream.
Several months later,
I met
a female who told me about Mr. Epstein.
She portrayed him as
an amazing man who genuinely cared for people and that he was
going to be able to help me in a modeling career.
I was excited to meet him, after hearing her talk
about him.
He sounded like an amazing person.
An introduction
was made at his New York home, and it is there that I was
SOUTHERN DISTRICT REPORTERS, P.C.
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805-0300
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even know I was a victim until I spoke with my ~awyers. 
I had 
i 
no idea. 
I had so much self-hatred and doubt and just guilt 
I 
! 
for everything. 
I still do. 
I still don't feel like I deserve 
to say I'm a victim, and I think that's a big problem with our 
society right now, that people ...

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sexually assaulted.
I left his home, after he threw me,
basically put money on the table, and I was ashamed.
I was
embarrassed.
This was not the way I was brought up, and I
couldn't believe this had happened to me.
I left and my world kind of spiraled after that.
I
stopped going on modeling castings.
I gained weight.
I became
depressed.
I stopped going out with my friends,
and only five
months after I had been in New York City to pursue my dream,
I
left.
I left the modeling industry,
and I left New York City,
and I totally switched my career paths.
I buried this deep within me, and all of the new
occurrences that have come up in the media is what brought it
back up for me.
And I feel sickened and saddened that it took
so many years,
and God knows how many victims, for this to
finally come out, but I'm thankful it did.
And I'm just angry
that he's not alive anymore to have to pay the price for his
actions.
So I thank you for your time.
THE
COURT:
You're very welcome.
MR.
EDWARDS:
Your Honor, Jane Doe No.
4,
I believe,
is going to speak now.
JANE
DOE NO.
4:
Good morning, your Honor.
THE COURT:
Good morning.
JANE
DOE NO.
4:
I just have something very short to
say.
I met Jeffrey Epstein at a very vulnerable place in my
life,
and whatever the outcome is with everything,
I just
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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sexually assaulted. 
I left his home, after he threw me, 
basically put money on the table, and I was ashamed. 
I was 
embarrassed. 
This was not the way I was brought up, and I 
couldn't believe this had happened to me. 
40 
I left and my world kind of spiraled after that. 
I 
stopped going on modeling castings. 
I gained weight. 
I became 
depressed. 
I s...

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wanted to express that we, the victims,
we will always carry
irreparable damage and pain throughout our lives after this.
It's something that's never going to go away.
You know, whoever we marry in our life, whatever
future we have in our life, it's always going to be something
that's always there for us.
And I'm very nervous right now.
And Jeffrey Epstein, he took away the chance I had at having
the future I had envisioned for myself as a young girl, and I
think many of us here today will never fully heal from that
pain and the heartache that we'll continue carrying with us.
So I just wanted to say that.
It's something that
it's irreparable.
I can't even really use a better word to
describe that.
So thank you for hearing us today.
THE COURT:
You're very welcome.
MR.
EDWARDS:
Your Honor, Jane Doe No.
5 would like to
speak.
JANE
DOE NO.
5:
This is a letter that I wrote; so
it's going to be:
Dear Jeffrey,
I think you are a mentally
disturbed human being.
You used your power to make me believe
at a young age that I could have
my dreams of being a model.
You paid for your freedom.
You violated my rights.
You should
have to pay for them, just as anyone else.
You got a plea deal
that no one else would have been able to get.
You used your
money to get out of paying the price for your actions.
Also, as a victim,
I never got to see what the
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000960
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
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wanted to express that we, the victims, we will always carry 
irreparable damage and pain throughout our lives after this. 
It's something that's never going to go away. 
You know, whoever we marry in our life, whatever 
future we have in our life, it's always going to be something 
that's alw...

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agreement was or why the special treatment got approved.
I
think you should have been in jail for several years in
population and live like everyone else that is mentally
disturbed like you.
You paid for yourself to get special
treatment while you were in jail.
I don't even think you spent
a day in a jail as a normal human being.
You had investigators come to my house and also went
to my friend's house to question them.
I will never be able to
over — I will never be able to get over the overwhelming
emotions and embarrassment I experienced from that trauma.
I
needed therapy several times a week and had high stress and
anxiety levels.
You paid your way to make the public think that the
girls had nothing in life going on for them.
You wanted to try
and blame that we were lower class and that was the problem
with the girls.
I was from a middle class family and did well
in school.
I lived the American girl dream — or the American
girl life.
I went on family vacations around the world, grew
up in a good city, and my parents are still married to this
day.
Basically, everything you said that we didn't have in our
life,
I did.
It all came down to I was told I was making $200 in an
hour.
Being young, that was a lot of money,
and I didn't know
any better.
Sadly,
you were the one with an illness that you
should have to go and see a doctor and also have a mentor group
SOUTHERN DISTRICT REPORTERS, P.C.
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805-0300
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agreement was or why the special treatment got approved. 
I 
think you should have been in jail for several years in 
population and live like everyone else that is mentally 
disturbed like you. 
You paid for yourself to get special 
treatment while you were in jail. ...

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J8RPEPS2
for the sickness you have.
I will continue with writing my
book about that secret life, with all the newspaper articles of
the case,
my high school agenda book of official dates.
I'm
basing that proof that I deposited cash after leaving
Jeffrey's.
I still have all of the information, articles that
I collected over the years.
You mentally and physically traumatized me.
I went to
therapy, and it was the best thing I did for myself.
If anyone
only learns one thing from this case,
I hope is that money
should not let you buy your way free.
A crime is a crime and a
victim is a victim.
Thank you.
THE COURT:
Thank you.
Thank you very much.
MR.
EDWARDS:
Your Honor,
my next client is Chauntae
Davies, C-h-a-u-n-t-a-e, Davies, D-a-v-i-e-s.
MS.
DAVIES:
I met Jeffrey Epstein through my first
massage teacher,
a man who took me in as his apprentice to
teach me a practice I wanted to learn while in desperate search
to find a cure for a debilitating neurological disorder that I
have, which manifests into violent vomiting attacks, largely
triggered by stress.
It's called Cyclic Vomiting Syndrome.
I was recruited by Ghislaine Maxwell.
Upon my first
meeting of her,
I wouldn't know I had been recruited until many
years later,
when I would read it in a headline.
Ghislaine and
Jeffrey took me in.
They sent
me to school.
They gave me a
job.
They flew me around the world, introduced me to a world I
SOUTHERN DISTRICT REPORTERS, P.C.
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805-0300
CA/Aronberg-000962
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RPEPS2 
for the sickness you have. 
I will continue with writing my 
book about that secret life, with all the newsp~per articles of 
the case, my high school agenda book of official dates. 
I'm 
basing that proof that I deposited cash after leaving 
Jeffrey's. 
...

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J8RPEPS2
had only dreamt of and made me feel as though L had become a
part of their family, another thing I was desperately searching
for .
But on my third or fourth time meeting them, they
brought me to Jeffrey's island for the first time, and on the
first night there, Sarah Kellen came tapping on my door late at
night to inform me Jeffrey was ready for another massage.
My
instincts told me this didn't feel right, but I got up and
followed her to a villa I hadn't yet seen.
Jeffrey and
Ghislaine's villa.
I began my massage, trying not to let him smell my
fear and obvious discomfort, but before I knew what was
happening, he grabbed onto my wrist and tugged me towards the
bed.
I tried to pull away, but he was unbuttoning my shorts
and pulling my body onto his already naked body faster than I
could think.
I was searching for words but all I could say was
meek,
"No, please stop," but that just seemed to excite him
more.
He continued to rape me, and when he was finished,
he
hopped off and went to the shower.
I pulled my shorts up, and
I ran as fast as I could back to my own villa,
my feet bloodied
from the rocks.
I cried myself to sleep that night.
I spent two weeks vomiting, almost to death, in a
Los Angeles hospital after that first encounter.
Jeffrey's
abuse would continue for the next three years, and I allowed it
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805-0300
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RPEPS2 
had only dreamt of and made me feel as though I
1 had become a 
part of their family, another thing I was desperately searching 
for. 
But on my third or fourth time meeting them, they 
brought me to Jeffrey's island for the first time, and on the 
first night there, Sarah Kellen came tapping on my door late at 
night to...

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J8RPEPS2
to continue because I had been taken advantage of my entire
life and had been conditioned to just accept it.
It took me a long time to come forward, too long
maybe,
and all it took to bring — and all that it took to
bring this man to justice has been robbed by his death.
Every
day, every week I've spent in the hospital since, I've suffered
and he has won.
Every job offer that's been offered to me and
then retracted because of
my connection to this case,
I have
suffered and he has won.
Every public humiliation I have
endured,
I have suffered and he has won.
Every relationship
that I've had to end because of the abuse that I have endured
by the hands of this man,
I have suffered and he has won.
Every woman sitting in this room today,
and all of the
women who have yet come forward and who have not yet to come
forward and whose lives have been affected by Jeffrey Epstein's
sick abuse of young girls,
we have all suffered,
and he is
still winning in death.
I refuse to let this man win in death.
I couldn't
fight back when Jeffrey Epstein sexually abused me because I
hadn't yet found my voice.
Well,
I have found my voice now,
and while Jeffrey may no longer be here to hear it,
I will not
stop fighting, and I will not be silenced anymore.
I needed
him to hear the pain he's caused, what I've gone through
because of him.
I wrote a 350-page book of all the pain that I
have endured at the hands of this man that I really needed him
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000964
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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to continue because I had been taken advantage bf my entire 
life and had been conditioned to just accept it. 
It took me a long time to come forward, too long 
maybe, and all it took to bring 
and all that it too...

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to hear.
His death has robbed me of that justice.
Please don't rob us of justice again.
Thank you.
THE COURT:
Thank you.
MR.
EDWARDS:
Your Honor,
I think I have one more
client that is going to speak today, Anouska
De Georgiou.
THE COURT:
Would you spell that?
MS.
DE GEORGIOU:
Good morning, your Honor.
THE COURT:
Good morning.
MS.
DE GEORGIOU:
My name is spelled A-n-o-u-s-k-a,
D-e, space, G-e-o-r-g-i-o-u.
Thank you, your Honor, for giving us the opportunity
to be heard this morning.
THE
COURT:
Sure.
MS.
DE GEORGIOU:
When I was introduced to Jeffrey
Epstein,
I was young and full of hope and the foolishness of a
teenager.
I was idealistic, and I saw the good in people.
Jeffrey Epstein manipulated me, coerced me and sexually abused
me.
Something I think is very important to communicate is
that loss of innocence, trust and joy is not recoverable.
The
abuse, spanning several years,
was devaluing beyond measure and
affected my ability to form and maintain healthy relationships,
both in
my work and my personal life.
He could not begin to
fathom what he took from us, and I say "us" because I
am every
girl he did this to, and they're all me.
And today we stand
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
CA/Aronberg-000965
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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to hear. 
His death has robbed me of that justice. 
Please don't rob us of justice again. 
Thank you. 
THE COURT: 
Thank you. 
MR. EDWARDS: 
Your Honor, I think I have one more 
client that is going to speak today, Anouska De Georgiou. 
THE COURT: 
Would you spell that? 
MS. DE GEORGIOU: 
Good morning, your Honor. 
THE COURT: 
Good morning. 
MS. DE GEORGIOU: 
My name is spelled A-n-o-u-s-k-a, 
D-e, space, G-e-o-r-g-i-o-u. 
Thank you, your Honor, for giving us the opportunity 
...

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J8RPEPS2
together, those that are present and those that; aren't.
I was a victim,
and it has taken me many,
many years
to stand here and say, yes, it was me.
I was a victim, but I
will not remain a victim and be silent for one more day.
Although I think it's tragic when anybody dies before their
time, I'm extremely relieved that Jeffrey Epstein will not be
in a position to hurt anymore children or anymore women, and
I'm glad to be part of a group of women who are now bonded
forever in the trauma that we endured at the hands of this man.
Thank you.
THE COURT:
Thank you.
MR.
EDWARDS:
Your Honor,
we had one client who was
not able to be here but sent a message through a letter.
Her
name is Michelle Licata, M-i-c-h-e-l-l-e; last name,
L-i-c-a-t-a.
And Brittany Henderson, of my office, is going to
read her letter as instructed.
THE COURT:
Sure.
MS.
HENDERSON:
Thank you, your Honor.
THE
COURT:
Yup.
MS.
HENDERSON:
What happened to me occurred many
years ago when I was in high school, but it still effects
my
life.
I was told then that Jeffrey Epstein was going to be
held accountable, but he was not.
In fact, the government
worked out a secret deal and didn't tell me about it.
The case
ended without
me knowing what was going on, without him being
SOUTHERN DISTRICT REPORTERS, P.C.
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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together, those that are present and those that: aren't. 
I was a victim, and it has taken me many, many years 
to stand here and say, yes, it was me. 
I was a victim, but I 
will not remain a victim and be silent for one more day. 
Although I think it's tragic when anybody dies before their 
time, I'm extremely relieved that Jeffrey Epstein will not be 
47 
in a position to hurt anymore children or ...

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J8RPEPS2
held responsible, without any explanation and without a chance
for
my voice to be heard.
I was treated like
I; did not matter.
Many years later, he was arrested again.
These
investigators and attorneys representing the United States have
been completely different.
I
am still mad, concerned and
confused about how he committed suicide and escaped
responsibility again, but I know it is not the fault of the
judge or the government attorneys.
I was allowed to be a part of the process this time.
My attorney was able to tell me what was going on at every
stage because they kept him informed.
Thank you for inviting
me.
It means more to me than you can ever know.
I was not
able to be here this time, but I know that I was allowed to be
and I had the chance to attend this hearing, which is helping
me in my healing process.
The fact that I mattered this time
and the other victims mattered is what counts.
For that,
I
am
grateful.
THE
COURT:
Thank you.
MR.
EDWARDS:
Your Honor, finally, in 2008 when I
filed the case under the Crime Victims Rights Act, it wasn't
me
alone.
I did it with Paul Cassell and Jay Howell.
Paul Cassell is here today, and I think your Honor
even cited to a piece of — an opinion of his from when he was
on the bench, and he has some remarks to make.
Once again, your Honor,
I really do believe that this
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held responsible, without any explanation and without a chance 
i 
for my voice to be heard. 
I was treated like I! did not matter. 
I 
Many years later, he was arrested again. 
These 
investigators and attorneys representing the United States have 
been completely different. 
I am still mad, concerned and 
confused ...

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is a model for how victims should be treated in a criminal
process,
and we really do appreciate it.
Thank you.
THE COURT:
Thank you.
MR.
CASSELL: I'll be very brief because I know there
are others that want to speak here.
I'm Paul Cassell,
C-a-s-s-e-1-1, previously served as a federal judge at the
District of Utah, currently a law professor, where I teach
crime victims rights at the University of Utah, College of Law.
I just wanted to take one minute to address some
suggestion that there would be no need for a hearing this
morning.
I think, having heard already from these powerful
victims and recognizing how important giving those statements
will be in the trajectory of their lives, makes clear that your
Honor has followed exactly the right path.
Legally, there is
one precedent, which is U.S.
v. Heaton,
a case that you cited
that I wrote about a decade ago,
and as explained in that
opinion, victims have important interests in the criminal
justice system that can only be recognized if they're given
their day in court.
With all due respect to other law professors that have
recently written an article,
I think transparency is one of the
overriding objectives in our criminal justice system,
and the
one substantive action that I would urge your Honor to take
today is to publish your remarks as a published opinion.
The
Heaton case is, to my knowledge, the only reported decision on
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is a model for how victims should be treated in' a criminal 
process, and we really do appreciate it. 
Thank you. 
THE COURT: 
Thank you. 
49 
MR. CASSELL: 
I'll be very brief because I know there 
are others that want to speak here. 
I'm Paul Cassell,...

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;
this particular issue, even though it's more than a decade old
and, yet,
we can see today that these problems recur in many
I
other cases.
Your remarks today,
I think, should be published
so that they can serve as a guide for other judges around the
country.
I would encourage you to add into your remarks a
reference to the Crime Victims Rights Act.
The Crime Victims
Right Act promises victims the right to be treated with
fairness, dignity and respect, and the process that we see
unfolding this morning is a clear example of how victims can be
treated with fairness, dignity and respect.
So I know that your Honor is wondering what is the
appropriate action here.
Unfortunately, it seems like there
are no other legal options, but there was a legal option for
you to decide to exercise, which was to allow these victims to
come forward.
And if there's been one positive thing that has
come out of the tragedies, the abuse, the other events of this
case, it's been your decision to allow these victims to be
heard this morning, and I encourage you to publish your
decision and to encourage other judges to follow what is
clearly a model for crime victims rights and is clearly an
example that should be followed in other cases down the road.
THE
COURT:
Thank you very much.
I appreciate your
being here.
I had no idea that you would be here when I wrote
the remarks, but it was clear from the literature that you are
50
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this particular issue, even though it's more than a decade old 
I 
and, yet, we can see today that these problems recur in many 
I I 
other cases. 
Your remarks today, I think, should be published 
so that they can serve as a...

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the leading expert formerly of the District Court of Utah,
I
believe, and it's a pleasure to have you here today.
MR.
CASSELL:
Thank you, your Honor.
THE COURT:
Thanks.
Mr. Boies?
MR.
BOIES:
Thank you, your Honor.
David Boies of
Boies Schiller Flexner.
We have with us today five of the
victims that we represent.
There are a number of additional
victims who either were unable to attend or are still unwilling
to come forward publicly.
This has been an enormously
traumatic aspect of their lives, something that, as you've
already heard and will hear more today, is something that they
can never entirely escape from.
I want to, as prior counsel have,
commend both the
Court and counsel for the Department of Justice for the
consideration and respect and attention that they have paid to
the victims.
We believe that that is not only right, as a
matter of human dignity, but we think that is exactly what the
law requires and intends.
I will be more blunt than the Court has been, or
Professor Cassell has been about Professor Green's article.
That is an article that cites no authority, and I believe there
is no authority for his proposition.
I entirely respect his
right to advocate on behalf of his client Alan Dershowitz,
who
has retained him in connection with litigation that we've
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J8RPEPS2 
the leading expert formerly of the District Court of Utah, I 
believe, and it's a pleasure to have you here today. 
MR. CASSELL: 
Thank you, your Honor. 
THE COURT: 
Thanks. 
Mr. Boies? 
51 
MR. BOIES: 
Thank you, your Honor. 
David Boies of 
Boies Schiller Flexner. 
We have with us today five of the 
victims that we represent. 
There are a number of ad...

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brought against Mr. Dershowitz, but I would have expected that
the Law Journal or Professor Green himself would have disclosed
that connection, which I think is a conflict.
But regardless of the appropriateness of his
disclosure, or lack of disclosure,
I think that his article
opposing allowing the victims to have a voice in this
proceeding is inconsistent not only with the policy that
underlies the Crime Victim Rights Act and the very statute that
Mr. Epstein is being prosecuted under, but it ignores the
actual language of those statutes, and many other statutes, in
which Congress has made clear that the purpose of the criminal
law is no longer simply to punish the individual defendant, but
it is to find some way of trying to mitigate the damage that
has been done to the victims through restitution and economic
mitigation, but also through the ability to confront and to
have the court system and the justice system and the
prosecutors treat these victims as they are victims, as they
are human beings, and they are entitled to the respect that our
society needs to give every human being.
So I think that this
is not only commendable, but I think it is what the
Law
requires.
In response to the question the Court asked,
I have
discussed this hearing with my clients.
I have told them that,
under the applicable law, the government has no alternative but
to move to dismiss this case, and I believe under the
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brought against Mr. Dershowitz, but I would have expected that 
the Law Journal or Professor Green himself would have disclosed 
that connection, which I think is a conflict. 
But regardless of the appropriateness of his 
dis...

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applicable law in this circuit, the Court has no alternative
but to grant that motion.
I think the current law is outdated, as the Court
suggested in some of its remarks.
I think there will come a
time when either an Appellate court or the Congress will make
clear that, just as it's possible to continue civil cases
against someone after they have deceased, it is possible, at
least for purposes of things like restitution, to continue
criminal cases, but
we are not there now.
And, fortunately, in
this case, there are other ways and perhaps even more efficient
ways to vindicate the interests of the victims here.
We greatly appreciate the remarks of the
representative of the Department of Justice today, and we, too,
on behalf of the victims, are not going to stop when we walk
out of this courtroom.
We are going to continue to seek
vindication against Mr. Epstein's estate and, in some senses,
perhaps even more important, against the people who worked with
him and enabled him.
As you have already heard,
and will hear more,
Mr. Epstein did not act alone.
He could not have done what he
did,
on the scope and the scale of what he did, for as many
years as he did it without the activities and support and the
co-conspirator activity of a number of other key individuals,
and those individuals also need to bear their share of
responsibility,
and those people need to have a reckoning as
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applicable law in this circuit, the Court has np alternative 
but to grant that motion. 
I think the current law is outdated, as the Court 
suggested in some of its remarks. 
I think there will come a 
53 
time when either an Appellate court or the Congress...

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J8RPEPS2
,
well.
My partner Sig McCawley, who's been working with me
for more than five years on this case, is going to, with the
Court's permission, introduce five of our clients who will
speak briefly to your Court.
Thank you very much.
THE COURT:
Thank you very much,
Mr. Boies.
Pleasure
to have you here.
MS.
McCAWLEY:
Thank you, your Honor, the first victim
that would like to speak today is Theresa J. Helm.
THE
COURT:
Can we have the spelling of your name?
MS.
McCAWLEY:
Sure.
Sigrid, S-i-g-r-i-d,
and the
last name is M-c-C-a-w-l-e-y, and I'm a partner at Boies
Schiller Flexner.
THE COURT:
Thank you.
MS .
HELM:
Good morning.
THE COURT:
Good morning.
MS .
HELM:
Thank you, prosecutors and Judge, and the
Court.
My name is Theresa Helm.
I note today I do feel
respected and listened to; so I appreciate that,
and I have to
say that I commend the boldness of the New York prosecutors for
pursuing a man that has,
you know — and others, that have
clearly taken a lot from a lot of people.
17 years ago I knew him only as "Jeffrey."
I was
recruited and brought from California to New York, and that
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well. 
My partner Sig Mccawley, who's been working with me 
for more than five years on this case, is going to, with the 
Court's permission, introduce five of our clients who will 
speak briefly to your Court. 
Thank you very much. 
54 
THE COURT: 
Thank you very much, Mr. Boies. 
Pleasure 
to have you here. 
MS. McCAWLEY: 
Thank you, your Honor, the first victim 
that would like to speak today is Theresa J. Helm. 
THE COURT: 
Can we have the spelling of your name? 
MS. McCAWLEY: 
Sure. 
Sigrid, S-i-g-r-i-d, and the 
last name is M-c-C-a-w-1-e-y,...

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experience for the last
17 years has been a dark corner in my
story, in my life, in
my life story and that has been
definitely made worse by
my own self-shame and that — and
anger for normalizing all of the red flags.
I feel like we are
conditioned to do that, and that's something that needs to
change.
So I'm here today,
you know, I'm coming forward
because it is time to bring light to that darkness,
and it's
time to replace that darkness with light.
And I
am a survivor
of this, and I do aim to progress further from being a
survivor,
you know.
I feel I've worked hard, guite hard, to
get to where I'm at now, and I'm definitely at a place in my
life where I will no longer cover up.
I'11 no longer cover up
what needs to be brought to light.
Jeffrey is no longer here,
and the women that helped
him are, Ghislaine Maxwell.
My experience is with Ghislaine
Maxwell and Sarah Kellen,
and they definitely need to be held
accountable for helping him, helping themselves, helping one
another carry on this huge, almost like a system.
So they need
to be held accountable, all of them,
and I would like to see
that, certainly on behalf of myself and for everyone here.
Thank you.
THE COURT:
Thanks so much.
MS.
McCAWLEY:
Our next client,
who is going to speak
this morning, is Virginia Roberts Giuffre.
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experience for the last 17 years has been a dark corner in my 
story, in my life, in my life story and that has been 
definitely made worse by my own self-shame and that 
and 
55 
anger for normalizing all of the red flags. 
I feel like we are 
conditioned to do that, and that's something that needs to 
change. 
So I'm here today, you know, I'm coming ...

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MS.
GIUFFRE:
Good morning, your Honor;
THE
COURT:
Good morning.
How are you?
MS.
GIUFFRE:
Okay.
Thank you.
My name is Virginia
Roberts Giuffre, that's V-i-r-g-i-n-i-a, Roberts,
R-o-b-e-r-t-s, Giuffre, G-i-u, double F, for Fred, -r-e.
I
am a victim of Jeffrey Epstein and Ghislaine Maxwell
in the dark and cruel and criminal acts they committed against
me and hundreds of other girls and young women for years and
years and years, unstopped.
Thank you for allowing me to address the Court and
speak the truth.
I commend the prosecutors from the Southern
District of New York for the ongoing investigation and its
pursuit of justice for us victims.
It has given me hope, and I
will not let go of that hope.
When I was recruited by Ghislaine Maxwell at
Mar-a-Lago, just before I was 17,
I thought I was given a big
break, and I'd be able to reset
my life and become an actual
real massage therapist.
My hopes were quickly dashed, and my
dreams were stolen.
Jeffrey Epstein is no longer alive, but
this is not about how he died.
This is about how he lived.
He will not have his day in court, but the reckoning
of accountability has begun, supported by the voices of these
brave and beautiful women in this courtroom today.
The
reckoning must not end.
It must continue.
He did not act
alone and we, the victims,
know that.
We trust the government
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J8RPEPS2 • 
• 
MS. GIUFFRE: 
Good morning, your Honor. 
THE COURT: 
Good morning. 
How are you? 
MS. GIUFFRE: 
Okay. 
Thank you. 
My name is Virginia 
Roberts Giuffre, that's V-i-r-g-i-n-i-a, Roberts, 
R-o-b-e-r-t-s, Giuffre, G-i-u, double F, for Fred, -r-e. 
56 
I am a victim of Jeffrey Epstein and Ghislaine Maxwell 
in the...

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is listening and that the others will be brought to justice.
Thank you, your Honor.
THE
COURT:
Thank you very much.
MS.
McCAWLEY:
The next client of ours that will be
speaking this morning is Sarah Ransome.
MS.
RANSOME:
Thank you, your Honor.
My name is Sarah
Ransome, R-a-n-s-o-m-e.
I'm a victim of Jeffrey Epstein and
Ghislaine Maxwell's international sex trafficking ring.
I would like to thank the Court for the dignity and
the respect you are showing me here today, as well as the other
victims.
I would also like to acknowledge and extend my
gratitude to the prosecutors from the Southern District of
New York for pursuing justice on behalf of the victims.
Please, please finish what you have started.
I struggled to
find the words to adequately say how important your work is to
us .
For a very long time Jeffrey Epstein gamed the system
at every level,
and when he realized he couldn't do that any
longer,
he showed the world what a depraved and cowardly human
being he is by taking his own life.
But we, the victims, are
still here, prepared to tell the truth,
and we all know he did
not act alone.
We are survivors, and the pursuit of justice
should not abate.
Thank you, your Honor.
THE
COURT:
You're very welcome.
MS.
McCAWLEY:
Our next client who is going to be
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J8RPEPS2 
is listening and that the others will be brought to justice. 
Thank you, your Honor. 
THE COURT: 
Thank you very much. 
MS. McCAWLEY: 
The next client of ours that will be 
speaking this morning is Sarah Ransome. 
MS. RANSOME: 
Thank you, your Honor. 
My name is Sarah 
Ransome, R-a-n-s-o-m-e. 
I'm a victim of Jeffrey Epstein and 
Ghislaine Maxwell's international sex tr...

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speaking this morning is Annie Farmer.
MS.
FARMER:
Good morning, your Honor.
THE
COURT:
Good morning.
MS.
FARMER:
Annie, A-n-n-i-e, Farmer, F-a-r-m-e-r.
I had the opportunity to speak at Jeffrey Epstein's
bail hearing, and I really appreciate that you heard me and
listened to me that day.
I
am so sorry that others will not
have the opportunity to stand before him the way that I did.
But I'm here today to speak on behalf of
my sister, Maria
Farmer,
who could not be here.
Jeffrey Epstein, Ghislaine Maxwell not only assaulted
her, but as we're hearing from so many of these brave women
here today, they stole her dreams and her livelihood.
She
risked her safety in 1996,
so many years ago, to report them,
to no avail,
and it is heartbreaking to her and to me that all
this destruction has been wrought since that time.
We were deeply disappointed and disturbed by Epstein's
death and the fact that that was allowed to happen while he was
in the government's custody,
and I'm encouraged to hear that
there will be a full investigation as to how that was allowed
to happen.
But it is extremely important, as others are saying,
that he did not act alone and that the other people that were a
part of what he did are held accountable and that that
investigation continues.
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speaking this morning is Annie Farmer. 
MS. FARMER: 
Good morning, your Honor. 
THE COURT: 
Good morning. 
MS. FARMER: 
Annie, A-n-n-i-e, Farmer, F-a-r-m-e-r. 
I had the opportunity to speak at Jeffrey Epstein's 
bail hearing, and I really appreciate that you heard me and 
listened to me that day. 
I am so sorry that others will not 
have the opportunity to stand before hi...

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I believe that we have a real problem in this country
with perpetrators of sexual abuse and sexual assault being held
accountable.
There are so many roadblocks to victims being
heard, to cases being investigated thoroughly, and then to
those cases being prosecuted.
And so I think this is a really
important signal to send a message to victims out there that
people will take you seriously, people will follow through, and
that even those in power, as we have unfortunately seen, that
has not been often are able to escape that, that even those in
power will be held accountable.
Thank you.
THE
COURT:
Thanks so much.
MS.
McCAWLEY:
Our next client, who's going to address
the Court is Marijke Chartouni.
She says it much more
beautifully than I do; so I'll let her say it.
MS.
CHARTOUNI:
My first name is spelled,
M-a-r-i-j-k-e; last name is C-h-a-r-t-o-u-n-i.
My name is Marijke Chartouni, and I
am a victim of
Jeffrey Epstein and the sophisticated sex trafficking operation
he ran, where he allegedly was to be a financier.
I was 20 and previously modeled and was living in the
West Village.
I met a young woman named Rena through a mutual
friend.
We were friends for a few months.
She was an amazing
artist and liked to party.
One day she called me and asked if
I was interested in meeting a friend of hers.
She told me he
wanted to meet me and really liked blonds, and I thought he was
SOUTHERN DISTRICT REPORTERS, P.O.
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J8RPEPS2 
I believe that we have a real problem in this country 
with perpetrators of sexual abuse and sexual assault being held 
accountable. 
There are so many roadblocks to victims being 
heard, to cases being investigated thoroughly, and then to 
those cases being p...

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J8RPEPS2
;
i
i
i
our age and liked to do the same things we did at that age; so
I agreed.
I
On a sunny, crisp day,
we took the train together to
the Upper East Side.
She then began to talk a little bit about
him on our way to his house.
I was at his house.
I was
sexually assaulted by both Rena and Jeffrey Epstein in his
mansion.
It left me feeling both disgusted and betrayed.
As we walked home to the subway afterwards, she
continued to tell me about the man who had just abused me with
her participation.
She seemed exhilarated from the horrific
experience.
I was shocked and in a daze.
This is a few things
that she had told me.
She told me he went to Cooper Union.
He
was a mathematical genius.
That he had favorite girls that he
would take to Chanel for 15-minute, all-you-can-buy shopping
trips.
She told me his right-hand person had connection to the
arts and the fashion world,
and she could help me.
This is not my complete story. I'll stop here.
I'm
in a good, stable place in my life, and I had decided to come
forward to be a voice to the victims who may not be able to
tell their story, or at least not yet.
I feel like I
am a
survivor.
Thank you, Judge Berman, for inviting victims to speak
today before you.
We hope the government is listening very
closely to the words
we are saying.
THE COURT:
Thank you very much.
SOUTHERN DISTRICT REPORTERS, P.C.
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I 
•I 
I 
I 
I 
I 
60 
our age and liked to do the same things we did ?t that age; so 
I agreed. 
On a sunny, crisp day, we took the train together to 
the Upper East Side. 
She then began to talk a little bit about 
him on our way to his house. 
I was at his house. 
I was 
sexually assaulted by both Rena and Jeffrey Epstein in ...

J8RPEPS2
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MR.
BOIES:
Your Honor, just very briefly.
THE
COURT:
Sure.
MR.
BOIES:
I would like to express to: the Court how
proud I
am of all of these women who have come forward.
It's
taken an enormous amount of strength and courage for them to do
so.
Thank you.
THE
COURT:
Thanks,
Mr. Boies.
Hold on one second.
(Pause)
MS.
LERNER:
Thank you, your Honor.
My name is
Kimberly Lerner, of Lerner and Lerner, and your Honor, with
your permission,
I would like
my client, Jennifer Aroz, to
stand next to me.
THE COURT:
Sure.
MS.
LERNER:
Would that be okay?
THE COURT:
Absolutely.
MS.
LERNER:
Your Honor,
I would like to begin by
saying that I
am in awe of all of these beautiful women.
I
just want to let you know,
on behalf of Jennifer and myself,
we
admire you,
we respect you, and we applaud you,
and you are
brave survivors.
And Jennifer's heart is with all of you, and
we thank you so much for coming forward.
Jennifer,
when she went public, she thought she was
one of the only ones, and to see all of these faces is,
I know,
amazing for her.
Jeffrey Epstein was a predator,
a pedophile and a sick
SOUTHERN DISTRICT REPORTERS, P.C.
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805-0300
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RPEPS2 • 
• 
MR. BOIES: 
Your Honor, just very briefly. 
THE COURT: 
Sure. 
61 
MR. BOIES: 
I would like to express to the Court how 
proud I am of all of these women who have come forward. 
It's 
taken an enormous amount of strength and courage for them to do 
so. 
Thank you. 
THE COURT: 
Thanks, Mr. Boies. 
Hold on one second. 
(Pause) 
MS. LERNER: 
Thank you, your Honor. 
My name is 
Kimberly Lerner, of Lerner and Lerner, and your Honor, with 
your permission, I would like my client, Jennifer Aroz, to 
stand next to me. 
THE COURT: 
Sure. 
MS. LERNER: 
Would that be okay?...

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individual.
However,
he was also a thief.
He stole Jennifer's
childhood dreams, her innocence and her self-confidence.
She
was
14 years old.
What he could not buy,
he forcibly took.
Why?
Because he surrounded himself with a network of powerful
people who not only looked the other way, but also actively
facilitated and participated in his sexual abuse of children.
Jeffrey Epstein thought he was above the law, and
essentially he was until now.
The system let Jennifer and the
other victims down, but it does not have to end here.
We ask
the U.S. Attorney's Office and the FBI to bring all of
Epstein's enablers and co-conspirators to justice.
It has taken Jennifer
18 years to find her voice, and
again, Jeffrey Epstein has tried to silence her.
While she
will never have her chance to face him in court,
he no longer
has any power over her.
Today, this brave survivor will be
heard.
MS.
AROZ :
Thank you for allowing me to be able to
have
my chance in court today, to be able to tell you what this
horrific man did to my life.
You can't even imagine how much
it affected my childhood, all the way through my adult life.
He robbed me of
my dreams.
He robbed me of my chance to pursue
a career I always adored.
He stole
my chance at really feeling
love because I was so scared to trust anyone for so many years
that I had such severe anxiety.
I didn't want to leave my
house let alone my bed.
SOUTHERN DISTRICT REPORTERS
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p.c.
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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individual. 
However, he was also a thief. 
He stole Jennifer's 
childhood dreams, her innocence and her self-confidence. 
She 
was 14 years old. 
What he could not buy, he forcibly took. 
Why? 
Because he surrounded himself with a network of powerful 
pe...

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J8RPEPS2
The fact that he felt entitled to take:away my
innocence, the fact that he felt that he could do whatever he
wanted, regardless of the laws, hurts
me so very much.
It took
me years to tell anyone what Epstein did to me because I was so
ashamed and embarrassed at what people would say or think of me
until I found out there were other victims, girls just like me.
I knew I could no longer keep my silence no matter how ruthless
and powerful Epstein was,
and still is even after his death.
The fact I will never have a chance to face my
predator in court eats away at my soul.
Even in death, Epstein
is trying to hurt me.
I had hoped to at last get an apology,
but this evil man had no remorse or caring for what he did to
anyone.
I felt let down by the people who were supposed to
watch him in prison.
They let this man kill himself and kill
the chance of justice for so many others in the process, taking
away our ability to speak.
Out of all the damages and side effects that Epstein
caused by his heartless and selfish acts, it's very hard to put
my feelings and emotions into words, trying to let his
horrendous actions go and attempting to forgive him, has been
so difficult for me.
Yet, as hard as it's been to come so
publicly forward,
I refuse to let Epstein take me as a victim
anymore.
I
am a survivor.
The many that stand before me here
today that have shared the horrific experiences with this
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RPEPS2 
The fact that he felt entitled to take: away my 
innocence, the fact that he felt that he could do whatever he 
wanted, regardless of the laws, hurts me so very much. 
It took 
me years to tell anyone what Epstein did to me because I was so 
...

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deplorable human being, because even though this weak, evil
coward tried to steal all of our childhoods, tried to steal all
I
of our innocence and tried to steal all of our means of
justice, he will never steal our inner strength,
and he will
never, ever, ever steal our voice.
Thank you so much.
THE COURT:
You're welcome.
MS.
GIBBS:
Good morning, your Honor.
Teri Gibbs,
T-e-r-i, G-i-b-b-s.
For the record,
I
am a California
attorney.
I'm not admitted to the New York State bar.
I
am
here to make a statement on behalf of New York attorney, Lisa
Bloom.
I work for her firm,
The Bloom Firm.
Lisa Bloom represents four of Jeffrey Epstein's
victims, Jane Doe 6, for the record, Jane Doe
7 and Jane Doe 8.
I am so proud of all of you victims who are here today and are
able to voice yourselves today.
I will not and cannot comment
on the criminal case, or Ms. Bloom's communications with her
clients.
Ms. Bloom would like to share three of her client's
statements for the record.
Here are the statements.
Statement
of Jane Doe 6.
To the Honorable Richard M. Berman.
Jeffrey Epstein
stole
my innocence.
He gave me a life sentence of guilt and
shame.
I do not consider myself a victim.
I see myself a
survivor.
The abuse that I endured cannot continue.
Let's
stop this before it happens to other young women.
Jane Doe.
SOUTHERN DISTRICT REPORTERS, P.C.
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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deplorable human being, because even though this weak, evil 
coward tried to steal all of our childhoods, tried to steal all 
I 
of our innocence and tried to steal all of our means of 
justice, he will never steal our inner strength, and he will 
never, ever, ever steal our voice. 
Thank you so much. 
THE COURT: 
You're welcome. 
...

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Statement of Jane Doe 7.
To the Honorable Richard M.
Berman.
I used to be relatively carefree, inquisitive, hopeful
and excited about life, but
my life changed because of Jeffrey
Epstein.
My perspective on life became very dark when I was
unknowingly recruited by one of his agents.
Jeffrey Epstein
ruined me.
His recruiter ruined me.
The far-reaching
consequences of that day ruined my family's lives.
I've chosen to remain anonymous in order to protect my
family from unwanted media attention.
I was just trying to figure out my path in life when I
encountered Jeffrey Epstein in his New York City mansion.
I
cannot even begin to summarize the many detriments this
experience of sexual assault has had on my life.
Immediately
following the incident,
I was unable to function and be around
other people.
My parents had to rescue me and bring me home,
where I became a recluse for years.
I was changed forever and buried my assault deep down,
where the darkness couldn't hurt me anymore, but of course, it
has always been here, lingering and affecting me unconsciously.
At the time,
I was mired in shame, guilt and humiliation.
I
had somehow tricked myself into thinking that I had allowed the
assault to happen, that I did it to myself, that I don't
deserve to be alive or to be loved.
I believed that I was a
disgusting, shameful person who does not deserve to ever be
happy.
These are the thoughts I've lived with on a daily
SOUTHERN DISTRICT REPORTERS, P.C.
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805-0300
CA/Aronberg-000984
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RPEPS2 
Statement of Jane Doe 7. 
To the Honorable Richard M. 
Berman. 
I used to be relatively carefree, inquisitive, hopeful 
and excited about life, but my life changed because of Jeffrey 
Epstein. 
My perspective on life bec...

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basis.
Furthermore, because I couldn't tell anyone, out of
fear of judgment, blame or retaliation, keeping this secret
completely hindered my ability to uncover why these issues
existed for me, which could have led to a path of healing over
the years .
It is time for those of power to do the right thing.
It is time for compassion toward our fellow human beings to
reign over money, power and greed.
We need to protect our most
vulnerable to allow them a chance at a normal life, and nothing
should come in the way of that.
I believe that for future
generations, including my own children, this case will set a
precedent that victims must no longer suffer in silence on our
own or be shamed for coming forward to seek protection.
This case should demonstrate to those who want to harm
others that there will be a reckoning,
and they will pay dearly
for the harm they inflict on innocent people.
Judge Berman,
I
thank you for from the bottom of
my heart for this forum and
opportunity.
To all of those survivors who came before me,
I
commend your bravery.
There is no way I could have done this
without you.
Thank you to the public following this story, for your
outrage and desire for answers, which will hopefully move this
case forward so that victims can stop having to relive their
SOUTHERN DISTRICT REPORTERS, P.C.
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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basis. 
Furthermore, because I couldn't tell anyone, out of 
fear of judgment, blame or retaliation, keeping this secret 
completely hindered my ability to uncover why these issues 
existed for me, which could have led to a path of healing over 
the years. 
It is time for those of power to do the right thing. 
It is time for compassion toward our fellow h...

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J8RPEPS2
experiences every day and move on to begin to heal.
God bless the victims, their families, the
investigators and public servants working so diligently to find
those answers and to right all these wrongs.
Jane Doe 7.
(Continued on next page)
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J8RPEPS2 
experiences every day and move on to begin to heal. 
God bless the victims, their families, the 
investigators and public servants working so diligently to find 
those answers and to right all these wrongs. 
Jane Doe 7. 
(Continued on next page) 
SOUTHERN DISTRICT REPORTERS, P.C. 
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J8RsEPS3
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THE
COURT:
Thanks very much.
;
MS.
GIBBS:
One more.
Statement of Jane Doe 8.
In the past few weeks,
I have had to reflect on my
interaction with Jeffrey Epstein and realized that, though I
have yet to put it all behind me,
I am still a victim.
I say
this because I have to come to terms with it in an effort to
truly get past the abuse I suffered at the hands of Epstein.
Pursuing criminal penalties against him and having an
opportunity to address the egregious crimes he committed
against me and other young woman would have helped my recovery
process.
This all came to an abrupt halt when he took his own
life.
This point of disclosure is lost.
I cannot say that I
am pleased he committed suicide,
but I
am at peace knowing he will not be able to hurt anyone
else.
However,
a sad truth remains.
I, along with other
people, will never have an answer as to why.
I will never have
an apology for the wrongdoing.
And most importantly, Epstein
will not be justly sentenced for his crimes.
Now I sit in my
home questioning the well-being of those girls like myself.
In
choosing death, Epstein denied everyone justice.
Any efforts made to protect Epstein's name and legacy
send a message to the victims that he wins and that he is
untouchable.
I understand his case may be dismissed or closed,
but this makes me feel as though I, and anyone else who fell
pry to his hands, simply do not matter.
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000987
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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• 
J8RsEPS3 
THE COURT: 
Thanks very much. 
MS. GIBBS: 
One more. 
Statement of Jane Doe 8. 
In the past few weeks, I have had to reflect on my 
interaction with Jeffrey Epstein and realized that, though I 
have yet to put it all behind me, I am still a victim. 
I say 
this be...

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J8RsEPS3
I ask that you very seriously consider the final
decision, because it will undoubtedly affect all other facets
of this case, including any future charges brought against the
recruiters or third parties to his crimes.
I do not want the
narrative to be,
Those poor girls.
I want to send a message to
anyone who would consider engaging in similar acts to think
twice beforehand.
I want some sort of closure for those of us
who relive those horrible moments where we were assaulted,
abused, and taken advantage of by Epstein.
You have the opportunity to help us seek that closure.
I appreciate your time and consideration and ask for your
continued support in dealing with this case to illustrate that
we, Epstein's victims,
do matter.
Sincerely, Jane Doe 8.
On behalf of Lisa Bloom and The Bloom Firm, thank you,
your Honor.
THE COURT:
Thank you,
Ms. Gibbs.
Did we have any other victim's counsel or victims?
Ms. Allred.
MS.
ALLRED:
Good morning, your Honor.
THE COURT:
Good morning.
How are you?
MS.
ALLRED:
Fine.
Thank you.
Allred, Maroko
& Goldberg by Gloria Allred,
G-l-o-r-i-a A-l-l-r-e-d.
Your Honor, thank you so much for this opportunity to
SOUTHERN DISTRICT REPORTERS, P.C.
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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• 
J8RsEPS3 
I ask that you very seriously consider the final 
decision, because it will undoubtedly affect ali other facets 
69 
of this case, including any future charges brought against the 
recruiters or third parties to his crimes. 
I do not want the 
narrative to be, Those poor girls. 
I want to send a message to 
anyone who would consider engaging in similar acts to think 
twice beforehand. 
I want some sort of closure for those of us 
who relive those horrible moments where we were assaulted, 
abused, and taken ...

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J8RsEPS3
afford the victims their voice, because many of' them have never
spoken before.
They never spoke in Florida.
They never spoke
anywhere.
They never told their mother.
They never told their
father.
They never told their family members.
This is an
opportunity for them to be heard.
We thank you for that.
Your Honor, for
43 years
my firm has been the leading
women's rights private law firm in the United States.
We have
helped thousands of victims.
And I, as an officer of the
court,
and as a believer in the system, have tried to encourage
the victims to have confidence in the system that should
provide them access to justice that should help them to assert
and vindicate their rights in a court of law.
It has been
increasingly difficult in this case for me to say to my clients
that they should have confidence in the system of justice given
what has occurred in this case, People v. Jeffrey Epstein.
Having said that,
I
am encouraged by the fact that
this court, essentially, in an unprecedented situation where
the defendant is deceased, is still affording these victims an
opportunity to be heard.
So we thank you for that.
It is some
encouragement.
Your Honor,
you also asked do our clients wish to be
heard in reference to some of the issues that have been raised
this morning, including what should happen into this case.
Your Honor, there has been a suggestion that the court should
investigate the circumstances of the death of Mr. Epstein.
I'm
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000989
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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afford the victims their voice, because many of them have never 
spoken before. 
They never spoke in Florida. 
T~ey never spoke 
anywhere. 
They never told their mother. 
They never told their...

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not going to repeat the arguments made by counsel, but I would
say that if there is jurisdiction,
and I know that is a legal
issue which has been previously argued, that certainly it would
increase the confidence of my clients.
Not just
my clients,
but victims all over,
and some are,
by the way, located in
other parts of the world, to have the court oversee the
investigation.
We are encouraged by the sensitivity of the attorneys
for the United States Attorney's office for the Southern
District of New York and the investigation that is going on
with the separate team.
However, and, of course, the defense
is also conducting its own investigation.
But I do think the
greatest confidence would be if the court in some way would be
able to oversee an investigation because the court is a neutral
party.
And although the court certainly has a stake in finding
out what happened to defendants who are in the custody of the
federal system and who should be there to face the prosecutors
and the charges against them, but now are not because clearly
the system has failed.
And the United States Attorney has admitted that, and
even before he admitted that, everybody knows the system
failed.
Failed the victims, failed the court, failed everyone.
In any event, your Honor, having seen so many
thousands of victims of gender violence, sex harassment, sexual
assault, I've dealt with child sex trafficking, child
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000990
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
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not going to repeat the arguments made by counsel, but I would 
say that if there is jurisdiction, and I know that is a legal 
issue which has been previously argued, that certainly it would 
increase the confidence of my clients. 
No...

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molesters,
I mean, this is a unique case because there are so
many victims and so many failures of the system.
At this
point, what we would really ask for is not just words, but
words have been helpful, but deeds,
and that is very important.
In addition,
I would like to say, throughout this case
is the running theme of the betrayal of trust.
Betrayal of
trust by Jeffrey Epstein.
Betrayal of trust by the system.
And betrayal of trust to the victims who had a right to
justice.
And the Crime Victims' Act should not just be words,
it should have meaning and it should be enforced.
In essence,
we are asking, although you may need to,
of course, grant this motion to dismiss,
I think because the
court has shown sensitivity to victims and victims' needs, if
there is a way to at least keep the record open so that victims
who have not been able to be physically present in the
courtroom today and who have not been able to submit to the
court any letters, victim impact, and who have not been able to
secure attorneys or speak to attorneys yet — so, for example,
I'll still hearing from victims who I have not been able to
meet with yet because they just recently are now contacting
me — so if they could submit, at least for the record, their
victim impact statements, that,
I think, would be a very
important assistance to them.
So that would be, at least they
would know that what they are sharing is on the record.
So, in summary,
I would say that they are looking
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
CA/Aronberg-000991
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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molesters, I mean, this is a unique case because there are so 
many victims and so many failures of the system. 
At this 
72 
point, what we would really ask for is not just words, b...

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forward to the very serious investigation by the United States
Attorney of who may have conspired in this case,
and that is
very hopeful, and we're hoping that everyone who may have a
role to this criminal prosecution will submit that evidence.
This is about power.
This is about many victims
having lived in fear — fear of the rich, the powerful, the
famous, fear that the system will not afford them justice.
So
fear of not coming forward.
And fear, of course, is a weapon
that the rich, powerful, famous, and sexual predators used to
silence the victims.
But that is gone for a lot of victims
because they refuse to suffer in silence.
Finally, it does take courage to speak truth to power.
We thank this honorable court for giving these victims a voice.
We thank them, even after the death of the defendant, for
showing respect for the victims, allowing them dignity,
allowing them a voice.
We do want truth,
we do want justice,
we do want accountability, and we do want those conspirators to
face the justice system.
Your Honor, right now we have two of our clients who
would like to address the court.
THE COURT:
Sure.
MS.
ALLRED:
Then I have a couple of statements on
victims who do not wish to address the court.
As they come up, we'll give them the opportunity to
say either their name or Jane Doe.
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FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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forward to the very serious investigation by the United States 
Attorney of who may have conspired in this case, and that is 
very hopeful, and we're hoping that everyone who may have a 
role to this criminal prosecution will submit that evidence. 
This is about power. 
This is about many victims 
having lived in fear -- fear of the r...

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By the way, thank you, your Honor, for allowing some
of these victims to be called Jane Doe.
What number the court
affords to them, we'll accept whatever that is.
Thank you.
THE COURT:
We're up to nine.
MS.
ALLRED:
Thank you.
MS.
DAVIES:
Hello.
My name is Teala Davies.
That is
T-e-a-l-a D-a-v-i-e-s.
I was going to start this statement by saying that I
was a victim of Jeffrey Epstein.
But that's not the case.
I'm
still a victim of Jeffrey Epstein.
I'm still a victim because
the fear of not being heard stopped me from telling my story
for so many years.
This lingering fear almost stopped me from
attending this monumental movement of strength and power.
I'm still a victim because I
am fearful for
my
daughters and everyone's daughters.
I'm fearful for their
future in this world, where there are predators in power,
a
world where people can avoid justice if their pockets run deep
enough.
I'm still a victim because the 17-year-old Teala was
manipulated into thinking she had found someone who cared,
someone who wanted to help.
Jeffrey knew I had nowhere to go.
He knew I was vulnerable, and he took advantage of that poor
girl,
who will never be the same.
I cannot eat at the thought that Jeffrey Epstein — I
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000993
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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By the way, thank you, your Honor, for allowing some 
of these victims to be called Jane Doe. 
What number the court 
affords to them, we'll accept whatever that is. 
Thank you. 
THE COURT: 
We're up to nine. 
MS. ALLRED: 
Thank you. 
MS. DAVIES: 
Hello. 
My name is Teala Davies. 
That is 
T-e-a-1-a D-a-v-i-e-s. 
I was going to start this statement by saying that I 
was a victim of Jeffrey Epstein. 
But that's not the case. 
I'...

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cannot eat at the thought of Jeffrey Epstein not serving the
time he needed to realize the pain and suffering he caused so
many vulnerable young girls.
He thought he was untouchable,
and honestly, so did I.
I thought he was the most powerful
person I would ever meet.
But the end is here and here I stand becoming more
powerful than he will ever be.
Thank you.
THE
COURT:
Thank you.
JANE
DOE:
Jane Doe.
Um, in 2004,
when I was 15 years old,
I flew on
Jeffrey Epstein's plane to Zorro Ranch, where I was sexual
molested by him for many hours.
What I remember most vividly
was him explaining to me how beneficial the experience was for
me and how much he was helping me to grow.
Yikes.
I remember feeling so small and powerless, especially
after he positioned me by laying me on his floor so that I was
confronted by all the framed photographs on his dresser of him
smiling with wealthy celebrities and politicians.
After he finished with me,
he told me to describe in
detail how good my first sexual experience felt.
That was the
first of many lies I was forced to carry for him, the weight of
which proliferated my trauma.
I felt powerless not merely
because one man wanted to strip me of
my innocence, but because
I was the victim of a system that just enfranchises human
beings, making them vulnerable to pedophilic exploitation.
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000994
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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cannot eat at the thought of Jeffrey Epstein no~ serving the 
time he needed to realize the pain and suffering he caused so 
many vulnerable young girls. 
He thought he was untouchable, 
and honestly, so did I. 
I thought he was the most powerful 
person I would ever meet. 
But the end is here and here I stand becoming...

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:
As unjust as what happened to me was, I believe that
experience to be a symptom of insidious and pathological
violence that extreme wealth yields,
a violence which
ultimately stays hidden through channels of extreme power that
serve it.
I first identified with this feeling the night after I
was molested by Epstein,
when another girl and I took out two
of his ATVs and raised them across the mesa.
I crashed mine
and expressed my concern to the other girl of getting in
trouble, which she replied to me, Don't worry,
no one gets in
trouble for anything here.
Even as a child,
I understood, in a sad and precocious
way, what I hoped we have the ability of changing now.
Even
though Epstein is dead, there is still justice to be brought
for the crimes we felt powerless against concealing for him and
the system that supported him for all these years.
Thank you.
THE COURT:
You're very welcome.
MS.
ALLRED:
Thank you.
Your Honor,
may it please the court.
I would like to
read a statement for Jane Doe,
my client,
who is present in
court, but requested that I read it.
We only have one opportunity at childhood.
One
opportunity to develop.
One opportunity to find direction for
our lives.
Jeffrey Epstein robbed and denied me at each
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000995
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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As unjust as what happened to me was, I believe that 
experience to be a symptom of insidious and pathological 
violence that extreme wealth yields, a violence which 
ultimately stays hidden through channels of extreme power that 
serve it. 
I first identified with this feeling the night after I 
was molested by Epstein, when another girl and I took out two 
of his ATVs and raised them across the mesa. 
I cras...

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opportunity he had.
I came from a small Texas town, not far from the New
Mexico border.
My mother died when I was 11, after suffering
from cancer for many years.
My father was devastated, as were
my siblings and I.
My father was saddled with debt.
My only
hope for college was to get a scholarship.
When I was 15,
I was.a blossoming freshman in high
school and was trying to carry on
my mother's dream.
She
wanted me to master the violin.
After school,
I would often go
to a mall in a nearby city.
A lady approached me and saw I had
a violin case with me and asked if I was any good.
We talked
about the violin,
my family,
and why I had clothes that looked
like hand-me-downs.
The lady told me she works for a very rich man who had
a home close by and that he would pay to hear me play.
I was
told that if I could get away,
she could arrange for
transportation to and from his place and have me back before
anyone knew I was gone.
After some hesitation,
I agreed.
This
decision was the beginning of the end of
my childhood.
The man who only identified himself as J or Jeff had
asked if I would give him a massage, and over four visits,
eventually progressed to forced oral copulation.
The money he
gave me further placed my young soul into a perverse sense of
hell.
I was so utterly disgusted with myself and what he did
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
!
CA/Aronberg-000996
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
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opportunity he had. 
I came from a small Texas town, not fat from the New 
Mexico border. 
My mother died when I was 11, after suffering 
from cancer for many years. 
My father was devastated, as were 
my siblings and I. 
My father was saddled with debt. 
My only 
hope for college was to get a scholarship. 
When I was 15, I...

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to me that I stopped going to see him.
I had documented the
events with a Texas rape crisis center about the man I know now
as Jeffrey Epstein.
Epstein targeted and took advantage of me,
a young
girl, whose mother had recently died a horrific death and whose
family structure had deteriorated.
His actions placed me,
a
young girl, into a downward spiral to the point where I
purchased a gun and drove myself to an isolated place to end my
suffering.
A voice that could only have been from my mother told
me, quote,
I
am not the victim,
I
am the victor,
and I dare not
pull the trigger." I returned the gun days later.
Epstein is a coward.
He lived his life leaching off
the souls of inspiring,
young girls due to the fact that he
could never know how it feels inspired to live.
Like a leach,
once Epstein had his fill, he would unlatch and seek out
another victim.
The only sense of justice I had hoped to see was
Epstein being sentenced.
However, Epstein died as he lived,
taking the easy way out without any responsibility.
Your Honor, the next statement is also a statement of
a Jane Doe.
May it please the court.
I was a 16-year-old virgin when Jeffrey Epstein first
raped me.
I was naive and gullable.
He was a pillar of
finance and a giant in the world that I was an insignificant
78
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000997
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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to me that I stopped going to see him. 
I had documented the 
events with a Texas rape crisis center about the man I know now 
as Jeffrey Epstein. 
Epstein targeted and took advantage of me, a young 
girl, whose mother had recently died a horrific death and whose 
family structure had deteriorated. 
His actions placed me, a 
young girl, into a downward sp...

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part of.
I was so impressed that this great man would even
talk to me and impart any of his wisdom on me.
I gladly jumped
at the chance to meet him again,
when he told me how impressed
he was with my personal story and maturity for
my age.
When I was in his presence,
he made an effort to call
celebrities and influential people on speakerphone, like
Academy Award-winning actresses and super models,
who always
answered his calls.
Sadly,
I was impressed.
He was friends with former and future heads of states
and every other fixture in the New York social scene and
beyond.
He knew important people in my own world that I looked
up to and revered, but he spoke about them like they were sweet
distractions far beneath his stature.
He could easily reach
down from his position and influence the people directly
involved with my daily life and future prosperity.
I was the
perfect victim.
My whole life was extremely turbulent.
But one of
my
mother's greatest wishes was that all her children would
graduate from respectable universities.
He promised me that he
would write me a letter of recommendation for Harvard if I got
the grades and scores needed for admission.
His word was worth
a lot,
he assured me, as he was in the midst of funding and
leading Harvard's studies on the human brain, and the president
was his friend.
The fact that all of you already know these next
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
,
CA/Aronberg-000998
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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part of. 
I was so impressed that this great mah would even 
talk to me and impart any of his wisdom on me. 
I gladly jumped 
at the chance to meet him again, when he told me how impressed 
he was with my personal story and maturity for my age. 
When I was in his presence,...

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details, which I'll share, should ignite fire instead of induce
the complacency they did in the past,
when heard repeatedly
over the years, but yes,
an innocent massage turned sexual
almost immediately.
"Here,
come.
Come help me with a kink in my shoulder
while we finish our discussion."
A large vibrator and a couple
of hundred dollars, disgust and dirty secret,
more praise and
imparted wisdom from a godlike figure,
a deliberate diabolical
depression of grooming and submission for his pleasure and
release.
Even if I resisted,
I was no match for him.
I felt
powerless, ashamed, and embarrassed.
I wanted to vomit
remembering these moments.
What I learned in those depraved sessions, staring up
at the dome ceiling in his private massage room, tore a violent
hole through any normal sexual awakening.
I'm haunted forever,
having learned everything there is to know about sex through a
vile criminal.
Every time a new molestation would bring a new
lesson, the progressive and constant unwinding.
I was nothing
more than a teenage prostitute.
I was his slave.
I had never even kissed a boy before I met him, and
never throughout the horrific abuse did Jeffrey Epstein kiss
me
even once.
When he stole
my virginity, he washed my entire
body compulsively in the shower and then told me, "If you're
not a virgin,
I will kill you."
And then I wasn't a virgin
anymore.
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-000999
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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J8RsEPS3 
details, which I'll share, should ignite fire instead of induce 
the complacency they did in the past, when heard repeatedly 
over the years, but yes, an innocent massage turned sexual 
almost immediately. 
"Here, come. 
Come help me with a kink in my shoulder 
while we finish our ...

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He forcefully penetrated me.
I was numb.
There was
pain, but his use of the vibrator and his fingers in previous
sessions with me had left a black hole-like void between my
legs.
I protested, but he forced my face into the bed to
stifle my cries.
That was my first time.
I got a few hundred dollars, as usual, as he led me
out of his mansion with assurances that I was on the right path
guided by him.
I lied to myself and tried to believe him.
I
became a hollow shell.
If I missed an appointment,
he
threatened me and let me know who was in charge.
"Do you know
how important
my time is? I'll bury you.
I owe this — I
won't say the word — F'ing town."
He would hang up.
I would stand there frozen in the street, terrified
that his assistant would call to reschedule.
I made sure to
stay in line and not disobey him.
I was in complete denial.
Being paid after every scheduled meeting felt routine and
disgusting.
He was the master of the universe and the world
bent to his will.
He would eventually brag to his assistants about
my
ability to please him sexually right in front of me, leaving me
feeling grotesque and worthless.
Everything in my outside life
was falling apart.
I distanced myself from friends and grew
further away from my family.
I felt less human after each
ordeal.
My psyche broke down completely and wouldn't let
me
continue.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
CA/Aronberg-001000
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He forcefully penetrated me. 
I was numb. 
There was 
pain, but his use of the vibrator and his finge~s in previous 
sessions with me had left a black hole-like void between my 
legs. 
I protested, but he forced my face into the bed to 
stifle my cries. 
That was my first time. 
I got a few hundred dollar...

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One day I walked out of his residence and passed a
girl similar to myself.
When I turned around, she was entering
Jeffrey's residence.
He no longer even tried to schedule his
appointments with other girls in secrecy from me.
Maybe he
never did.
I was too stupid to see.
My world shattered.
I had been so naive.
I had an
epiphany in a calvary of desperation.
I realized I was just
one of many young girls he had in rotation come to perform for
him for money.
I went into a deep depression and never lifted
completely.
I wanted to inflict pain on myself.
I was
humiliated, angry, and suicidal.
I locked myself away from
everything.
I cut myself off forever from the world I had
known.
I endured the daily agony of knowing my life would
never be the same.
I could never go back to New York City and
the wonderful life I had taken for granted before I met this
demon named Jeffrey Epstein.
This creature had manipulated and outwitted the whole
system, including some of the most intelligent scientists,
political people, prosecutors, and power players.
How easy was
it to manipulate a 16-year-old virgin who never had a boyfriend
and came from a background of hardship with no parental
guidance or support.
I went to therapy and was given antidepressants for
severe anxiety and depression.
My only solace, years later,
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
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J8RsEPS3 
One day I walked out of his residence and passed a 
girl similar to myself. 
When I turned around, she was entering 
Jeffrey's residence. 
He no longer even tried to schedule his 
appointments with other girls in secrecy from me. 
Maybe he 
never did. 
I was too stupid to see. 
My world shattered. 
I had been so naive. 
I had an ...

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was my desire to succeed on
my own terms.
I emersed myself
into my studies and was accepted to every college I applied to,
graduating from a top university.
To this day, there is still
an ache in
my being that I did not apply to Harvard in fear of
his influence there.
They say you never forget your first.
I'm in a
never-ending nightmare trying to do just that.
I'm forever
suffering because everything reminds me of that horror.
This
new wave of worldwide publicity only worsens my despair.
It was only many years later that I was finally
intimate with a man again, and those moments were marred by my
actions as a child with Jeffrey Epstein.
Even now is
impossible to separate his treachery from any care of a good
man.
For one brief moment there was elation when he was
recently arrested.
I would finally get my chance to see him
again face to face and show him what I had become, that I had
succeeded on my own, that I was worth something in spite of his
abuse,
and that I had surmounted the monumental obstacles he
laid before me throughout
my entire life since falling prey to
him.
I had hoped humanity would prevail, but it seems to me
that he outsmarted everyone so far, and his ghost is still
laughing at us.
I appeal to all of those just and true that
his evil legacy and his death not stand in the way of
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
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J8RsEPS3 
was my desire to succeed on my own terms. 
I 
I em,ersed myself 
into my studies and was accepted to every college I applied to, 
graduating from a top university. 
To this day, there is still 
an ache in my being that I did not apply to Harvard in fear of 
his influence there. 
They say you never forget your first. 
I'm in a...

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resolution and justice for all of his underagedl victims.
Thank you, your Honor.
.
And then just one last one, and this is much shorter.
Statement of Jane Doe, also my client.
I was a model in another country when I came to the
United States.
I was told by a booker that I needed to meet
with a man named Jeffrey Epstein,
who was the owner of
Victoria's Secret.
The booker told me that Mr. Epstein could
help me get into Victoria Secret's world.
It was
my childhood dream to be a Victoria's Secret
model.
So I went one day in the afternoon and I met
Mr. Epstein in his office in his mansion in New York.
A woman
introduced herself and suggested to me that I should be
extremely nice to Mr. Epstein, because if he liked me,
he would
probably have photographers shooting photos of me right away.
The told me to go upstairs and directed me to Jeffrey
Epstein's office.
Mr. Epstein had a white robe on and we
chatted very briefly.
I had my portfolio of photos, but he
didn't even look at it.
Suddenly, he took his robe off and got
close to me.
I got up to leave, but the door was locked.
I didn't know what was going on.
It was
my first
official meeting to be cast in the United States.
I was a
young girl and confused.
He got very close to me, and I had a
skirt on.
He started to touch my genitals.
I refused him.
Then he went to the massage table and showed me the vibrator.
SOUTHERN DISTRICT REPORTERS, P.C.
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resolution and justice for all of his underaged1 victims. 
Thank you, your Honor. 
84 
And then just one last one, and this is much shorter. 
Statement of Jane Doe, also my client. 
I was a model in another country when I came to the 
United States. 
I was told...

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J8RsEPS3
I took it and threw it at him.
At that point,
I ran to the door again and figured out
how to get out of there.
A girl outside asked me where I was
going and she said to be careful.
She said that Mr. Epstein
knew a lot of powerful people, including Bill Clinton, and that
if I didn't do what Mr. Epstein wanted,
I would not be able to
have any job in the industry.
I was so scared.
I couldn't wait to get out of there,
and I left.
I took the train home.
I had spent all of
my
savings getting Victoria's Secret lingerie to prepare for what
I thought would be my audition.
But instead, it seemed like a
casting call for prostitution.
I felt like I was in hell.
Thank you, your Honor.
Thank you.
THE
COURT:
Thank you,
Ms. Allred.
Was there anybody else,
any victim's counsel or any of
the other victims who have not been heard and wish to be heard?
Well,
OK then.
All I have to say, really, is thank
you, all of you, for your participation in today's remarkable
hearing.
I think everybody has benefited greatly from your
input, and especially from the testimony of victims here today
and who have had the courage to come forward.
We have also benefited throughout these proceedings,
however brief altogether, from the attorneys' legal advocacy
and their written and oral submissions.
I'm grateful to them
SOUTHERN DISTRICT REPORTERS, P.C.
(212)
805-0300
CA/Aronberg-001004
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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I took it and threw it at him. 
I •' 
85 
At that point, I ran to the door again and figured out 
how to get out of there. 
A girl outside asked me where I was 
going and she said to be careful. 
She said that Mr. Epstein 
knew a lot of powerful people, including Bill Clinton, and that 
if I didn't do what Mr. Epstein wanted, I would not be able to 
ha...

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as well, both for the government and the defense and those
representing the victims.
j
Finally, we're also grateful to the press for their
very diligent coverage of seemingly every detail of this case.
That concludes our work for today and we stand
adjourned.
Thanks.
(Adjourned)
SOUTHERN DISTRICT REPORTERS, P.G.
(212)
805-0300
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as well, both for the government and the 
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defensi2 
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and those 
Finally, we're also grateful to the press for their 
very diligent coverage of seemingly every detail of this case. 
That concludes our work fo~ today and we stand 
adjourned. 
Thanks. 
(Adjourned) 
SOUTHERN DISTRICT REPORTERS, P.C. 
(212) 805-0300 
CA/Aronberg-001005 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

Appendix 12
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Appendix 12 
CA/Aronberg-001006 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

The Balm Beach Post
REALNEWSSlAMS HERL
■
The Man Who Had Everything: Jeffrey Epstein craved big
homes, elite friends and underage girls
By Andrew Marra
Posted Jul I?’ 2019 at 6:02 AM
From the archives: When Palm Beach detectives started asking
questions and teenage girls started talking, a wave of legal resistance
followed.
Editor s Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after
Jeffrey Epstein's arrestin 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 thepolice detectives, who sifted through the garbage outside and kept records ofvisitors, it
was the lair of a troubling target.
Epstein, one of the most mysterious of the country’s mega-rich, was known as much for his
secrecy as for his love of fine things: magnificent homes, private jets, beautiful women,
friendships with the world’s elite.
But at Palm Beach police headquarters, he was becoming known for something else: the
regular arrival of teenage girls he hired to give him massages and, police say, perform sexual
favors.
Epstein,was different from most sexual abuse suspects; he was far more powerful. He counted
among hisfriends former President Bill Clinton, Donald Trump and Prince Andrew, along
with some of the most prominent legal, scientific and.business minds in the country.
When detectives started asking questions and teenage girls started talking, a wave of legal
resistance followed.
CA/Aronberg-00.1007
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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'The· .:Ma n,::.who ;Had ,iEver.
7:th'in•· . : -J ef:frtr : E ----stein :cr;aved:•ibl ··; 
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homes; elileJri.ends .:and:::tntd·e~agp•,;girls 
By:Andre~ Marra 
Posted Jul ff201·9.at 6:02 AM 
From the _archive...

» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work-
release
If Palm Beach police didn’t know quite who Jeffrey Epstein was, they found out soon enough.
Epstein, now 53, was a quintessential .man ofmystery. He amassed his fortune and friends
quietly, always in the background as he navigated New York high society;
When he first attracted notice in the early 1990s, it was on account of the woman he was
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
In.a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love,” the British
Mail on Sunday tabloid laid out speculative stories that the socialite’s beau was a CIA spook, a
math teacher, a concert pianist or a corporate headhunter.
"But what is the truth about him?” the newspaper wondered. “Like Maxwell, Epstein is both
flamboyant and intensely private.’’
The media frenzy did not begin in full until a decade later. In September 2002, Epstein was
flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to
Africa on his private jet.
I
Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair
published lengthy profiles. The New'York Post listed him as one of the city's most eligible
bachelors and began describing him in.its gossip columns with adjectives such as “mysterious”
and “reclusive.”
Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
Building a life ofextravagance
He was born blue-collar in 195'3, 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
butbecame a math teacher at the prestigious Dalton School in Manhattan.
The story goes that the father of one of Epstein’s students was so impressed with the man that
he put him in touch with a senior partner at Bear Stearns, the global investment bank and
securities firm.
CA/Aronberg-00.1008
FILED: P...

In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J.
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,OOO-square-foot hilltop mansion on.a 10,000-acre ranch
outside Santa Fe. Many believed it to be the largest home in the state.
In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre
private island in the Virgin, Islands.
» PHOTOS: The players in the Jeffrey Epstein saga
Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
the highest echelons of power. This includes not only socialites but also business tycoons,
media moguls, politicians; royalty and Nobel Prize-winning scientists whose research he often
funds.
"Just like other people collect art, he collects scientists," said Martin Nowak, who directs the
Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of
a $30 million research donation from Epstein.
Epstein is said to have befriended former Harvard President Larry Summers) prominent law
Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher...

And yet he managed for decades to maintain a low profile. He. avoids eating out and was rarely
photographed.
"The odd thing is I never met him/’ said Dominick Dunne, the famous chronicler of the trials
and tribulations of the very rich. “I wasn’t even aware of him/’ except fpi; a Vanity Fair article..
Epstein’s friendship with Clinton has attracted the most attention.
Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at
an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become
close friends until after Clinton left the Oval Office and moved to New York.
Epstein-has donated more than $1 00,000 to Democratic candidates’ campaigns, including John
Kerry’s presidential bid, the reelection campaign of New Mexico Gov. Bill Richardson and the
Seriate 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 fife story. The 2003 article said he
left Bear Stearns in the wake of a federal probe and a possible Securities arid 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 arid previous employers was Steven
Hoffenberg, riow serving a prison term after "bilking investors out ofmore 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 Palin. Beach home over a dispute about less
than $16,000 in furnishings.
A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
owed him nothing.
» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says
CA/Aronberg-00.1010
FILED: PALM BE...

“It’s a bad memory. I would rather not have ever met Jeffrey Epstein,"said Michael Stroll, the
retired former president ofWilliams Electronics and Sega Corp. “Suffice it to say I have
nothing good to say about him.”
Among the characteristics most attributed to Epstein is a penchant for women.
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
and London. Previous, girlfriends are: said to include a former Ms. Sweden and a Romanian
model.
"He’s a lot of fun to be with,” Donald Trump told New Yorkmagazine in.2002. “It is even said
that he likes beautiful women,as much as I do, and many of them are on the younger side. No.
doubt about it, Jeffrey enjoys his social life.”
Investigation leads to Epstein
Although he was not a frequenter of the Palm, Beach social scene, he made his presence felt.
Among his charitable donations, he gave 590,000 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.
CA/Aronberg-001011
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"It's;abad memory, I wol!ld:r_ath_er:npt have ever me...

Palm Beach police and the state attorney's office have declined to discuss the: case,. But a Palm
Beach police report.detailing the criminal probe.offers a window into what detectives faced as
they sought to close in on Epstein.
Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to
perform a massage. She said the: friend told her to say she was 18 if asked. At-the house, she
said she was paid $300 after stripping to her panties and massaging the: man while he
masturbated.
Police interview 5 alleged victims
The: investigation began, in full after the girl identified Epstein in a photo as the man who had
paid her. Police arranged for garbage trucks to set aside Epstein’s trash so police could sift
through it. They set up a video camera to record the comings and goings at his home. They
monitored an airport hangar for signs of his private jet’s arrivals and,departures.
They quickly learned that the woman who took the 14-year-old girl to Epstein’s house was
Haley Robson, a Palm Beach Community College student from Loxahatchee. In a sworn
statement at police headquarters. Robson, then 18, admitted she had taken at least six girls to
visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said.
During the drive back to her house, Robson told detectives, “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 Epstein's former employees:told investigators that young-looking girls showed up to
perform massages two...

One employee told detectives he was told to send a dozen roses to One teenage girl after a high
school drama performance. Others were given rental cars. One, according to police, received a
-$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 oyer 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 Eronstin, he said the investigators worked for Roy Black, the
high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
Kennedy Smith.
While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law
professor, traveled to West,Palm Beach with information about the girls. From their own
profiles on the popular Web site.MySpace.com, he obtained copies of their discussions about
their use of alcohol and, marijuana.
He took his research to a meeting with prosecutors in early 2006, where he sought to cast
doubt on the teens' reliability.
The private eyes had dug up enough dirt on the,girls to make prosecutors skeptical. Not only
did some of the girls have issues with drugs or alcohol but also some had criminal records and
other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she
told police she was younger than 18 when she started performing massages for Epstein,
After the meeting, prosecutors postponed their decision to take the case ...

In the following weeks, police received complaints that two of the victims or their families had.
been harassed or threatened. Epstein s legal team maintains that its private investigators did
nothing illegal or unethical during their research.
By then, relations between police and prosecutors were fraying. At a key meeting with
prosecutors and the defense, Detective Joseph Recarey, the lead, investigator, was a no-show,
according to Epsteins attorney.
"The embarrassment on the.prosecutor’s face was evident when the police officer never
showed up for the meeting,” attorneyJack Goldberger said.
Later in April, Recarey walked into a prosecutor’s office at the state attorney’s office and
learned the case was taking an unexpected turn.
The prosecutor, Lanna Belohlavek, told Recarey the state 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 ofthe plea offer.
The deal never came to pass, however.
Future unclear after charge
On May 1, the department, asked prosecutors to approve warrants to arrest Epstein on four
counts ofunlawful sexual activity with a minor and to charge his personal assistant, Sarah
Kellen, now 27, for her alleged role in arranging the visits. Police officials also wanted to
charge Robson, the self-described Heidi Fleiss, with lewd and lascivious acts.
By then, the department was frustrated with the way the state attorney’s office had handled the
case. On the same day the warrants were requested, Palm Beach Police ChiefMichael Reiter
wrote a.letter to State Attorney Barry Krischer suggesting he disqualify himselffrom 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.
CA/Aronberg-00.1014
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• 
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Ju, the following weeks, police receive.cl complaints that two of the ...

It is not-known how many of the girls testified before the grand jury. ButEpstein'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 of theft made against them by their employers. There was evidence ofdrug 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 haye.remained silent as tabloids and Internet blogs feast on the public details ofthe
police investigation.
Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future
plea deal, He insists Epstein will emerge in the end with his reputation untarnished,
“He will recover from this,” he said.
Staff writer Larry Keller and staff researchers: Bridget Bulger, Angelica Cortez, Amy Hanaway and
Melanie Mena contributed to this story.
amarra@pbpost.com
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@AMarraPBPost
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273 / 278 - Tuesday, November 16, 2004
Edition:- FINAL
Section: A SECTION
Page: 1A
Source: By PAUL OWERS Palm Beach Post Staff Writer
Illustration: PHOTO (C & 2 B&W):& MAP (B&W)
Memo: Ran all editions.
Dateline: WEST PALM BEACH
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
When it came time to bid Monday for the palatial Palm Beach digs ofAbe 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. Rovz."
But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at
513 N. County Road. He wants to. - what else? - sell it and make more money.
The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super
luxury house" that would be the "finest anywhere in the United States?' He might build
another house before .flipping the entire package.
"I've known about this house for quite some time," Trump said. "It's probably the best piece
of land in Florida - and probably the country - for luxury real estate."
Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor
Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith
said she's not worried about Trump’s plans.
"He's been a very good property owner in the town of Palm Beach," she said. "He does his
projects very well. He's a perfectionist."
Monday's auction took place at U.S. Bankruptcy Court in West Palm.Beach as part of
Gosman's Chapter 7 bankruptcy case. Proceeds, from the sale;will go into escrow for eventual
distribution to creditors.
The: auction began at. exactly noon after Judge Steven Friedman dismissed an objection from
an attorney representing money manager. Jeffrey Epstein. The lawyer argued unsuccessfully
that Trump was not a qualified bidder .bec...

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 fight.to buy
the 29,000-square-foot home (a typical Palm Beach County single-family house is about
2,200 square feet). The property .also has a tennis house, a pool house and 1930s-era service
quarters.
The closing.could take place within a week but probably won't happen until next month.
Trustee Joe Luzinski and creditors said they were pleased with the outcome,
"We knew we were dealing with some substantial people
. ,. who were going to bid it up a
bit," Luzinski said.
"The system worked," said Charles Tatelbaumj 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 alter 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 pai...

The, trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
an ownership interest inhis 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 decisionthat will affect how much money will be available to creditors .
Cirno acknowledged that Monday wasn't the best of days for the Gosmaris but said they were
willing to move Forward, in part because the upkeep of the estate now exceeds their means.
"This is not a happy occasion for them, but at least we're moving to the next level," CimO
said. "That's not a house you want to live in unless you’re making large amounts of money
like Donald Trump."
paul_owers@pbpost.com
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The, hustee alleged during .a week long trial in May that Gosman fraudulently gave his wife 
an ow11ershjp interest in;his nome and other belongings only to .avoid los~ng them in 
bankruptcy. Gosman has denied any wrongdoirtg, saying he made the property transfers in 
19991 well before he filed for.bankruptcy. 
Lessen is exp:ected to rule in the next two. months whether· Gosman made·irriproper transfers, 
a decisi9n '.t}:iaj will ~ffect how lllu~h m9ney will be ~v~f}able to creditors, 
Cimo acknowledgedthat Monday wasn't the best of days for the Gosman:s·but said they were 
wHJin.g to move ,forward, ·i.n pa1t be93,l!S.e th,e \lpke~p of the estate IJ.OW ex~eeds 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 w~nt to live. in unless you're rnaking large amounts of money 
like Donald Trump.'' 
paul'---owers@pbpost.com 
CA/Aronberg-00.1019 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:...

11/11/2019
Indi^TOnt: Billionaire1 Solicited 3 Times - News - The;Palm Beach Host- West Palm Beach, FL
ThePalm Beach fest
REALNEWSSTftRTSHERE
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 onJuly 25,
2006)
Billionaire money manager and Palm Beach part-time residentJeffrey Epstein,
solicited or procured prostitutes three or more times between Aug.
1 and Oct. 31
of last year, according to an indictment charging him with.felony solicitation of
prostitution.
Epstein, 53, was booked; at the Palm Beach County jail at 1:45 a.m. Sunday. He
was released On $3,000 bond.
Epstein s case is unusual in that suspected prostitution johns are usually charged
with a misdemeanor, and even a felony charge is typically made in a criminal
information - an alternative to an indictment charging a person with the
commission of a crime.
His attorney, Jack
to discuss the charge.
State attorney’s office spokesman Mike Edmondson also had little to say.
"Generally speaking, there is a case that has a number of different.aspects to it,”
Edmondson said of a
charge being submitted to a grand jury.
"We first became aware ofthe case months ago by Palm Beach police."
Prosecutors and police worked together to bring the case to the grand jury, he
said.
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]ndictment: Bi!IHonaire Solicite_d 3 Time:s 
Posted _Jul 11 2008,at 12:01 AM 
Updated.bet i,2019. at·2:3ci PM 
(EDITOR'S NOTE: This ~tory origi1Jally publisheq fn The Palm Beadt Post onjuly 25, 
2006) 
Billionairemoneymanager and Palm Beach part-time tesident)effrey Epstein. 
solicite.d or procured prostitutes three· or more times bet:vVeen Aug, 1 and Oct, 31 
of last year,, according tQ an.indictment-charging:him with...

11/11/2019
Indictment: Billionaire Solicited.3 Times- News - The Palm Beach Post- West Palm Beach; FL.
Palm Beach police-confirmed that and said the department will release a report
today regarding its investigation.
Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-squarc-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 - 5'1,000. 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.com7news/20080701/indictment-billionaire-solicited-3-times
CA/Aronberg-00.1021
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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11/11/2019 
Palm Bea.ch police confir,med that and.said the department wilhelease a report 
today regarding its investigation. 
Epstein has owned a five"bedroom, 7 1/2~hath, 7,234-square~foot;home with a 
pool and a boat dock oh the lrttracoastal Waterway since 1990,. according to 
propertyrecords. A man answering the door there Monday said that Epstein 
wasn't home .. A, Cadill~~ Escal~de registE!red ro him was parked:in rhe driyeway1 
whichis flanked by two massive gargoyles. 
Epstein suecf PrC>pef!Y Appraiser G'.ary NikoHts in 2001, con~ending thatthe 
assessmentof.his home exceedeq...

11/11/2019
After long p^e, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
The Palm Beach Post
REflLNEWSSTflRTSHERE
j
After long probe, billionaire faces solicitation
charge
Posted Jul 27,2006 at 12:01 AM
Updated Oct 3, 2019 at 3:11 PM
(EDITOR’S NOTE: This story originally published in The Palm Beach Post onJuly 26,
2006)
Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young
women brought to his home, where he received massages and sometimes sex,
according to an investigation by the Palm Beach Police Department.
Palm Beach police spent months sifting through Epstein’s trash and watching his
waterfront home and Palm Beach International Airport to keep tabs on his
private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
him with,one count of felony solicitation ofprostitution.
Palm Beach police thought there was probable cause to charge Epstein with
unlawful sex acts with a minor and lewd and lascivious: molestation.
Police Chief Michael Reiter was so angrywith State Attorney Barry Krischer’s
handling ofthe Case that he wrote a memo suggesting the county’s top
prosecutor disqualify himself.
‘‘1 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 arid
their ability to testify.
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After Jong probe, bt,lil!ioiraire faces s.oltci:tatio:n ...

11/11/2019
Afterlorig^We, billionaire faces solicitation charge - News - The Palm beach Post - West Palm Beach, FL
I
'
By the nature of their jobs, police officers look at evidence from a “one-sided
perspective,” Edmondson said. “A prosecutor has to look at it in a much broader
fashion,” weighing the veracity ofwitnesses and how they may fare under
defense attorneys’ questioning, he said.
Epstein s attorney, Jack Goldberger, said his client committed no crimes.
"The reports and statements in question refer to false accusations that were not
charged because the Palm Beach County state attorney questioned the credibility
of the witnesses,” Goldberger said. A county grand jury "found the allegations
wholly unsubstantiated and not credible/’ and that’s why his client was not
charged with sexual activity with minors, he said.
Goldberger said Epstein passeda 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-pld 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 arid placing massage oils nearby.
- Police took sworn statements from five alleged victims and 17 Witnesses. They
contend that on three occasions, Epstein had sex with the girls.
A money manager for the ultra-rich, Epstein was named one of New York’s most
eligible bachelors in 200.3 by The New York Post. He reportedly hobnobs with
the:likes of former PresidentClinton, former Harvard University President
Lawr...

11/11/2019
After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West PalmBeach, FL
He has contributed tens of thousands of dollars to Democratic Party candidates
and organizations, including Sen. John Kerry’s presidential bid, and the Senate
campaigns ofJoe Lieberman, Hillary Clinton,. Christopher Dodd,and Charles
Schumer.
Goldberger is one of five attorneys Epstein has retained since he became the
subject of an investigation, Edmondson said. Among the others: Alan.
Dershowitz, the well-known Harvard law professor and author, who is a friend
of Epstein- Dershowitz Could not be reached forcomment.
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 ajournalism major at Palm Beach Community
College when she was questioned by police last October. She has an unlisted
phone number and could.not be reached for comment.
Robson said she met Epstein when, at age 17, a friend asked her if she would like
to make: money giving him a massage. She said she was driven to his five-
bedroom; 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs
to a bedroom with a massage table and oils. Epstein, and Robson were both naked
during the massage, she said, but when he grabbed her buttocks, she said she
didn’t want to be touched.
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He ha:s contributed tens of thousands' of dollars to Democratic Party candidates 
and ·organizations, including Sen. John Kerry's presidential'bid, an~ the Senate 
campaigns ofJoe Lieberman•, Hillary Clinton,. Christopher Dodd.aAd Charles 
Schumer. 
Goldberger ·is one oHive attorneys Epstein has retained since he became the 
subject qfan-investiga,tion, Edmondson...

11/11/2019
After long
billionaire'faces solicitation charge - News - The Palm B^rch Post - West Palm Beach, FL
Epstein said he’d pay her to bring him more girls - the younger the better,
Robson told police. When she tried once to bring a 23-year-old woman to him,
Epstein said she was too old, Robson said.
,
Robson,, who. has not been charged in the case, said she eventually brought six
girls to Epstein who were paid $200 each time, Robson said. “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 of the girl called to say she
thought the child had recently engaged in sex with a Palm Beach man. The girl
then got into a fight with a classmate who accused her ofbeing a prostitute, and
she couldn’t explain why she had $300 in her purse.
The girl gave police this account ofher meeting with Epstein:
She accompanied Robson and a second girl to Epstein’s house on a Sunday in
February 2005. Once there, a woman she thought was Epstein's assistant told the
girl,to follow her upstairs to a room featuring a mural of a naked woman, several
photographs ofnaked women on a shelf, a hot pink and green sofa and a massage
table.
She stripped to her bra and parities: and gave him a massage.
Epstein gave the 14-year-old $300 and she and the other girls left, she said, She
said Robson told her that Epstein paid her $200 that day.
Other girls told similar stories. In most accounts, Epstein’s personal assistant at
the time, Sarah Kellen, now 27, escorted the girls to Epstein’s bedroom.
Kellen, whose most recent known’ address is in North Carolina, has not been
charged in the case.
Palm Beach police often conducted surveillance ofEpstein’s home, and at Palm
Beach International Airport to see if his private jet was there, so they would...

11/11/2019
After long probe,.billionaire faces solicitation charge - News - The Palm Beach; Post - West Palm Beach, FL
from Palm Beach sanitation workers, collecting papers with names and phone
numbers, sex toys and female'hygiene products.
One note stated that afemale could not come over at 7 p.m. because of soccer.
Another said a girl had to WorkSunday - "Monday after school?” And still
another note contained the work hours of a girl, saying she leaves school at 11:30
a,m. and would come over the next day at 10:30 a.m.
Only three months before the police department probe began, Epstein donated
$90,000 to the department for the purchase of a firearms.simulator, saidJane
Struder, town finance director, The purchase: was nevermade.. The money was
returned to Epstein on Monday, she said.
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After long.,.billionaire faces solicitation charge - News - The Palm I: 
Post - West Palm Beach, FL 
from Pal:lll Beac:h sanitatfon workers, cqllect_ing pc1pers with na111e~ c1nd phone 
numbers, :sex toys and female'hygiene prod_ucts. 
One:notestated thata·female could not come over at7 p.m. because ofsoccer. 
Another said a girl had to work Sunday., "Monday after school?'' And still 
another note contained the work hours of a girl; s·aying slie leaves scho.61 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 
$9Q,000 to the.depc1rtment for the purchase ofa firec1rllls. simulatc;>r, sa:icl]ang 
Strude.r, town fjnance:dire~t_or, The purchase:wa,,s never made., The money was 
returned to Epstein on Monday, she said. 
hllps://www.palmbeachpost:com/news/20060727/after-long-probe.-billionaire-faces-solicitation-charge 
CA/Aronberg-001026 
FIL...

11/11/2019
Police^^awyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
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 Beadv Post on July
29,2006)
Famed Harvard law professor Alan Dershowitz met with the Palm. Beach County
State Attorney's Office and provided
about teenage girls
who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually
charged,massages, according to police reports.
The reports also state that another Epstein attorney agreed to a plea bargain that
would have allowed Epstein to have no criminal record. His current attorney
denies this happened.
And the documents also reveal that the father of at least one girl complained that
private investigators aggressively followed his car, photographed his home and
chased off visitors.
Police also talked to somebody who said she was offered money if she refused to
cooperate with-the Palm Beach Police Department probe of Epstein.
The state attorney's office said it presented the Epstein case to a county,grand
jury this month rather than directly charging Epstein because, of concerns about
the girls' credibility. The grand jury indicted Epstein, 53, on a single count of
felony solicitation of prostitution, which carries a maximum penalty of five years
in prison.
Police believed there was probable cause to charge Epstein with the more serious
crimes of unlawful sex acts with a minor and lewd and lascivious molestation.
Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
Krischer a memo in May suggesting he disqualify himself from the case.
https://www.palmbeachdailyhewsxom/article/20060729/NEWS/190917573:
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Police ray lawyer tried to discreditleenage,girls
News 7 Palm BeacITDaily News - Palm Beach, FL.
The case originally was going to be presented to the grand jury in February, but
was postponed after Dershowitz produced information gleaned from the Web
site myspace.com showing some ofthe alleged victims commenting on alcohol
and marijuana use, according to the police report prepared by Detective Joseph
Recarey.
Haley Robson, a 20-year-old Royal Palm Beach woman who ,told police she
recruited girls for Epstein, also is profiled on myspace.com. Her page includes
photos of her and her friends, including one using the name "Pimpin’,Made EZ."
Robson, who was not charged in the case, is a potential prosecution witness.
According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with,
Epstein, accepted the deal, in which Epstein would plead guilty to one count of
aggravated assault with intent to commit a felony, be placed on five years’
probation and have 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 deniesthere Was any
agreement by any of Epstein’s attorneys to a plea deal.
"We absolutely did not agree to a plea m this case,” he said. Neither Belohlavek
nor a state attorney's spokesman could be reached for comment.
The parent or parents of alleged victims who complained of being harassed by
private investigators provided license tag numbers of two ofthe men. Police
found the vehicles were registered to a private eye in West Palm Beach and
another in Jupiter, according to Recarey’s report.
"I have no knowledg...

11/11/2019
•
•
Polices?lawyer tried to discredit teenage girls - News - Palm BeacTOaily News - Palm Beach, FL
who did talk "will be dealt with/’ the woman said she was told. Phone records
show the woman talked with the person who allegedly intimidated her around
the time she said, Recarey reported.
Phone records also show that the person said to have made the threat then
placed a call to Epstein's personal assistant, who in turn called a New York
corporation affiliated with Epstein, the report states.
The issue in the Epstein case is not whether females came to his waterfront
home, but whether he knew their ages.
“He’s never denied girls came to the house,” Goldberger said. But when Epstein
was given a polygraph test, “he passed on knowledge, of age,” the attorney said.
After the-indictment against Epstein was unsealed this week, Police Chief Reiter
referred the matter to the FBI. “We’ve received the referral,:and were reviewing
it,” said FBI spokeswomanjudy 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 ofthe police chief.’'
Reiter has declined to comment on the case.
Prosecutors have not presented a sex-related case like Epstein’s to a grand jury
before, said Mike Edmondson, spokesman for the state attorney’s office; "That’s
what you do with a case that falls into a gray area,” he. said.
The state: attorney’s office did not recommend a particular criminal charge on
which to indict Epstein, Edmondson said. The grand’jury was presented with a
list of charges from highest to lowest, then deliberated with the prosecutor out of
the room, he said.
“People are: surprised at the grand jury proceeding/’ West Palm Beach defense
attorney Richard Tendler said. “It's a Way for the prosecutor’s office to: not take
the full responsibility for not filing the (...

11/11/2019
•
•
Police^^Hawyer tried to discredit teenage girls - News - Palm.Beact^aily News - Palm Beach, FL
Defense attorney Robert Gershman was a prosecutor for six years. "Those girls
must have been.incredible or untrustworthy, I don’t know,” he said.
Other attorneys said Epstein's case raises the issue ofwhether wealthy, connected
defendants like Epstein - whose friends include former President Clinton and
Donald Trump - are treated differently from others. Once he knew he was the
subject of:a criminal probe, Epstein hired a phalanx of powerful attorneys such as
Dershowitz and Lefcourt, who is a past president ofthe 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 atone point.
Said defense attorney Michelle Suskauer: "I think it’s unfortunate the public may
get the perception that with power, you may be treated differently than the
average Joe."
https:Wwww.palmbeachdailynews.corn/article/20060729/NEWS/i909i7573
4/4
CA/Aronberg-00.1030
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11i1112019 
Poiic.wyertried to discredit teenage girls - News - PainfBea.y News • Palm Beach, FL 
Defense attorney Rob.ert Gershman was a ;prosecmtor for six years. "Those girls 
must have been.incredible or untrustworthy, I don't know," he said. 
Other attorneys said Epstein's case. raises the .issue of whether wealthy, connected 
defendants like Epstein - whose friend~- include forrner Presidt!ntCli_ntpn ,_md 
Donald T ruinp - are treated differendy from qthers. On_ce he knew he· was the 
subjec_t ofa criminai probe, Epstein hired a phalanx ofpowedul attorneys such,as 
Dershowitz and Lefcourt, who is a past president ofthe National Association of 
Crirhina] Defense Lawyers. 
Miami lawyer Roy Black - vvho became nationally known when he successfully 
defended William Kennedy:Smith o...

TheBata Beachfest
REALNEWSSTARTSHERE
Expert: Ignorance of age isn’t
defense in sex cases
Posted Aug 5. 2006 at 12:01 AM
Updated Oct 3,2019 at 1:38 PM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on Aug. 5,2006)
Even if Palm Beach money managerJeffrey Epstein didn?t
know that girls. who police say gave him sexual massages at
his Intracoastal home were under the legal age, that alone
wouldn’t have exempted him from criminal charges of
sexual activity with minors.
“Ignorance is not a valid defense," said Bob Dekle, a legal
skills professor who was a Lake City prosecutor for nearly
30 years, half of that time specializing in sex crimes against
children,
“There is no knowledge element as far as the age is
concerned," Dekle said.
After an 11-month investigation, Palm Beach police .said
there was probable cause to charge Epstein, 53, with
unlawful sex acts with a minor and lewd and lascivious
molestation. They contend that Epstein - friend of the rich
and famous and,financial patron of Democratic Party
organizations and candidates - committed those acts with
five underage girls.
In the past week, New York Attorney General and
gubernatorial candidate Eliot Spitzer has returned about
$50,000 in campaign contributions: he received,from
Epstein,, arid Mark Green, a candidate to replace Spitzer in
CA/Aronberg-00,1031
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The: PalnI Bt1a:ch Post 
.• • : . ;, , ·."':k~~:N_EWSSTA~Hatf : ~: '~ 
•.. '. 
E.1<pert: lg.ngran«:J ;r,f :~gQ~ isal't 
,:dJe:f:tu1se: In:: sex·:c·ase.s 
Posted i'.\ug 5; 2006 at-12:01 AM 
Updatgd Oc;t ~. 2019 at 1 :~8 'PM 
(EDITOR'S NOTE: This story originally published in The_ 
Palm Beach Post on Aut 5, 2006) 
Even if Palm Beach money manager Jeffrey Epstein didn't 
'know that girls,who police s_;1.y gave hi:m sexu_;1.l massages at 
his Intra coastal home were under the legal age, that alone 
wouldn't nave exempted him...

his current job, has returned S10,000 to'him because of the
Palm Beach scandal, the New York Daily News has
’
reported.
Rather than file charges, the state attorney’s office
presented the case to a county grandjury. The panel
indicted Epstein last-week oh a single, less serious charge of
felony solicitation of prostitution.
The case raised eyebrows because the state attorney’s office
rarely, if ever, kicks such charges to a grand jury. And it
increases the difficulty of prosecuting child sex abuse cases,
especially when the defendant is enormously wealthy and
can hire high-priced, top-tier lawyers.
At least one of Epstein’s alleged,Victims told police he knew
she was underage when the two of them got naked for
massages and sexual activity. She was 16 years old at the
time and said Epstein asked her questions about her high
school, according to police reports.
A girl who said she met Epstein when she was 15 said he
told her if she told anybody what happened at his house,
bad .things could happen, the police reports state.
Epstein’s youngest alleged victim was 14 when she says she
gave him a massage, that included,some sexual activity. She
is now 16. The girl's father says he doesn’t know whether
she told Epstein her age.
“My daughter has kept a lot of what happened from me
because of sheer embarrassment,” he said, "But she very
much looked 14. Any prudent, man would have had second
thoughts about that.”
Defense 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/Aronberg-00.1032
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CA/Aronberg-0O1032 
• 
• 
his rnrrent job,, has returned $10,000to:h:im because of,:he 
. 
I 
Palm ,Beach scandal,...

"A prosecutor has to look at it in a much broader fashion,” a
state attorney's spokesman said last'week.
! NTElMGENT QR©
f
Epstein hired Harvard law Professor Alan Dershowitz
when he became aware he was under investigation, and,
Dershowitz.gave prosecutors information that some ofthe
alleged victims had spoke of using alcohol and marijuana on
a popular Web site, according to a Palm Beach police
report.
Prosecutors typically consider two things in deciding
whether to charge somebody with sex-related offenses
against minors - whether there is sufficient evidence and
whether there is a public interest in doing so, Dekle said.
If two teens are in a sexual relationship and the boy turns
18 before the girl, he could be charged with a sex crime'if
the sex continues. There would be no public interest in
pursuing that, Dekle.said.
But where there is a large gap in ages - and especially in.
cases of teachers with students - there is a public interest in
prosecuting, he said. Likewise if the accused has a track
record,of sex with minors.
CA/Aronberg-00.1033
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• 
• 
"A prosecutor has to look at it in a much broader fashiori," a 
~t.ite attorney's spokesman said last'\veek. 
Epstein hired Harvard law Professor Alan Dersho:witz 
whel} he._peaJ.m.e ;iware h~was under investigation, artd. 
Dershowitz,gave prosecutors information that some of tp.e 
alleged victims had spoke of using afcohol and marijuana o.n 
a pop',!lar Web site, according to a Palm Beach police 
report, 
Prosecutors typically consider two things in .deciding 
whether to charge somebody with sex:..relate<l offenses 
against m1110.rs -whether there is sufficient eVidertte ahd 
whether'there is a,public interest in doing so, Dekl~ s.;,tid. 
Iftwo teens are in a sexual rdationship. and the .boyt!-]rns 
1'8. before the girl, he could be charged with a sex crime'if 
the sex c:.o.ntlnue~. Th.ere wquld.be no p...

Still there is a "universal constant” in prosecuting these
cases, Dekle said. Men who exploit underage children for
sex often carefully choose their victims in ways: that Will'
minimize the risk to them, he said.
Victims usually are from a lower social status, and they may
suffer from,psychological problems, Dekle said.
"Lots of child sexual abuse victims have been victimized by
multiple people over a period of time. Then the act of abuse
produces behavior in the victims that further damages their
credibility.” Examples include promiscuous behavior and,
drug abuse.
Some ofthe 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-00.1034
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---• 
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-• 
Still th.ere is a "universal const_.1nt" in prosecuting these 
cases, Dekle said. Men wli.o exploit underagechilclrenfo:r 
sex often ,carefully choose their victims in ways that will
1 
minimize...

•
•
TheMm Beach Post
REALNEfcSTARTSHERE
EpsteincampcaHs female accusers
liars
Posted Aug 8,2006 at 12:01 AM
Updated Oct 3,2019 at 3:35 PM
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on Aug. 8,2006)
Attorneys and publicists for Palm Beach financierJeffrey
Epstein went on the offensive Monday, contending that
teenage:girls who have accused Epstein of sexual
shenanigans at his waterfront home are liars and saying
that the Palm Beach Police Department is “childish.”
"There never was any sex between Jeffrey Epstein and any
underage women,” his lead attorney, Jack Goldberger, said
from Idaho where he was vacationing with his family.
Epstein did have young women, come to his house to give
him massages, Goldberger said; "Mr. Epstein absolutely
insisted anybody who came to his house be over the: age of
18, How he verified that, I don't.know. Thequestionis, did
anything illegal occur. The law was not violated here,”
He had no explanation as to why Epstein would pay girls or
women with no massage training - as the alleged victims,
said was the case - $200 to $300 for their visits. “The
credibility of these witnesses has been seriously
questioned,” Goldberger said.
Epstein, 53, was indicted by a county grand jury last month
on a charge of felony solicitation of prostitution. After an
1 Umonth investigation thatincluded sifting- through
Epstein’s trash and surveilling his home, Palm Beach police
concluded there was enough evidence to charge him with
sexual activity with minors. When the grand jury indicted
CA/Aronberg-00.1035
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CA/ Aronberg-00.1035 
;Ep.ste.in c·~_mp~:e·ans.·no1lale: }~'C,«;Us·e_rs 
liaJts 
Po.sted Aug 8, 2006 at 12;01 AM 
Updci,eq Oct 3, 2019 aq~35 PM 
(EDttOR'S NOTE: This story originally published in The 
Palm Beach Poston Au$, s; 2006) 
Attorneys and publicists for Palm Beach financier Jeffrey 
Epstein went Qnthe offensive Monday, c:ontendi...

9
•
Epstein on the less serious charge, Police Chief Michael
Reiter referred the case to the FBI to determine whether
there were federal law violations.
After a spate of stories about the case last week?, New York
publicist Dan Klores - whose client list has included Paris
Hilton and Jennifer Lopez - said on Saturday that Epstein’s
camp was ready “to get their story out.”
They did that Monday via Goldberger and a Los Angeles
publicist for Miami criminal defense attorney Roy Black,
who also has represented Epstein in the case.
"We just-think there has been a distorted view of this: case
in. the media presented by the Palm Beach police)”
Goldberger said.
Reiter has consistently declined to comment on the case
and did 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 charges1 directly against him is wrong,
Goldberger said.
CA/Aronberg-001036
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CA/Aronberg-0O103.6 
• • 
• 
• • • •  
Epstein on the Jess serious charge, PQli\:=e Chief Mic_hg,eJ_ 
Reiter referred the case to the FBI to dt!termine whether 
there were federal law violations. 
After a spate of stoties ·about the case last week, New Y~rk 
pµblidstDan l\.lores - whose client list has included· Paris 
Hilton.andJennifer;LC>pez - said:on Saturday that :Epstein's 
camp was ready "to:get their story oue' 
They did that Monday via Goldberger and a: Los AngeJc·s 
publicistfor Miami ~rhninal defense attorney Roy 13lack, 
who.also has represented,Eps_teinintht! 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 dedine_d to ,c_omment on the c~s_e 
and did not tespond to a request for comment Monday: 
The implication: that State Attorn:ey·Barry Kristher was 
easy on Epstein by presenting the cas...

•
•
The Palm Beach Police Department was happy and
ecstatic” that the panel was going to review the evidence. "I
think what happened is they weren’t happy with the result.
They decided to use the press to embarrass: Mr. Epstein.”
But records show that-Reiter wrote Krischer on May 1 -
well before the case went to the grand jury - suggesting that
Krischer "consider if good and sufficient reason exists to
require your disqualification from the prosecution ofthese
cases.”
Rather than flat-out decline to charge Epstein, Krischer
referred the case to the grand jury to "appease” the chief,
Goldberger said.
A state attorney’s spokesman would say only that the office
refers cases to the grand jury when,there are issues with the
viability ofthe evidence or witnesses’ credibility.
Bpththe 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 fbr sexual massages?
"I don’t-have an answer aS to what was the motivation for
these women to come forward and make these allegations,"
Goldberger said.
CA/Aronberg-001037
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. . 
-
' • 
The '.Palm l3each Pplic~· Department was "happy· ;md 
ecstatic;' thatthe·panelwasgoingto review the.evidenct!. "I 
think what happened is theywere·n't happy with the res tilt. 
They decid~d to use the press to embarrass Mr. Epstein." 
l3ut _records sliow that·Reitenvrote Krischer on M'ay 1 -
w...

The Palm Beach Post (West Palrn’Beach, Florida)
• 14 Aug 2006, Mon • Page7
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Reiter focus of fire in Epstein case
Clipped By:
' .O'
relter_m
Sat, Apr 22, 2017
Copyright © 2019 Newspaperslcom. All Rights Reserved.
Mew^
CA/Aronberg-00.1038
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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• 
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The Palm Beac_h Post·(West Palm·Beach, Florida)· 14 Aug 2006, Mon· Page 7, 
Downloaded on Nov.11.2019 
Reit~r focus of fire in Epstein case 
, .relte_r_m 
.Sat, Apr 22; 20·17 
Copyright© 2019 Newspapers:com. AU Ri[!hfs Reserved .. 
CA/Aronberg-00.1038 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

TheTata Beach Post
REALHEWSSTARTSHERE
Belays in Epstein ease 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 Bcacher’s solicitation case.
Nearly eight months after Palm Beach tycoon Jeffrey
Epstein was charged with felony solicitation of prostitution,
there has been no discernible progress in his case. No
witnesses deposed. No trial date set. Nothing, save for
routine court hearings reset without explanation.
"Usually that would be unusual," said criminal defense
attorney Glenn Mitchell, who has no involvement in the
case.
"As a general rule, it would be unusual for nothing to have
happened,” agreed Michael Dutko, a criminal defense
attorney in Fort Lauderdale. He represents Haley Robson,
20, of Royal Palm Beach, potentially a key witness in the
case.
A routine hearing for Epstein was pulled from the court
docket last week and reset for May 16. The delays arid
inaction could be due to a potential federal probe of Epstein
or because a plea deal is in the works, attorneys say.
Unusual is the word that best describes everything about
the case against Epstein, .54, an enigmatic money manager
in New York.City who counts Bill Clinton and.Donald
Trump among his friends.
CA/Aronberg-001039
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CA/Aronberg-001039 
D:~1a·ys ib:Epst~Jn :c:ase,, un11stoU, 
hiw;yets say; 
Posted Mar 13, 2007 at 12:01 AM 
Updated Oct 3, 2019 at.3:Mi PM 
(EDITOR'S NOTE: This story originally pub'lished in The Palm 
J?eqch Posl AfqrGh J3: 2007) 
A federal probe or a plea de.al ·could explain thewait:in the 
Palm Beac:her's solicitation case; 
Nearly eight months after Palm Beach tycoon Jeffrey 
Epstefo was charged with felony solicitation ofprQstitution, 
there has been no discernible. progress in his case. No 
witnesses depo...

"Highly unusual” is how Palm Beach Police Chief Michael
Reiter described State Attorney Barry Krischer’s handling
of the case in a bluntly critical letter to Krischer last year
before Epstein was indicted.
,
Reiter referred the matter to the FBI to determine whether
any federal laws had been violated. Epstein’s allies
countered by attacking the chief personally and
professionally.
Reiters department investigated Epstein for 11 months.
Police sifted repeatedly through his trash and conducted
surveillance on his five-bedroom, 7 1/2-bath, 7,234-square-
foot home on the Intracoastal Waterway.
Police said Epstein paid women and girls as young as 14 to
give him erotic massages at his home. Police thought there
was probable cause to charge him with unlawful sex acts
with a minor and lewd and lascivious molestation.
Epstein responded by hiring a phalanx of lawyers. One of
them, Harvard law professor and author Alan Dershowitz,
provided the state attorneys office with information about
alcohol and marijuana use by some of the girls who said
they were with Epstein.
Prosecutors then referred the case to the grand jury rather
than file charges directly, against Epstein.
Epstein's attorneys deny he had sex with underage girls.
The lawyers say the girls’ stories are not credible, But .if the
court file is any indicator,, they’ve made no effort to depose
the girls.
Neither prosecutors nor defense attorneys have sought to
question Robson, said Dutko, her attorney. She recruited
teenage girls to visit Epstein for, massages and sexual
activity, Palm Beach police said, and presumably would be a
key witness.
CA/Aronberg-00.1040
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I 
• 
e! 
"Highly unusual" is how Palm Beach Police,ChiefMicl)a~I 
Reiter descr(bed State. Attorne.yBarry .K.rischer's handling 
of the .case jn a :bluntly critical letter to Kris ch er last year 
i 
before Epstein was indicted. 
Reiter referred th...

Epstein s attorneyJack Goldberger did not return phone
messages.
A source close to the case suggested it is languishing
pending a decision by the FBI on whether to refer it,to
federal prosecutors.
“We still have a pending case,” FBI 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
riot 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 dealfor 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/Aronberg-00.1041
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• 
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. . . •  
i 
.Epstein s attorney JacikGoldberger did.n9t return phon¢ 
messages. 
A source. close to. the case suggested it:is languishing 
pertding,a decision hy the FBI on whether to refer itto 
federaL prosecutors. 
"We·still have apen_ding case," FBI spokeswomanJudy 
Orihuela said Monday. 
State Attorney· Ktischer did...

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/Aronberg-00.1042
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•• • 
• 
• 
• 
• •• 
Edmondson, spokesman for State Attorney Krisc.,her, satd 
there -is no ·plea offer and no request for the prosecution to 
showits cards. 
"To.my knowledge, it's,neverhappenedbefore on a filed 
c:ase," he said. 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

252 / 278 - Thursday, O.ctober 18, 2007
Edition: FINAL
Section: LOCAL
Page: 5B
Source: The Associated Press
Illustration?PHOTO (B&W)
Memo: Ran all editions.
Dateline: NEW YORK
WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16
A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage
prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had
sought his help becoming a model.
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financierJeffrey Epstein had
the teen perform a sex act when she brought photographs of herself for him to review in his Upper
East Side mansion sometime in 2000.
Epstein,. 54, a money manager, told the teen he managed finances for Victoria's. Secret and "could get
you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice"
included massages and. other favors.
When the girl told.Epstein, "I am 16 years old and just want to model," he replied, "Don't worry, I
won't tell anybody," court papers say.
Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been
indicted in Palm.Beach on charges of soliciting underage prostitutes. That case is pending.
The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural
sex acts” while she was a minor, the lawsuit says.
Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends,
stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her
40s). 1 love girls your age.'
"
The young Woman,.now 23, kept returning to Epstein because she has "mental issues," said her
lawyer. William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result
of severe mental disease and defect."
Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can
read...

TheMmBeach 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 onJuly 1,2008)
Jeffrey Epstein will serve 1 1/2 years on teen solicitation
charges,
He lives in a Palm Beach waterfront mansion and has kept-
company with the. likes of President Clinton, Prince.
Andrew and Donald Trump, but investment bankerJeffrey
Epstein will call the Palm Beach CountyJail home for the
next 18 months.
Epstein, 55, pleaded guilty Monday to felony solicitation of
prostitution arid procuring a person under the age of 18 for
prostitution, After seiying 18 months in jail, he will be;
under house arrest for a year. And he will have a lifelong
obligation to register as a sex:offender. He must submit to
an HIV test within 48 hours, with the results being
provided to his victims or their parents.
As part of the plea deal, federal investigators agreed to drop
their investigation of Epstein, which they had taken to a
grand jury, two law enforcement sources said,
Epstein was indicted two years ago after an 11-month
investigation by Palm Beach police. They received a
complaint from a relative of a 14-year-old girl who had
given Epstein, a naked massage at his five-bedroom, 7,234-
square-foot, $8.5 million Intracoastal home.
Police concluded that there were several other girls brought
in 2004 and 2005 to an upstairs room at the home for
similar massages and sexual touching.
CA/Aronberg-00.1044
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CA/Aronberg-00.1044 
.P-ann _Beacb,er :ple:~ds ln ,s,X: :e,iise
1 
, 
Poste9_ Jul, 1, ZOOS at 1_2:0J AM 
Updated dct 3, 20i 9 at 1 :47,PM 
{EDITOR'S NOTE: This s,tory originally published in The 
Palm Beach Post on}uly 1, 2008) 
Jeffrey Epstein will serve ,1 1/2 years on teen solicitation 
charges. 
He li_ves in a Palm Beach waterfront mansion ang has _kept. 
company with the, likes ...

The indictment charged Epstein only with felony
solicitation of prostitution. The state attorney’s office later
added the charge of procuring underage girls for that
purpose.
Prosecutor Lanna Belohlavek said ofthe plea: "I took into
consideration the. length the trial would have been arid
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 rib 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-00.1045
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• 
• 
• • •  
The indictment charged 'Epstein only with felony 
solicitation ofprostitutiol'i. The state attorney's office later 
,added the charge of procuring underage girls for that 
pt1rpo...

When he is released fromjail, there is a chance that Epstein
will be forced to move. Sex offenders are not allowed to live
within 1,000 feet of a school, park or other areas where
children may gather. No determination has been made as to
whether Epstein’s home complies, but attorneys said it
likelydoes.
Sex offenders also typically must attend counseling sessions.
Belohlavek said that was. waived for Epstein because his
private psychiatrist is working with him. The judge was
skeptical but agreed to it.
Epstein’s legal woes don’t end with Monday’s plea. There
are four pending federal civil lawsuits and one in state court
related to his behavior. At least one woman has sued him in
New York, where he owns a 51,000-square-foot Manhattan
mansion.
“It’s validation of what we’re saying in the civil cases,” said
Miami 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 lie 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 8200 to 8300 each after the massage:
sessions.
Tm like a Heidi Fleiss,” Haley Robson, now 22, told police
about her efforts in recruiting girls for Epstein,
There was probable cause to charge Epstein with unlawful
sex acts with a minor and lewd and lascivious molestation,
police concluded.
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• 
When heJs released from:jail, there is-a chance that Epstein. 
will be forced to move. Sex offenders are not allowed to live 
within 1,QOO feet qf a school, pru:-lc or other: ;ire~s where 
chiidren may gather. No-determination has bee...

The state attorney’s office said questions about the girls’
credibility led it to take the unprecedented step of
presenting the evidence against Epstein to a grand jury,
rather than directly charging him.
Palm Beach Police Chief Michael Reiter was furious with
State Attorney Barry Krischer, saying in a May 2006 letter
that the prosecutor should disqualify himself. "I continue to
find your office’s treatment of these cases highly unusual/’
he wrote. He then asked for and.got a federal investigation.
Epstein hired a phalanx of high-priced lawyers - including
Harvard law professor and author Alan Dershowitz - and
public relations people who questioned Reiter’s competence
and the victims’ truthfulness.
In addition to mansions in Palm Beach and Manhattan,.
Epstein owns homes in New Mexico and the Virgin Islands.,
He’s a frequent contributor to Democratic Party candidates.
He also donated $30 million to Harvard in .2003.
Former New York Gov. Eliot Spitzer returned a $50,000
campaign contribution from Epstein after his indictment,
then resigned this year during his own sex scandal. And the
same Palm Beach Police Department that vigorously
investigated Epstein returned his $90,000 donation for'the
purchase of a firearms,simulator.
Staffwriter Eliot Kleiriberg arid former staff researcher
Michelle Quigley contributed to this story.
i
CA/Aronberg-00.1047
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CA/ Aronberg-00.104 7 
• 
The state attorney's office said questions about the girls:· 
credibility led it to take the unprecedented step of 
pr!;:!senting the, evid~nce against Epstein to a grand jury,, 
rather than directly charging him. 
Palm Beach Police ChiefMichael Reiter was furious with 
State Attorney Barry Krischer, saying iri a May 2006 letter 
that th(;! pros_ecutor should di_squalify himself. "1 coptinue to 
find your office's tteat:trren:t of these cases highly unusµal/" 
.he wrote. He then asked fot and got aJederal f...

The.Fata Beach Bost
REALNEWSSTARTSHERE
Jeffrey Epstein: Scientist,
stuntmen; ‘sexsUa've’visitjaiBed
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 youngwomen, before,he got
into trouble for paying teenage girls to give him sexual
massages at his Palm Beach mansion.
Not much has changed, even though he now resides in a
dorm at the Palm Beach County Sheriffs Office's 17-acre,
967-bed stockade near the fairgrounds.
During his first month of confinement, Epstein was visited
by the female assistant who, girls told police, had escorted
them to the room at his mansion where they gave him
naked massages.
Also trekking to the jail was a young woman whom Epstein
purportedly described as his Yugoslavian sex slave.
The wealthy financier and science wonk also has been
visited by an expert on artificial intelligence, as well as a
man who is a mixed martial arts aficionado and sometime
movie stuntman.
The only other people to visit him at the jail, according to
records, are a Singer Island man and an individual who
listed Epstein's Palm Beach address as his own.
Epstein, 55, pleaded guilty 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-00.1048
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letfr.~y.·_:f:rlsl~ill= ·Sci~n'Jist~. 
·stu·ntman\ 'se~ ·shiv.et :vis~it'j'.alled; 
tY~iJQht' 
By LARRY KELLER lPalm 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, 1ncluding beautiful young·women, before:he got 
into trouble for paying teenage girls to ·give him s_exual 
massages at his Palm Beach mansion. 
Not much has changed, even though he. now resides in a 
...

girls $200 to $300 in 2004 and .2005 for massages in his
home that sometimes included.sexual touching, Palin 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 familyin Yugoslavia
Epstein paidmoney 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 2.003.. He became; “chieflearning officer” at.the
online Trump University in 2005. Schank listed his address
as being in Stuart, and records show he also owns a home
in Lake Worth.
CA/Aronberg-001049
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• 
• 
girls ·$200 to $300 in 2004 and .2005 for massages in his 
home that sometimes included. sexual touching, P'alm Beach 
polic;e sald, 
His jail visitors inJuly included: 
- Sarah...

CA/Aronberg-001050
Epsteinhas financed a number of scientists over the years,
including Nobel Prize winners. He gave $30 million to
Harvard University in 2003. In November, he formed the
not-for-profit Florida Science Foundation, which he said
finances scientific research.
- Igor Zinoviev, a Russian mixed martial arts fighter, who
coaches a Chicago team in the International Fight League.
He also has worked as a personal trainer, celebrity
bodyguard and movie stuntman, according to the league’s
Web site. The New Jersey resident visited Epstein seven
times in July.
Zinoviev, Schank and Mar.cinkova could not be reached for
comment.
Staff researcher Niels Heimeriks contributed to this story,.
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I 
I 
Epste~ financed a number of scientists over !~s, 
1ndu9,ingNobel Prize winners, He gave $30 m..iJlio)J.to . 
Harvard University in.2003. In November,heformedtfe 
hoVJor'"ptofit Florida Science Foundation, which he sa+d 
finances scientific research. 
- Igor: Zinoviev, a Russ1an.mixed martial arts fighter, who 
coaches a Chicago team in the' Internati.onal Fight L.eagµe. 
He also haswotked as a.personal trainer, celebrity 
bodygµard ;3.n,dmoyie stuptqian, according to the league's 
Web sit!:!. The:NewJersey resident visited Epstein sE:!ven 
times in July. 
Zinoviev, Scharik and Marcinkova could not be reached for 
comm~nt. 
Staffresearch~r Niels Hdme:riks cQntr1butE:!d; to this story. 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

felmtechMIf News
;
i
Bi1Iionaire sexoffensier leaves jail
six days aweek forwork
Posted Jul 1.2008 at 12:01 AM
Updated Oct 4,2019 at 9:27 AM
Palm Beach billionaireJeffrey Epstein, who’s serving 18
months in jail for soliciting an underage girl for
prostitution, is allowed to leave the Palm Beach.County
Stockade six days a week on a work-release program.
Teri Barbera, spokeswoman for the Palm .Beach County
Sheriffs Office, confirmed that Epstein, 55, has'been in the
work-release program since Oct. 10.
"He works six days a week: Friday through Wednesday 10
a.m. to 10 p.m.,” Barbera said via e-mail. ”(He) works at his
local West Palm Beach office, monitored on an active GPS
system (he wears an ankle bracelet), Mr. Epstein hires a
permit deputy, at his expense, for his own security at his
workplace, during the time he is out.”
Miami attorneyJeffrey Herman represents six young
women who ve sued Epstein, claiming he sexually abused
them at his Palm Beach home when they were minors.
Herman said he received a letter about the work-release
program from the U.S. Attorney's Office within the.past
few days. But Herman says Epstein had. been out on work¬
release for several weeks before the notification.
“My clients expressed shock and disappointment,” Herman
said. “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/Aronberg-00.1051
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B,iUi'q1,1ajie s~x;·:siff~nde)~ :1~·":v . .,s=jail 
six; :da, s ~tw.a:fe]tlor: \WO'tk-· 
--·-- .... _Y,_ ... -
·: ... ·• ·-
___ ,., ....... . 
l?ost~d Jul 1, 20.08.at 12:01 AM 
Updated Oct 4, 2019 af 9:27 A.M 
Palrn Beach billjqnaire j effrey Epstein, who's serving 18. 
months in jail for soliciting an 'tmdera~e girlfor-
prostittition, is allowed to leave the Palm Be<!-ch.County 
Stoc...

arrangement is not unusual.
"He goes to work every single day and,goes back to jail at
night, just like everybody else (in the program),”
Goldberger said.
Epstein pleaded guiltyJune 30 to two felony counts:
soliciting prostitution and procuring a person under 18 for
prostitution. As part ofthe plea agreement, Epstein must
serve one year of house arrest and register as a lifelong sex
offender.
CA/Aronberg-00.1052
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• 
• 
arrangeme11t is no_tu11_usual. 
"He: goes to work every single day and, goes _back to jail a,t 
ni~ht,justlike everybody eise (in the program)," 
Goldberger said. 
Epstein pleaded.guiltyJune 30to two felony cou!).ts: 
solid ting prostitution and procuring a p<:1rson,under- l8' for 
prostitution.- As part of the plea agreement, Epstein must 
serve one year of house arrest and register as a lifelong sex 
offender. 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

The’Whn>e®ch Bast
REALNEWSSTARTSHERE
I
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 so itwas.
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.
CA/Aronberg-001053
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CA/ Aronberg-0O1053 
-
. 
I 
i\AJQ:ment '.Vif~Pl Epstebr.s~x ,p'le,; :d,al 
:urtstulled: 
.. -
.,. .,.,. - -·,. ,-
Posted Jul 1, 2008 at 12:0l AM' 
Updated 0d 2; 2019 af2:23 PM 
(EDITOR;S NOTE: This story originally published in The 
Palm Beach Post June 10, 2009) 
Their attorneys will ask a judge to openJeffr~yEp$tein's 
records. 
When wealthy money manager Jeffrey Epstein: of Pa:im 
Beach pleaded guilty last year to procuring teens for 
prostitu.tion,his case det9ured a,roundlqcal and state rnles_ 
regarding the ,sealing -of co_urt documen:ts. 
At a plea conference: on the .state charges, a jtidge, a defense 
lawyer and a prosecutor huddled at the bench and decided 
th.at ...

Epstein sown attorneys, in federal filings', have referred to
his confidential deferred prosecution agreement with the
U.S. attorney’s office, struck in September 2007, as
"unprecedented” and "highly unusual.” And it was "a
,
significant inducement” for Epstein to accept the state’s
■
deal, observed the state judge who accepted his plea,
CountyJudge Deborah Dale Pucillo.
Epstein now faces at least a 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 ofthose women want his agreement
with federal prosecutors unsealed and will ask CircuitJudge
Jeffrey Colbath to do so today.
"It.is against public policy for these documents to be have
been sealed and hidden from public scrutiny. As a member
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 ofthe 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/Aronberg-00.1054
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.! 
Ep,tei!wn attorneys, in federal fiiings; h:ave referred to 
his confldential deferred prosecution ,agr.eemeht with the 
U.S. attorney's office, struck in September 2007, as 
"un...

During a Palm Beach Police Department investigation, five
victims and 17 witnesses gave statements. They told of
young women brought by his assistants to Epstein’s
mansion on El Brillo Way for massages and; sexual activity,
and then being paid afterward.
At Epstein's plea conference last year, his -attorney, Jack:
Goldberger, and.then-Assistant State Attorney Lanna
Belohlavek approached Pucillo in a sidebar conference.
Pucillo, who had left the bench nine years earlier, was
filling in temporarily as a senior judge.
According to a transcript, Goldberger told Pucillo that
Epstein had entered a confidential agreement with the U.S.
attorney’s office in which federal prosecutors brokered not
pursuing charges against him if he pleaded guilty in state
court. Pucillo then said she wanted a sealed copy of the
agreement filed in his case, and Goldberger concurred that
he wanted it sealed, Belohlavek later signed off on it.
The Florida Supreme Court has expressed "serious concern”
arid launched an all-out:inquiry into sealing procedures
across the state followingmedia 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.
i
CA/Aronberg-001055
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CA/Aronberg-0O1055 
• 
• 
During a Palm Beach Police Department investigation,Jive 
victims a,nd 17 witp.es~es gave sti:lten1ents. Tpey tqlcl of 
young women broughtbyhis,assistants to Epstein's 
mansion on El Briilo Way for massages and, sexual activ.ity, 
and then being paid afterward. 
At Ep~tein's plea coµference lastyear, :his ,attor11ey, Jack: 
Gqldb~rger, and;then-Assistant State Anorney Lanna 
Befohlav...

The PalmBeach Bast
REALNEWSSTARTSHERE
Epstein secret
reveals “highly unusual” terms
Posted Jun 10,2009 at 12:01 AM.
Updated Oct 4,2019 at 9:23 AM
(EDITORS 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-severalfederal crimes, including
engaging minors in commercial sex. The crimes are
punishable by anywhere from 10 years to life in prison.
But federal prosecutors backed down and agreed to recall
grand jury subpoenas if Epstein pleaded guilty to
prostitution-related.felonies in state court, which he
ultimately did; He received an 18-month jail sentence, of
which he served 13 months.
The U.S. Attorney's Office also agreed not to charge any of
Epstein’s possible co-conspirators: Sarah Kellen, Adriana
Ross,. Lesley Groff and Nadia Marcinkova.
The deal was negotiated in part by heavyweight New York
criminaldefense attorney Gerald Lefcourt.
Unsealed on Friday after attorneys for some ofEpstein.'s
victims and The Palm Beach Post sought its release, it offers
the first public look at the deal Epstein’s high-powered legal
counsel brokered on his behalf.
CA/Aronberg-00.1056
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CA/ Aron berg-0O1056 
f pste'i:n: se.c.re,t;p'a~t. with,: teds 
r.eveals "hl • hi ··• urui-su:af'·terms, 
,'" . , . _g., .Y 
. , 
. .·. . . 
, , 
Posted Jun 10, 2009 at 12:01 AM. 
Updated Oct 4, 2019 at 9:23 AM 
(EDITQR;S NOTE: This story origina'lly published'ln The 
Palm Beach Post on September 19, 2009) 
A s~cret non ..:prosecution ~greement multimillionaire 
financier Jeffrey Epstein struck withfederal prosecutors is 
being called "highly...

MarkJohnson of Stuart, a former federal prosecutor,
described the disparity in potential sentences as unusual,
but even more so a provision on attorney payment.
The first draft of the agreement in September 2007
required that Epstein pay an attorney — tapped by the U.S.
Attorney’s Office and approved by Epstein -- to represent
some of the victims. That attorney is prominent Miami
lawyer Bob Josefsberg.
But an addendum to the agreement signed the following
month struck Epstein’s duty to payJosefsberg if he and the
victims'did not accept settlements — capped.at SI 50,000 —
and instead pursued lawsuits.
Johnson.said it appears the government was trying to
balance the lesser sentence for Epstein with recovering
SI50,000 for each victim. “I’ve never, ever seen anything
like that in my life,” he said. TVs highly unusual.”
The deal does not say whether any victims were contacted
of consulted before the deal was made.
Attorney Brad Edwards of Fort Lauderdale, who represents
three of the young women, believes that none of the 30 to
40 woman identified as victims in the-federal'investigation
were told ahead oftime. Edwards said his clients received
letters from the. U.S. Attorney’s Office months after the deal
was signed, assuring them Epstein would be prosecuted.
"Never consulting the victims is probably the most
outrageous aspect of it/’ Edwards said. “It taught them that
someone With money can buy his way out of anything. It’s
outrageous and embarrassing for United States Attorney’s
Office and the State Attorney’s Office.”
Epstein now faces many civil lawsuits filed by the women,
who are represented by a variety of attorneys. In many, the
allegations are the. same: that Epstein had a predilection for
teenage girls, identified poor, vulnerable ones and. used
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.• 
. 
. 
.: 
Mark~son of Stuart, a former federal prosecutor, 
described. the di...

other young women to lure them to his Palm Beach
mansion. They walked away with between. $200 and
$1,000.
:
.
i
Former CircuitJudge Bill Berger, also representing victims,,
called the agreement a "sweetheart deal,”
"Why was it so important for the government to makethis
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 arid avoid federal
prosecution.”
The backroom deal with federal prosecutors is all the more
interesting in.light ofthe legal powerhouses who have
worked for .Epstein, including Harvard professor Alan
Dershowitz and Bill Clinton investigator Kenneth Starr.
Lefcourt is a past president of the National Association of
Criminal Defense Lawyers.
Epstein’s local defense attorney, Jack Goldberger, issued a
statement Friday saying he had fought the release ofthe
sealed agreement to protect the third parties narried there;
"Mr. Epstein has fully abided by all of its terms and
conditions. He is looking forward to putting this difficult
period in his life: behind him. He is continuing his long¬
standing history of science philanthropy.”
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other yoqng women to lur.e them to his Palm Beach 
man:sion. They walked away with betwe.e1t$20Q and 
$1;000. 
I 
. 
. 
. I 
Former Circ:uitJudge Bill Be...

The investigation triggered tensions between police and.
prosecutors, with then-Palm Beach Chief Michael Reiter
saying in a May 2006 letter to then-State. Attorney Barry
Krischer that the chiefprosecutor should disqualify himself.
“I continuelo 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 ofwhat a
many-million-dollar defense can accomplish,” Reiter told
the. Palm Beach Daily News upon his retirement.
I
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. 
.i 
The investigation trigge:recl tensio-qs betwe~n_poljce and. 
prosecutors, with then:-PalmBeach.Chief Michael R~ite,r 
saying in a May 2006 letter to then-State Attorney Barry 
Kris ch er that the chief prosecutor should disqualify himself.,, 
. 
I 
"I conti_nue'to find your office's treatment of these-cases 
highly unusual/ Reiter wrote; He"the11 asked for anci got 
the· federalinvestigation that ended in the sealed de.al. 
"The Jeffrey Epstein matter was an experience of what a 
many-million-dollar defense can accornplish," Reiter told 
the; Pafm Beach Daily News upon his retirement. 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

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,: ajudge
Tuesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to
subpoena abortion records from women who are, seeking millions in damages froth 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 c.ouldn'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 ah 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 vyomen 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 arc protected by our constitutional right of privacy," he said, referring to the
Florida Constitution.
After the hearing, Silver said an appeal won’t be necessary until,Epstein attorneys seek the
records.
In another ruling Wednesday, Hafele also said that videos from depositions in the state cases
can't be released without a court order. The ruling came after Epstein attorney Robert Critton
complained that a video of Epstein being asked whether he ha...

TheMmBeach Bost
REALNEWSSTARTSHERE
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.
Epstein Journal’s Findings Could
Resurrect Case
By Jane Musgrave
Posted Sep17,2019 at 12:01 AM
Updated Oct1,2019 at 10:51 AM:
(EDITOR’S NOTE: This story originally published in The
Palm Beach Post on March 20, 2010)
A purloined journal that is said to contain the names of
"hundreds” ofvictims of convicted sex offender Jeffrey
Epstein could be used to'reopen the investigation into the
multi-millionaire's appetite for teenage girls, an attorney
representing seven of the victims said Friday.
New details about the contents of the journal were released
this week when.Alfredo Rodriguez, who worked as a
property manager for the Palm Beach resident, pleaded
guilty to obstruction ofjustice for lying to federal agents
when asked if he had any information about his former
boss' criminal activity. He later tried to sell the journal he
Stole from Epstein for $50,000 to an unidentified person,
who alerted authorities, according to court records.
As part of the plea agreement, federal prosecutors saidthe
journal “contains information material to the. Epstein
investigation, including the names of material witnesses
and additional, victims.”
"Had the items been produced in response to the inquiries
ofstate or federal authorities ... the materials would have
been presented to the federal grand jury,” federal
prosecutors wrote.
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Ep~s:tein lournaI's• fio:~in,gs £OJiJdl 
·Re.sutrect: 1C11se· 
, 
. 
~ 
-
. 
, . 
. 
,,,, 
By Ja11e. Musgrave: 
Posted Sep 17, 2019 at "12:01 AM 
Upd.ated Oct 1, 2019 at 10:51 AM 
(EDil"OR'S NOTE: Thts story originally published in The 
Palm Beach Post on March 2012010) 
A purloined journal that is said to contain the names of 
"hundreds" ofvictims of c9nvicted s~x.offencier Jeffrey 
Epstein co.uld be used to'reop·en the investigation into the 
...

Instead, prosecutors short-circuited the grand jury
investigation and cut a deal with Epstein. They agreed riot
to pursue federal charges if he didn’t contest prostitution-
related felonies in state, court. The money manager pleaded
guilty in July 2008.to procuring-a minor for prostitution
and soliciting prostitution. He served 13 riioriths of an 18-
month sentence.
Attorney Adam Horowitz, who represent s seven of the
roughly 18 women who have filed civil suits against;
Epstein, said the new information could trump the so-
called non-prosecution agreement.
The multifaceted agreement, he said, deals only with a
specific list,of victims that the U.S. Attorney's Office knew
about when it penned the deal in 2007. If additional victims
are listed in the journal Rodriguez stole) Horowitz said
federal prosecutors could reopen the investigation.,
Tt:opens the door for further prosecution,” he said.
In addition to turning over the journal to federal agents,
Rodriguez told them he knew his former boss was having
sex with.underage girls when he worked for him in 2004
and 2005. He had seen naked girls, who looked like,minors,
in the pool of Epstein’s $8.6 million mansion. He had seen
pornographic images of young girls on Epstein’s computer,
according to court records.
Neither Epstein's criminal defense attorney, Jack
Goldberger, nOr attorney Robert Critton, who represents
Epstein in the civil lawsuits, could be reached. Federal
prosecutors have consistently declined comment.
The Wording of the controversial agreement is unclear. It
says federal prosecutors Would provide Epstein’s attorneys
“with a list of individuals whom it has identified as victims,”
Miami- attorney RobertJosefsbergwas appointed to
I
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• 
• 
Instead, prosecutors short--:circuited. the grand fury 
investigation a:nd.c:uta deal With Epstein. They agreed not 
tq p1.1rsue fec:lera...

represent any of the victims on the list who wanted to
pursue Epstein in civil court. As part of the agreement,
Epstein is to pay for Josefsberg to represent the women.
Some ofthe 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 saidhe was afraid Epstein
would make him "disappear.” The information, he told
investigators, was his “insurance policy,”
He faces a maximum 20 years in prison when he is
sentenced on June 18.
jane_musgrave@pbpost.com
@pbpcourts
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• 
• 
rep_resent any of the victims on .the list who wanted t◊ 
pursue_ Epstein in civil court. As part of the; agreement; 
Epstein is to pay for Josefsberg to represent·the women. 
Some of the,womeh; rhost identified as Jane Doe in 
laws_uit~, ha_d already hired attqmeys tc>represent them. 
Some haye since settled their suits with Epstein, although 
termsWere,not disclosed. 
Horowitz said he has filed court papers to get the joµr_I)al 
that Rodriguez stole. "It's ,mother piece of evidence that 
shows our clients were at Epstein's manSion,"'.he said. 
Rodri&ueztold prosecutors he.didn't turn over the fournal 
when both FBI _and I,Jalm Beach police -~sked-for i_t because 
he wanted money for it. He· also said he was afraid Epstein 
would make him ''disappear." The,ihformation, he told 
investigators, was hi~ "insurance poli<:y." 
He.faces a maximum 20.years _in prison when he is 
sentenc.:ed onJune 18. 
jane_musgrave~@pbpost.com 
@pbpC(?Uf...

The Palm Beach Post
REALNEWSSTflRTSHERE .
Epstein paid three women $5.5 million to end underage-
sex lawsuits
By Jane Musgrave
Posted Oct 3; 2017 at 12:01,AM
Updated Oct 4,2017 at 12:46 AM
Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young
women who claimed he used them as sex toys, court documents filed last week show he shelled
out $5.5 million to settle lawsuits with,three of more than two dozen teens who sued him.
Responding to requests from Epstein’s attorneys in a complex lawsuit that was spawned by the
sex scandal, attorney Bradley Edwards said the politically-connected 64-year-old convicted sex
offender paid more than $1 million to each of the three women Edwards represented.
Identified in court papers only by their initials or pseudonyms because of the nature ofthe
allegations and.their youthful ages, L.M. was paid SI million, E.W. $2 million,andJane, Doe
$2.5 million, Edwards said ofthe settlements he negotiated with Epstein to end the lawsuits.
Jack Goldberger, one of Epstein’s criminal defense attorneys, on Tuesday declined comment on
the revelations, citing confidentiality agreements that were part of the settlements. For the
same reason, he declined to say whether Epstein,paid,similar amounts to settle roughly two
dozen lawsuits filed 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 th&information will help him undermine Epstein’s claims that
Edwards “ginned up” the allegations to help; his former law partner, imprisoned and disbarred
Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1,2 billion Ponzi scheme.
CA/Aronberg-00...

The revelations of the settlements came as part of an ongoingdawsuit:that started as a dispute
between Epstein and Rothstein, both billionaires.
J
A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a
minor for prostitution, he sued Rothstein and. Edwards, claiming they trumped up the
allegations of sexual molestation to perpetuate the Ponzi scheme.
Rothstein was sentenced to 50 years in prison in 2010 after admitting; he had built his wildly
successful law firm by forging the names of federal judges and others to persuade investors he
had negotiated settlements in lawsuits against high-profile people. Investors were told they
could get a cut of the cash.
One of the high-profile people Rothstein used to lure investors was Epstein, according to a
lawsuit West Palm Beach attorney Robert Critton filed on Epstein’s behalf. According to the
lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the. lawsuits
With the teens for $200 million — a claim Critton described as “a complete fabrication.”
After Epstein dropped the.lawsuit in 2012, Edwards turned the tables on him. Edwards accused
Epstein of filing the.lawsuit maliciously to punish him for representing the young women.
Although Edwards was a partner in Rothstein's now defunct firm, Scarola claims Epstein had
no evidence Edwards was involvedin the .Ponzi scheme. Federal prosecutors successfully
charged other attorneys and members of the firm, butEdwards 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 Torija Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the:
trial, in part, because she claimed she.has been unable to talk to her client since his estate on Jus
private island in the U S. Virgin Islands was devastated las...

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 Searola'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'smalicious prosecution case has/been difficultfbr 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 lawsuitis 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 settle lawsuits filed against him by dozens of his underage victims.
CA/Aronberg-00.1066
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Palm Beach Daily
Judge rules feds’.agreement with
Jeffrey Epstein pact violated/teeft
victims’ rights
By Jane Musgrave
Posted Sep 17,2019 at 4:02 PM
Updated Oct 8,2019 at 12:31 PM
(EDITOR’S NOTE: Titis 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 bn dozens of federal charges in
connection with the girls’ claims that he paid them for sex
at his Palm Beach mansion, U.S. DistrictJudge Kenneth
Marra ruled on Thursday.
In a blistering 33-page ruling, Marra meticulously and
methodically detailed the numerous steps federal
prosecutors took to hide the agreement from more than 40
young women who claim Epstein paid them for sex when
they were as young as 14,
"While the government spent untold hours negotiating the
terms and implications ofthe NPA with Epstein's attorneys,
scant information was shared with the victims,” Marra
wrote.. "Instead,:the victims were told to be 'patient' while
the investigation proceeded.”
By then, it was too late. A deal had already been cut with
then-South Florida U.S. Attorney Alex Acosta and.Epstein's
attorneys to shelve a 52-page federal indictment against
Epstein, a former math teacher turned money manager
who counts Presidents Donald Trump and Bill Clinton
among his friends.
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Jud·e~tules ifeds' t~r··reem:entw,ith,· 
.. __ g: .. ' . ··"· · .. , .. .. ••--"-:"· ·.··' ......... -•. 
Jef:frey,.!~psteiatp.ac.t v1otated,J.;eu1: 
ivlcti~:s' ti:ghts 
By Ja11~Jv1usgr~ye 
Posted Sep i7, 2019 at4:02 PM 
Updated Oct 8; 20.19. at 12:31 PM 
(EDITOR'S NOTE: This story originally published in The' 
f'alm _Beach Post on February 22; 2019) 
Federal prosecutors violated the rights of Jeffrey Ep_stein's 
teenage, victims by failin&·to reveal they had dropp...

Prosecutors failure to alert the young women about the
deal violated the Crime Victims’ Rights Act,.Marra ruled.
"At a bare minimum the (act) required the government to
inform (the young women) that it intended to enter into an
agreement not to prosecute Epstein,” he wrote.
Still, Marra said he wasn’t second-guessing prosecutors'
decision not to pursue Epstein on federal charges 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 thefacts 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
attorneyJack Scarola, who is representing the two Jane
Does who challenged the prosecutors' actions.
Further, he said, there is no road map to follow. The
lawsuit attorney Bradley Edwards filed on behalf of the' two
unidentified young, women, 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.
5
Scarola said he and Edwards will ask that the nOn-
prosecution agreement be thrown out, That would open
the possibility that the long-shelved federal indictment
could be dusted off and filed against the 66-year-old
Epstein, who spends most of his time on a private island he
owns in the U.S, Virgin Islands.
i
..
... .. ...
,„i..
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•• 
• 
Prosecutors' failure to alert the young women about the 
deal violated the Crime Victim...

"I don’t see the government conceding to that remedy,”
Scarola admitted. Further, he said, it is likely Epstein will be
allowed to weigh in. Miami attorney Roy Black years: ago
filed papers asking to intervene on Epstein’s behalf.
The U.S. Attorney’s Office said it wouldn’t comment on
Marra's ruling. Neither Black nor New York City attorney
Jay Lefkowitz, who led efforts to bury the federal
indictment, responded to emails or phone calls for
comment. West Palm Beach attorneyJack Goldberger, who
represents Epstein, also didn’t respond.
Scarola said it is likely Epstein’s star-studded legal team will
argue that Epstein fully complied with the terms of the
agreement he made in 2007 with federal prosecutors and
therefore the agreement can’t be undone.
As he promised, Epstein pleaded guilty in June 2008 to state
charges of soliciting a minor for prostitution and soliciting
prostitution. He served 13 months of an 18-month jail term
in a vacant wing of the county stockade that he was allowed,
to leave 12 hours a day, six days week.
Further, as agreed, he paid settlements to the young women
who sued him. While the settlements were confidential,
court records show he.paid three women a total of $5.5
million.
In return, federal prosecutors held up their end of the
bargain.. Their investigation ceased.
Having done all that prosecutors asked of him, Scarola said
Epstein Will make a simple argument: “You can’t turn
around and deprive me ofthe benefits 1 bargained for.”
However, Scarola said, using’ Marra's ruling,, hewill counter
that the contractEpstein signed was illegal and therefore
unenforceable.
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-• 
• 
"ldort't see the government conceding to that remedy;'' 
Scarola admitted. Further, he safd, ids likely Epstein will l?e 
allowed to weigh in. Mfami attorney 'Ro¥, Black years ago 
fil'ed papers asking to intervene on Epstein'.shehalf. 
The U....

Even if Marra agrees to toss out the non-prosecution
agreement; Scarola conceded that doesri’t mean Epstein will
face federal charges.
“The contract can be set aside and the federal government
can attempt to enter into the same agreement/’ he said.
“Except the spotlight of public attention will be oh 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’tknow'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
testily 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 shewasn’t entitled to know about the prosecutors’
plans to drop the charges. “There is ho dispute that Epstein
sexually abusedJane Doe 2 while she was a minor,” he
wrote. "Therefore, regardless of her comments to the
prosecutor, she was a victim.”
Before the case is finally resolved, Scarola predicted that “a
lot ofpeople are going to have to. answer a lot of questions/’
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• 
• 
Even if Marra agrees to toss out the non~prosecution 
agreement, Scarola conceded that doesn't mean Epstein will 
face federal. charge_s. 
I 
"The contract can be set .a5ide and the· federal .government 
cari;attempt to enterinto...

•
•
In his ruling, Marra detailed what appeared to be a cozy
relationship between.Acosta, his line prosecutors and
Epstein’s team of lawyers. His phalanx oflawyers included
noted Harvard law professor Alan Dershowitz and Kenneth
Starr, the former U.S. solicitor general whose investigation
led to the impeachment of President Clinton.
Marra describes an October .2007 breakfast, meeting
between Acosta, who is now U.S. labor secretary, and
Lefkowitz shortly after the 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 ofthe identified
individuals, potential witnesses, or potential-civil claimants
and their respective, counsel in this matter.”
Marra quoted an equally pleasant note then-Palm Beach
County State Attorney Barry Krischer sent to Assistant U.S,
Attorney Marie Villafana, who was the lead prosecutor in
Epstein’s case. "Glad we could get this worked out for
reasons I won't put in writing,” Krischer wrote, shortly
after the non-prosecution agreement was sighed. "After this
is resolved I would love to buy you a cup at Starbucks and
have a conversation."
Many of the notes that were exchanged dealt with
prosecutors’ and Epstein's lawyers’ shared desire to keep the
deal secret from Epstein's accusers. In a September email,
Villafana asked Lefkowitz for guidance about what she
should reveal. “And can We have a conference call to discuss
what I may disclose to ...,the girls regarding the:
Agreement,” she asked.
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•• 
• 
In his rulin~, Marra detailed whar appeared to be a cozy 
relationship between.Acosta, his line prosecutor~and 
Ep~tein' s t~a111 of lawyers .. His phalan;x: of lawyers indud~.d 
note~ Hal'Vard.law professor Ala:nDershowitz and:Kenneth 
I 
Starr, t...

•
•
Such cooperation between prosecutors and defense
attorneys is unusual, Marra said. “It was a deviation from
the government’s:standard practice to negotiate with
defense counsel about the extent of crime Victim
notifications,” he wrote.
Further, he noted, that when Edwards and his two young
clients asked for information, they were repeatedly misled.
“The CRVA was designed to protect victims’ right 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/Aronberg-00.1072
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
NOT A CERTIFIED COPY
CA/Aronberg-00.1072 
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Such cooperation betweenprosecutors and defen~e 
atton1eys is unusual, Marr.a said. "Jt w_as a deviationrrom 
the government's:standard practice to n·e·gotiate with 
defense counsel about the. extent of crirne victim 
notifications,'' he wrote. 
Further, he noted, that when E.dwards and his. twp yoµ11g 
clients asked for information, they were repeatedly misled. 
"The CRVA was designed toprotectvictirns' right and 
ensure their ,involvement :in the criminal justfre proc:ess ," 
Marra wrote. "When the government gives information to 
vittiJns it cannot be misleading." 
Ultimately, the terrns of the non~ptosec:ution agreement 
werer.evealed only after Edwards:am:l at:torneys for the 
press s~ccessfully sued to make them public. 
jm usgrave@pbposLcom 
:·. ••·:. ·,_,.,_._ :;.,, .. ;-••·-• . 
..::..::..;.... __ ._.,_,. __ .'. ··.·,··~--... • ,;,-., . ._ .t 
. .:.co. ·--!'! _, -~ 
@pbpcourts 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

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76 / 278 - Tuesday, July 9, 2019
Edition: Final
Section: A Section
Page: 1A
Source: By Jane Musgrave, The Palm Beach Post
Epstein/ indicted on sex charges
Part-time Palm Beacher pleads not guilty to sex
trafficking, conspiracy charges in federal court in
Manhattan.
Dressed in a blue prison jumpsuit^ billionaire Jeffrey Epstein on Monday pleaded not guilty
to charges accusing him of creating a vast network of girls as young as 14 that he exploited
for his sexual pleasure at' his homes in Palm Beach and Manhattan.
The 66-year-old.money manager's appearance in U.S. District Court in New York City
capped more than a decade of recriminations,by young;women and their.attorneys,who
claimed Epstein used his money and political influence to avoid federal prosecution.
Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking
charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach
County Jail for 13 months more than a decade ago.
However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to
shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state
prostitution charges, prosecutors in New York.indicated they aren't willing to deal. Acosta is
now U.S. labor secretary.
"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey
Berman said at a
morning news conference, "And while the charged conductis from a number of years ago, it
is still profoundly important to many of the alleged victims, now young women. They
deserve their day in court."
At a detention hearing scheduled,for Monday, Berman said he will ask a federal judge to
keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to
commit sex trafficking, Epstein paid dozens of young women to give him nude massages
that, for most, led to sex, he said.
If convicted of exploiting: dozens ofyoung women, including many Palm.Beach County girls
who were studen...

"We think he's a significant flight risk," Berman said of the man who: ferried Britain's Prince
Andrew, actor Kevin Spacey, famed Harvardlaw 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 oh the hdhprbsecutidn 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'sclaims.
New York prosecutors were able to ignore the controversial nonprosecutibn 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 "Emplo...

U.S. District Judge Kencnth Marra has already ruled that Acosta violated! the federal Crime
Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked.
Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight
Monday, explaining what action Marra should take to redress: that wrong.
Gassell 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 againstEpstein in New York, Scarola said
he's not focused oh whether Epstein will face charges here.. Instead, ho 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-monthsentence 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-Wcst 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’sEave a proper court case," Frankel sai...

"If you believe you are a victim ofthis man, JeffreyEpstein, we want to hear from you,"
Berman said. A special number, 1-800-CALLFBI, will, link victims of authorities.
Bill Sweeney, assistant director ofthe FBI's New York office, said after years of being
ignored by federal agents, the victims' voices will be heard.
"The Jeffrey Epstein matter is No.
1 on the major case list in the country,'1 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-00.1076
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
NOT A CERTIFIED COPY
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"If you believe you are a victim of this-man, J effrey:Epstein, we want to. hear from you/ 
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. . . 
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. . 
. 
... 
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Bennan said. A speciaJ 1_1umper, 1-800-CALLFBI, will)inkvic~i,01s of authorities. 
Bill Sweeney, assistant director of the FBI's New York office, said. after years of being 
ignored ·by federal agents, the vi~tims' voi~es will be he,ard. 
• 
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"The Jeffrey Epstein inatter is No. l on the major ca:se list. in the country," Sweeney said. 
Turning to address-Epstein's vi'ctims directly, he said: "Yo.ur bravery m1:ty empower others to 
speak out against crimes against. them." 
jmusgrave@pbpost.com 
CA/Aronberg-00.1076 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

Appendix 13
CA/Aronberg-001077
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
NOT A CERTIFIED COPY
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Appendix 13 
CA/Aronberg-001077 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

IN THE CIRCUIT. COURT
IN AND
FOR PALM BEACH
COUNTY,
FLORIDA
CASE NO.
:
50 - 2019-CA-014681
Circuit civil division:
"ag"
CA FLORIDA HOLDINGS LLC PUBLISHER
OF THE
PALM BEACH POST.,
P1aintiff/Petitioner
-vs-
DAVE ARONBERG,
SHARON :R.
BOCK,
De fendant/Respondent s
HEARING BEFORE THE HONORABLE KRISTA MARX
(ZOOM CONFERENCE)
Wednesday., June 3,
2 02 0
10:08 a.m.
- 10:28 a.m.
REMOTE
ZOOM CONFERENCE
Tort Saint Lucie, Florida
Stenographically Reported By:
SONJA M.
REED
'Court Reporter
OEPOSITIONSOluflOHV
CA/Aronberg-00.1078
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
NOT A CERTIFIED COPY
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IN THE CIRCUIT COURT 
IN AND FOR .PALM BEACH COUNTY, FLORIDA 
CASE NO.: 
S0.-20i9-CA-cH4fr81 
CIRCUIT CIVIL DIVISION: "AG" 
Cl\ fLORJDA HC:fLDING$ I.LC PUBLI:SHE~ 
OF ~HE PALM BEACH POST I 
Piaintiff/Petition:er 
DAVE ARONBERG; 
SHARON R. B.OCK, 
Defendant/Respondents. 
---------------------I 
CA/ Aronberg-0O1078 
;HEARING BEFORE TJ::IE HONO~BLE Is:RISTA MARX 
(ZOOM' CONFERENCE) 
Wedrres.day,, June 3, 2020 
1 o : O 8 a . m . 
-
.1 o : 2:s a . m . 
REMOTE ZOOM CONFERENCE 
:port Saint Lucie, Florida 
Stenqgr~phic:ally Reported By: 
$0NJA M, REE.D 
Court Repot'ter 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3,/28/2023 2:27:00 PM 

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APPEARANCES:
On behalf of the Plaintiff/Petitioner:
GREENBERG TRAURIG,
P.A.
1840 Century 'Park East
Suite 1900
Los Angeles, California 90067
310. 586 .7700
boyajian@gtlaw.com
BY:
NINA D.
BOYAJIAN,
ESQUIRE
On behalf of the Defendant/Respondent:
JACOB,
SCHOLZ
& WYLER,
LLC
961687 Gateway Boulevard
Suite 2011
Fernandina Beach, Florida 32034,
904.261.3693
doug. wyler@comcast .-net
BY:
DOUGLAS A.
WYLER,
ESQUIRE
On behalf of the Defendant/Respondent;
CLERK
'& COMPTROLLER.,
PALM BEACH
COUNTY
P.O-
BOX 229
West Palm Beach, Florida 33401
561.355.2983
nfingerhut@mypalmbeachclerk.com
BY:
NICOLE R.
FINGERHUT,
ESQUIRE
ESQUOtE
: ’'.rV deposition: souhwhs
CA/Aronberg-00.1079
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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APPEl,\R..ANCES: 
On behalf ·of the Plaint:·iff/Petitioner: 
GREENBERG TRAURIG, P.A. 
1840 Century Park East 
Suit::e 1900 
Los Angeles, c'aliforriia 9:0067 
310.586.7700 
boyajian@gtlaw.com 
BY': NINA D. BOYkJIAN, ESQUIRE 
on behalf of the Def_endant/Respo:ndeht: 
J:ACO:e, SCHQLZ & WYLER, LLC 
~61687 Gateway Botilevard 
Suite 20ii 
Fernandina Beach, Florida 32034, 
904.261.3693 
doug. wyler@comc:a:sb.net 
B:Y: DOUGLAS A. WYLE_R, 
ESQUIE,E 
On_ behalf qf, the pefendant:./Respo!}qent: 
CLERK '& COMPTROLLER., 
PALM BEACH COUNTY 
P -. Q .· B.ox 2 2 9 
West Palm Beach~ ?lorida 334Dl 
5 61 . 3· 5 5 . 2 9 8 3 
nf.ihgerhu.t@mypalmbeachclerk.com 
BY: NJ:CO.LE R. E'INC:ERHCJT, E$QUIB:E 
CA/Aronberg-001079 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM 

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PROCEEDINGS
*****
i
THE COURT:
We are here today for a very
limited purpose.
I'm sure the attorneys are aware of
that, but I just don't want there to be any
confusion.
We are here On Defendant Dave Aronberg
and Defendant Sharon Bock for the: Comptroller and the
State Attorney's motion to dismiss Count II.
You're all acutely aware as the lawyers that
this is a question of law.
So. we're not going to be
diving into facts and the Court will not be deciding
the merits: of this motion, this morning.
We are
simply here for the sole purpose of that motion to
dismiss.
So I just wanted to make sure that we all
stay on track and we're all on that same page.
So,
Ms. Boyagian, I'll send it to you first,
Ma'am.
I -- of course,
we all know that the Law 101,
I must look at the four corners of the motion, which
alleges that the State Attorney, David Aronberg, and
the clerk and comptroller, Sharon Bock, actually have
custody and control of these, grand jury proceeding.
Whether that is true or not is not for this
court to determine because I'm looking simply at the
four corners of the complaint.
But, not for nothing,
I think we all know that they don't have control and
OfPOSITiON SOLUVIOtH
I
CA/Aronberg-00.1080
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
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'PROCEEDINGS 
THE COURT: 
We are here today for a very 
limited purpose. 
I'm sure the att9rneys ,;lre aware of 
t:hat:, ou:t I j11st don•' t want the.re to ·be. al).y 
confusion. 
We are here on Defendant Dave,Aronber:9 
and De.f:endant Sharon Bock for the CoTI).ptroller and the 
:State Attorney's ITI.Otion to dism;i.ss Cov.nt ;II. 
You're a11 acute1y aware as the lawyers that 
this is a question of law. 
So we•' :te not going to be 
di virtg into facts a.nd thE? Court wi:1-1 n:ot pe deciqirtg 
the mer.its -of this...

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custody of the records.
But I'm going to assume that
it's correct because that's what has been alleged.
So what I first want to hear from is; the
attorney for Florida Holdings with regard to,
assuming arguendo, that Florida Statute 905.27 does
create a cause of action, what relief is it that
you're seeking from -- in Gount II, specifically.
Not the dec action.
We're not- here on that today --
what is it you hope to get, a judgment?
MS.
BOYAGIAN:
Thank you, your Honor.
Good
morning, and thank you for the privilege of appearing
before this court.
The relief we are seeking is disclosure of the
grand jury records, pursuant to the Furtherance of
Justice Exception to 905.27.
And under the First
Amendment.
The press, as your Honor is aware, has a right
of access under the First Amendment as a surrogate of
the public --
THE COURT:
Let me just stop you .for a minute.
I'd like you to answer my specific question.
So I
am not particularly convinced
— and I'd
like for you to address that.
So we're not going to
dive into facts or the press's standing because
that's not something we're here to discuss today.
CA/Aronberg-00.1081
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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cU$tody of the Ye.c:ord.s. 
But I im goirtg to' as$lit'ne that 
it '·S co.rrect because that's what has been alleged. 
So what I f1rst want to hear from 1.s the 
attorney for Florida Holciings :wit'h regard to, 
c1ssuming arguendo, thc1t Flor_idc:1 Statute :9'0$. 27 does 
create a cause of action, what relief is it that 
you're seeking from -~ in Count Il, spec'ifically. 
Not J:he de.a action. 
We 're not h,ere on t.haJ: today 
what i.s it you hope to g,et, a judgment? 
MS. BOYAGIAN: 
Thank •you, your. Honor. 
Good 
morn.:lD-9, axid thc:tnk you, for tJ::ie priyileg~ of a,ppeFl,;i;iqg 
beef.ore this...

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And. I have read the voluminous paperwork --
I've received paperwork as -- and -- five-minute ago
from some: of the other parties.
But I deeply
appreciate the fact that you sent this to me so much
in advance and j have been able to spend some time
with, as I said, the voluminous paperwork that was
provided.
•But as you know, Ma'am,
we are here: for such an
extremely limited issue today, and that their motion
to dismiss where they state "you're suing the wrong
people"; that the court has these’ records.
And so, more importantly, I want, you to address
whether -Section 905.27 gives you a private Cause of
action against the state attorney arid the clerk.
Again, I'm going to assume the facts are true
that are asserted in the motion.
Whether they are or
riot -- because I think we can all agree we're not for
sure if they ever -- that the state attorney doesn't
have these records.
So what is it you're seeking in
COtint IT -- riot the dec action.
I know you want the
records,
I've got that.
But in; Count II,
specifically,- what do you -- what's the relief you're
seeking and, more importantly,
how under .this: statute
do you get to assert a private action -- a private
cause of action against the state attorney and the
CA/Aronberg-00.1082
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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Arid. I h~v.e read th€;! voluminous paper&ork 
I 
I've rece:i'.ved paperwork as -- and -- five~minute ago 
.from some of the other parties. 
But I deeply 
appteciate t'he fact tha.t you SE;!nt this to me so much 
,in advanqe a:n,<;1 l l:1c;J.ye 'be:en ahle to :-:;pend some time 
with, as I .sa:Ld, the voluminous paperwork that was 
provided. 
-But as you kl1pw, Ma' a.m, we a.re llere, :f'or such an 
extreme1y limited issue today/ ancf that their motion 
'to dismiss where they: state 
...

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clerk?
MS.
BOYAGIAN:
Your Honor,
we are aware, of
course,: that there is no expressed private right of
action, 905.27.
But that does not end the inquiry.
As the Florida Supreme Court stated:
"Where a statute like 905.27
forbids an act Which, is to Plaintiff's
injury, the Party injured should have
an action."
And that's the Smith. Piezo case in the volume
of materials that we sent you.
There's no. question here that the denial of the
FIRST AMENDMENT right to the press is an injury which
gives rise to a right of action.
Stated another way, looking at the analysis
that the Fischer Metcalf Court, looked at, there, are
three factors in determining whether, there is; a
private right of action where a statute does not
expressly provide for one.
One is whether the Plaintiff is part, of the
class for which the statute is intended to protect;
second is a legislative history-; and the third is the
underlying purposes of the statutory scheme.
The first factor I already addressed, that the;
press is part of the class that the statute is
OPPOSITION SOlUIIOHS
CA/Aronberg-001083
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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clerk? 
MS. B'OYAGIAN: 
Your Honor, we are aware, of 
course, that there is no expressed private right of 
a<;::1.ion, 905.27. 
But that doei:, not end the. inquiry. 
As the Floricia. Supre.:me. CoUcrt state.cl.:. 
"Whe-re :a statute like 905. 27 
forbids an act which is to Plaintiff•.s 
ir1j u_ry, the pc:t-rty ,inj µreel s.hould hcJ.ve 
an action. 11 
And that '·s the Smith. Piez'o case in the volume 
ot tnateria1};; that we sent you. 
'Ther.e:' s no quest.ion here that the deniai of the 
FIRST AMENDMENT right to the J?ress is an injury which 
gives :t.i:se to a right ol action. 
St:ated another way, looking at the analysis 
that the Fischer Metcal...

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intended to benefit, being the surrogate of the
public and exercising its first, amendment right.
The second issue of legislative history and the
purpose -- statutory purpose are somewhat related.
We were unable to find much legislative history on
this issue of a private right of action under the
statute.
There is nothing that says we intend to create
a private action, but there's certainly nothing that
says we do not want to Create a private right of
action.
What we do have .is that in 1994., the same time
that 905.27 was reenacted., a statute that pertains to
the secrecy of State Grand Jury -- Statewide grand
juries was also enacted.
That, provision,, which is
905.395, has no exceptions for -- for revealing these
records,
By Contrast, the legislature intentionally
enacted 905.27 with the Furtherance of Justice
Exception.
If the public through the press can't bring a
private right of action to enforce that exception or
to seek relief under that exception, that
intentionally placed exiception of furthering justice
is essentially rendered hollow --
(Speaking simultaneously.,)
^ESQUIRE
CA/Aronberg-001084
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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intended to penefit, be·ing the surrogate of the 
public and ~xercising its first amendment right. 
The second issue of legislative history and the 
purpo?e -- .statutory purpose are somewhat related, 
We were u11ab1e to f ir1d. nmc'.h legislative hd,story on 
thfs issue of a. private right of action under the 
'Statute. 
Tl:Ier~ is rioth.ing that says we intenc:1 to c,reate 
a. private action, but there's ce·rtainly nothing that 
says we do not want to create a private risht of 
·a Gt: i CH) . 
What we do have .is that in 1994J the· same time 
that 905.27 was reenacted; a statute that pertains to 
the secrecy o...

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THE COURT:
Okay.
Pause for a minute.
I don't think anybody is saying that there
isn't a cause of action or that the press doesn't
have standing.
That's not what I'm asking you.
I'm
asking you.,
how are the clerk and the state attorney
the proper defendants?
So, you know, nowhere have I said there isn't a
cause of action.
Clearly there is.
I'nv puzzled by
the procedural posturing of this case naming the
state attorney.
And, you know, I'm further stymied by the fact
that you allege in your complaint that they have
particularly David Aronberg the State Attorney --
that he has these records.
But I'm going to assume that's true.
So I'm
not telling you, you don't have a cause of action.
I'm just saying, okay, let's run this all the way
out.
Let's say you win and you get a judgment
against the; State Attorney Dave Aronberg.
What's he supposed to do with it?
He can't
release, the grand jury testimony.
He has no
authority whatsoever to do that.
MS.
BOYAGIAN:
well, your Honor, as you stated,
this is a motion to dismiss stage, and we are
entitled to discovery on the issue of possession,
OEPOSinON SOI UI lows
CA/Aronberg-00.1085
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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THE CdlJRT: 
Okay'. 
Paµs'e 
I don't think anybody is 
• 
for a minute. 
. 
I 
s.aying that. there 
• 
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isn't a cause of action or that the press doesn't 
have standing. 
That's, not what I 'm asking you, 
I'm 
asking you, how a.re, the clerk an.ct t:he stat:e, a.ttorney 
the proper defendants? 
So, you know, nowhere .have I said there isn't a 
ca:1.1se of actiori. 
Clearly there is. 
I 1m· puzzled. by 
the procedural posturing of this case naming the 
state attorney. 
And, you know, I' nt .further 13ty1TI:igd by tl\e :fact 
that you allege in your complaint that they have --
particularly David Aronber...

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custody, and control.
My understanding is that the
state attorney has asserted that he does not have
possession.
It's not my understanding that the. clerk
has taken that position.
So the clerk may indeed be
the -- someone who does have possession, custody, and
control.
In any event,
we would submit, that the state
attorney, even it does not have actual possession at
this time,, it might be. able to have the power to
control or direct the entity or persons who do have
control and possession to release those -- to effect
the judgment;
THE COURT:
So let me ask you this:
So the
clerk is the keeper of the record.
But even if you
got a judgment against her -- let's say you asserted
this cause of action and let's say you win and you
get a judgment against the clerk.
The clerk cannot
release grand jury testimony to you.
Only the court
can.
So really -- all I'm saying to you is I do not
understand the way this case was filed or why these
are the defendants because it's impossible for them
to perform.
I mean., I'm going to assume, based bn your
motion, again,: that they do have the records.
But we
^ESQUIRE
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1 -TV
OPPOSITION SOUH IONS
CA/Aronberg-00.1086
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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i:::U$tody, arid control. Ny understanding i$ that the 
state attorney has asserted that ·he does not have 
possession. 
It's not my understanding that the. clerk 
has taken that position. 
So the clerk may incleed be 
t.he. --
$Omeo11e who does have. possession, c:::ustody, and 
control. 
In ,any event, we would submit that the state 
attorney, even it cloe1:;1 not have act:ual posses•sio11 at 
this time, it might be.able to have the power to 
cont-r-e:H or direct the entity or persons who do have 
t:ontr6.l and. posses.sion to release th6s$ -·- to .ef feet 
the judg...

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all know -- everyone in the room knows they do not --
that only the court -- they're -- they're with a
court interpreting.
And only the court can release
the records.
So if you get a judgment against either the
state attorney or the clerk, they cannot - - I mean, I
guess what you're saying to me is, well,
we want to
do discovery and we want them to say unequivocally "I
have these records" or "I don't have them."
And --
I. mean, the law is abundantly clear.
You cannot do it without a court determining whether,
in the furtherance of justice, the release is
appropriate.
MS.
BOYAGIAN:
And that is a determination
we're asking your Honor to make, and we're asking for
an order from your court.
THE COURT:
When we get to the merits of the
case, sure it. is.,
But, again, you’re' asking me to
make that determination and for me to make a
determination of whether the grand jury records
should be released.
And the. only thing we're here
today about is why should the clerk and the state
attorney have to, defend a civil action when it's a
possibility of performance?
They -- even if you were
to win and get a judgment against them, they cannot
^ESQUIRE
CA/Aronberg-00.1087
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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all kn9w· - - eveYyone in the rootn krtows they do not 
that .only the court - - they I re - - they' re with a 
court interpreting, 
And only the court c~n release 
the records. 
So if you get a judgment against either the 
'State attorney or the clerk, they cannot 
,guess what you're say;ing to me is, wel1, we want to 
cio disc:overy an:d we w:ant thern to sci.y lln1::::guivocally "I 
have these re·cords 11 ox "I don't have them.
11 
And - -
I. mean, the law is. abundantly clea'r. 
Y:9u cannot do ,it without a, court det,errninirtg whether, 
in the :further;an...

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give you what they doh't have.
So — I mean, it's as simply as this::
Are,
you -- you just want to engage in some discovery for
them to absolutely assert, particularly, the state
attorney,
"I don't have' these records"; look to the
rules that say the moment the grand jury's over,
they're sealed and they're turned over and they
cannot be released without court order?
So I'm not addressing the merits or whether you
have an exception or you're able to argue that
there's ah exception in the furtherance of justice.
We're not getting there today.
I'm. simply saying why
should these two entities have to defend this lawsuit
when even down the toad if they win they can't give
you what they don't have?
MS.
BOYAGIAN:
As your Honor stated, I'm not
sure that'S the case with the clerk.
That was not in
their -- that issue was not stated in their papers.
THE COURT:
Let me ask you this, then:
Do you
think, if you got a judgment and. I or the court
doesn't make the determination that the grand jury
records should be released, that the clerk would be
able to perform?
Would they be able' to say "here you go"?
I
mean, could the clerk just make that unilateral
CA/Aronberg-00.1088
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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give y9u·what they don't have, 
So --
I mean,. it's as simply as this·: 
Are. 
you -- you just want to engage in some discovery for 
them to absolute·ly a{:lsert, particularly, :the stat-e 
attorney, 
11 I d.on ,. t have· these records 11 •; 
lc:>ok to t_he· 
rules that .say the moment the grand jury's over,. 
they're sealed and they're turned over and they 
c::annot be releaseq without court 9rger? 
So I'm not address:i'.ng the merits Qr whether you 
have ah exception or you're able to argue tha·t 
there'$ c;J-IT e_xteptio_n ,in the furth_erance of justj,c...

decision "I'mgoing to release the records, Sealed
confidential records"?
Does she have any authority to do that?
MS.
BOYAGIAN:
My understanding, your 'Honor, is
that 905.27 requires a court order before the records
are unsealed ,s
THE COURT:
Exactly.
Exactly.
All right.
Let me hear from Mr. Aronberg's
attorney,
Mr. Wyler.
MR.
'WYLER:
Thank you, your Honor.
May it
please the Court --
THE COURT:
Good morning', Sir.
MR.
WYLER:
Good morning.
Your Honor,
I just wanted to let you' know that
I spoke with counsel for the clerk,
Ms. Fingerhut,
a
couple of days before this hearing, and we decided
that I would just make the presentation for both of
of us, being that our arguments overlap except for
the fact of who this claim -- whether they have the
records or not, which, of course, we've said we don't
have custody of the records -
But, nonetheless, our arguments overlap.
The
Plaintiff is attempting to assert a cause of action
under Section 905.27.
That statute settled testimony
not to be disclosed exceptions.
So it's just
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CA/Aronberg-00.1089
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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deci1:3i9n. "I'm .going to :t$leas(= the records, $ea.led 
confidential records"~ 
Does she have any authority to do that? 
MS, BOYAG:IAN: 
My understanding, your ~Honor, is 
t:hat 90.5. 27 requires ·cl c:::ourt order bef:ore th:e r.ecord;i 
are unsealed .. 
THE COURT: 
Exactly. 
Exactly. 
A11 r-igh.t:, 
Let me 11:ear from Mr, l:\,rqnberg' s 
attorney, Mr. Wyler. 
MR. 'WYLER: 
Thank you, your .Honor. 
May it 
please th.e Court 
'THE COURT: 
Good morning·, Sir. 
MR. WYLER : 
Good morning . 
Y9u:t Honor, I just wanted to. let you: knqw that 
I spoke with counsel for the clerk, Ms .. Fing,erhut,. a 
couple of days before this hearinsr., and we decided 
t...

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explaining exceptions to the disclosure of the grand
jury testimony.
Our position is. that it doesn't set forth a
Cause of action and that it's impossible for us to
perform what they're asking.
I know you said you didn't really want to get
into the Furthering Justice Exception, but I know
that's what they're using as their basis to get to
these.
But it's our position that the clear
unambiguous statutory language:, it shows that this
disclosure only applies to a civil or criminal case,
and that within that civil or criminal --
(Speaking simultaneously.)
THE COURT:
Again, sir -- I'm sorry.
As I told
Plaintiff's counsel --
MR.
WYLER:
-- Can only be used in the defense
for
- -
THE COURT;
Okay.
We're not there.
We're not
discussing the merits of the case, and -- I'm not
ready to cross that bridge.
I'm here for a very,
very limited hearing today.
So just as I stopped Plaintiff's counsel from
arguing the merits of the Case: and whether or not the
Furtherance of Justice Exception will apply in this
instance, we're not even there yet.
'
CA/Aronberg-00.1090
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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explaining exceptiohS to the dis9·1osure of the ,grand 
jury testimony. 
Our ~p:osition is. that it do:esn' t set forth a 
cause of action. and t:hat it's impossible f:or us to 
perform what they'' ;re ·ctsking. 
I know you s:aid you didn't really want to get 
into the Furthering Justice Exception, but I know 
tl:iat' s whc:lt 1:hey' re m~ing as their pas-is to get to 
these. 
But it's our position that the c:lear 
unambiguous statutory· language, it shows :that th-i-s 
dis-closure on,ly appli~El to ct c~i vil qr crimii:i~l ca_se, 
and that wit'hin that civil or criminal 
(Speaking simultaneously.) 
-THE COURT: 
Again, sir - -
I 1·m sorry. 
As I tQld 
Plaintiffr...

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I'm only here for the purpose of determining
whether or not the clerk and state attorney should be
dismissed.
And I am bound by the four corners of the
document, which assert that you do have control and
custody over it•
So if you'll fashion your argument with regard
to that limited purpose,
I would, appreciate it.
MR.
WYLER:
No problem, your Honor.
I
apologize.
Within the four Corners of their complaint,,
Our
position is that they failed to state a cause of
action under 905.27.
It does not provide for -- it
doesn't list that there's no element that they have
adequately pled to assert a cause of action under
that.
There's -- and the only thing they're asking
for is records that we don't have.
There's really not much more to it, your Honor
And we would ask that you. would grant our motion to
dismiss for failure to state a cause of action.
THE COURT:
Okay.
Ms. Fingerhut, are you still
on the phone?
MS.
FINGERHUT:
Yes, your Honor.
THE
COURT:
Is there anything you wish to add?
MS.
FINGERHUT:
We agree with the state
CA/Aronberg-00.1091
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3. 28 2023 2:27:00 PM
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• 
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I"m only here f9r the pµrpose of get~rminirtg 
whether or not the clerk and state atc.torney should be 
dismissed. 
And I am bound by the four corners of the 
document, which assert that you do have contr9l and 
custody over it. 
So if you'' 11 fashion your argument with regard 
to that limited purpose, I would. appreciate it. 
MR, WYLER: 
No problem, your Hon.or. 
I 
apologize. 
Within the four corners of their compla:i.n:t, our 
pos·it;i.on is tl:lat: they fa,ileq to state ~ c~use of 
act.ion under 905 .,27. 
It does not provide for 
it 
doesn't list that there's .no element that they 'have 
,adequ.;3.tely pled to assert a cc:i.use of action under 
that. 
There's -- and the only th...

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attorney's position, and we also agree with what the
Court has said, that the plain language of the
•statute, a cause of action doesn't exist.
And we
really cannot -- we'll be defending something without
the four corners.
We're simply involved in this
action because the clerk is the custodian of the
records.
THE COURT:
Okay,.
Thank you,- Ma'am.-
Ms. Boyagian, back to you.
MS.
BOYAGIAN:
Your Honor, I'd like to note
that in the Butterworth case in which the Supreme
Court limited the application 905.27 by saying that a,
witness can reveal her Own testimony and prohibiting
that they violate the First Amendment --
THE
COURT:
Say that again, please.
MS.
BOYAGIAN;
In the Supreme Court Case, the
Butterworth case', in which the Supreme Court ruled
that 905.27 can't restrict a Grand Jury witness from
revealing her own testimony, that would be a
violation of First Amendment,
in- that case, the state
attorney was, in fact,
a party.
THE COURT;
Well,
I assume the state attorney
that was present -- I mean, I don't find that that's
close to what we're talking about here, and that's
whether or not -- I mean, as we know,, this was in
ESQUIRE
o.f?6sinoN soiuuoHv
CA/Aronberg-00.1092
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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attornE:!y·• s po1?ition, and w~ -also agree:! wi.t-h what the 
Court has said, that the plain language of the 
·statute, a cause of action doesn't ex1st. 
And we 
really cannot -- we 1 11 'bE:! defending something without 
t:he f,qur c::orners. 
We' re_ simply involve.ct in this 
action becaus.e the clerk is the custodian of the 
records. 
THE COlJRT: 
Oka,y. 
'X'han}< you,. Ma, I clffi .. 
Ms.. Boyagian, back to you. 
MS. HOY.AGIAN: 
Your Honor, I'd like 't'o note 
tha,t in the Butte:r:worth ca,se in whic:h the _$µp:r'~me: 
Court limited the app,l...

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2006.
Certainly Dave ArOnberg wasn't even the state
attorney then.
But this is about the release of
records\
I want to give you ample opportunity -- and
again,,
;i sincerely appreciate that all of the case
law and the way that it was presented to the Court in
such a timely fashion.
I really do.
And I did spend
some time with it.
But I want to give, you whatever
opportunity you want to take to convince me that it
is in -- as to Count 2, again.
Not the dec action --
whether these would be the appropriate defendants.
And, you know, really, I want you to boil it
down, for me as to this -- let's take it all the way
down the road.
You win,
You get a judgment, against
the clerk and the state attorney.
I know there's other reasons why you might have
filed it this way.
But I'm just simply puzzled
because I do hear what the clerk and the state
attorney are saying, and that is, performance is
impossible-
They don't have the records and
cannot -- absolutely.
There's not even an inch of
wiggle room -- that they could release the records
even if you got a judgment.
It is solely a
determination for the court.
I, frankly, think, you know, there's ways to
OFPOSinON SOLUTIONS
CA/Aronberg-00.1093
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:27:00 PM
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2006. 
<;:ertaittly Dave Arortbe-rg -wafJh' t even th~ ·state 
attorney then. 
B.ut this is ,about the, release of 
records. 
I want to give you ample qpportunity -- and 
again,, I s,i_ncere1y appre.cii::ite that all of the cas·e 
law and the way that it was pre·sented to the Court in 
'Such a timely .fashion. 
I really do.. 
And I did spend 
sorne :time with it. 
But I want to give you whatever 
opportunity you want to take to convirrce: me that it 
is in-~ as to Count 2, again. 
Not the dee action 
whether the_se wou1d be the 9ppropriat...

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get to your records.
There's ways to get
confidential records.
But it isn't by suing the
state attorney and the clerk.
So I just want to hear your last final argument
on how Count IT, the appropriate defendants are the
clerk and the state attorney.
Even assuming arguendo
they have the records -- we know they don't -- you
were to get a judgment against them,
how would you
expect them to perform?
MS.
BOYAGIAN:
Two points, your Honor:
One is
that-, again-, the clerk did not assert, in her papers
that she does not have control,.
That is a position
that the State Attorney's Office has asserted.
It is
Our allegation, and as your Honor noted, allegations
must be accepted as true -- as true at this stage of
the proceedings.
Second, it is also our understanding that the
state attorney and the clerk intend to block access
to these records.
So our allegation is that they do
have possession, custody, or control, which the clerk
has not denied; and second, that they are trying to
block access to the records --
THE COURT:
What do you mean.?
What do you
mean?
They're not trying to block it..
They're
saying that despite the fact -- let's just talk about
CA/Aronberg-00.1094
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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get to yo,,.fr records. 
Th~r~' s way~f t-6 9et 
confidential records. 
But it isn't by suing the 
state attorney and the clerk. 
So I jui:it want 1;:.o hear your la~t finc;':ll argument 
on how Count II, the ·cl.ppropriate d_ef endant$ are the 
clerk and the .state attorney. 
Even assuming arguendo· 
they have the records ""' - we know they don't -~ -- you 
w~-r~ to get a judgmE=nt agc:1,inst:. thE::TTJ, h,ow would you 
expect them to perform? 
MS. BOYAGIAN: 
Two points_, your Honor: 
One is 
thqt,, a,gaiD--, t;:he clerk did not ~ssert in her pap~rs 
that she does not ha...

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the clerk, because we all know the state attorney
doesn't have it.
So the clerk is the custodian of records.
That's her main job.
There's no doubt about it.
We
all know that.
But we also know, unequivocally --
unequivocally, only the court can make the
determination of whether the moving party has
satisfied that there is an exception that these
should be released.
So, again,
I ask you -- she is, in fact, the
custodian of the records -- is it your opinion that
if you got. a judgment saying clerk and comptroller
gets a judgment against them, that she can release
the records without the court -- without the court
weighing in, without the court making that
determination as required by law?
MS.
BOYAGIAN:
No, your Honor.
We are asking
your Honor to order the clerk to do that under your
discretion.
THE COURT:
All right.
Mr.
— Ms. Fingerhut,, you wish to be heard on
that?
MS.
FINGERHUT:
Your Honor, our position is
that we're hot trying to block access to the
records --
CA/Aronberg-00.1095
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
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the, .cleYk, becq,use we all know ·the state attc:irney 
does.n' t have it. 
So the clerk is the custodian of records. 
That's her tnain job. 
There's no doubt about it. 
We 
~11 know tllc3.t. 
But:. we als:o know, unequivocal;J_y 
·unequivoca:lly, only the court can make the 
·determination of whether the moving party has 
sc3.t:isfie4 that there is an e:x:ception thc3.t t).1,ese 
should be released. 
So, aga'in, I ask you -- she is, in fact, the 
cust9dia:n o.f the records - - is it your opinion that 
if you got a j:udgment s:aying c.lerk and comptroller 
gets a judgment against themi that she can release 
the records without the co1,1:tt - - without the ,court 
weighing in, without. the court making that 
determination as required by ...

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(Speaking simultaneously.)
THE COURT:
Can you hear?
Can the attorneys
hear?
MS,
FINGERHUT:
- - custodian the records and
that he cannot release the records without court --
THE COURT:
Exactly.
Okay.
All right.
Anything further.,
Mr. Wyler?
MR.
WYLER:
No, your Honor.
I concur with the
attorneys for the clerk's office that it's impossible
for us to. release these records.
There's no intent
to hide them or block anything from the Plaintiff.
THE
COURT:
Okay.
Anything further,.
Ms. Fingerhut?
MS.
FINGERHUT:
No, your Honor.
THE
COURT.:
And,
Ms. Boyagian, anything
further, Ma'am?
MS.
BQYAGIAN:
Nothing further, your Honor.
THE
COURT-
Okay.
I will, get an order out
quickly.
Thank you, folks so much.
And I'll see you
On the next round.
Thanks a lot.
MS .
BOYAGIAN:
Thank you., your Honor.
MR.
WYLER:
Thank you, your Honor.
(The: proceedings concluded at 10:28 a.m.)
Of PO $ JT10 N: 5 61U
0 N 5
CA/Aronberg-00.1096
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
NOT A CERTIFIED COPY
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(Speaking $imulta.nec5usly·,) 
THE COURT.: 
Can you hear? 
Can the attorneys 
hear? 
MS' FINGERHUT: 
- - custodian the• records .ahd 
that 'he cannot release t:he records without <:ourt --
THE COURT: 
Exactly. 
Okay. 
All ri9.ht. 
Anything further, Mr. Wyler? 
MR. 'WYLER: 
No, your Honor. 
I 9QilCUr with the 
attorneys for the clerk's office that it"s impossible 
for us to release these records. 
There's no intent 
to hJpe them or block anytb.ing, fror:n the PlaJnt;if f. 
THE COURT,: 
Okay. 
Anything further,. 
Ms. Fingerhut'? 
MS. FINGERHUT: 
No, your Honor. 
THE COURT.: 
And, Ms. 'Boyagian, anything 
further, Ma'am? 
M$, BQYAGIAN.: 
Nothing further, your Honor. 
THE COURT: 
Okay. 
I wfll. get an ortjer out 
qu1ckly. 
Thank you, folks so much. 
And I'll see you 
on the next round. 
Th~nk§ a lot. 
MS. BOYAGIA:t...

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2 5.
CERTIFICATE OF REPORTER
I, Sonja M. Reed, Court Reporter, certify that
I was authorized to and did stenographically report the
foregoing proceedings and that the transcript, pages
1
through 19, is a true and complete record of my
stenographic notes.
Dated this 3rd day of June, 2020.
Sonja
M. Reed
Court Reporter
CA/Aronberg-00.1097
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
NOT A CERTIFIED COPY
• 
• 
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CERTIFICATE OF RKPORTER 
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r, Sonja M. Reed, Court ReportE=r, certify that 
t was auth0rize·d to and d"id sbenog:ua:phically report the 
foregoi'ng pro.eeedings and that t:he transcript, pages 1 
thr011gh 19, is -~ true and c;:om~lete recc:;:>rd of my 
stenographi,~ pqtes. 
Da_ted this 3rd d<:ly oJ .,Tune, 2020, 
~ 
Sonja M. Reed 
Court Reporter 
CA/ Aronberg-001097 
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM