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EFTA00298342.pdf

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Page 500 I', -1r 502 1 2 IN 741E CIRCUIT COURT OF THE FIFTEENTH JUDICIAL MOAT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.50200SCA037315000004B AB 1 2 1 APPEARANCES On tehalf Janc Den I thectralt 8: JESSICA BOOK ESQUIRE I MERME1812:214 & HOROW112, l'A. 3 W205 lagoon nukearr1 Son 2218 4 S M phon ironit e Plaintiff. 5 6 7 On batonMtn Plaintiff, lane Doe Nall: 6 -vs- VOLUME IV OF IV ISOM MANUEL Minn mom 7 GARCIA. ELKINS & BOEFIFUNGER 9 224 Dina Mew Saito 900 War tide 33401 Defendants Phan 9 I 11 sad 12 TARA k FINNIGAN,!MUM 10 TARA& FINNIGAN.PA 11 13 VA Miura Street 12 DEPOSITION OF State WO DETECTIVE JOSEPHRECAREY 14 West Pailliarida 33401 13 Mono 14 Friday,March 19, 2010 15 16 an Wulff of the Datong,hffny Emleos 15 10:03 - 5:23 p m 17 MICHAEL PIKE, ESQUIRE 16 505 South [take Drive BURMAN, CRIITOR LETT/ER& COLEMAN, LIP Suite 1100 la 303 014066 Boolean 17 West Palm Beach, Florida 33401 Stile 4'.0 18 19 West /MC 33401 19 Phone' 20 20 and 21. 21 22 a Reported By. MIUION O. WhlMIRO. ESQUIRE Jana Ricciuti. Mit FPR. CLR 22 LAW00110E OF MILTON G. WEINBERG 23 Notary Public. Stew ofFlorida 20 Pin Pima 23 Suite WOO, Prose Gault Reporting Bent 02116 24 24 Moue: 25 25 Page 5C. Page 503 1 1 Appearances continued... 2 uNDED STATES DISTRICT COURT 2 On behalf of the Witness: ' SOUTHERN DISTRICT OP FLORIDA 3 3 JOANNE M. O'CONNOR, ESQUIRE CASE NO.10-80309 JONES, FOSTER, JOHNSON & STUBBS, P.A. 4 505 South Flagler Drive, Suite 1100 5 JANE DOE NO. 103. West Florida 33401 Plaintiff, 5 Phone: 7 VOLUME IV OFIV 6 JRPFREY CPSIEIN, 7 9 Defendant. Also Present Jeffrey Epstein 8 10 9 11 10 12 DEPOSITION OF 11 DEIECTIVE JOSEPH RECAREY 12 13 14 Tuesday, April 27, 2010 13 15 10:03 - 5:23 pm. 14 16 505 Saab Flagler Drive 15 Stitt 1100 16 17 Weft Palm Beach, Florida 33401 17 18 18 19 20 19 21 20 22 Reported By: 21 Jam Fticciuti, RPR, FPR, CLR 22 23 Notary Public, State ofFlorida 23 Prose Cain Reporting 24 24 25 25 .... - 2 (Pages 500 to 503) PROSE. COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 ) Electronically signed by Jeana RIccluti (601 ) bdcd1876•c7242.432(1-8c40-0190e656129/ EFTA00298342 Page 504 Page 506 1 1 counsel? INDEX 2 MS. ARBOUR: Form. 2 3 THE WITNESS: I believe so, yes. 3 I wrrNESS: COMM CROSS CROSS REDIRECT RECROSS 4 BY MR. WEINBERG: 5 DETECTIVE JOE RECAREY 5 Q. And that was an offer that was extended by the 6 BY MR. WEINBERG 505 6 State Attorney following discussions with the Palm Beach BY MS. ARDOUR 636 7 Police Department, correct? 7 BY MR. GARCIA 636 8 A. That was when we had just heard about it. We 9 9 were unaware that the offer was made. 10 --- 10 Q. And how did you become aware that the offer EXHIBITS 11 was made? 11 12 A. I had made numerous telephone calls to the 12 NUMBER DESCRIPTION PAGE 13 13 State Attorney's office to inquire where we were, and DEPOSITION EX. 29 MESSAGE BOOKS 592 DEPOSITIONEX. 30 HANDWRITTEN NOTE ON 617 14 did not receive any return phone calls. I went over to 14 JEFFREY E. EPSTEINMEMO 15 the State Attorney's office personally on an tmrelated PAD 16 incident to drop off some filittpackets, and that's 15 DEPOSITION EX. 31 HANDWRITTEN MESSAGE 622 17 when I went by and I saw =was in her office. 16 17 18 Q. was an experienced State attorney, 18 19 correct? 19 20 MS. ARBOUR: Form. 20 21 THE WITNESS: I know she had been there for 21 22 some time. 22 23 23 BY MR. WEINBERG: 24 24 Q. And you knew she had been a prosecutor for sex 25 25 offense cases for some time, correct? Page 505 Page 507 1 PROCEEDINGS 1 A. She did a lot of crimes against children. 2 2 Q. And she, on other occasions, advocated 3 BY MR. WEINBERG: 3 prosecution of people on felony charges, correct? 4 Q. Good afternoon, sir. 4 A. I hadn't had many dealings with her so I don't 5 A. Good afternoon. 5 know. You know, l knew Mier. She was actually at the 6 Q. To finish up the subject that we were talking 6 office, State Attorney's office, when I was employed 7 about right before the recess, do you ever recall 7 there many years ago. 8 dicr-ncsions with the State Attorney's office about an 8 Q. And that was how many years ago? offer that was extended to Mr. Epstein to plead guilty 9 A. I've been with Palm Beach almost 19 years. 10 and receive a five-year period of probation for an 10 Q. So we're talking about at least 20 years ago? 11 aggravated assault charge? 11 A. Yeah. 12 A. Yes. 12 Q. And she had been there, to your knowledge, 13 Q. And that was a subject ofdiscussion between 13 continuously from the time that you knew she was there 14 you and members of the State Attornes fice? 14 20 years ago? 15 A. With Assistant State Attorney 15 A. Yeah. 16 I don't know if that's her last name, how 16 Q. And you knew her specialty to be charging 17 it's pronounced, but close enough. 17 people that were — for offenses that dealt with 18 Q. If we call her =, I think we both know who 18 violations of underagtal people, mama 19 we're discussing. 19 MS. ARBOUR: Fonn. 20 A. Yeah. 20 THE WITNESS: I believe so. I believe so. 21 Q. And those discussions occurred within or 21 Like I said, I didn't have many dealings with her. 22 around the winter of 2005,'6? 22 BY MR. WEINBERG: 23 A. I believe so. 23 Q. So you saw her in the office that day? 24 Q. And was that a sentence and a charge option 24 A. And that was the time that I just had learned 25 that was extended to Mr. Epstein through his then 25 of the offer that was made to previous counsel. 3 (Pages 504 to 507) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana ificciuti (801M Electronically signed by Jeana Moduli (601 bdecH 876 c72o.432d-8c10-bt 9ac656129t EFTA00298343 Page 508 Page 510 1 Q. And did you take a position on that offet? 1 correct? 2 A. Personally, I told her I didn't agree with it, 2 MS. ARBOUR: Form. 3 but I couldn't speak for the department. It actually 3 THE WITNESS: f know that when there's 4 had to come from people with a higher pay grade than 4 misdemeanor arrests in the Town of Palm Beach, a 5 mine, so I just relayed the information back to 5 lot of officers pretty much try to gain any 6 Chief Reiter. 6 intelligence they can from any of the people that 7 Q. And what, if anything, did Chief Reiter do? 7 they encounter. Some of the information actually 8 MS. ARBOUR: Form. 8 leads to other cases, clearance ofminor rocas 9 THE WITNESS: I believe he tried to make 9 thefts, bike thefts. 10 contact with State Attorney Barry Krischer. 10 BY MR. WEINBERG: 11 BY MR. WEINBERG: 11 Q. And in this case, it led to you going to sec 12 Q. Did he make contact with State Attorney 12 Jane Doe 103, first calling her on October 10th and then 13 KriSehe', to your knowledge? 13 visiting ha in Jacksonville on October 11th, correct? 14 A. I'm not 100 percent certain if he did or 14 A. Yes. 15 didn't. I bow there was some time where none of our I5 Q. And you also, in your investigation, learned 16 calls were being returned from the State Attorney's 16 that Jane Doe 103 had lost her job at Victoria Secret 17 office. 17 for stealing, did you not? 18 Q. Jane Doe 103 was one of the witnesses who was 18 A. No. 19 at the center of the State investigation, correct? 19 Q. You never received any information regarding 20 A. One of them, yes. 20 Jane Doe 103's employment history with Victoria Secret? 21 Q. And you knew that Jane Doe 103 had a MySpace 21 A. She was actually employed there when I went up 22 page that was one of the MySpace profiles that was 22 to seeker. Thrift where I met with her. 23 provided to the State Attorney by Mr. Epstein's then 23 Q. Did you ever team at any time that she had a 24 counsel, Professor Dersbowitz, correct? 24 problem that led to her losing her employment? 25 A. Yes, I knew that there were pages sent of the 25 A. No. Page 509 Page 511 1 MySpaces, but I wasn't sure of whom at that particular 1 Q. So you knew she had been arrested for 2 time. They provided us copies thereafter, but right 2 marijuana? 3 there, immediately, I wasn't aware of whom had pages. 3 A. Uhelmh. 4 Q. You eventually received than and reviewed 4 Q. You knew she had a MySpace page where there 5 than, correct? 5 was information that was -- that showed her to use 6 A. tJb-huh. 6 thugs, correct? 7 Q. And you understood that from even before then, 7 A. Uh-huh. 8 that Jane Doe 103 had a background that involved at 8 MR. PIKE: Yes or no? 9 least one arrest, correct? 9 THE WITNESS: Yes. 10 A. Yes. 10 BY MR. WEINBERG: 11 Q. And you understood that when she was arrested 11 Q. You knew that the role of the State Attorney, 12 in early October, she in fact informed the arresting 12 the prosecutor that would have to present this case to 13 officers that she had information regarding Mr. Epstein, 13 the jury, was to weigh evidence, correct? Not only the 14 correct? 14 evidence you provided but also any evidence that was 15 A. I believe so. 15 provided by those representing the target of criminal 16 Q. And if you go to your probable cause affidavit 16 investigation? 17 ai page 11, at the bottom of 10, it starts, 'On 17 A. Yes. 18 September 11, 2005, Jane Doe 103 was arrested by the 18 Q. And knew that as a result of that weighing 19 Palm Beach Police Department for misdemeanor possession 19 process, =, an experienced State Attorney, told you 20 ofmarijuana. During the arrest, Jane Doe 103 told the 20 that she believed at least that Jane Doe 103 was a 21 arresting officer that she had information about sexual 21 consenting participant and not a victim of criminal 22 activity taking place at the residence ofMr. Epstein." 22 offenses by Mr. Epstein, correct? 23 A. Yes. 23 MR. GARCIA: Object to the form. 24 Q. Jane Doe 103 essentially was asking the 24 THE WITNESS: I don't — consenting victim, 25 arresting officer to assist in her cooperating; is that 25 you mean? 4 (Pages 508 to 511) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciutl (601 Electronically signed by Jeana Ricciutl (601 bdcd1876-c720.432d-acre-blbae6561291 EFTA00298344 Page 512 P&p:: .., 14 1 BY MR. WEINBERG: 1 case, "Is it okay to take a taxi". 2 Q. She told you that there were no victims here 2 MS. ARBOUR: Form. 3 when — 3 BY MR. WEINBERG: 4 A. Originally, that was her statement, yes. 4 Q. Is that right? 5 Q. Right. And if there were no victims here, 5 MS. ARBOUR: Same objection. 6 then she's really saying to you that, after reviewing 6 THE WITNESS: Yes. 7 all of the evidence that she received, not only from you 7 BY MR. WEINBERG: 8 but from the defense, she didn't consider Jane Doe 103 8 Q. So whoever was at die Epstein home receiving 9 to be a victim? 9 the call would essentially write this denim on a message 10 MS. ARBOUR: Form. 10 pad that had at least two different layers? 11 111E WITNESS: 1believe that's what she 11 MS. ARBOUR: Fem. 12 stated. 12 THE WITNESS: Yes. 13 BY MR. WEINBERG: 13 BY MR. WEINBERG: 14 Q. And given her knowledge of what occurred on El 14 Q. And that when you seized the message pad from 15 Brillo Way, she didn't see any victims in this case. 15 the trash pulls, there was only one layer, which was the 16 MS. ARBOUR: Form. 16 original that had been thrown out or crumpled out, 17 THE WITNESS: 1believe that's what she 17 correct? 18 stated. 18 A. Yes. 19 BY MR. WEINBERG: 19 Q: AM when you went on October 20th and 20 Q. Whether or not she physically did possess the 20 conducted a search and seizure, you would seize the pads 21 message pads or whether she had access to information, 21 that included all of the copies of the original 22 the message pads that you reviewed were in the hundreds, 22 messages, correct? 23 if not thousands, correct? 23 A. Yes. 24 A. Uh-huh. 24 Q. And they were in various handwriting, were 25 Q. And that these pads reflected incoming calls 25 they not? Page 513 Page 515 1 to Mr. Epstein's phone that was in Mr. Epstein's 1 A. Yes. 2 residence on El Brillo, correct? 2 Q. And they provided you with leads to witnesses, 3 A. Correct. 3 did they not? 4 Q. And they reflected messages that came from 4 A. Yes. 5 people that left their phone numbers? 5 Q. And provided you with names and numbers? 6 A. Yes. 6 A. Yes. 7 Q. And it reflected messages that included, for 7 Q. And gave you information that there was lots 8 instance, from.. on July 9, 2004, is available 8 ofpeople who, at least according to these telephone, 9 on Tuesday. Was that a message that was concluded in 9 incoming telephone calls, were inviting themselves to 10 these message pads? 10 Mr. Epstein's home — 11 MS. ARBOUR: Form. 11 MS. ARBOUR: Form. 12 111E WITNESS: Yes, that was some like that, 12 BY MR. WEINBERG: 13 yes. 13 Q. — either directly or through their friends, 14 BY MR. WEINBERG: 14 correct? 15 Q. And that is clutmeteristic of lots of the 15 MS. ARBOUR: Form. 16 messages that were being received by whoever was taking 16 MR. GARCIA: Object to form. 17 down a message at the Epstein residence, correct? 17 THE WITNESS: There were several messages that 18 . MS. ARBOUR: Form. 18 I recall was written to Mr. Epstein indicating 19 THE WITNESS: Iih-huh, yes, correct. 19 girls' names and times that they were available. 20 BY MR. WEINBERG: 20 BY MR. WEINBERG: 21 Q. And the way it worked, if I'm right, is that 21 Q. Like, for instance here, she wants to confirm 22 somebody would answer the phone and, for instance, the 22 a 11:00 tomorrow, message for JAE from a woman's name. 23 message would say on July 19, '04, Mr. Epstein: Phone 23 That would be typical messages on these pads that you 24 call fromM., leaving a reply mobile phone number or 24 reviewed? 25 cellular number, and leaven very short message, in this 25 MS. ARBOUR: Form. 5 (Pages 512 to 515 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeans Ricciuti (601 bdcd1876-c720-432(1-8c10-b19iie6.56129f EFTA00298345 Page 516 THE WITNESS: That would be some, yes. 1 of 18; is that right? 1 2 BY MR. WEINBERG: 2 A. What groupings? 3 Q. And many of them appeared to be incoming calls 3 Q. Well, let's say, did you ever interview a 4 from different girls which said, Em in town, can I come 4 woman namedII.? 5 over, can I schedule a meeting? 5 A. Yes. 6 MS. ARBOUR: Form. 6 O. And youlcnew that her date of birth was in 7 THE WITNESS: Some were like that. 7 and that she was over 18 when you 8 BY MR. WEINBERG: 8 interviewed her — Q. And some appeared to be responses to a phone 9 A. Yes. 10 call made by someone at the El Bulb home asking, are 10 Q. — and represented herself to be over 18 when 11 12 you available, and there would be a phone call back saying, Pm available tomorrow afternoon or Wednesday 11 12 she saw Mr. Epstein? MS. ARBOUR: Font I 13 morning or Thursday afternoon. 13 THE WITNESS: Yes. I 14 A. Correct. 14 BY MR. WEINBERG: 15 Q. And by and large, these messages did not 15 Q. And, likewise, was another person who 16 include any negotiation over dollars? In other words, 16 said yes, she had been to Mr. Epstein's house at a time 17 there was not on a message pad that any of these 17 when she was over 18? 18 incoming girls were saying, I will come over ifIeffrey 18 A. Correct 19 gives me $500 or $300; there was no evidence of that 19 Q. And then M. was in her 20s when you 20 kind ofincoming phone call, correct? 20 interviewed her? 21 MS. ARBOUR: Form. 21. A. Yes. 22 THE WITNESS: Not that I can recall, no. 22 Q. And there was an., who after the publicity 23 BY MR. WEINBERG: 23 came out, called in and said she was 25 at the time she 24 Q. And likewise, there was no indication on these 24 met with Mr. Epstein? 25 message pads that any of the people calling 25 A. Yes. Page 517 Page 519 1 Mr. Epstein's home were, in essence, particularizing 1 Q. And., who you interviewed, who told you 2 what they were going to do or what they intended to do 2 that yes, she went to Mr. Epstein's home on many 3 or what they might do once they got there, correct? 3 occasions, and she was over 187 4 MS. ARBOUR: Form. 4 A. Yes. 5 THE WITNESS: Can you repeat that question? 5 Q. And a 6 BY MR. WEINBERG: 6 A. She was a licensed masseuse. 7 Q. Sure. Theres nothing on these message pads 7 Q. Licensed masseuse who was over 18. 8 that indicates, I'll come over and give a topless 8 A. Yes. 9 massage to Mr. Epstein? 9 Q. And some of the people interviewed had tumcd 10 A. No. 10 18 during the period that they were seeing Mr. Epstein 11 Q. These are essentially contact and scheduling 11 and so told you, correct? In other words, that they had 12 calls? 12 started seeing Mr. Epstein when they were 17, and then 13 MS. ARBOUR: Form. 13 they became 18 and continued to see him when they were 14 THE WITNESS: Yes. 14 18 and, in fact, you interviewed them when they were 18? 15 BY MR, WEINBERG: 15 MS. ARBOUR: Form. 16 Q. And often reflect the fact that the callers 16 THE WITNESS: Some, yes. 17 are not connecting on the first call, so they're going 17 BY MR. WEINBERG: 18 back and forth and trying to arrange times for a 18 Q. And they, too, are included in Mese book of 19 particular woman to come over to Mr. Epstein's home, 19 message pads? In other words, this was not limited, the 20 correct? 20 incoming calls were not limited to girls that were 17 or 21 MS. ARBOUR: Form. 21 16, and included girls that were 18, 19,20, 25 and even 22 THE WITNESS: Yeah. 22 older, correct? 23 BY MR. WEINBERG: 23 MS. ARBOUR: Form. 24 Q. And some of these calls come from a whole 24 THE WITNESS: Correct. 25 grouping of persons that you learned were over the age 25 BY MR. WEINBERG: 6 (Pages 516 to 519) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Rlcciuti (401Ia Electronically signed by Jenne Ricclutl (601 bded18714:726432d4d0-019.44561291 EFTA00298346 Page 520 Page 522 Q. Now, when you drafted the search warrant 1 now almost five years ago, that she had said to you that 7 affidavit and you agreed with me that you understood 2 Jeffrey Epstein preferred girls between 18 and 20. 3 when you drafted it, as an experienced detective of 3 A. I would have documented that in the incident 4 almost two decades, that the judge would be relying on 4 report, but... 3 the content of what you preiented to him, correct? 5 Q. Would it be an important modification of the 6 A. Yes. 6 statement attributed to her that Jeffrey Epstein wants 7 MS. ARBOUR: Form, asked and answered. 7 young girls, correct? 9 BY MR. WEINBERG: 8 MS. ARBOUR: Form. 9 Q. That the judge did not have some external 9 THE WITNESS: Had she said it, but again, I 10 bases to test the representations, either for 10 don't — 11 completeness or for accuracy? I1 BY MR. WEINBERG: 12 MS. ARBOUR: Form. 12 Q. I understand. Had she said it, it certainly 13 THE WITNESS: Correct. 13 would have been considered important enough to include 14 BY MR. WEINBERG: 14 in the various affidavits that you drafted that relied 15 Q. And you made representations in the search 15 in part on what told you. 16 warrant affidavit that were repeated in the probable 16 MS. ARBOUR: Form, the tape speaks for itself. 17 cause affidavit, did you not, that were attributed to 17 BY MR. WEINBERG: 18 18 Q. Correct? 19 A. Yes. 19 A. Correct. 20 Q. And directing myself to the probable cause 20 Q. The message pads include messages like, was 21 affidavit, because that's the one that is unsealed and 21 wondering if she would get work tonight, she couldn't 22 an exhibit in this case, you essentially said to, on the 22 work yesterday because of some family event. That's the 23 probable cause affidavit, thatM. said that Jeffrey 23 messages, those contents, you would have view of the 24 Epstein wanted young girls — 24 message pads, correct? 25 A. Yes. 25 MS. ARBOUR: Form. It speaks for themselves. Page 521 Page 523 1 Q. correct? 1 THE WITNESS: Oh-huh. 2 Do you recall that during your tape recorded 2 BY MR. WEINBERG: 3 interview with M., she told you that Jeffrey Epstein 3 Q. Did you ever interview n woman namedM.? 4 preferred to receive massages from girls between 18 and 4 A. I attempted it, and I don't think she ever 20 years old? 5 returned my calls. A. I recall her slating, "The younger, the 6 Q. Did you cvcr go to her house? 7 better," but I don't recall that he prefers girls A. Let me think. I may have. I mean, I can't 8 between 18 and 20. 8 recall if I went to her house or not, but I know I 9 Q. Will augrce with me that if the tape 9 telephoned her and I never got any call back from her. 10 recording of interview with you reports that as a 10 Q. Did you, dining this investigation, ever, 11 statement made by her, that the tape recording would be 11 yourself, go to MySpace pages to conduct any background 12 the most accurate source of what she told you back in 12 investigation on the various women that you were 13 early October 2005? 13 proffering to the State Attorney as reliable witnesses? 14 MS. ARBOUR: Form. 14 MR. GARCIA: Objection, asked and answered. 15 MR. GARCIA: Do you have the tape recording to 15 MS. ARBOUR: Joined. 16 play, because my understanding is that's under FRI 16 THE WITNESS: Again, I looked at them when 17. control. 17 they were turned over, but no, l didn't. 18 MR. WEINBERG: asking questions about 18 BY MR. WEINBERG: 19 whether or not it included — 19 Q. I'd ask you to look at page 65 of the incident 20 MR. GARCIA: Without playing the tape 20 report, paragraph 4, and see if that refreshes your 21 recording, I think it's an unfair question. 21 recollection. 22 MR. WEINBERG: You can object. I'll ask it. 22 A. Yes, I did. 23 THE WITNESS: If the recording indicated? 23 Q. And do you recall just how you accessed 24 BY MR. WEINBERG: 24 MySpace? Did you run through a list of all your 25 Q. That III. told you in early October of 2005, 25 witnesses and saw whether or not certain of them had 7 (Pages 520 to 523) 'PROSE COURT REPORTING. AGENCY, INC.. Electronically signed by Jeana Ricciuti (601M Electronically signed by Joana Rlcciu0 (601 bdcd1876c72e-432d-13cf0-b19no6561291 EFTA00298347 Page 524 Page 526 1 MySpace pages? 1 Beach, Mr. Epstein? 2 A. Correct. 2 A. Yes. 3 Q. And you concluded that -- ifs all redacted 3 Q. And the question is: You went on MySpace, you 4 hero, but it looks like 10 or 12 of your witnesses had 4 looked at certain pages that reflected at least some of 5 MYSPoce Pages. 5 your witnesses who were not only using drugs but 6 A. Correct. 6 bragging about using drugs publically and publishing 7 Q. And did you download the infonnaticm from 7 pictures or references to themselves as drug users, 8 these MySpace pages into sonic evidentiary format? 8 correct? 9 A. I believe either I printed them or I might 9 A. On the MySpace page, right. 10 have viewed them and made reference of it, that 10 Q. Right. Did you do anything else, as an 11 they had a MySpace page. 11 experienced investigator, to try to determine by 12 Q Did you ever study the contents of the MySpace 12 through the investigation into the background of any of 13 page? 13 the witnesses? 14 A. The ones that were viewable, 1 looked at. Thu 14 A. I believe I checked than under the local 15 ones that weren't, eventually they all became private. 15 systems to see if they had been arrested. I did like a 16 Q. And the ones that were viewable, did you 16 criminal background check on them and the sworn taped 17 identify certain of your witnesses as including in their 17 statement that we took as well. 18 MySpace page evidence that they were involved in the use 18 Q. October 20th you went to Mr. Epstein's home 19 of drugs? 19 with a group of others; is that correct? 20 A. I recall pictures of like a marijuana leaf, 20 A. Uh-huh. 21 comments made of being high when the photo was taken and 21. MR. PIKE: Yes? 22 some alcohol use. I remember that as well. 22 THE WITNESS: Yes. 23 Q. And did you include those obsavations in your 23 BY MR. WEINBERG: 24 incident report that ultimately would have gone to the 24 Q. And you went there with a search warrant — 25 State Attorney to assist the State Attorney in assessing 25 A. Correct Page 525 Page 527 1 the credibility of the people that you were proffering 1 Q. — correct? And in the search warrant, you 2 to them as witnesses? 2 requested the authority to seize all computers, all 3 A. Did I include those in with the State 3 equipment, any discs, any DVDs, any media, correct? I Attorney? I believe they had them by then. That was 4 A. Uh-huh. the winter of '05, '06. 5 MS. ARBOUR: Form, asked and answered. 6 Q. But this was an independent review of MySpace 6 THE WITNESS: Correct. 7 that was not related to what Professor Dershowitz gave 7 BY MR. WEINBERG: the State Attorney; this was something you were 8 Q. And you seized whatever you found there, reporting that you did on your own, correct? 9 correct? 10 A. I tray have done it on my own to view it myself 10 A. Yes. 11 after learning from the State Attorney's office. I'm 11 Q. And you, yourself, looked through what you 12 not —I can't recall if I did it totally on my own or could look through and asked your forensic people to 13 when I first heard of the MySpace pages, J researched it :3 look through what you couldn't look through; is that 14 myself to view it myself. 14 correct? 15 Q. Did you do anything other Than look at MySpace 15 A. That is correct. 16 pages to try to assess the credibility of any of your 16 Q. And as a result of the search and seizure, 17 witnesses based on what you could learn about them from 17 there was no picture of Jane Doe 103 that was seized, 18 other people? In other words, you were essentially 18 correct? 19 proffering to the State Attorney certain statements that 19 A. That's correct. 20 had been made to you regarding what occurred on El 20 Q. And there was no camera that was found in the 21 Milo Way, correct? 21 massage room, no coven camera found in the second floor 22 A. Uh-huh. 22 massage room of the Epstein home, correct? 23 Q. And you were relying on those statements and 23 MS. ARBOUR: Form. 24 their detail as a basis for asking the State Attorney to 24 THE WITNESS: No, we did not find a camera 25 bring a criminal prosecution against a residence of Palm 25 that day, no. ccers 14 / .-7,- a -2-- , 44.4aredeSev*......-4t-YeetSiers, Mr-nteaf J 8 (Pages 524 to 527 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana IlIcciutl (601 Electronically signed by Jeans Riccluti (601 bded1876-c726-432da-f0419666661291 EFTA00298348 Page 529 Page 530 1 BY MR. WEINBERG: 1 THE WITNESS: Yes. 2 Q. The only camera you found was the camera that 2 BY MR. WEINBERG: 3 you knew about from your 2003 investigation, the one 3 Q. At any time prior to that, did Jane Doe 103 4 that was in the clock aimed at Mr. Epstein's desk and 4 ever call you and say that she was concerned about an 5 the second camera that was in the garage, correct? 5 investigator? 6 A. We found, yes, the second camera in the 6 A. Yes. 7 garage- • 7 Q. And did she call — do you recall when she 8 Q. Did you ever, on any other day, find any 8 called you? Before or after the service of the 9 10 camera other than the cameras you, yourself, installed in 2003 and the camera that Mr. Epstein pointed out to 9 10 subpoena, if you remember? A. It was before. I 11 you in 2003 from the lint floor area? 11 Q. And did she call you at night or in the day I 12 A. No, we didn't see — we didn't find any other 12 time? 13 cameras. 13 A. I believe she called me in the evening time 14 Q. And you had only been to his house, twice; is 14 and left me a voice mail, and I returned her call in the 15 that correct? Once — 15 morning. 16 A. The day of the search warrant and the day that 16 Q. And when she left you a voice mail, where 17 I assisted by putting the cameras. 17 would she have called, into the office, or... 18 Q. You never went back in and altered his home 18 A. Into the Police Department. 19 after October 20, 2005, did you? 19 Q. Did she have your cell phone number? 20 A. No. 20 A. I had provided the victims with a cell phone 21 Q. Do you know of any audio or wire electronic 21 number, yes. 22 interceptions that were directed against Mr. Epstein or 22 Q. Was that a cell phone number that you carried? 23 his residence at any time by anyone? 23 A. Uh-huh. 24 A. No. 24 Q. Was it one of several cell phones you carried? 25 Q. There were certainly none that was connected 25 A. Yes. Page 529 Page 531 1

EFTA00158789.pdf

DataSet-10 Unknown 2 pages

July 29, 2021 VTC with AUSAs FBI Operational Support Technician • Showe chains of custody for property acquired from PBPD o identified as list of what . took from PBPD in August 2006 o recalled that PBPD had executed a search warrant; on August 28, 2006,■ and other agents went to PBPD and obtained all of their evidence; think may have been by GJ subpoena; took original evidence that PBPD seized while executing a search warrant as well as interviews of girls • Showed . notes and 302 for 2006 interview of o . identified notes and 302 as written by handwriting on notes o Interviewed remember flying to =and interviewing 2 hours of touchiarialown and flying out the next day o thinks they interviewed. at her house o s typical practice was that the other agent took notes if Mwas leading the witness interview; =practice was to review the 302 and make sure everything in the 302 was what she recalled and reflected her recollection; two people listed on 302 are present at the interview o Mpractice was to initial the 302 to reflect its accuracy o FBI was going from ACS to Sentinel at this time; 302 may be a copy; 302 is in Sentinel once agent reviews it and says it's accurate o 302 being in the system with name on it means that. reviewed the 302; both agents have to review and sign off on the 302 as true and accurate • Showed certain message pads from FBI custody o practice was to mark evidence with 1B shi m o Showed handwritten sheet in 1B1-1 folder; handwriting; sheet indicates to.that message pad was removed for evidence review and maintained in safe o Writing on IB I (Item #2) manila envelope — not handwriting o Discussed coming to NY to review evidence in person • Stopped working on JE case in approximately 2009 • . not aware of anything exculpatory as to GM; her investigation was not focused on GM; they were focused on JE and three assistants • Law enforcement career 0 0 0 0 3514-025 Page 1 of 2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00007748 EFTA00158789 3514-025 Page 2 of 2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00007749 EFTA00158790

EFTA00175054.pdf

DataSet-10 Unknown 5 pages

From: To: Subject: Disposition Project: Retention ECD Required -- UNCLASSIFIED Date: he, 14 Dec 2021 16:19:24 +0000 Importance: Normal Classification: UNCLASSIFIED Good Morning, You are being contacted because you recently responded that one or more of your cases requires the evidence be maintained. Per policy a retention EC is required to maintain the evidence for closed and pending inactive cases. Please submit a retention EC for the following cases: Holding Case Case Case Case Primary Evidence Evidence Evidence D Collected Responsible Operational Responsible UCFN Wu* Manager Office Division Division Entity Subtype Gamed* escnihm" On Date (Evidence) 1) TAPED CONVERSATION PEIPD05•237(1)2)AUDIO TAPE 41 KIPP 05-243(1) 3) AUDIO TAPE 82 (2) 4) COPY OF TAPE e1 (3) 3) MICRO TAPE P8PD06-293(1) 8) PHOTO UNE•UP PEIPD OS 957(1 ) 7) AUDIO TAPE POPO 05294(118) MICRO TAPE I?) 9) CD PBPO 05-295/2)10) C- 90 CASSETTE PBPO 05- 313(1) 11)NX MAIL N M PEIPD OS4780 ) 121WHITE PAPER CrlfrInal EPSTEIN. G.M. (2) NEW MM. atEAta JEFFREY 13)MESSAGE P.S. (3) 14) MIAMI Invesbaabse Pendng_Inactoe GENERAL 193 E4229233 812812006 YORK DrisSen PO2 108457 a WHITE PAPER J (4) 16)MONTGOIFERYcouNrc MD J.8. (5) 18) WHITE PAPER V. PBPO 05-379(1)17) WHITE PAPER FLIGHT INFO (2) 18) THREE WHITE PAPERS PREMIO COMPUTER INC (3) 19) WHITE PAPER PHONE PI:WOOS-380W 20) YELLOW RECEIPT 04/04/06(2)21) WHITE PAPER C.W. (3)22) WHITE PAPER J. (4)23) WHITE PAPER RIGHT DUMAN 15) 24) WHITE PAPER G. (6) NEW MIAMI °urinal 31E,I.181 EPSTEIN. Pendng_Inzarre GENERAL 199 E6516714 Ono box containing: 1) WHITE 0,20/2000 YORK IMOSITEIM) Plgj 108062 JEFFREY a PAPER A. PBPO DS-381(112) Deleon WHITE PAPER JET BLUE a RECEIPT (2) 3) WHITE PAPER JU. (3)4) WHITE PAPER JO. (4)5) MESSAGE M.H. (6)8) WHITE PAPER H. S. (8)7) WHITE PAPER A. (7)8) WHITE PAPER J.S. (8)9) WHITE PAPER H. (9) 10) WHITE PAPER ST BARTHS (10) 11) MESSAGE • G. (11) /2) MESSAGE • JL 4/2) 13) WHITE PAPER • F. (13)14) MESSAGE 5. (14)15) MESSAGE -J.L (15)16) MESSAGE J.L. GIRL (16) 17) WHITE PAPER • S. (17) 18) WHITE PAPER OS (18) 19) WHITE PAPER • J. (19) 93) WHITE PAPER - J. (20) 21) WHITE PAPER (917) (21)22) WHITE PAPER DA1. (22) 23) PHONES PRINT OUT (23) EFTA00175054 Ono box cortaining: 1) FIVE MESSAGE PRINTOUTS PBPO 06-382(1) 2) WHITE PAPER C. J. (2) 3) MESSAGE M. (3) 4) MESSAGE Ps. (4) 5) MESSAGE A. (5) 6) MESSAGE J.L. 16)71MESSAGE T. (7)8) CLEAR PLASTIC STICK (8)9) TWELVE WHITE PAPER - EXPENDITURES PBPD 05- 383(1) 10) WHITE PAPER J. (2) 11) WHITE PAPER O. (3) 12) WHITE PAPER C. (4) 13) WHITE PAPER J. (5)14) WHITE PAPER J. (8)161 Can nal EPSTEIN. WHITE PAPER M. (7)18) NEW WM- 3 1E-MM- JEFFREY MIAMI Invosbgobve 105062 Pendng_Inactree GENERAL 1/1.5 05518715 WHITE PAPER 812812006 YORK Dwision P82 a (8/ 17) MESSAGE A. PAPERS 4(1) 18) WHIM PAPER T. (2) 19) WHITE PAPER J.N. (3) 20) WHITE PAPER F. (0)21) MESSAGE G 0. (5)22) MESSAGE * (GI 23) MESSAGE M M. It (()24) WHITE PAPER C.(. (8) 25).WHRE PAPER (917) POPO OF-'61441)213)WHITE PAPER A. (2)27) WHITE PAPER E. (3) 28) WHITE PAPER B. F. (4)29) WHITE PAPER 513 (51 30) FOUR WHITE PAPERS (6) 1) MEDICAL SUPPLIES PBPO 06488(1) 2) 727 LETTERHEAD (2) 3) INVOICE $42700 (3/ 4) AMAZON.COM AM. (4) 5) WHITE PAPER J.L. (5)8) MESSAGE FROM J. (6) 7) MESSAGE FROM J.L (7181 WHITE PAPER as (8)9) WHITE PAPER 19171(9) 10) MISC. DOCUMENTS - TRASH PULL PBPO 05474011H PAiSC PAPERWORK- TRASH PULL PBPO 05.878(11 12) TWO MAGAZINES • TRASH PULL PBPO 05-901(1113) PAPER WITH AS. TRASH PUU.PBP0 05-915(1I 14) VHS T-160 CASSETTE PBPD 05- Cricricol EPSTEIN. 929(1) 15)SONY MICRO NEW MM. 31E.M1.6 JEFFREY CASSETTE (2) MR SONY MIAMI Ity.051gabv* Pend Ag eaAlt GENERAL 155 E•1229233 &2812006 YORK Dession P02 108062 MI a MICRO CASSETTE (3)17) SONY MICRO CASSETTE (4) 18) SONY MICRO CASSETTE PEPE/ 05-937(1) 19) SONY MICRO CASSETTE (2)20) SONY MICRO CASSETTE (3) 21)SONY MICRO CASSETTE (t) 22) MISC PAPERWCRK - TRASH PULL PBPD D5-941(1) 23) SONY MICRO CASSETTE PBPD 05442(1)24150W MICRO CASSETTE (2)25/ MISC PAPERS • TRASH PULL POPD 05-943(1) 26) CLEAR PIECE OF PLASTIC PBPD 05- 944(1) 27)MISC PIECES OF PAPER - TRASH PULL (2) 28) SONY MICRO CASSETTE PBPD 05•945(1) 29) SONY MICRO CASSETTE (2) NEW MIAMI CrImnai 31E-MM- EPSTEIN. Peodo0_Nam, GENERAL mg, E42292$4 1) SONY MICRO CASSETTE 5/252006 YORK Inws80abve P82 108082 JEFFREY a PROP 05-972(1) 2) SONY Cwison MICRO CASSETTE (2) 3) SONY MICRO CASSETTE (3) 4) MISC PAPERWORK - TRASH PULL PBPD 95- 1005(1) 5) THREE FLOOR PLANS MAD 05-1023(1)13) DRAWING A.M. PE1PD 05- 1025(1) 7)MISC PHONE EFTA00175055 MESSAGES- TRASH PULL PSPD 05-1027(1) 8) T.180 VIDEO CASSETTE PBPD 06. 105.2(1)9)SONY MICRO CASSETTE (2)10) SONY MICRO CASSETTE PBPD 05- 106401111THREE EMAIL FROM DMV/DL (2) 121VHS VIDEO CASSETTE PBPD 1069(1) 13) VHS VOW CASSETTE (2) 14) CD PBPO 05.1079(2)15) MINI DV TAPE POPO 05-10110(1116)VHS V10E0 TAPE... (2) 1T)MINI DV TAPE (3) 18)30NY MICRO CASSETTE PBPD 05.1087(1) 19)S0NY MICRO CASSETTE PSPD 05-1090(1) 20) SONY MICRO CASSETTE PBPD OS- 1092(1121) PHOTO LINE-UP (2) 221SONY MICRO CASSETTE PBPD 05.1203(I) 1) VHS TAPE OF SURVEILLANCE PBPO 05- 1205(112) VHS TAPE OF SURVEILLANCE (2) 3) VHS TAPE (3)4) VHS TAPE (4)6) VHS TAPE (5) 8) VHS TAPE (61 7) VHS TAPE (718) SIXTEEN DVD-R DISCS P8S0 PSPD 05-121911) 9) CIRCULAR ENVELOPE WITH SUBPOENA INFO PSPD OS/245(1) 10) EPSTEIN. CINGULAR WIRELESS CO (2) Carin91 NEW MAI. AIF./A51 JEFFREY II) SONY MICRO CASSETTE YORK MIAMI Inv0E9080v8 P.000(KLIOEK4M) GENERAL 158 E4229235 8/262006 Dwison P62 108%7 a POPO 05-21(1) 12) GREEN a FOLDER A. P8PD 06-24(l) 131 SONY MICRO CASSETTE PSPD 0639(1) 14) SONY MICRO CASSETTE PSPD 59I1) 15) SONY MICRO CASSETTE PBPD 03.95(1) 18) T.160 VIDEO CASSETTE PEPD 06-120(1) 171SONY MICRO CASSETTE PSPD 06- 182(1) 18)S0NY MICRO CASSETTE %WO DS-34W) 19)CO PSPD 084970) NEW MIAMI Ceirrenal Mil. 31E-MM EPSTEIN. Pendng_Inacem> GENERAL 162 E4229229 (31) 32) ONE THRIFTY 6212L06 YORK InVeSbaaVe PB2 116_02 JEFFREY a RENTAL PvIelon AGREEMENT 3 NOTE FROM 146 (33) 34) ELEVEN COS - (34) 35) MEtgArs BOOK GUESTHOUSE..... . . . (49) (361ONE MESSAGE (50) (37) T140 COMPACT FLASH CARDS (SI) (38) SD( CDS • GUEST (39) POWER CORO TO CPU • GUEST HOUSE_. .. (69) (40) CPU - OFFICE.. (55) 41) ONE POWER GAD (58) 42) THREE COS • OFFICE (58) 44) ONE GREEN FRAMED PHOTO (59) EFTA00175056 1) ONE PHONE MESSAGE BOOK Pl3P005-1024 (1) 21 THREE PHONE MESSAGE ONE FILE FOLDER WITH TWO FILES (3)4) SHREDDED PAPER (4)5) ONE FILE FOLDER • ORANGE (7)8) BLACK FRAMED PHOTO OF NUOE GIRL (8i 9ININE PICTURES IN FRAMES (9) 101 EIGHT PHOTOS FROM OFFICE (10) 11/ TWO PHOTOS • SITTING ROOM (11)12) TWOPHOTOS - TABLE (12) Gunn& EPSTEIN. 13) TAO VHS TAPES -POOL NEW PAM. 11F-MM- JEFFREY AREA 03114) TWO CDS - MIAMI Inve'llabve Pendng_Inectne GENERAL ILI E4229228 8028/20013 YORK CWS:011 P82 ICRLCS2 a /AARXED 'HAPPY BIRTHDAY' a FLOOR 118) MESSAGE PAD - 1ST 171ONE //ESSAGE PAD -DESK (17) 18) THREE CDS • DESK (18) 19) ONE 8/AM - DESK 119) 20) UNFRA1AED PHOTOS - DESK (20) 21) IWO FRAMED PHOTOS • DESK (21) 221TWO FRAMED PHOTOS • TABLE (22) 23) THREE SOAPS ON A ROPE (23)241 TWO VIBRATORS -TWIN TORPED7 124) 251TWO SOAPS CNA RCPE (26)27) ONE HIGH SCHOOL TRANSCRIPT • AH (27) 281 ONE BOTTLE OF JOY JELLY • MASTER BEDROOM 128) 29) THREE VIDEOTAPES - MASTER BEDROOM One red rope contannF I) Gunn& EPSTEIN. BOOK • AN INVITATION 70 NEW PAM. 11F-MM- JEFFREY YORK MIAMI Inve'llabve P82 108052 Pendng_Inectne GENERAL 188 E6518782 POETRY 2) VICTORIA'S 4130/2007 DyeItion a SECRET WHITE BRAAND a PANTIES SET Canto' EPSTEIN. NEW MIAMI MAI• 31E-MM- JEFFREY E65167,, Ore red rope: ONE (I) BOOK YORK lovertolgaivO P82 108052 Pend00_,Ini ne GENERAL 1614 '4 MASSAGE FOR DUMMIES , ZOO/ DivISOO a NEW MIAMI Criminal MM- Pending_Inactive GENERAL 181 E613783 ONE CELLOPHANE NIONOMIttl YORK Investigative P82 CONTAINING: Division Black LG Verizon cell phone. EFTA00175057 October 26, 2017 ONE CELLOPHANE Criminal CONTAINING: NEW MM- MIAMI Investigative Pending_Inactive GENERAL 1B2 E613762 DVD copy of Search of RUNNUMB YORK PB2 Division Black LG Verizon cell phone. October 26, 2017 Per policy, the retention EC should contain the following information: • The justification for retention • Concurrence from the AUSA • Anticipated Disposition Date The EC is required to be approved by the ASAC level and the Case Agent should set a lead to NY-O558-EVID to update the retention date in Sentinel. A snapshot of the Field Evidence Management Policy guide has been provided below. For Any questions or concerns please reach out to the NY Evidence unit via email at NY Evidence or via phone at OperatioratSupport Tregnician (051) T'etv To:CFI&Offire Tatra!Butram ofTherstigalion Classification: UNCLASSIFIED EFTA00175058

EFTA01718393.pdf

DataSet-10 Unknown 14 pages

pommair • f FBI - Head uarters FOR INTERNAL USE ONLY Name/Room J. Edgar Hoover Building 935 Pennsylvania Avenue, NW Washington, D.C. 20535-0001 TO: 0 Albany t= Indianapolis o Oklahoma City o Abu Dhabi 0 Kabul ca Seoul Cl Albuquerque 0 Jackson o Omaha o Almaty o Kiev o Singapore o Anchorage o Jacksonville o Philadelphia czi Amman ci Kuala Lumpur =Sofia 0 Atlanta o Kansas City o Phoenix o Ankara o Lagos =Tallinn 0 Baltimore o Knoxville o Pittsburgh o Athens o London oTbilisi o Birmingham o Las Vegas 0 Portland o Baghdad cm Madrid oTel Aviv o Boston o Little Rock o Richmond o Bangkok o Manila o Tokyo 0 Buffalo o Los Angeles c3 Sacramento Beijing o Mexico City 0 Vienna o Charlotte o Louisviie o Saint Louis o Berlin o Moscow t=i Warsaw o Chicago em his ci Salt Lake City o Bern o Nairobi 0 o Cincinnati Miami o San Antonio o Bogota ci New Delhi o Cleveland o Milwaukee o San Diego o Brasilia =Ottawa o Columbia cc, Minneapolis o San Francisco o Bridgetown cm Panama City 0 Dallas o Mobile 0 San Juan o Brussels o Paris 0 Denver o Newark =I Seattle o Bucharest 0 Prague =3 Detroit o New Haven o Springfield o Budapest o Pretoria 0 El Paso o New Orleans 0 Tampa o Buenos Aires CD Rabat o Honolulu o New York o Washington Field = Cairo o Riyadh o Houston o Norfolk o Canberra =Rome o Caracas O Sanaa o Copenhagen C3 Santiago o Butte ITC 0 Pocatello ITC O Quantico (ERF) o Hong Kong o Santo Domingo o CJIS, Clarksburg o Quantico (CIRG) o Quantico (Lab) o Islamabad 0 Sarajevo o Ft. Monmouth ITC o Quantico (Div. 2) 0 Savannah ITC CLASSIFICATION LEVEL (CHECK ONE> CZI UNCLASSIFIED - NOT SENSITIVE p5 UNCLASSIFIED - SENSITIVE o CONFIDENTIAL Mon Mouton Program o SECRET UNA EFTA01718393 7/16/2004 - 7/19/2004 15 u.ts 16 %um 17 flit Jul.% 19 u.19 ! I Iul2004 EPSTEN ALKIVES N PALM BE-. : calls (9 18 AM) calk (:240 PM) (1241 PM) IN calls (7.15 PM) calls (7 36PM) ath (8.10 PM) ails (10 06 PM) cats (1107AM) cal (12 23 PM) M at 1(1:07 PM) cals... (2.10 PM) calls (2:11 PM) calls (4.49 PM) calls (4 26 PM) callsM4 53 PM) calls J Message Pad from_19MM)*Was in a car accident on her way so can not come. She just got back' (6:45 PM) II Message Pad from 'Me & can come tomorrow any terse alone (6:55 PM) I II calls (11 33 AM) calls= (12 03 PM) calls (3 35 PM) IIIII zalls (3.56 PM) OM ;al Epstein Residence (9:16 PM) calls (8.57 AM) calls (9 33 AM) Jul 2004 to 17 41 17 18 ag. to '"'"'""altrnir as 19 AIN Legend • Iligh: Me:sag! Pad 4e/7re-ft:paten inp 1 EFTA01718394 iMar zoos a47 al—a 51PM) 1M .7: : =:9 / :Mk 711=1 13 13PM IN calill 0 911PM) i ii.(32I PM ag a (9 15 "a . cal= (3 2) PM) cal Erato ItsWest. (10% AM =a " 1114.11 —(a (2 17 DM) 0•IIM 0 59 no Ica 34 PM ' (400 PLO cal-335 PM) (7 21 EM) = as° cal= 0 40 PM) uil 75 PM) Mall (409 PM Truk Put •1030 on En arounf 2 (717cle =` 41_ (a 35 PM) MN a5 InK 7 (a= es( no OM PM talM(953 PM) A = (1) 72 AM) W!(11......) K,...,,o,A11)41M (IV NS AIM ore, 31MO IMOcalMal 91AK 'o53 AM) es readmit cal= (II 10MA) a Enloe Raneletce c,1 (345 PM = 1.1= (913 AM) M B= 055 AN) nem w AM Am7.11Eatt at Wear C 1 X AK. cd (1)38AM) cal 26 AM ill cal.. (1051 APM iel..029 AIM a 0146 A14) MN AIM" AM) IIMS 1d II 53 A14) 1 PM/ IMA= 003 MO (I 16 1M1 'rub Pia NS& aamas).7' =1=7 4 25PM) (2 31 Pm) r PM col= =can" e g PM) Trask ' t, calm 5 lOpro Owlet tt. vacant( to.inf.: Tr P.41=catinnc(1at 5 13• Trash Pe wall Stardom 1031 Manage P•4 E (v. mosaic/ Mar 20:6 Ape N705 1_ _ A_ 1_ 1_1 _t _ I_ 1_ _I I 1 I I 1 1 1 1 i Min II= II DIA " Ill" "C PE/ LIP " Mr " . IMM= am", Ciesipi• lob EFTA01718395 Sep 2005 cal (9.59 AM) (9 59 AM) MO call (10 05 AM) call (11:48 AM) call (5.17 PM) MI call (8.46 AM) Epstein Residence call (10 31 AM) Illiext message (10:51 AM) Epstein Residence call (11 03 AM) text message (11:15 PM) cat (11:45 AM) cal— (12.30 PM) cal (9:24 AM) ! Epstein Residence can (942 AM) call (12.10 AM) Trash Pull for a good tine call Stall) Trash Pull 1M :swot come at 7pm tomorrow b/c of soccer' Trash Pun 1pm. 4 30pm, Tuna 9Prn. 12 (back side 'delude answer tomorrow. unprommART Sep 2005 J Legend Fhght • Trash Pill] astray Epstein. Tnp EFTA01718396 Sep 2005 Oct 2065 I calM11 57 AMP :4= ;3 26 PM) i nl' M a eg (12 41 PM) (1242PM) I = call= (12 46 PM) Mt all= (1246 PM) Nil cal.. (142 PM) "1'1=706 PM) message (8 56 AM) 1 cal= (9.35 AM) Mi ca 1 (9 32 AM) 1 Message Psi frcelli. 1=lortzened at : la= in 4pne (9.50 AM) cali (1142 AM) cal= (4 32 PM) cal Epstein Residence (6 48 PM) n1651 P) _can (9 37 P) = can (9.38 Pty =‘ 46 (9 48 Plst) _cal (937 AM) caDMI(11 21AM) calls (3 59 PM) cal= (400 PM) = el° (4 01PM) Message Pad from.. Mvs11 be linos late' (4 10 PM) (936 (641210 Igo cal, AM) Mica (10 57 AM) call (11 15 AM) allot 21 AM) Sep 2005 Oct 2005 I I 1 1 I I I I I El Flight ■ Meccas/. Pad II seam teem • 0.5 EFTA01718397 (AA it- P ic k a e4, et -rf bTa_. EFTA01718398 fi • • • • • 03/12/2004 thru 07/04/2004 thru 08/21/ 004 thru • 07)22/2004 thru 12/06/2004 thru 02/13/2005 thru 07/24/2005 x ■ 7/19/2004 . 11/02/2005 • 08/23/2005 11/26/2005 10/03/2005 04/25/2004 [Fru 07/15/2004 thru OS/1 / 004 thn 11/12/20▪ 04 thru 1/13/203• 5 thru 10/04/2005 07/08/2035 02/17/2005 03/29/2005 10/2/2005 ti en 3775 4950 3116 4059 Li 1318)4 .413 EFTA01718399 U et.c EFTA01718400 (Dsbron ens ‘otort • 03/1 / 004 thru U 07/04/2004 thru • • 08/21/ 004 thru IN . 07/22/2004 thru 12/06/2004 thru 02/13/2005 thru 07/24/2005 7/19/2004 11/02/2005 08/23/2005 11/26/2[05 El 10/03/2005 I fl . . in 04/25/2004 thru 07/15/2 E004 l Ulm 08/19/2004 thru 11/12/2004 thru 1/13/2005 thru 10/06/2005 07/08/2005 02/17/2005 03/29/2005 10/2 2005 r I 73 96 rdr# Ir II SO 24 EFTA01718401 frown M . • . M . 03/1 /2004 thru 07/04/2004 thru 07/22/ 004 thru 08/21/ 004 thru 12/06/2004 thru 02/13/ 005 thru 07/24/2005 . 7/19/2004 .■ 11/02/2005 08/23/2005 11/26/2005 10/03/1005 . M fl 11 04/25/ 004 thru 02/15/2004 thru 06/1 /2004 thro 11/1 / 004 Oro 1/13/2005 thru i r 10/06/2005 07/08/2005 02/17/2005 03/29/2005 10/2 2005 ll A ste a 411 IC 73 96 ll A.... 24 381; ll ll EFTA01718402 ■ 07/04/2004 thru 08/2 /20▪ 04 thru 11/12/2004 thru 07/2 /• 004 thru 02/13/2005 thru 03/29/2005 7/19/2004 11/02/2005 08,23/2005 ■ ■ ■ 10/03/2005 fl ■ fl 04/25/2004 thru 07/15/2004 thru 08/19/ 004 thru 12/06/2004 thru 03/12/20▪ 04 thru in 10/06/7005 07/08/7005 ii 7 02/17/2005 A- 3815 11/26/2005 07/24/2005 1k 781 1 283 382 1 34 25 9476 ti ll A Rice 1 EFTA01718403 Whey Conan red leffrev Einten 03/12/20▪ 04 thru 07/15/20▪ 04 thru 08/21/20▪04 thru 12/06/20▪ 04 thus 07/24/2005 07/08/2005 08/23/2005 11/26/2005 MI . 04/2512004 thru 07/22/2004 thru 11/12/2004 thru 02/13/2005 thru 10/06/2005 11/02/2005 03/29/2005 10/03/2005 tI fi 16 II EFTA01718404 1)7( EFTA01718405 en aM Jeffrey Epstein • • • • 03/12/2004 thru 07/15/2004 Lbw 08/21/2004 that 12/06/2004 thru 07/24/2005 07/08/2005 08/23/2005 11/26/2005 ■ • ■ 04/25/2004 thru 07/22/2004 thru 11/12/2004 thru 02/13/20▪ 05 thru 10/06/2005 11/02/2005 03/29/2005 10/03/2005 xl ti xl 3 1 16 10 EFTA01718406

EFTA00159483.pdf

DataSet-10 Unknown 227 pages

Plaintiff, JEFFREY EPSTEIN, Defendant. Reported By: Wendy Beath Notary Public, State of Florida Esquire Deposition West Palm Beach SUBJECT TO Larry Visoski 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 4 Suite 1650 5 6 7 On behalf of the Defendant: 8 9 10 11 On behalf of the Witness: 12 BRUCE REINHART, ESQUIRE 13 Suite 1400 14 15 ALSO PRESENT: 16 1220 N.W. 157th Avenue 17 18 19 20 21 22 23 24 25 SUBJECT TO Larry Visoski 1 2 3 4 5 WITNESS: 6 LARRY VISOSKI 7 BY MR. EDWARDS: 6 8 BY MR. CRITTON: BY MR. EDWARDS: 9 BY MR. CRITTON: 10 11 12 13 14 15 16 NUMBER 17 PLAINTIFF'S EX. 1 18 19 PLAINTIFF'S EX. 2 PLAINTIFF'S EX. 3 20 PLAINTIFF'S EX. 4 PLAINTIFF'S EX. 5 21 22 23 24 25 SUBJECT TO Larry Visoski 1 2 3 Deposition 4 Certified 5 the State 6 7 8 9 10 11 12 even 13 14 15 16 17 was produced 18 19 20 21 22 23 24 have to deal 25 SUBJECT Larry Visoski 1 that 2 3 and not 4 because 5 6 7 have 8 9 10 put on? 11 12 13 agree 14 we'll 15 16 these 17 understanding 18 19 20 file 21 22 I'm not 23 my office 24 25 what SUBJECT TO Larry Visoski 1 2 Thereupon, 3 4 having 5 and testified as follows: 6 7 8 BY MR. EDWARDS: 9 10 11 12 deposition taken 13 A. No. 14 15 you questions. 16 give us answers that 17 court reporter can 18 other verbal 19 when 20 your 21 pictures or 22 A. I understand. 23 24 this in 25 or not -- but I SUBJECT Larry Visoski 1 the question 2 the question. 3 4 5 6 Q. Right. 7 8 9 it's true. 10 11 12 BY MR. EDWARDS: 13 14 understand the question 15 don't 16 best of 17 it, I will. 18 A. Okay. 19 20 A. 22 23 24 25 A. SUBJECT Larry Visoski 1 Q. 2 A. 3 4 S 10 11 A. NES, LLC. 12 13 14 do the 15 16 A. Yes. 17 18 since 1991? 19 A. Yes. 20 21 22 that my check 23 24 them paying you? 25 SUBJECT TO Larry Visoski 1 helicopters. 2 3 you answer to at NES, LLC? 4 5 from 6 MESSAGE PAD 119 MESSAGE PAD 119 COMPLAINT 139 INMATE VISITOR LOG 161 3527-003 Page 3 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009678 EFTA00159485 October 15, 2009 4 PROCEED I NGS taken before Wendy Beath Anderson, Realtime Reporter and Notary Public in and for of Florida at Large, in the above cause. - - - MR. EDWARDS: We're going to put something on the record about -- well, we'll do it this way -- MR. REINHART: Do it at the end, after we get him -- whatever you want. It's your show MR. EDWARDS: Okay. There were don't think Mr. Willits is aware of this. There was a subpoena duces tecum for this witness, as well as the previous witness, which was another pilot, Dave Rogers, and that duces tecum was to bring the flight logs related from 1998 through 2005. What at the previous deposition were flight logs from 2002 through 2005, and now Mr. Reinhart has agreed to produce the remainder of the flight logs requested, those going from 1998 through 2002. MR. REINHART: Correct. They're pilot logs, not flight logs. There are other records we indicated are corporate records, and with those you with Mr. Critton. MR. CRITTON: However, with the proviso, too, 3527-003 Page 4 of 227 TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009679 EFTA00159486 October 15, 2009 5 we're going to work out that these records are to be used within the confines of this litigation to be spread to the press or anyone else, they do contain confidential information as to who may have been on the plane and other records of Mr. Rogers, which but for the subpoena would been only available to the FAA or some other law enforcement agencies. MR. EDWARDS: Okay. Is that all you want to MR. CRITTON: Yes. MR. EDWARDS: I'm not saying I necessarily or disagree with you. That's something that deal with some other day. MR. CRITTON: Bruce, you'd better produce records, but there has to be some sort of before -- MR. REINHART: Correct. MR. EDWARDS: I won't do anything until you whatever you until we work whatever it is out in court. I'll say that on the record, that doing anything with the records outside of until some judge deals with it. MR. REINHART: And for the record, I'll adopt Mr. Critton said on this one limited occasion. 3527-003 Page 5 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009680 EFTA00159487 October 15, 2009 6 MR. EDWARDS: All right. (LARRY VISOSKI) been first duly sworn or affirmed, was examined THE WITNESS: Yes, I do. DIRECT EXAMINATION Q. Can you tell us your name for the record. A. Lawrence Visoski, Jr. Q. And Mr. Visoski, have you ever had your before? Q. Okay. Here's the process: I'm going to ask You're going to give us answers. Try to we all understand and that the take down, such as yes, no, or some answer that we can understand. It's easy we get in a casual conversation to nod or shake head, and the court reporter is not writing anything else. Q. The other thing is, and I've been accused of other depositions -- I don't know if it's true need to wait until you finish answering 3527-003 Page 6 of 227 TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000968I EFTA00159488 October 15, 2009 7 and you need to wait until I finish asking A. So you're not allowed to interrupt me? Q. And you're not allowed to interrupt me. A. Like I just did? MR. CRITTON: Cara just snickered when you said you've been accused because she recognizes MR. EDWARDS: I don't know what the meaning of her snickering was. Q. But for what it's worth, if you don't or I've asked a bad question, I want you to guess. Give me the best answer to the your knowledge and if you need me to rephrase Q. Okay. Tell me your current address. Q. How long have you lived there? A. Approximately nine years. Q. Okay. Who do you live there with? 3527-003 Page 7 of 227 TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_UXX0682 EFTA00159489 October 15, 2009 8 Q• Who's your employer right now? Q. How long has NES, LLC been your employer? A. I'm guessing. I'd say back 1991. I have to math, but 17, 18 years. Q. Has that been your only employer since 1991? Q. And has that been your only source of income Q. And what is NES, LLC? A. I don't really know. I mean, it's the company comes from. Q. What do you do for NES, LLC that results in A. I am chief pilot for the aircraft and 3527-003 Page 8 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009683 EFTA00159490 October 15, 2009 9 Q. And do you have a specific boss or somebody A. Several people would call to schedule flights the office, being it either Mr. Epstein or, you would just get a phone call and they would Q. Okay. Aside from Mr. Epstein, who else would would call to schedule flights? Q. Leslie who? Q. When's the last time you talked to Leslie A. Probably two weeks ago, three weeks ago. Q. And where is she currently? A. I believe in New York, is where I spoke to her Q. What's the telephone number you call to reach Q. And what address is Leslie Gruff at? A. Do you mean where the office is located? 3527-003 Page 9 of 227 TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009684 EFTA00159491 October 15, 2009 10 Q. And it's my understanding from other that there are also apartments in that building? Q. And Mr. Epstein either owns or leases or rents of those apartments. Is that your MR. CRITTON: Form; speculation. THE WITNESS: I'm only speculating. I don't -- to my understanding, I don't know. Q. Do you know other people that live in that A. Well, it would be myself, Dave Rogers -- well, you say "live,' explain. Q. When you're saying yourself and Dave Rogers -- A. See, we don't live there. I mean, we have -- when we would have a trip. Q. Okay. When you would fly up to New York and New York, the place where you would stay, is A. Yes, that's correct. Q. That's also a location you've indicated in that is the office for NES, LLC? 3527-003 Page 10 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTASO009685 EFTA00159492 October 15, 2009 11 Q. What floor or suite number is NES, LLC in? A. I believe -- well, I don't know that NES, LLC office there. I know that's where Leslie has the where I call. So I don't know for a fact office there. Q. And what suite number, then, would Leslie to answer that telephone number at A. I think it's III. Q. And when you stay at number or what apartment number do you stay Q. And how about Dave Rogers, where does he stay? A. I'm guessing, because it's been some time been there, 10B, but don't quote me on it. Q. Who are the other people in that building that know to stay there on a regular -- fairly regular A. I've seen people in the elevator that, you the airplane. Case in point, maybe but I don't know for a fact that she lives anybody else for that matter. Q. Okay. When you say you've seen 3527-003 Page II of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009686 EFTA00159493 October 15, 2009 12 A. I only assume she lives there. I don't know I'm trying to be honest and factual for So I couldn't honestly say if I knew she lived O. Where do you think lives? A. I would think she lives there. Q. You don't have a better location? A. I don't have another location. A. Not to my knowledge. I mean, I'd only be that people live in that building that -- you don't have any facts to prove that they actually I mean, I don't think you want me to guess. Q. Well, NES, LLC, would you say that the owner controller of that company is Jeffrey Epstein? MR. CRITTON: Form. THE WITNESS: I don't know that for a fact. Q. Jeffrey Epstein is somebody you've indicated worked for for 17 or 18 years, right? Q. And over the 17 or 18 years you've become with him as well, correct? MR. CRITTON: Form. THE WITNESS: I don't understand how you mean 3527-003 Page 12 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009687 EFTA00159494 October 15, 2009 13 Define that. Q. Well, more so than just a pilot that takes him A. That is my job. Q. Right. But you know him on a personal level had personal conversations that don't with flying from Point A to Point B; MR. CRITTON: Form. THE WITNESS: More specific, meaning we talk I mean, does that make you a personal Q. Have you ever gone to his house to eat? Q. Have you been to his New York home? Q. How many occasions have you been to his New MR. CRITTON: Object to form. THE WITNESS: We normally pick up luggage in the lobby, so it would probably be quite often. we depart out of New York, we stop by the pick up luggage and head to the aircraft. 3527-003 Page 13 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009688 EFTA00159495 October 15, 2009 14 Q. Other than picking up luggage, have you been home to visit or socialize with him? A. Not to socialize, no. Q. Have you been to his Palm Beach home? Q. To Mr. Epstein's Palm Beach house? Q. Have you been there? Q. Have you been inside? how many occasions have you been inside A. The same, as far as picking up luggage, and on a regular basis, you know, for a We wouldn't always go to the house to pick it made it easier for loading the it done prior to departure. Q. Is that the only reason that you have ever Beach home over the last 18 years, is Q. What other reasons have you gone there? A. I've set up several home theater equipments, 3527-003 Page 14 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009689 EFTA00159496 October 15, 2009 15 know, televisions and such. Q. Is that another hobby or job or something of Q. Does he pay you for that? A. Not any more than my salary. Q. What's your current salary? A. At this time, 180,000. Q. And what are you paid $180,000 to do? A. To manage his aircraft. Q. What does that entail? A. Scheduling maintenance. Anything that has to flight, whether it be weather, flight and distance to and from a location, any running an operation that has Q. In addition to the 180,000, does he give you A. There have been Christmas bonuses. Q. Over the years, you mean, there have been Q. Is 180,000 the most he's ever paid you? Q. All right. Were you making -- when was the 3527-003 Page 15 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009690 EFTA00159497 October 15, 2009 16 that you were making an amount different than Q. That would be 2008? A. That would be correct. Yeah, we all took a cut, I don't know the exact date. It might have year. It was last Christmas we all took Q. Do you know why? A. Economic reasons. Q. And who told you that you were going to have A. Darren Indyke. Q. And did you ask for an explanation? A. He explained it was due to economic reasons Q. Okay. So in 2008, how much was -- were you paid by NES, LLC? Q. And is 200,000 the most that you've ever made Q. And on top of that $200,000, did you get a year as well? MR. REINHART: Which year are you talking 3527-003 Page 16 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009691 EFTA00159498 October 15, 2009 17 MR. EDWARDS: 2008. THE WITNESS: That year, I think we skipped Christmas bonuses that year. The last bonus might 2007. you ever got a bonus from Mr. Epstein deriving this from you using the term A. Holiday bonus. Q. -- am I correct to assume sorry. Am I to assume that if you got a bonus, there was was at the end of the year, around the Q. Okay. And how much was the 2007 holiday have to ask my wife, to be honest. I my paycheck in 27 years, so I believe it Q. And in 2007 you also made $200,000? A. With a question mark. I'm trying to be as I can, but yes. 3527-003 Page 17 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009692 EFTA00159499 October 15, 2009 18 Q. Something pretty close to that? Q. Okay. So with the bonus it was 210,000, Q. Okay. And how long were you making that A. Probably -- he was very religious about giving increases, so I would probably say 2006, you was -- we would get increment -- increases of year. So I would say 2006. So it you know, progressive. Q. Okay. Do you remember the progression if we Do you remember roughly what the was up through 2007/2008, when you were A. No, I wouldn't know the progression. Q. Okay. Do you remember what you were making and was NES, LLC the company paying you back in A. I don't know. I don't remember. Let me say way. I don't remember. Q. Okay. When -- how long do you remember NES, payer of your check? A. Personally, two years, because I've never seen 3527-003 Page 18 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009693 EFTA00159500 October 15, 2009 19 So I don't even know what's written on the That would be something that only your wife You're right, since she probably wouldn't know answer either, because she's looking at the right and not the top column. Right. When is the first time that you had name NES, LLC, that company? Five, six years, and even questioned what it And I think to this day I couldn't answer honestly, what it stands for. Okay. But it's your understanding that the paying you for the work that you do as a maintain the planes for Jeffrey Epstein? To my understanding, yes. And back in 1991, do you know if it was a was paying you or if it was Epstein directly paying you? I don't remember. I mean, I don't. Okay. Throughout your career with -- as a Jeffrey Epstein, since 1991, has there ever time when you believe you were paid directly from personally versus some company? Not to my knowledge, no. 3527-003 Page 19 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009694 EFTA00159501 October 15, 2009 20 Q. Okay. So whether it was NES, LLC or some company, it was all of a sudden a company name, to of your knowledge? A. Exactly, yes. Q. And back in 1991, do you remember how much you were being paid that year? A. Fifty-five or 60,000, is maybe what I started. A. You're going back a long ways. Q. Your relationship goes back that far. That's chose that year. Q• Okay. Did you get bonuses even back that far? Q. And do you remember what your bonuses were A. 5,000. I mean, that was kind of the -- the Q. Okay. In addition to monitary bonuses, were gifts or any other type of compensation that Jeffrey Epstein provided you? Q. And is that over the span of the 18 years? 3527-003 Page 20 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009695 EFTA00159502 October 15, 2009 21 Q. Okay. Tell me what some of those items are. A. I remember one specifically was a pool heater. Q. Excuse me? A. A pool heater. Q. When was that? Q. Okay. Why did you get that? A. I had built a pool and I didn't have a heater he kind of laughed at me saying, "How can you have a a heater?" So he says, "You ought to get a Q. Where were you when you had that conversation? A. In the airplane. O. How did he know that you had built a pool? A. Just in general conversation. Q. You were having a conversation with Jeffrey Q. And this is something that was happening on airplane, this conversation? A. During the flight. Yeah, it would have been cruise or something. Q. Okay. When you say •during the flight," does 3527-003 Page 21 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009696 EFTA00159503 October 15, 2009 22 A. Again, you're going back a long ways. Q. I understand. We're talking about 1995 right

EFTA00158859.pdf

DataSet-10 Unknown 4 pages

SOD-NY-3027571 Serial 626 -1 of 4 - F0.302 (Rev. 5-11-I0) FEDERAL. BUREAU OF INVESTIGATION Dakamin• 09/14/2021 was interviewed over video conference by AUSA , Detective and Special Agent After being advised of the identity of the above listed individuals and the nature of the interview, provided the following information: worked for JEFFREY EPSTEIN (EPSTEIN) around 2001. She would go there when no one else was there with She would go when EPSTEIN or GHISLAINE MAXWELL (MAXWELL) were not there. would watch the house keepers, water the plants, put out new tooth brushes, clean and gas the cars. Illilliould also take phone calls. ** ould go there for several weeks at a time. had previously spoken with the FBI about this case. The couple that took care of the house lived in the guest house. Around 2003 they called back At that time realized it was too much so she stopped going back. only met EPSTEIN about 1 or 2 times. They hired o make sure that the house keeper did not steal. New York, New York, United States (, Other (Video kwmananm 06/30/2021 at Interview)) hkN SOD-NY-3027571 Iktedraffia 07/20/2021 by This document contains neither recommendations nor conelusiorts ofMe FBI. It is the property or the FIB and is loaned to your agency; it and itscontents are not to be distributed unto& you: agency. 3517-004 Page I of4 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00007995 EFTA00158859 FD.302e (Rev. 5440) SOD-NY-3027571 Serial 626 SOD-NY-3027571 cmgiums m ofFwin a (U) Interview 0 ,On 06/30/2021 ,page 2 of 4 There would be $100's of dollars out on the counter whenilillillas there. M called over. ould put the money in the drawer if the air condition guy would get took messages when the phone rang. s a perfectionist. If the messages weren't perfect, then she would crumble them up and throw them in the garbage. being at EPSTEIN's house and with the wooden spoons in the kitchen. Some of the spoons got broken. recalls the laundry room was right outside in the guest house. Sometimes she would help FRANCINE, the housekeeper, fold towels while she was there. does not remember there being any torture chamber upstairs. recalls the house being upstairs but does not recall what street it was on. jot the job through a friend. She recalls telling that friend that she needed a job in which she could bring her son with her. MAXWELL called and hired recalls MAXWELL taking upstairs to her closet. MAXWELL told hat if any girl came there to not let them wear her clothes. MAXWELL trained On one occasion there was a gas leak in the house so knew to hit the button on the phone that said "New York called and someone answered and called the gas guy. MAXWELL told about this "New York" button for direct access to New York. was always called when the air-conditioning guy or the housekeeper would be there. MAXWELL and EPSTEIN did not want things fixed while they were at the house. MAXWELL told that if the phone rings to take a message on the message pad. The pad had white and blue letters, said messages and had lines. 3517-004 Page 2 of4 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00007996 EFTA00158860 FD.302e (Rev. 5440) SOD-NY-3027571 Serial 626 500—NY-3027571 Cominualicm of F06302 of (U) Interview of NICOLE HESSE .On 06/30/2021 ,pae 3 of 4 If the phone rang while was there she would answer it. recalled that a girl called once and asked if EPSTEIN was in town. said no. The girl was frantic and asked when he would be in town and stated that she did not know. Once EPSTEIN came to the house with lots of girls and bags. said hello and then left. Girls and important people would call. She recalls a female voice asking when is he coming back. This one call stuck out to IIIIIIIHever made calls to other people. met a chef once. She met FRANCINE the house keeper and the air-conditioning guy. Agent Note: At this point in the interview AUSA III shared her screen to show a portion of the message pads (#2) see attached. notices that to the left she recognizes "Nicole Hesse" on the bottom. ■ states the context of the messages did not mean anythin then but she does recognize her handwriting and signature. to her back states "that's my signature for sure". states that she just wrote whatever he said and does not know what the message was about. recognize her handwriting. states that she met MAXWELL in persons about 2 times. The first time was the "closet incident". The second time was a random time that MAXWELL came home when was there. only spoke with MAXWELL about 2 times. felt that MAXWELL and EPSTEIN were obviously boyfriend and girlfriend. They had a weird relationship because MAXWELL had mentioned not letting girls wear her clothes. FRANCINE tells that EPSTEIN is really healthy and he doesn't do drugs or drink. hought maybe EPSTEIN was a good guy. opped working there 3517-004 Page 3 of 4 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00007997 EFTA00158861 FD.302e (Rev. 5440) SOD-NY-3027571 Serial 626 500-NY-3027571 (U) Interview of Continumion of FD•302 of 06/30/2021 h p 4 of 4 Years ago people from the media called bout the case. M a 3517-004 Page 4 of4 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00007998 EFTA00158862

EFTA01250307.pdf

DataSet-10 Unknown 6 pages

• ••A • t, C i .• . E yficTipno Nop,,...*' ..4 • fic -tr. iipz:iiiP cc . •c 1 Z. ... a: , . f:t: . ti: . ill): , . • . 1. 14,4,,,,tik;. .._ ,, . s R.:. ...." C.: -1,a, it i?0 ' - 1- ' - t" ar •,.. ,,int;;:,, 1. . 71:: • s 1i. 4 •Stet * . : I' : 5 .'• AGE AT FIRST •. 15 14 15 • IC.-!l 2 CONTACT r .---- " HIGH SCHC/OL I.,- 9th Grade - Lake Worth HS (.4.3ea‘vette14 / kA.S. 4- Pc...1yr•IStacha14/ ' and John I Leonard I-IS CAJA- H.S. 3 ‘ • BROUGHT BY Ghislaine Mai-well 4 DATES OF Approx-. 1999 2001 - 7/2004 2003110/02/2005 See', v‘.., C1 14 LIM= CONTACT/SOURCE Testimony Testimony/Message Testimony/gTelephone 5 Pad . • &.V....e 6, 1 Air tr.- u3staketar (1;..t&J GIRLS RECRUITED and unidentified females ages 15 - 25. 6 • NUMBER OF Multiple Approx. 10-15 • MASSAGES • . 7 ENTICEMENT t'. : ' ' , . _ . • . • •y. 8 ythe.iteise2.42ilbf ' Interstate Commerce i: 1 •-:" .. r • ' ..r• ...' d• . .. et ., : 1: ;:,:7,feliscif..' .. ... ..,!•Fij-. 4„.'•? ce._ „,:..„..,,: : Telephone Records Connection 9 • . ' • Under 18 at time of YES - 17 YES -14 YES - 15 1/ !LS I 44, Of sexual activity 10 ." • Advised If asked to was state the9 were over advised to... . 18/Advised by was 17 by . • . whom? •‘... . ( 11 • ..." MM22-2009-000160 EFTA_00025675 EFTA01250307 A B C D • E VICT,Y#RI CAP1- : '. ' i ". .... . , . . .. . # • . ., 1 .. - -• ' - • Jane Doe 011. Jane Doe 112 Jane Doe #3 . Jane Goa 04 Knowledge or .. Epstein asked told JE she pp Discussion of Age 1 her age and she was 18 EeSto:t in Ora kak . with JE7 uttered "four" and then . ‘in.a.tr &i:19- a-Nr•Cipp. sad 17. Epstein responded by saying, -4- C5Q w v LAJL as i a) you are fourteen." JE also told_ ka4k600—L -S vas they would not tell anyone. U. . ' p . i v tr—Ivo 12 _ — Payment for YES4200.00-500.00 YES/I200.00 servicesWAmount YES rOO, Vitt 13 • Payment for $100.00her girl Epstein offered 14 recruitment $300.00 to bring Payments made by Epstein Epstein 15' Taken upstairs by LNU/ 16 Clothing worn during Bra and underwear, Topless and Nude. massage topless and nude. Toeless / War wen- 17 MM22-2009-000161 EFTA_00025676 EFTA01250308 A I B 1 C D I J E VICTIM WITNESS DOB . ' y • 1 1 JanixDoe #1 Jane Doe #2 Jane Doe,#3 Jane Doe #4 Sexual activity r 18 _ YES . Masturbation 19 YES yeS Ejaculation YES YES 20 Yes 14 MM22-2009-000162 EFTA_00025677 EFTA01250309 vs A E VICTIM WITNESS DOB 1 Jane Doe #1 Jane Doe #2 Jane Doe #3 Jane Doe #4 Sexual activity with 21 Statements made by Take off your shirt. Epstein Take off your pants. Are you going to get comfortable? Why are you going to keep your panties on? So you are 14. 22 Asked to bring Yes/Epstein Yiis/Epsierl stated JE others/By whom? said no black gi or girls 23 with tattoos.) MM22-2009-000163 EFTA_00025678 EFTA01250310 A B L c I D 1 E VICTIM WITNESS DOB MON 1 Jane Doe #1 Jane Doe #2 Jane Doe #3 Jane Doe #4 Gifts YES - Apartment rent YES - Victoria's Secret YES - $600.00-700.00 to paid by Epstein. bras and underwear, apply toward the purchase massage oils, book of a vehicle. Book - titled "Massage for Massage for Dummies. Dummies." Concert tickets to see the band Incubus at the Sound Advice Amphitheater. • 24 Physical Evidence MP / Massage for Telephone Records (I.e. Message Pads, Dummies Book MP - 9 Trash Pulls, Search Warrant, Payment Documentation, etc.) _ 25 TRAVEL 26 Title 18 USC 2423(b) Dates of Travel/Aircraft 27 I 1 HUMAN SEX TRAFFICKING 28 Title 18 USC 15911,1 ._ _-- ---. _. _ . Who Scheduled and LNU Appointments? i■ 29 --__ 30 Miscellaneous MM22-2009-000164 EFTA_00025679 EFTA01250311 A Et I c r D VICTIM WITNESS DOB IIIMI 1 Jane Doe #1 Jane Doe #2 Jane Doe #3 Jane Doe F4 — .- — __— M posed nude for . recently spoke . of ra hs taken by (Fall 2007). at JE's talked of her twin request. was paid boys and mentioned she $500.00 to pose nude. was livi in Manhattan. described as a storyteller and a bad liar. 31 . Interviewed by PBPD No No No 32 ii4 0 -- 33 Interviewed by FBI Yes Yes V e5.. MM22-2009-000165 EFTA_00025680 EFTA01250312

EFTA01688396.pdf

DataSet-10 Unknown 100 pages

U.B.Deportment of Jostles (A) Federal Bureau of Investigation !i2 B.. Fla Number Z L4:O 0 pry/ -4-40 1r 5e rn't)Y,-- Firja,OF IC CRIMINAL INVESTIGATIVE cassioinate on IL ATIRATIVE FILES Fed R Crim. P. c. Armed and Dangerous FOIPA DO NOT DESTROY NCIC ELSUR OCIS Escape Risk Suicidal Priva4lAcL Other See also Nos leek O4; 1 EFTA01688396 174 (Rev. 3.1848) • • ATTENTION The following documents appearing in FBI files have been reviewed under the provisions of The Freedom of Information Act (FOIA) (Title 5, United States Code, Section 552): Privacy Act of 1974 (PA) (Title 5, United States Code, Section 552a): and/or litigation ig...4 FOIA/PA • Litigation ❑ Executive Order Applied „ i / Requester: ,r+ . 1_46/ et AhP el • Subject: IP env Et2Cieln / Computer or Case Idefitification Number: /6242 gg 2 - 0 0 1 Title of Case: Section *File 21C — Min— roln4 2. Serials Reviewed: Al r Release Location: *File Section This file section has been scanned into the FOIPA Document Processing System (FDPS) prior to National Security Classification review. Please sec the documents located in the FDPS for current classification action, if warranted. File Number: Section Serial(s) Reviewed: FOIPA Requester: FOIPA Subject FOIPA Computer Number File Number: Section Serial(s) Reviewed: FOIPA Requester: FOIPA Subject FO1PA Computer Number: File Number. Section Serial(s) Reviewed: FOIPA Requester. FOIPA Subject FOIPA Computer Number: THIS FORM IS TO BE MAINTAINED AS THE TOP SERIAL OF THE FILE, BUT NOT SERIALIZED. SCANNED BY DocLAB (RMD) ATTENTION DATE: 5-1 -/3 DO NOT REMOVE THIS FILE LAST SERIAL: 70 EFTA01688397 09/06/66 • ICMIPR01 19:11:34 FD-192 Page 1 Title and Character of Case: EPSTEIN. JEFFREY Date Property Acquired: Sourc w h Property Acquired: DET. 08/28/2006 345 Y ROAD PALM BEACH FL 33480 Anticipated Disposition: Ac uired B : . Case ent: Description of Property: Date Entered 1B 1 1) ONE PHONE MESSAGE BOOK PBPD05-1024(1) 2) THREE PHONE MESSAGE BOOKS (2) 3) ONE FILE FOLDER WITH TWO FILES ' (3) 4) SHREDDED PAPER (4) 5) ONE FILE FOLDER - ORANGE (5) 6) BEIGE MASSAGE TABLE (6) 7) BROWN MASSAGE TABLE (7) 8) BLACK FRAMED PHOTO OF NUDE GIRL (8) 9) NINE PICTURES IN FRAMES (9) 10) EIGHT PHOTOS FROM OFFICE (10) 11) TWO PHOTOS - SITTING ROOM (11) 12) TWO PHOTOS - TABLE (12) 13) TWO VHS TAPES - POOL AREA (13) 14) TWO CDS - MARKED "HAPPY BIRTHDAY" (14) 15) THREE FRAMED PHOTOS - CABANA (15) 16) ONE MESSAGE PAD - 1ST FLOOR (16) 17) ONE MESSAGE PAD - DESK (17) 18) THREE CDS - DESK (18) 19) ONE 8MM - DESK (19) 20) UNFRAMED PHOTOS - DESK (20) 21) TWO FRAMED PHOTOS - DESK (21) 22) TWO FRAMED PHOTOS - TABLE (22) 23) THREE SOAPS ON A ROPE (23) 24) TWO VIBRATORS - "TWIN TORPEDO" (24) 25) TWO SOAPS ON A ROPE (25) 26) ONE LARGE FRAMED PICTURE - MA ER BEDROOM (26) 27) ONE HIGH SCHOOL TRANSCRIPT - (27) 28) ONE BOTTLE OF JOY JELLY - MASTER BEDROOM (28) 29) THREE VIDEO TAPES - MASTER BEDROOM (29) 30) SIX FRAMED PHOTOS - MASTER BEDROOM, BATHROOM (30) Barcode: Location: 09/05/2006 Case Number: 31E-MM-108062 Owning Office: MIAMI ..\ 13 • CvNe•-` - EFTA01688398 • Chain of Custody FD-192 Case ID . : 31E-MM-108062 1B1 Barcode . : Accepted By: Printed Name Signature: Reason:..Collected Date/Time:00.4 2-°O‘ ernCtr- Accepted By: Printed Name. Signature. Reason- Date/Time. Accepted By: Printed Name- Signature - Reason. Date/Time• Accepted By: Printed Name Signature• Reason• Date/Time. Accepted By: Printed Name• Signature. Reason- Date/Time. Accepted By: Printed Name- Signature - Reason. Date/Time. Accepted By: Printed Name- Signature- Reason- Date/Time• Accepted By: Printed Name- Signature• Reason- Date/Time. Accepted By: Printed Name. Signature• Reason• Date/Time. Accepted By: Printed Name• Signature. Reason- Date/Time- WEAPONS CHECKED & CLRARED BY FIREARMS INSTRUCTOR Printed Name. Signature. Date. L__ EFTA01688399 ••• 1 4 9/06/06 • • ICMIPR01 19:21:34 FD-192 Page 3 Title and Character of Case: EPSTEIN, JEFFREY Date Property Acquired: Source from which Property Acquired: DET. 08/28/2006 345 II UT IIIIMMUNY ROAD PALM BEACH FL 33480 Anticipated Disposition: Ac ired B : Case A ent: Description of Property: Date Entered 1B 2 31) ONE GREEN MASSAGE TABLE PBPD05-1024 (31) 32) ONE THRIFTY RENTAL AGREEMENT (32) 33) NOTE FROM (33) 34) ELEVEN CDSIIIIIIII CE (34) 35) MESSAGE BOOK - GUEST HOUSE (49) (36) ONE MESSAGE BOOK (50) (37) TWO COMPACT FLASH CARDS (51) (38) SIX CDS - GUEST HOUSE (52) (39) POWER CORD TO CPU - GUEST HOUSE (54) (40) CPU - OFFICE (55) 41) ONE POWER CORD TO CPU - OFFICE (56) 42) THREE CDS - OFFICE (57) 43) ONE PEACH MASSAGE TABLE (58) 44) ONE GREEN FRAMED PHOTO (59) Barcode: Location: 09/05/2006 Case Number: 31E-MM-108062 Owning Office: MIAMI -3/ aiorow f/d3 EFTA01688400 • i Chain of Custody FD-192 Case ID . : 31E-MM-108062 1B2 Barcode . : Accepted By: Printed Name: Signature Reason:..Collected Date/Time:CWar4.9. .. Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature - Reason. Date/Time• Accepted By: Printed Name• Signature- Reason- Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature - Reason. Date/Time• WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR Printed Name• Signature• Date• EFTA01688401 id..4 • • uv/012/06 • ICMIPR01 19:21:34 FD-192 Page 5 Title and Character of Case: EPSTEIN,SREY Date Property Acquired: Source from which Property Acquired: DET 08/28/2006 345 Y ROAD PALM BEACH FL 33480 Anticipated Disposition: • ilailli Description of Property: Date Entered 1B 3 1) TAPED CONVERSATION PBPD 05-237(1) 2) AUDIO TAPE #1 PBPD 05-243(1) 3) AUDIO TAPE #2 (2) 4) COPY OF TAPE #1 (3) 5) MICRO TAPE PBPD 05-256(1) 6) PHOTO LINE-UP PBPD 05-257(1) 7) AUDIO TAPE PBPD 05-294(1) 8) MICRO TAPE (2) 9) CD PBPD 05-295(2) 10) C-90 CASSETTE PBPD 05-313(1) 11) A/x MAIL N.M. PBPD 05-378(1) 12) WHITE PAPER G.M (2) 13) MESSAGE P.S. (3) 14) WHITE PAPER J (4) 15) MONTGOMERY COUNTY, MD J.B. ' (5) 16) WHITE PAPER V. PBPD 05-379(1) 17) WHITE PAPER FLIGHT INFO (2) 18) THREE WHITE PAPERS PREMIO COMPUTER INC (3) 19) WHITE PAPER PHONE # PBPD 05-380(1) 20) YELLOW RECEIPT 04/04/05 (2) 21) WHITE PAPER C.W. (3) 22) WHITE PAPER J. (4) 23) WHITE PAPER FLIGHT 04/05/05 (5) 24) WHITE PAPER G. (6) Barcode: Location: 09/06/2006 Case Number: 31E-MM-108062 Owning Office: MIAMI 3/G- (4" - 10 Coca- EFTA01688402 • • Chain of Custody FD-192 Case ID . : 31E-MM-108062 1B3 Barcode . : Accepted By: Printed Name Signature Reason:..Collected Date/Time:ADZ Accepted By: Printed Name. Signature• Reason- Date/Time. Accepted By: Printed Name. Signature - 'Reason. Date/Time- Accepted By: Printed Name- Signature- Reason- Date/Time. Accepted By: Printed Name. Signature - Reason• Date/Time• Accepted By: Printed Name• Signature• Reason- Date/Time. Accepted By: Printed Name. Signature. Reason. Date/Time- Accepted By: Printed Name. Signature - Reason. Date/Time• Accepted By: Printed Name- Signature- Reason- Date/Time• Accepted By: Printed Name. Signature. Reason• Date/Time• WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR Printed Name- Signature. Date. EFTA01688403 09/06/06 ICMIPR01 19:.21:34 FD-192 Page 7 A Title and Character of Case: Date Property Acquired: Source from whi h Property Acquired: DET. 08/28/2006 345 : O ROAD PALM BEACH FL 33480 Anticipated Disposition: Ac uired II : Case Aaent: Description of Property: Date Entered 1B 4 1) WHITE PAPER A. PBPD 05-381(1) 2) WHITE PAPER JET BLUE RECEIPT (2) 3)• WHITE PAPER JU. (3) 4) WHITE PAPER JO. (4) 5) MESSAGE M.H. (5) 6) WHITE PAPER H. S. (6) 7) WHITE PAPER A. (7) 8) WHITE PAPER J.S. (8) 9) WHITE PAPER H. (9) 10) WHITE PAPER ST. BARTHS (10) 11) MESSAGE - G. (11) 12) MESSAGE - J.L (12) 13) WHITE PAPER - F. (13) 14) MESSAGE S. (14) 15) MESSAGE - J.L. (15) 16) MESSAGE J.L. GIRL (16) 17) WHITE PAPER - S. (17) 18) WHITE PAPER #'S (18) 19) WHITE PAPER - J. (19) 20) WHITE PAPER - J. (20) 21) WHITE PAPER (917) (21) 22) WHITE PAPER D.M. (22) 23) PHONE # PRINT OUT (23) Barcode: Location: 09/06/2006 Case Number: 31E-MM-108062 Owning Office: MIAMI c3/E- mg (orao.2 -Y12 LI EFTA01688404 Chain of Custody FD-192 Case ID . : 31E-MM-108062 1B4 Barcode . : Accepted By: Printed Name: ignature:. Reason:..Collected Date/Time:...? Co..(I.;cow Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature- Reason- Date/Time• Accepted By: Printed Name• Signature - Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time- Accepted By: Printed Name• Signature- Reason- Date/Time• Accepted By: Printed Name• Signature- Reason- Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR Printed Name• Signature• Date• EFTA01688405 0906/06 ICMIPR01 1911{{21:34 PD-192 Page 9 • Title and Character of Case: EPSTEIN, JEFFREY Date Property Acquired: Sour which Property Acquired: DET 08/28/2006 345 SOUTH COUNTY ROAD PALM BEACH FL 33480 Anticipated Disposition: • Description of Property: Date Entered 1B 5 1) FIVE MESSAGE PRINTOUTS PBPD 05-382(1) 2) WHITE PAPER C. J. (2) 3) MESSAGE M. (3) 4) MESSAGE P.S. (4) 5) MESSAGE A. (5) 6) MESSAGE J.L. (6) 7) MESSAGE T. (7) 8) CLEAR PLASTIC STICK (8) 9) TWELVE WHITE PAPER - EXPENDITURES PBPD 05-383(1) 10) WHITE PAPER J. (2) 11) WHITE PAPER D. (3) 12) WHITE PAPER C. (4) 13) WHITE PAPER J. (5) 14) WHITE PAPER J. (6) 15) WHITE PAPER M. (7) 16) WHITE PAPER # (8) 17) MESSAGE A. PBPD 05-384(1) 18) WHITE PAPER T. (2) 19) WHITE PAPER J.H. (3) 20) WHITE PAPER F. (4) 21) MESSAGE G.D. (5) 22) MESSAGE # (6) 23) MESSAGE M.M. H. (7) 24) WHITE PAPER C.W. (8) 25).WHITE PAPER (917) PBPD 05-385(1) 26) WHITE PAPER A. (2) 27) WHITE PAPER E. (3) 28) WHITE PAPER B. F. (4) 29) WHITE PAPER S.B (5) 30) FOUR WHITE PAPERS (6) Barcode: Location: 09/06/2CCG Case Number: 31E-MM-108062 Owning Office: MIAMI (3/O-mh-t-coptog-lE7.5 EFTA01688406 Chain of Custody FD-192 Case ID . : 31E-MM-108062 1BS Barcode . Accepted By: Printed Name: Signature Reason:..Collected Date/Time Onr ‘..ICav-- Acceptedpted By: Printed Name• Signature• Reason. Date/Time- Accepted By: Printed Name. Signature- Reason- Date/Time. Accepted By: Printed Name- Signature- Reason- Date/Time- Accepted By: Printed Name. Signature. Reason. Date/Time- Accepted By: Printed Name Signature. Reason• Date/Time. Accepted By: Printed Name• Signature. Reason- Date/Time- Accepted By: Printed Name. Signature - Reason. Date/Time- Accepted By: Printed Name- Signature - Reason. Date/Time. Accepted By: Printed Name. Signature. Reason. Date/Time- WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR Printed Name• Signature. Date. EFTA01688407 op/adios ICMIPR01 1 21:34 FD-192 Page 11 Title and Character of Case: EPSTEIN, JEFFREY Date Property Acquired: Source from which Property Acquired: DET 08/28/2006 345 QTY ROAD PALM BEACH FL 33480 Anticipated Disposition: Ac ired B : Case A ent: Description of Property: Date Entered 1B 6 1) MEDICAL SUPPLIES PBPD 05-386(1) 2) 727 LETTERHEAD (2) 3) INVOICE #42700 (3) 4) AMAZON.COM A.M. (4) 5) WHITE PAPER J.L. (5) 6) MESSAGE FROM J. (6) 7) MESSAGE FROM J.L. (7) 8) WHITE PAPER 2#S (8) 9) WHITE PAPER (917) (9) 10) MISC. DOCUMENTS - TRASH PULL PBPD 05-874(1) 11) MISC. PAPERWORK - TRASH PULL PBPD 05-878(1) 12) TWO MAGAZINES - TRASH PULL PBPD 05-901(1) 13) PAPER WITH A.S.- TRASH PULL PBPD 05-915(1) 14) VHS T-160 CASSbiib PBPD 05-929(1) 15) SONY MICRO CASSETTE (2) 16) SONY MICRO CASSETTE (3) 17) SONY MICRO CASSETTE (4) 18) SONY MICRO CASSETTE PBPD 05-937(1) 19) SONY MICRO CASSETTE (2) 20) SONY MICRO CASSETTE (3) 21) SONY MICRO CASSETTE (4) 22) MISC PAPERWORK - TRASH PULL PBPD 05-941(1) 23) SONY MICRO CASSETTE PBPD 05-942(1) 24) SONY MICRO CASSETTE (2) 25) MISC PAPERS - TRASH PULL PBPD 05-943(1) 26) CLEAR PIECE OF PLASTIC PBPD 05-944(1) 27) MISC PIECES OF PAPER - TRASH PULL (2) 28) SONY MICRO CASSETTE PBPD 05-945(1) 29) SONY MICRO CASSETTE (2) Barcode: Location: 09/06/2006 Case Number: 31E-MM-108062 Owning Office: MIAMI 31E- l0t0142 EFTA01688408 Chain of Custody PD-192 Case ID . : 31E-MM-108062 1B6 Barcode . : Accepted By: Printed Name: ignature: Reason:..Conecte Date/Time: 0$12..s/2(.3?, C, tier". Accepted By: Printed Name• Signature• Reason. Date/Time. Accepted By: Printed Name- Signature- Reason- Date/Time- Accepted By: Printed Name- Signature- Reason- Date/Time• Accepted By: Printed Name. Signature- Reason- Date/Time. Accepted By: Printed Name Signature• Reason• Date/Time. Accepted By: Printed Name• Signature - Reason. Date/Time. Accepted By: Printed Name- Signature- Reason- Date/Time. Accepted By: Printed Name- Signature. Reason- Date/Time• Accepted By: Printed Name- Signature- Reason- Date/Time• WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR Printed Name• Signature- Date- EFTA01688409 090706/06 ICMIPR01 19:21:34 FD-192 Page 13 Title and Character of Case: EPSTEIN, JEFFREY Date Property Acquired: Source from which Property Acquired: DET 08/28/2006 345 1.11.TY ROAD PALM BEACH FL 33480 Anticipated Disposition: Ac tared E : Description of Property: Date Entered 1B 7 1) SONY MICRO CASSETTE PBDP 05-972(1) 2) SONY MICRO CASSETTE (2) 3) SONY MICRO CASSETTE (3) 4) MISC PAPERWORK - TRASH PULL PBPD 05-1005(1) 5) THREE FLOOR PLANS PBPD 05-1023(1) 6) DRAWING A.H. PBPD 05-1025(1) 7) MISC PHONE MESSAGES - TRASH PULL PBPD 05-1027(1) 8) T-160 VIDEO CASSh -i8 PBPD 05-1052(1) 9) SONY MICRO CASSETTE (2) 10) SONY MICRO CASS lib PBPD 05-1064(1) 11) THREE EMAIL FROM DMV/DL (2) 12) VHS VIDEO CASSETTE PBPD 05-1069(1) 13) VHS VIDEO CASSETTE (2) 14) CD PBPD 05-1079(2) 15) MINI DV TAPE PBPD 05-1080(1) 16) VHS VIDEO TAPE... (2) 17) MINI DV TAPE (3) 18) SONY MICRO CASSETTE PBPD 05-1087(1) 19) SONY MICRO CASSETTE PBPD 05-1090(1) 20) SONY MICRO CASSETTE PBPD 05-1092(1) 21) PHOTO LINE-UP (2) 22) SONY MICRO CASSETTE PBPD 05-1203(1) Barcode: Location: 09/06/2006 Case Number: 31E-MM-108062 Owning Office: MIAMI 1 31e (06062-167 EFTA01688410 Chain of Custody FD-192 Case ID . : 31E-MM-108062 1B7 Barcode . : Accepted By: Printed Name: Signature: Reason:..Collected Date/Time. 47/ 2.1( 7/3) Co Accepted By: Printed Name. Signature• Reason Date/Time. Accepted By: Printed Name• Signature• Reason• Date/Time. Accepted By: Printed Name Signature. Reason. Date/Time. Accepted By: Printed Name- Signature- Reason- Date/Time. Accepted By: Printed Name- Signature- Reason- Date/Time• Accepted By: Printed Name- Signature• Reason• Date/Time. Accepted By: Printed Name Signature• Reason• Date/Time. Accepted By: Printed Name Signature. Reason. Date/Time- Accepted By: Printed Name- Signature- Reason- Date/Time- WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR Printed Name- Signature- Date• EFTA01688411 r • 09,4f6/06 • ICMIPR01 /9:21:34 FD-192 Page 15 Title and Character of Case: EPSTEIN, JEFFREY Date Property Acquired: Source from which Property Acquired: DET 08/28/2006 345 11.1.1TY ROAD PALM BEACH FL 33480 Anticipated Disposition: Ac uired B : Case A•ent: Description of Property: Date Entered 1B 8 1) VHS TAPE OP SURVEILLANCE PBPD 05-1205(1) 2) VHS TAPE OF SURVEILLANCE (2) 3) VHS TAPE (3) 4) VHS TAPE (4) 5) VHS TAPE (5)• 6) VHS TAPE (6) 7) VHS TAPE (7) 8) SIXTEEN DVD-R DISCS PESO PBPD 05-1219(1) 9) CINGULAR ENVELOPE WITH SUBPOENA INFO PBPD 05-1245(1) 10) CINGULAR WIRELESS CD (2) 11) SONY MICRO CASSETTE PBPD 06-21(1) 12) GREEN FOLDER A. PBPD 06-24(1) 13) SONY MICRO CASSETTE PBPD 06-39(1) 14) SONY MICRO CASSETTE PBPD 06-59(1) 15) SONY MICRO CASSETTE PBPD 06-95(1) 16) T-160 VIDEO CASSETTE PBPD 06-120(1) 17) SONY MICRO CASSETTE PBPD 06-182(1) 18) SONY MICRO CASSETTE ' PBPD 06-348(1) 19) CD PBPD 06-397(1) Barcode: Location: 09/06/2006 • • Case Number: 31E-MM-108062 Owning Office: MIAMI CI (-3/E-mm-fos'042-/A Sr EFTA01688412 I Chain of Custody FD-192 Case ID . 31E-MM-108062 188 Barcode Accepted By: Printed Name Signature: Reason:..Collected Date/Time:,9X.2$ a<<0 C, I I; dutrs- Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature- Reason- Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature - Reason. Date/Time• Accepted By: Printed Name• Signature - Reason. Date/Time• Accepted By: Printed Name• Signature - Reason. Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time• Accepted By: Printed Name• Signature• Reason• Date/Time- WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR Printed Name• Signature• Date• EFTA01688413 (Rev.01.31.2003) • FEDERAL BUREAU OF INVESTIGATION Precedence: ROUTINE Date: 07/24/2006 To: Miami Attn: SSA From: Miami C So gnut adact 28:-2 .11 , Approved By: Drafted By: OREM• -1 =10 Case ID #: 31E-MM 4/11#7Strj 2/!94 CIAs...:.7__". ALPHA 4= Title: Synopsis: 000 - ;1:1 PROSTITUTION efucm inns,— DATE To request case be opened and assigned. AC ..4 1 Details: From March 2005 through February 2006, the Palm Beach County Police Department conducted an_ingestigation re s -in DOB 01/20/1953 and !it tlp e underage female n or a en one local area hi were recruited by or t e purposes (:o,_ engaging in sexual activity w-t effery Epstein. The xual activity between Epstein and the minors occurred at 2 rirs'-• 4.esidence, -358—EI"Brillo-WaSt; PalM Beach,'Florida.` received monetary coMpeniation-for-her'reCruitment some incidents, her delivery of the underage females. AP. Appointment ed for Epstein by his personal assistant, Once the underage females arr. t Epstein's residence, they would be introduced to iiiili, who in turn would take their names and telephone num ers. The underage females would then be taken to Epstein's bedroom where they were instructed by Epstein to remove partial or all of their clothing and provide Epstein a massage. In some cases as the minor •rovided the massage Epstein would at least three occasions, Epstein had Ia.%3epg 0 3/6. ....f08.0Cia-• HK EFTA01688414 To: Miami From: Iliami Re: 31E-MM, 07/24/2006 females. At the conclusion of the sexual activity, t e minors were paid sums of money ranging from $200.00 - $1,000.00. It is requested by SA that the above captioned case be opened and asslgne . ♦♦ 2 EFTA01688415 c • abable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Police Case#: 05-368 (1) Defendant: Jeffrey Epstein Race/Sex: White Male DOB: 01-20-1953 Charges: Unlawful Sexual Activity with a Minor (4) counts Lewd and Lascivious Molestation From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, and Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein, 358 El Grillo Way, Palm Beach. Several of the victims were recruited by and gid, brought to the residence by to perform massages for Epstein, for which received monetary compensation. During the visit they would be introduced to , Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the masse e. As the victims corn lied and vided the masse es E stein would At the conclusion of the massages the victims were paid sums of money ranging front $200 - $1,000. The facts, as reported, arc as follows: On 03/15/2005, A white female, hereinafter referred to as do and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. . reported that a subject known to her as "Jeff" had touched her hile within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, stated that and classmate , worked for a wealthy man and did sexual favors for him. She also admitted that ad offered her an opportunity to make money. During the beginning of the month of February 2005, explained that she was first approached by to go with her to Epstein's house. • stated that along with a Hispanic female, later identified at pick her up at her father's house on a Sunday.• was not sure of the exact dates but knew it was a Sunday. • told her father that they were going shopping but in reality drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed State of Florida before me this lit day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 3f 6- st '" /Oro lid2 EFTA01688416 •bable Cause Affidavit • Palm Beach Police Department Agency OFtlg FLO 500600 conversation occurred between and whereas reportedly told. that if Jeff asked her age, she should say she was eighteen. Itaajater confirmed by the Ss father that picked his daughter up on February 6, 2005. According to father, drove a pick up truck. described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house.stated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they wanter stated they were there to see Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly thereafter, Epstein and his assistant, described as white female with blond hair and later identified as entered the kitchen. Epstein introduced himself to described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving■ alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. was instructed to follow upstairs. recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa.. recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would he up in a second. Epstein entered the room wearing only a towel and told. to take off her clothes.. stated Epstein was stem when he told her to take off her clothes.. said she did not know what to do as she was the only one there in the room so she took off her shirt leaving her bra on. Epstein had removed his towel and told the. to take off everything.I stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. stated she then removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. As• began to give Epstein the massage, he told her to get on his back.. stated The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA01688417 kbable Cause Affidavit • Palm Beach Police Department Agency ORIN FLO 500600 • recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. Epstein then left the room and E . She went back downstairs where she met with_. IE said she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked.. to leave her phone number. As and were leaving the house, told El she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for .6 to assist with the on. At our direction cellular telephone IMI Si • spoke with conducted controlled taped phone calls to in an attempt to arrange another meeting with Epstein. IE asked what did she need to do to make more money. .fated, "the more you do, the more you get paid." had subsequently called back • and left a voice mail message for her indicating that she had set up an tment for ato go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from fi voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor of the . The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated =land name at 11:00 ant. This was the time frame Sad informed. to be ready to go work at Epstein's house. On October 3, 2005, Sgt and I went to -s residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. d I knocked on the door and met with was told that we were investigating

EFTA00075841.pdf

DataSet-10 Unknown 2 pages

GG 000 Thud Avenue New Yoek. NY 10022 COHEN & GRESSER LLP +1 212 957 7600 phone owswoohensresser corn Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com April 7, 2021 BY EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write to renew our request that you produce the FBI case file concerning the investigation of We had originally asked for the file in our discovery request letter dated October 13, 2020. You denied our request for the file on October 28, 2020, stating that the file has "no relation to your client and has no bearing on the charges in this case." See 10/28/2020 Letter at 7. Now that the S2 supersedii.dictment has broadened the allegations against Ms. Maxwell up to in or about 2004, Mr. is very much relevant to the charges in this case and the file should be produced. For example, in your letter to defense counsel dated March 29, 2021, you specifically identified several Bates numbers which you say relate to the new accuser referenced in the indictment as Minor Victim-4. Those Bates numbers include messa e ads containing numerous n that we believe were taken by, and signed by, using the initials ese message pad slips appear to be some of only a handful of documents upon which the nil:e nt intends to rely to corroborate the testimony of Accuser-4. Furthermore, Mr. was discussed extensively at the February 29, 2016 meeting between AUS nd attorneys Brad Edwards, Stan Pottinger and Peter Skinner, where the attorneys pitched the government to open an investigation into Epstein and Maxwell. See SDNY_GM_02742882. The notes appear to reflect an explanation of Mr. conduct that formed the basis for his obstruction charge. See id. As you are aware, the discussions at the February 29, 2016 meeting are squarely at issue in Ms. Maxwell's motion to suppress. As such, the information contained in the FBI investigation file will be relevant at any hearing that takes place on Ms. Maxwell's motion and should therefore be produced. EFTA00075841 April 7, 2021 Page 2 Thank you in advance for your attention to these matters. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP cc: Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi Sternheim, Esq. EFTA00075842

EFTA00164738.pdf

DataSet-10 Unknown 1 pages

Epstein/Maxwell Timeline On 12/6/18, FBI NY initiated a child sex trafficking case after SDNY contacted FBI regarding several victims that had been sexually abused by JE in the mid-2000s. Epstein was indicted on 7/2/19 and arrested on 7/6/19 for Child sex trafficking and conspiracy. Residential NYC SW on 7/6. Arrested Arrest 7/6/18 at Terterboro airport, NJ. Another NYC SW on 7/11and LSJ SW on 8/12. NY notified JE found dead in his cell on 8/10. FBI open death invest 8/12/19-12/5/22. GM: Ghislaine Maxwell was first mentioned in the case file 4/23/19. GM was indicted on 6/29/20 and arrested 7/2/20. Trial began on 11/28/21. She was convicted on 12/29/21 of 5 out of 6 counts, including 1ct sex traff minor, transport minor with intent to engage in crim sex activity, and 3ct conspiracy. (Not sustained ict enticing a minor). She was sentenced on 6/28/22 to 20 years. Appeals window closes 4/10/25. Trial: Gov exhibits included message pad (black contact book) excerpts, birth certs of minor victims, photos of people and places, photos/vids from PBPD search, FBI NY search photos, financial exhibits, phone records, flight records, maps, Interlochen records (what is this??), school records, fedex records, Mar-A-Lago records, signed stipulations, and other physical and electronically stored info/docs. 72MM: Obst of justice, former employee, 10/28/09-3/13/13 FBI Miami Palm Beach RA, UCO, all evid sent to NY in 2019 and included into 50D. Only evid item of use was the black contact book. 31E: Child Prost from PBPD, 7/25/06, result guilty plea state court. Case file and all 1B sent to NY in 2019. Pending Inactive for civil litigation. MCC drug invest open-10/21/23 Civil Rights/Color or Law, MCC correct officer, open-10/21/23 EFTA00164738

EFTA00102168.pdf

DataSet-10 Unknown 3 pages

From: To: Cc: Subject: Re: Discovery questions Date: Tue, 18 Aug 2020 22:39:54 +0000 Hey guys, Apologies but today I was out In the field on surveillance and Mandy was also out of the office so we've not been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best to get on this list. That being said I don't want to make you any promises that everything will be compiled by tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if you like to square some of this away. Maurene I did receive your "pages from Miami_case_docs" PDF. Child Exploitation Human Trafficking Task Force °Nicol Cell: Fax: From Sent: Tuesday, August 18, 2020 6:03 PM To: Cc: Subject: E: Discovery questions Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these materials tomorrow or Thursday? " hanksw From: Sent: Tuesday, August 18, 2020 4:41PM To: EFTA00102168 Cc: Subject: RE: Discovery questions Hi- The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to provide us with all of those scans this week? With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes on them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans. Thanks, From: Sent: Tuesday, August 18, 2020 4:45 AM To: C Subject: RE: Discovery questions Sorry, got a bounceback for Mandy too. I'm just attaching the one page I referenced in my email below. Hopefully that will go through. From: Sent: Tuesday, August 18, 2020 4:40 AM To: Subject: FW: Discovery questions I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went through for Mandy so she can see it. If not, please let me know. .- hankss From: Sent: Tuesday, August 18, 2020 4:33 AM To: Cc: Subject: Discovery questions Hi Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent batch you provided, and wanted to check in on the longer term tasks we discussed last month. EFTA00102169 Below are some questions regarding the discovery Paul dropped off a few days ago with requests for additional items: • The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it contains grand jury transcripts. Have you given us those transcripts? • The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think Mandy mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad—and those copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad scans" folder. Would you please get us a scans of these without post-its on them? • It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant. Would you please get us copies of those returns? Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you please be able to get us these this week? • Full FBI sentinel file • CART paperwork regarding the extraction of data from all devices seized during the investigation • All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard copy) seized during the investigation, including from Epstein's properties. • Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials • Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how many such images were scanned, where they were from, and where they are being stored. • Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how many such images were located, where they were from, and where they are being stored. Please let me know if you have any questions or if it would be useful to hop on a call. EFTA00102170

EFTA00085051.pdf

DataSet-10 Unknown 2 pages

From: To: Cc: Subject: RE: Discovery questions Date: Tue, 18 Aug 2020 08:45:17 +0000 Attachments: Pages_from_Miami_Case_Docs.pdf Sorry, got a bounceback for M'too. I'm just attaching the one page I referenced in my email below. Hopefully that will go through. From Sent: ues ay, ugust , : AM To: > Cc: Subject: FW: Discovery questions I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went through for Mandy so she can see it. If not, please let me know. Thanks, From: Sent: Tuesday, August 18, 2020 4:33 AM To: (NY) (FBI) < > Cc: (USANYS) Subject: Discovery questions Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent batch you provided, and wanted to check in on the longer term tasks we discussed last month. Below are some questions regarding the discover dropped off a few days ago with requests for additional items: • The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it contains grand jury transcripts. Have you given us those transcripts? • The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad—and those copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad scans" folder. Would you please get us a scans of these without post-its on them? • It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant. Would you please get us copies of those returns? EFTA00085051 Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you please be able to get us these this week? • Full FBI sentinel file • CART paperwork regarding the extraction of data from all devices seized during the investigation • All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard copy) seized during the investigation, including from Epstein's properties. • Scans of the filesMprovided to the FBI and provide us with all of those scanned materials • Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how many such images were scanned, where they were from, and where they are being stored. • Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how many such images were located, where they were from, and where they are being stored. Please let me know if you have any questions or if it would be useful to hop on a call. Thanks very much, EFTA00085052

EFTA01085219.pdf

DataSet-10 Unknown 11 pages

#291874/mep IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAO JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTI [STEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, AMENDED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS COMES NOW the Counterplaintiff, BRADLEY J. EDWARDS, by and through his undersigned attorneys and hereby lists his exhibits for trial as follows: DEF. PLF. DATE OFFERED MARK ADMIT NO. NO. TED DESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED I. All applicable criminal statutes t 2. All applicable Florida Statutes 3. All applicable Rules of Evidence 4. Video of Defendant, Jeffrey Epstein's home and route from Plaintiff tc Defendant's home 5. Order confirmation from Amazon.com for purchase of books "SM 1 Realistic Introduction," "Slave Craft: Roadmap for Erotic Servitude- Principles, Skills and Tools" and "Training Miss Abernathy: A Wor: for Erotic Slaves and Their Owners" 6. Non-Prosecution Agreement EFTA01085219 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 2 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED 7. Jane Doe 102 Complaint 8 Messages taken from message pads found at Defendant's home Documents related to Jeffrey Epstein produced by Alfredo Rodrigue: 9. Jeffrey Epstein flight logs 10 Jeffrey Epstein phone records 11. hone records 12 Jail Visitation Logs 13 Jeffrey Epstein's probation file 14. All probable cause affidavits related to criminal investigation ofleffi 15. Epstein All evidence, infonnation and documents taken or possessed by FBI 16. related to criminal investigation of Jeffrey Epstein Plaintiffs and other victims' statements to the FBI related to criminal 17. investigation of Jeffrey Epstein Video of Search Warrant of Jeffrey Epstein's home being executed IS. Application for Search Warrant of Jeffrey Epstein's home 19 Complaint Jane Doe v. Epstein and all subsequent Amended Comply 20. All records of homes, properties, bank accounts and any and all reco 21. related to Jeffrey Epstein's assets Jeffrey Epstein's passport (or copy) 22. Jeffrey Epstein's driver's license (or copy) 23 List of corporations owned by Jeffrey Epstein 24 All documents evidencing relationship between Jeffrey Epstein and . 25. Luc Brunel EFTA01085220 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 3 of II DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS All documents evidencing relationship between Jeffrey Epstein and I' 26. or any modeling agencies Yearbooks of plaintiff, Jane Doe 27 2002 Royal Palm Beach High School Year Book 28 2001 Royal Palm Beach High School Year Book 29 2003 Palm Beach Gardens High School Year Book 30. Affidavit and Application for Search Warrant on Jeffrey Epstein's hr 31 Tape recording or transcript of recording of conversation between Je 32 Epstein and George Rush Notepads found in Jeffrey Epstein's home and/or during trash pulls 33. outside of his home during criminal investigation The Palm Beach State Attorney's Criminal file against Jeffrey Epstei 34. All documents related to Jeffrey Epstein's 6/30/08 conviction 35. Jeffrey Epstein's criminal plea colloquy 36. 37. Public records from the Department of Corrections related to Jeffrey Epstein Records from the Florida Department of Law Enforcement related to 38 Jeffrey Epstein All statements made by Jeffrey Epstein 39 List of properties and vehicles in Larry Visoski's name 40. All of Jeffrey Epstein's Responses to Requests for Production, Requ. 41 for Admission, Answers to Interrogatories in this matter, and cases l 80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-808 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 All discovery related responses of Jeffrey Epstein in this matter and , 42 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08. 80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 Jeffrey Epstein's Answers and Affirmative Defenses in all civil case 43. against him EFTA01085221 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 4 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED All Complaints in which Jeffrey Epstein was a plaintiff or defendant 44 Jeffrey Epstein's Deposition testimony and discovery responses in th 45. and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 084 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 Jeffrey Epstein's Deposition testimony and discovery responses in St 46 Court cases LM v. Jeffrey Epstein, Case No. 502008CA0280513OO( AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXI% Jeffrey Epstein Deposition Testimony and discovery responses in SU- 47. Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No. 502009CA040800XXXXMBAG Any and all newspaper articles, online articles or publications related 48. Jeffrey Epstein Report and Analysis of Jeffrey Epstein's assets 49 Video footage (DVD) of walk through site inspection of Jeffrey Epst 50. home. Photos of all of Jeffrey Epstein's properties, cars, boats and planes 51. Probable Cause Affidavits prepared against Jeffrey Epstein and Saral 52. Audio tape of 53. Photographs, videos and books taken in the search warrant of Jeffrey 54. Epstein's home Documents related to or evidencing Jeffrey Epstein's donations to la. 55. enforcement Victim Notification Letter from US Attorney's Office to Plaintiff 56. 57. Expert Dr. L. Dennison Reed's Report of Plaintiff Palm Beach Police Department Incident Report dated 4/20/06 58 All reports and documentation generated by Palm Beach Police 59. Department related to Jeffrey Epstein All Witness Statements generated by Palm Beach Police Department 60. relating to Jeffrey Epstein Passenger Manifests of Jeffrey Epstein's aircraft and private plane fl 61. logs EFTA01085222 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 5 of I I DEF. PLF. DATE NO. NO. OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 62 Passenger lists for flights taken by Jeffrey Epstein 63. Letter from Jeffrey Epstein to Alberto Pinto regarding house island p 64. Jeffrey Epstein's bank statements Jeffrey Epstein's tax returns 65. MC2 emails involving communications of Jeffrey Epstein, Jeff Fuller, Pappas Suat, Jean Luc Brunel and Amanda Grant 66. DVD of plea and colloquy taken on 6-30-08 67. Transcript of plea and colloquy taken on 6-30-08 68. Massage Table 69. Lotions taken from Jeffrey Epstein's home during search warrant 70. Computers taken from Jeffrey Epstein's home during search warrant 71. Vibrators, dildos and other sex toys taken from Jeffrey Epstein's hom( during search warrant 72. No Contact Orders entered against Jeffrey Epstein 73 Criminal Score Sheet regarding Jeffrey Epstein 74. Documents evidencing Jeffrey Epstein's Community Control and Probation 75. Jeffrey Epstein's Sex Offender Registration 76. Jeffrey Epstein's Booking photograph 77. CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480 78 List of Jeffrey Epstein's House contacts Documents related to Jeffrey Epstein's investments 79. EFTA01085223 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 6 of II DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED Letter from Chief o Barry Krischler 80 List of planes owned by Jeffrey Epstein 81. Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06 82 Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06 83. Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06 84 Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06 85 Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06 86 Letter from Goldberger dated 6-22-06 87 All subpoenas issued to State Grand Jury 88. Documents related to the rental of a vehicle for 89 Ted's Sheds Documents 90. Documents related to property searches of Jeffrey Epstein's propertir 91. Arrest Warrant of 92 Police report regarding icking up money dated 11-2 93. List of Trilateral Commission Members of 2003 94 Alan Dershowitz Letter dated 4-19-06 and Statute 90.410 95 Guy Fronstin letter dated 4-17-06 96. Jeffrey Epstein Account Information 97 Jeffrey Epstein Criminal Closeout Sheet 98 Jeffrey Epstein Polygraph Test and Results 99. EFTA01085224 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 7 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED Plaintiff's GED testing information and results 100. JEGE, Inc. Passenger Manifest 101. Hyperion Air Passenger Manifest 102. Flight information for 103. 104. Passenger List Palm Beach flights 2005 Jeffrey Epstein notepad notes 105. Pleadings of Jane Doe 1 and 2 v. US case 106. Jeffrey Epstein 5 Amendment Speech 107. Reiter letter to Krisher dated 5-1-06 108. Jail receipts of Jeffrey Epstein 109. Police Report dated 11-28-04 110. Compulsory Medial Examination of victim, CMA 111. Plaintiff's school records and transcripts 112 Victim Notification letter dated 7-9-08 113. Plaintiffs employment records from IHOP 114. Police report of Juan Alessi theft at Jeffrey Epstein's home 115. Plaintiff's Medical Records from Milton Girls Juvenile Facility 116. Plaintiff's Medical Records from Dr. Randee Speciale 117. Plaintiff's Medical Records from Wellington Regional Hospital 118. Plaintiff's Medical Records from St. Mary's Medical Center 119. EFTA01085225 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COIJNTERPLAINTIFF, BRADLEY EDWARDS Page 8 of 11 DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS Plaintiff's Medical Records from United Health 120. All surveillance conducted by law enforcement on Jeffrey Epstein's I 121 Emails received from Palm Beach Records related to Jeffrey Epstein 122. All items listed on the Palm Beach Police Property Report Lists 123 All items taken in the execution of the search warrant of Jeffrey Epst 124. home: 358 EL BRILLO WAY, PALM BEACH FL 33480 All copies of convictions related to Jeffrey Epstein 125 Jeffrey Epstein criminal records 126. All documents .roduced b Palm Beach Police Department prior to t 127 deposition of Photographs of all persons listed on Plaintiff's Witness List 128. Statements, deposition transcripts, videotaped depositions and transc 129 taken in connection with this and all related cases and exhibits theret Any and all expert witness reports and/or records generated in preps] 130. for this litigation by any party to this cause Curriculum vitaes of any and all listed experts 131 Curriculum vitae of Dr. Ryan Hall 132 My articles or publications of Dr. Ryan Hall 133. Any articles or publications of Dr. Richard Hall 134. Any articles or publications of Dr. L. Dennison Reed 135. All items and documentation review by Dr. L. Dennison Reed 136. Transcript and video (DVD) of IME of Plaintiff 137 All exhibits to Dr. L. Dennison Reed's Deposition 138 All exhibits to Dr. Richard Hall's Deposition 139. EFTA01085226 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COIJNTERPLAINTIFF, BRADLEY EDWARDS Page 9 of II DEF. PLF. DATE ADMIT MARX NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS All items and documents reviewed by Dr. Richard Hall 140. All items and documents reviewed by Dr. Ryan Hall 141 All exhibits listed on the Defendant's Exhibit List 142 Demonstrative aids and exhibits including, but not limited to, anatorr 143 charts, diagrams and models, surveys, photographs and similar mater including blow-ups of the aforesaid items. Any and all mortality tables 144. Plaintiffs reserve all objections to Defendant's Exhibits 145. Plaintiffs reserve the right to supplement and/or amend this Exhibit 1 146. By listing an Exhibit, Plaintiff is not waiving their right to object to s 147. trial and does not waive their right to amend same. All exhibits listed by Epstein subject to Edwards' objections. 148. All pleadings and attachments in the action under the Crime Victims 149 Rights Act prosecuted by Bradley Edwards on behalf of victims of Epstein's criminal molestations. All attachments to Edwards' Motion for Summary Judgment. 150. All time records and hourly billing documentation produced in disco 151 — — - All deposition testimony and discovery responses by Epstein submit' 152. this action. All pleadings filed by Epstein in the Rothstein bankruptcy proceedin 153. 7- -- - - All submissions by Epstein in connection with the Rothstein deposit 154. All Settlement Agreements between Epstein and victims of his sexut 155. molestations. Plaintiff reserves the right to amend this list. EFTA01085227 Edwards adv. Epstein Case No.: 502009CA040800)OOCXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page loot II I HEREBY CERTIFY that a true and correct copy of the foregoing has been finished by E- Service to all counsel on the attached list, this day of June, 2013. 7-1 Jack Scarola Florida Bar No.: 169440 Searcy Denney Scarola Barnhart & Shipley, P.A. war EFTA01085228 Edwards adv. Epstein Case No.: 502009CA040800000CMBAG EXHIBIT LIST OF COUNTERPLAINT1FF, BRADLEY EDWARDS Page I I of 11 COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldber er & Weiss, P.A. Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire orneys ore ey ps em Law Offices of Marc S. Nurik Bradley J. Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL Attorneys for Scott Rothstein Tonja I laddad Coleman, Esquire Fred Haddad, P.A. Attorneys for Jeffrey Epstein EFTA01085229

EFTA00229761.pdf

DataSet-10 Unknown 6 pages

Memorandum Subject Date Re: Jeffrey Epstein Investigation July 26, 2011 To From First Assistant U.S. Attorney I. Introduction This memorandum summarizes the conflict of interest related to the investigation by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap Year"; summarizes the resolution of Operation Leap Year by the Southern District of Florida; and addresses the events following the resolution of Operation Leap Year, including the basis for the conflict. Lastly, the memo briefly addresses the additional crimes that the FBI wants to investigate. IL "Operation Leap Year" The investigation of Jeffrey Epstein initially was undertaken by the City of Palm Beach Police Department in response to a complaint received from the parents of a 14-year- old girl, from Royal Palm Beach. When and another girl began fighting at school because the other girl accused of being a prostitute, one of the school principals intervened. The principal searched urse and found $300 cash. The principal asked where the money came from. initiall claimed that she earned the money working at "Chik-Fil-A," which no one believed. then claimed that she made the money selling drugs; no one believed that either. finalyslmitted that she had been paid $300 to give a massage to a man on Palm Beach island. parents approached the Palm Beach Police Department ("PBPD") about pressing charges. PBPD be an investigating the recipient of the massage, Jeffrey Epstein, and two of his assistants, and . PBPD identified 27 girls who went to Epstein's house to perform "massage services" (not including one licensed massage therapist). The girls' ages ranged from 14 years' old to 23 years' old. Some girls saw Epstein only once and some saw him dozens of times. The "massage services" performed EFTA00229761 also varied. Some girls were fully clothed while they massaged Epstein; some wore only their underwear; and some were fully nude. During all of these massages, Epstein masturbated himself and he would touch the girl performing the massage, usually fondling their breasts and touching their vaginas — either over their clothing or on their bare skin. Epstein often used a vibrator to masturbate the girls and digitally penetrated a number of them. For the girls who saw him more often, Epsteingraduated to oral sex and vaginal sex. Epstein sometimes brought his assistant/ irlfriend, into the sexual activity. One of the girls described as Epstein's "sex slave". On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by Epstein's cadre of lawyers. When PBPD arrived at Epstein's home two days later (10/20/05) to execute the search warrant, they found several items conspicuously missing. For example, computer monitors and keyboards were found, but the CPUs were gone.' Similarly, surveillance cameras were found, but they were disconnected and the videotapes were gone. Nonetheless, the search did recover some evidence of value, including message pads showing messages from many girls over a two year span. The messages show girls returning phone calls to confirm appointments to "work." Messages were taken by three of Epstein's "personal assistants." Photographs taken inside the home showed that the girls' descriptions of the layout of the home and master bedroom/bathroom area were accurate. PBPD also found massage tables and oils, the high school transcript of one of the girls, and sex toys. In sum, the PBPD investigation showed that girls from Royal Palm Beach High School would be contacted by one of Epstein's assistants to make an appointment to "work." Up to three appointments each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's assistant—usually M in the kitchen. The assistant would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage oils. The girl sometimes was instructed to remove her clothing. The assistant would leave and Epstein would enter the room wearing a robe. He would remove the robe and lie face down and nude on the massage table. Epstein would then instruct the girl on what to do and would ask her to remove her clothing. After some time, Epstein would turn over, so that he was lying face up. 'During a meeting, two of Epstein's attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructed Epstein to have the CPUs removed although they insisted that those instruction were given well in advance of the execution of the search warrant — not in response to a "leak." 2 EFTA00229762 Epstein would masturbate himself and fondle the girl performing the massage. When Epstein climaxed, the massage was over, and the girl was instructed to get dressed and to go downstairs to the kitchen while Epstein showered. Epstein's assistant would be in the kitchen and the girl would be paid—usually $200-and if it was a "new" girl, the assistant would ask for the girl's phone number to contact her in the future.2 Girls were encouraged to find other girls to bring with them. If a girl brought another girl to perform a "massage," each girl would receive $200. Each time a girl returned to the house, Epstein would pressure the girl to go further sexually, advancing to oral sex and sexual intercourse. Epstein would pay more for these acts — in the words of one girl, "the more you do, the more you make." The PBPD investigation consisted primarily of sworn taped statements from the girls. When PBPD began having problems with PBSAO, they approached the FBI. The investigation was formally presented to the FBI and to the U.S. Attorney's Office after PBSAO "presented" the case to a state grand jury and the state grand jury returned an indictment charging Epstein only with one felony count of solicitation of [adult] prostitution. After the matter was presented to the U.S. Attorney's Office and there was a determination that federal statutes had been violated, FBI, ICE, and the U.S. Attorney's Office opened files. The federal investigation focused on the interstate nexus required for all of the federal violations, so a number of grand jury subpoenas were issued for telephone records, flight manifests, and credit card records. The federal agents also re-interviewed some of the girls. The agents delved into Epstein's history and interviewed other girls and obtained records to corroborate the girls' stories. FBI also interviewed girls who came forward after the PBSAO indictment was reported in the papers and the additional girls identified through those interviews. The attempt to handle secretly the federal case was doomed from the start when the Chief of the Palm Beach Police Department gave a letter to each of the victims identified through his investigation telling them that, because of his disappointment in the way that the PBSAO had handled the case, the matter had been referred to the FBI. Almost immediately, Epstein's attorneys began calling to request a meeting with the U.S. Attorney's Office. When one attorney was unable to schedule a meeting, Epstein hired another attorney who called up the chain of command until someone agreed to a meeting. Between January and May 2007, an indictment package was prepared, charging Epstein and three of his personal assistants with a number of child exploitation offenses. The 'Sometimes Epstein made the payment and asked for the phone number, sometimes it was the assistant. 3 EFTA00229763 case agent made several appearances before the grand jury. Attorneys for Epstein made several presentations to the U.S. Attorney's Office to convince the Office not to prosecute, and made allegations of prosecutorial misconduct against the line Assistant and the First Assistant U.S. Attorney. Epstein also challenged the legal analysis behind the prosecution, both within the U.S. Attorney's Office (up to the U.S. Attorney) and to the Child Exploitation and Obscenity Section at the Justice Department. All of Epstein's challenges were considered and rejected. III. The Resolution of "Operation Leap Year" On September 24, 2007, Epstein signed a Non-Prosecution Agreement wherein the U.S. Attorney's Office for the Southern District of Florida promised not to prosecute Epstein for the crimes that were the subject of the grand jury investigation if: (1) he pled guilty to two crimes in state court — the state felony prostitution charge and a state charge of procuring minors into prostitution, which would require Epstein to register as a sex offender; (2) he were sentenced to at least 18 months' imprisonment, and (3) he agreed to pay damages to the victims of his offenses. After signing this Agreement, Epstein and his counsel decided that they were dissatisfied with its terms, and again complained to the Justice Department, seeking review to the Deputy Assistant Attorney General and the Deputy Attorney General. After those attempts also failed, on June 30, 2008, Epstein entered his guilty plea in state court and began serving his sentence. IV. Post-Resolution Events A few days before the plea and sentencing (in state court those occur on the same day), the Assistant U.S. Attorney handling the matter contacted counsel for three of Epstein's identified victims and informed him of the upcoming court date, encouraging his clients to attend and be heard. They did not appear. On July 7, 2008, two of those victims filed suit against the United States in federal court claiming that their rights had been violated under the Crime Victims' Rights Act because they had not been consulted before the Office entered into the Non-Prosecution Agreement. (This will be referred to as the "CVRA Action.") After an initial flurry of activity, the Petitioners obtained a copy of the confidential Non-Prosecution Agreement, and the Court ordered that it be shared with all of the identified victims. After it was provided, the Petitioners and most of Epstein's victims focused on their civil suits against him. In 2009, the U.S. Attorney's Office in Fort Lauderdale initiated an investigation into 4 EFTA00229764 a Ponzi scheme operated by Scott Rothstein through his law firm. As part of his Ponzi scheme, Rothstein told investors that his law firm represented several of Epstein's victims and that Epstein was willing to pay huge sums of money to avoid exposing his criminal activities. The attorney representing the victims in the CVRA Action, Brad Edwards ("Edwards"), worked at the Rothstein firm. Epstein sued Edwards, alleging that Edwards was part of the Ponzi scheme, and alleging that Edwards' attempts to subpoena some of Epstein's high-powered friends were done to increase the value of the Ponzi scheme, rather than for legitimate discovery purposes. In the summer of 2010, most of the civil suits against Epstein were settled, including the suits filed by the two victims in the CVRA Action. All of the settlements were confidential, so it is unknown how much each of the victims received. In September 2010, U.S. District Judge Kenneth Marra, who handled most of the civil cases and the CVRA Action, issued an Order closing the CVRA Action. Almost immediately thereafter, the Petitioners filed a Motion to Reopen, stating that they had obtained discovery through their civil suits against Epstein that showed that the U.S. Attorney's Office had violated their rights as victims. For several months, attempts were made to resolve the matter. In short, the victims have asked that the U.S. Attorney's Office disavow the Non-Prosecution Agreement, on the basis that the CVRA was violated, and bring charges against Epstein. Edwards has said that one of his clients repeatedly calls and asks him when Epstein is going to jail. One of the other attorneys on the case has suggested that emails he considers to be embarrassing to the Office will not be disclosed if we re-open our investigation of Epstein and prosecute him. Herein lies the conflict. If the U.S. Attorney's Office for the Southern District of Florida re-initiates a grand jury investigation of Jeffrey Epstein, it will be perceived — correctly or incorrectly — as having been done at the insistence of the victims in the CVRA Action. And Epstein will allege that any prosecution arising therefrom will have been undertaken in an effort to resolve the CVRA Action, not based upon the merits of the investigation itself. V. The FBI's Current Investigation The main focus of the FBI's current investigation is a victim, , who refused to speak with agents during the "Operation Leap Year" investigation. Based upon her debriefing, Epstein engaged in several additional crimes in the Southern District of Florida and, more importantly, in several other Districts, with and other minor females. 5 EFTA00229765 Epstein transported in his private airplanes to engage in sexual activity with him. Epstein also "pimped" to several of his other important friends, and transported her to those sexual encounters. This activity was not part of the initial investigation. also reported that, during the "Operation Leap Year" investigation, she was contacted by Epstein's investigators, lawyers, and Epstein himself, and offered payment to remain silent when contacted by the police. FBI agents are seeking grand jury subpoenas at this time to corroborate statement. They also are asking for permission to approach one of Epstein's "personal assistants," who was served with a target letter during the "Operation Leap Year" investigation, to give her a "de-target" letter and interview her. 6 EFTA00229766

EFTA00205964.pdf

DataSet-10 Unknown 4 pages

Memorandum SubjectDate Re: Jeffrey Epstein Investigation July 26, 2011 First Assistant U.S. Attorney I. Introduction This memorandum summarizes the conflict of interest related to the investigation by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap Year"; summarizes the resolution of Operation Leap Year by the Southern District of Florida; and addresses the events following the resolution of Operation Leap Year, including the basis for the conflict. Lastly, the memo briefly addresses the additional crimes that the FBI wants to investigate. II. "Operation Leapt" The investigation of Jeffrey Epstein initially was undertaken by the City of Palm Beach Police Department in response to a complaint received from the parents of a 14-year-old girl, from . Whenand another girl began fighting at school because the other girl accused f being a prostitute, one of the school pr. intervened. The principal searche purse and found $300 cash. The principal asked here the money came from. initially claimed that she earned the money working at ' " which no one believed. hen claimed that she made the money selling drugs; no one believed that either. finally admitted that she had been paid $300 to give a massage to a man on Palm Beach island. parents approached the Palm Beach Police Department ("PBPD") about pressing charges. PBPD began investi atin the recipient of the massage, Jeffrey Epstein, and and PBPD identified 27 girls who went to Epstein's house to perform "massage services" (not including one licensed massage therapist). The girls' ages ranged from 14 years' old to 23 years' old. Some girls saw Epstein only once and some saw him dozens of times. The "massage services" performed also varied. Some girls were fully clothed while they massaged Epstein; some wore only their underwear; and some were fully nude. During all of these massages, Epstein masturbated himself and he would , usually and — either over their clothin or on their bare skin. Epstein often used a vibrator to and a number of them. For the girls who saw him more often, Epstein uated to Epstein sometimes brought into the sexual activity. One of the girls described as Epstein's "sex slave". On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by Epstein's cadre of lawyers. When PBPD arrived at Epstein's home two days later (10/20/05) to execute the search warrant, they found several items conspicuously missing. For example, computer monitors and keyboards were found, but the CPUs were gone. Ft Similarly, surveillance cameras were found, but they were disconnected and the videotapes were gone. Nonetheless, the search did recover some evidence of value, including message pads showing messages from many girls over a two year span. The messages show girls returning phone calls to confirm appointments to "work." Messages were taken by three of Epstein's "personal assistants." Photographs taken inside the home showed that the girls' descriptions of the layout of the home and master bedroom/bathroom area were accurate. PBPD also found massage tables and oils, the high school transcript of one of the girls, and sex toys. EFTA00205964 In sum, the PBPD investigation showed that girls from would be contacted by one of Epstein's assistants to make an appointment to "work." Up to three appointments each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein': An the kitchen. The assistant would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage oils. The girl sometimes was instructed to remove her clothing. The assistant would leave and Epstein would enter the room wearing a robe. He would remove the robe and lie face down and nude on the massage table. Epstein would then instruct the girl on what to do and would ask her to remove her clothing. After some time E stein would turn over so that he was lying face up. Epstein would masturbate himself and When Epstein climaxed, the massage was over, and the girl was instructed to get dressed and to go downstairs to the kitchen while Epstein showered. Epstein's assistant would be in the kitchen and the girl would be paid—usually $200-and if it was a "new" girl, the assistant would ask for the girl's phone number to contact her in the future. Fz Girls were encouraged to find other girls to bring with them. If a girl brought another girl to perform a "massage," each girl would receive $200. Each time a girl returned to the house, Epstein would pressure the girl to go further sexually, . Epstein would pay more for these acts — in the words of one girl, "the more you do, the more you make." The PBPD investigation consisted primarily of sworn taped statements from the girls. When PBPD began having problems with PBSAO, they approached the FBI. The investigation was formally presented to the FBI and to the U.S. Attorney's Office after PBSAO "presented" the case to a state grand jury and the state grand jury returned an indictment charging Epstein only with one felony count of solicitation of [adult] prostitution. After the matter was presented to the U.S. Attorney's Office and there was a determination that federal statutes had been violated, FBI, ICE, and the U.S. Attorney's Office opened files. The federal investigation focused on the interstate nexus required for all of the federal violations, so a number of grand jury subpoenas were issued for telephone records, flight manifests, and credit card records. The federal agents also re-interviewed some of the girls. The agents delved into Epstein's history and interviewed other girls and obtained records to corroborate the girls' stories. FBI also interviewed girls who came forward after the PBSAO indictment was reported in the papers and the additional girls identified through those interviews. The attempt to handle secretly the federal case was doomed from the start when the Chief of the Palm Beach Police Department gave a letter to each of the victims identified through his investigation telling them that, because of his disappointment in the way that the PBSAO had handled the case, the matter had been referred to the FBI. Almost immediately, Epstein's attorneys began calling to request a meeting with the U.S. Attorney's Office. When one attorney was unable to schedule a meeting, Epstein hired another attorney who called up the chain of command until someone agreed to a meeting. Between January and May 2007, an indictment package was prepared, charging Epstein and three of his personal assistants with a number of child exploitation offenses. The case agent made several appearances before the grand jury. Attorneys for Epstein made several presentations to the U.S. Attorney's Office to convince the Office not to prosecute, and made allegations of prosecutorial misconduct against the line Assistant and the First Assistant U.S. Attorney. Epstein also challenged the legal analysis behind the prosecution, both within the U.S. Attorney's Office (up to the U.S. Attorney) and to the Child Exploitation and Obscenity Section at the Justice Department. All of Epstein's challenges were considered and rejected. The Resolution of "Operation Leap Year" On September 24, 2007, Epstein signed a Non-Prosecution Agreement wherein the U.S. Attorney's Office for the Southern District of Florida promised not to prosecute Epstein for the crimes that were the subject of the grand jury investigation if: (1) he pled guilty to two crimes in state court - EFTA00205965 the state felony prostitution charge and a state charge of procuring minors into prostitution, which would require Epstein to register as a sex offender; (2) he were sentenced to at least 18 months' imprisonment, and (3) he agreed to pay damages to the victims of his offenses. After signing this Agreement, Epstein and his counsel decided that they were dissatisfied with its terms, and again complained to the Justice Department, seeking review to the Deputy Assistant Attorney General and the Deputy Attorney General. After those attempts also failed, on June 30, 2008, Epstein entered his guilty plea in state court and began serving his sentence. IV. Post-Resolution Events A few days before the plea and sentencing (in state court those occur on the same day), the Assistant U.S. Attorney handling the matter contacted counsel for three of Epstein's identified victims and informed him of the upcoming court date, encouraging his clients to attend and be heard. They did not appear. On July 7, 2008, two of those victims filed suit against the United States in federal court claiming that their rights had been violated under the Crime Victims' Rights Act because they had not been consulted before the Office entered into the Non-Prosecution Agreement. (This will be referred to as the "CVRA Action.") After an initial flurry of activity, the Petitioners obtained a copy of the confidential Non- Prosecution Agreement, and the Court ordered that it be shared with all of the identified victims. After it was provided, the Petitioners and most of Epstein's victims focused on their civil suits against him. In 2009, the U.S. Attorney's Office in Fort Lauderdale initiated an investigation into a Pont scheme operated by Scott Rothstein through his law firm. As part of his Ponzi scheme, Rothstein told investors that his law firm represented several of Epstein's victims and that Epstein was willing to pay huge sums of money to avoid exposing his criminal activities. The attorney representing the victims in the CVRA Action, Brad Edwards ("Edwards"), worked at the Rothstein firm. Epstein sued Edwards, alleging that Edwards was part of the Ponzi scheme, and alleging that Edwards' attempts to subpoena some of Epstein's high-powered friends were done to increase the value of the Ponzi scheme, rather than for legitimate discovery purposes. In the summer of 2010, most of the civil suits against Epstein were settled, including the suits filed by the two victims in the CVRA Action. All of the settlements were confidential, so it is unknown how much each of the victims received. In September 2010, U.S. District Judge Kenneth Marra, who handled most of the civil cases and the CVRA Action, issued an Order closing the CVRA Action. Almost immediately thereafter, the Petitioners filed a Motion to Reopen, stating that they had obtained discovery through their civil suits against Epstein that showed that the U.S. Attorney's Office had violated their rights as victims. For several months, attempts were made to resolve the matter. In short, the victims have asked that the U.S. Attorney's Office disavow the Non-Prosecution Agreement, on the basis that the CVRA was violated, and bring charges against Epstein. Edwards has said that one of his clients repeatedly calls and asks him when Epstein is going to jail. One of the other attorneys on the case has suggested that emails he considers to be embarrassing to the Office will not be disclosed if we re-open our investigation of Epstein and prosecute him. Herein lies the conflict. If the U.S. Attorney's Office for the Southern District of Florida re- initiates a grand jury investigation of Jeffrey Epstein, it will be perceived — correctly or incorrectly — as having been done at the insistence of the victims in the CVRA Action. And Epstein will allege that any prosecution arising therefrom will have been undertaken in an effort to resolve the CVRA Action, not based upon the merits of the investigation itself. V. The FBI's Current Investigation The main focus of the FBI's current investigation is a victim, , who refused to speak with agents during the "Operation Leap Year" investigation. Based upon her debriefing, Epstein engaged in several additional crimes, in the Southern District of Florida and, more importantly, in several other EFTA00205966 Districts, with and other minor females. Epstein transported in his private airplanes to engage in sexual activity with him. Epstein also "pimped" to several of his other important friends, and transported her to those sexual encounters. This activity was not part of the initial investi ation. also reported that, during the "Operation Leap Year" investigation, she was contacted by Epstein's investigators, lawyers, and Epstein himself, and offered payment to remain silent when contacted by the police. FBI agents are seeking grand jury subpoenas at this time to corroborate statement. They also are asking for permission to approach one of Epstein's "personal assistants," who was served with a target letter during the "Operation Leap Year" investigation, to give her a "de-target" letter and interview her. During a meeting, two of Epstein's attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructed Epstein to have the CPUs removed although they insisted that those instruction were given well in advance of the execution of the search warrant — not in response to a "leak." FzSometimes Epstein made the payment and asked for the phone number, sometimes it was the assistant. EFTA00205967

EFTA00229830.pdf

DataSet-10 Unknown 12 pages

Memorandum SubjectDate Re: Operation Leap Year March 15, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman, First Assistant United States Attorney M, Chief, Criminal Division MAUSA, Northern Region Chief, Northern Region 1. Introduction This memorandum seeks approval for the attached indictment charging Jeffrey Epstein, M, a/k/a ," and . The proposed indictment contains counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes. The investigation initially was undertaken by the City of Palm Beach Police Department in response to a com laint received from the parents of a 14-year-old girl, ., from Royal Palm Beach. When . and another girl began fighting at school because the other irl accused of being a prostitute, one of the school princi als intervened. The principal searched .'s purse and found $300 cash. The principal asked . where the money came from. initially claimed that she earned the money working at "Chik-Fil-A," which no one believed. . then claimed that she made the money selling drugs; no one believed that either. finally admitted that she had been paid $300 to give a massage to a man on Palm Beach island. .'s parents approached the Palm Beach Police Department ("PBPD") about pressing charges. PBPD began investi atin the recipient of the massage, Jeffrey Epstein, and two of his assistants, and . PBPD identified 27 girls who went to Epstein's house to perform "massage services" (not including one licensed massage therapist). The girls' ages ranged from 14 years' old to 23 years' old. Some girls saw Epstein only once and some saw him dozens of times. The "massage services" performed also varied. Some girls were fully clothed while they massaged Epstein; some wore only their underwear; and some were fully nude. During all of these massages, Epstein masturbated himself and he would touch the girl performing the massage, usually fondling their breasts and touching their vaginas - either over their clothing or on their bare skin. Epstein often used a vibrator to masturbate the girls and digitally penetrated a number of them. For the girls who saw him more often, E stein duated to oral sex and vaginal sex. Epstein sometimes brow ht his assistant/girlfriend, into the sexual activity. One of the girls described as Epstein's "sex slave". On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by Epstein's cadre of lawyers. When PBPD arrived at Epstein's home two days later (10/20/05) to execute the search warrant, they found several items conspicuously missing. For example, computer monitors and keyboards were found, but the CPUs were gone. a Similarly, surveillance cameras were found, but they were disconnected and the videotapes were gone. Nonetheless, the search did recover some evidence of value, including message pads showing messages from many girls over a two year span. The messages show girls returning phone calls to confirm appointments to "work." Messages were taken by and . a The search also recovered numerous photos of Epstein sifting with naked girls whose ages are undetermined. Photographs taken inside the home show that the girls' descriptions of the layout of the home and master bedroom/bathroom area are accurate. PBPD also found massage tables and oils, the high school EFTA00229830 transcript of one of the girls, and sex toys. In sum, the PBPD investigation showed that girls from Royal Palm Beach High School would be contacted by one of Epstein's assistants to make an appointment to "work." Up to three appointments each day would be made. The girls would travel toits home in Palm Beach where they would meet Epstein's chef and Epstein's assistant—usually in the kitchen. The assistant would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage oils. The girl sometimes was instructed to remove her clothing. The assistant would leave and Epstein would enter the room wearing a robe. He would remove the robe and lie face down and nude on the massage table. Epstein would then instruct the girl on what to do and would ask her to remove her clothing. After some time, Epstein would turn over, so that he was lying face up. Epstein would masturbate himself and fondle the girl performing the massage. When Epstein climaxed, the massage was over, and the girl was instructed to get dressed and to go downstairs to the kitchen while Epstein showered. Epstein's assistant would be in the kitchen and the girl would be paid—usually $200-and if it was a "new" girl, the assistant would ask for the girl's phone number to contact her in the future. Fs Girls were encouraged to find other girls to bring with them. If a girl brought another girl to perform a "massage," each girl would receive $200. The PBPD investigation consists primarily of sworn taped statements from the girls. When PBPD began having problems with PBSAO, they approached the FBI. The investigation was formally presented to FBI and to me after PBSAO "presented" the case to a state grand jury and that grand jury returned an indictment charging Epstein with three counts of solicitation of prostitution. a 4 Once I determined that there were federal statutes violated, FBI, ICE, and I opened files. The federal investigation has focused on the interstate nexus required for all of the federal violations, so a number of grand jury subpoenas were issued for telephone records, flight manifests, and credit card records. The federal agents also re-interviewed some of the girls, but limited their questions to "new" topics, such as the specific means of contact, to avoid creating inconsistent Jencks materials. The agents also delved into Epstein's history and interviewed others and obtained records to corroborate the girls' stories. FBI also interviewed girls who came forward after PBSAO indictment was reported in the papers and the additional girls identified through those interviews. I will first address the different crimes with which Epstein can be charged, setting forth the elements of those offenses and the types of evidence that I intend to use to satisfy those elements. Second, I will summarize the evidence related to each girl who has been identified as a potential victim in this case. As to each date/event identified, I will note which offense was committed and, if charged, the Count number related to that offense. Appendix A also contains a sheet for each girl, which contains a photograph taken around the time she met Epstein, her date of birth, and a summary of the evidence related to that girl. Appendix B is a chart summarizing the evidence pertaining to each count. Following the discussion of the girls' statements and evidence, there is a discussion of the evidence from other witnesses, including corroborating evidence and information related to Epstein's background. The last section discusses forfeiture. II. The Law of the Offenses Charged Epstein's conduct violates a number of federal statutes, all of which are discussed herein. I erred on the side of over-charging to allow the Office to consider the options and to delete those counts that it considers to be the weakest. If any of the statutes or their penalties changed during the time period charged (early 2004 through mid-2005), it is noted. A. Coercion and Enticement: 18 U.S.C. § 2422 Whoever, using the mail or any facility or means of interstate . . . commerce, . . . knowingly persuades [ or ] induces . . . any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged EFTA00229831 with a criminal offense, or attempts to do so, shall be fined under this title and imprisoned not less than 5 years and not more than 30 years. 18 U.S.C. § 2422(b). The Eleventh Circuit Pattern Jury Instructions list the elements of this offense as: First : That the Defendant knowingly used a facility or means of interstate commerce to persuade or induce an individual under the age of eighteen to engage in prostitution or sexual activity; Second : That the Defendant believed that such individual was less than eighteen years of age; Third : That if the sexual activity had occurred, the Defendant could have been charged with a criminal offense under the law of Florida; Fs and Fourth : That the Defendant acted knowingly and willfully. The statute does not define "facility or means of interstate commerce" or "prostitution." 1. A telephone is a "facility of interstate commerce." The Eleventh Circuit, however, has ruled that evidence of the use of a cellular telephone satisfies the element of using a facility or means of interstate commerce. United States v. Drury , 396 F.3d 1303, 1311 (11th Cir. 2005) (the term "facility of interstate commerce . . . establishes federal jurisdiction whenever any "facility of interstate commerce" is used in the commission of [the] offense, regardless of whether the use is interstate in nature ( i.e. , the telephone call was between states) or purely intrastate in nature ( i.e. , the telephone call was made to another telephone within the same state)."). In Drury , the defendant used his land-line telephone to call an undercover agent's cellular telephone. Although both the defendant and the agent were in Georgia, the signals to the agent's cell phone had to pass through VoiceStream's Jacksonville, Florida switching center. The defendant argued that he did not know or intend that the call pass in interstate commerce. The Eleventh Circuit was unpersuaded: The calls were not accidentally or incidentally placed, but rather were made knowingly to further a scheme. . . . Accordingly, whether Drury knew or intended that they would travel across state lines is immaterial. Id. at 1313. In Drury , the Eleventh Circuit did not address whether the district court erred by instructing the jury that telephones are "facilities in interstate commerce." In an unpublished decision from last year, the Eleventh Circuit wrote, in dicta , that there was no error in instructing a jury that "the telephone system was a facility of interstate commerce." United States v. Roberts , 2006 WL 827293 n.1 (11th Cir. Mar. 30, 2006). See also United States v. Strevell , 2006 WL 1697529, *3 (11th Cir. June 20, 2006) (finding that a defendant's placing of "numerous phone calls from Philadelphia to Miami in order to arrange his sexual encounter" was sufficient to prove the use of a facility and means of interstate and foreign commerce). 2. What is "prostitution"? As noted above and discussed more thoroughly below, almost none of the girls engaged in traditional sexual intercourse with Epstein. The common activity included allowing Epstein to fondle the girl while he masturbated himself, Epstein's digital penetration of the girl, and Epstein's use of a vibrator on the girl while he masturbated himself. It is clear that this activity was done in exchange for money, but the defense will likely argue that some of the activity was not "sexual enough" to qualify as "prostitution." Title 18 carries no definition of "prostitution." In United States v. Prince , the Fifth Circuit approved of the generic definition "sexual intercourse for hire" where the West Virginia statues also lacked a definition. Prince , 515 F.2d 564, 566 (5th Cir. 1975). F6 In 1946, the Supreme Court defined prostitution as the "offering of the body to indiscriminate lewdness for hire." Cleveland v. United States , 329 U.S. 14, 17 (1946). Black's Law Dictionary contains several definitions of prostitution: Prostitution: Act of performing, or offering or agreeing to perform a sexual act for hire. Engaging in or agreeing or offering to engage in sexual conduct with another person EFTA00229832 under a fee arrangement with that person or any other person. Includes any lewd act between persons for money or other consideration. Within meaning of statute proscribing prostitution, comprises conduct of all male and female persons who engage in sexual activity as a business. Black's Law Dictionary (6th Ed. 1990) at 1222. The term "lewd" is especially broad, and probably covers all of the acts described below. The district court may decide to limit the term to the definition contained in Florida law. The Florida Statutes define prostitution as "the giving or receiving of the body for sexual activity for hire . . ." Fl. Stat. § 796.07(1)(a) (2005). Sexual activity, in turn, means "oral, anal, or vaginal penetration by, or union with, the sexual organ of another, anal or vaginal penetration of another by any other object; or the handling or fondling of the sexual organ of another for the purpose of masturbation . . ." Fl. Stat. § 796.07(1)(d). If this definition is used, those instances where the girls remained clothed and where Epstein did not fondle the girls' vaginas would probably fall outside the definition of "prostitution." 3. What is "any sexual activity for which any person can be charged with a criminal offense"? Section 2422 outlaws both the use of a facility of interstate commerce to entice a minor to engage in prostitution and the use of that facility to entice a minor to engage in "any sexual activity for which any person can be charged with a criminal offense." As set forth in the Pattern Jury Instruction above, the determination of what sexual activity is criminal is governed by Florida law. Florida law bars a person from procuring anyone under the age of 18 to engage in prostitution or to cause a minor to be prostituted. Fl. Stat. § 796.03 (2005). Florida also defines four categories of lewd or lascivious offenses that criminalize behavior between adults and children under the age of 16 : 1. "Lewd or lascivious battery" occurs when an adult le]ngages in sexual activity Ei with a person 12 years of age or older but less than 16 years of age." Fl. Stat. § 800.04(4)(a). 2. "Lewd or lascivious molestation" occurs when an adult "intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age to so touch the perpetrator." Fl. Stat. § 800.04(5)(a). 3. "Lewd or lascivious conduct" occurs when a person intentionally touches a person under 16 years of age in a lewd or lascivious manner or solicits a person under the age of 16 to commit a lewd or lascivious act. Fl. Stat. § 800.04(6)(a). 4. "Lewd or lascivious exhibition" occurs when a person intentionally masturbates or exposes his genitals in a lewd or lascivious manner in the presence of a victim who is less than 16 years of age. Fl. Stat. § 800.04(7)(a). All of these offenses are classified as second degree felonies when perpetrated by an adult. Fl. Stat. §§ 800.04, 800.04(5)(c)(2), 800.04(6)(b), 800.04(7)(c). Section 800.04 affirmatively bars two defenses to these charges. First, "[n]either the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by this section." Fl. Stat. § 800.04(2). Second, the "perpetrator's ignorance of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide belief of the victim's age cannot be raised as a defense in a prosecution under this section." Fl. Stat. § 800.04(3). Florida law does bar "sexual activity" between adults over the age of 24 and minors who are 16 or 17 years' old. Fl. Stat. § 794.05(1). In those cases, "sexual activity" is defined as "oral, anal, or vaginal penetration by, or union with, the sexual organ of another." Id. With this offense, ignorance of the victim's age, misrepresentation of the victim's age, and a bona fide belief that the victim is over the age of 17 are not defenses. Fl. Stat. § 794.021. 4. Charging Decisions EFTA00229833 Due to the differences in these statutes, for girls who were under the age of 16, I have charged instances of enticement to engage in sexual activity for which a person may be prosecuted and enticement to engage in prostitution. For girls who were 16 or 17 at the time, I have charged only enticement to engage in prostitution, unless the conduct with the particular girl rises to the level of "sexual activity" as defined in Fl. Stat. § 800.04(1)(a). 5. Conspiracy to Violate Section 2422(6). Unlike most of the other statutes discussed below, Section 2422(b) does not include its own conspiracy prohibition. Accordingly, a conspiracy to violate Section 2422(b) requires the allegation of a Section 371 conspiracy. While, generally speaking, it is nice to avoid the trouble of alleging a 371 conspiracy, in this case it actually may work to our benefit. First, it allows us to set forth in the indictment, in painstaking detail, the scope of the conspiracy. Second, it allows us to allege as "overt acts," items that might otherwise be excluded pursuant to Fed. R. Evid. 404(b). For example, if Epstein and his assistants engaged the services of an eighteen-year-old girl ("A") to perform a sexual massage on Epstein, that could not be charged as a substantive offense. But, if A was asked to bring additional girls and A later brought Epstein girls who were under eighteen, then the activities with A were overt acts in the conspiracy. Fs 6. Penalties and Forfeiture The charged offenses occurred before the enactment of the Adam Walsh Act, so each count carries a sentence of 5 to 30 years in prison, supervised release of up to life, and a $250,000 fine. Section 2428 states that the Court, in imposing sentence, "shall order, in addition to any other sentence imposed . . . that such person shall forfeit to the United States — (1) such person's interest in any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such violation[.]" Applying this language, Epstein's Palm Beach home and the two airplanes that he used to travel to West Palm Beach are subject to forfeiture. The charge of conspiracy to violate Section 2422 carries a penalty of only 5 years in prison because it must be charged as a Section 371 conspiracy. B. Travel with Intent to Engage in Illicit Sexual Conduct: 18 USC § 2423(b) A person who travels in interstate commerce or travels into the United States . . . for the purpose of engaging in any illicit sexual conduct with another person shall be fined under this title or imprisoned not more than 30 years, or both. 18 U.S.C. § 2423(b). 1. Proof of intent to travel The defendant will most likely assert that his travel to Florida was not done with the intent to engage in illicit sexual conduct—he traveled just to visit his home and attend meetings, etc.—so he lacked the requisite intent. The Eleventh Circuit has held that, in order to be convicted of violating Section 2423(b), the United States must prove that the defendant "had formed the intent to engage in sexual activity with a minor when he crossed state lines." United States v. Hersh , 297 F.3d 1233, 1246 (11th Cir. 2002). See also United States v. Han , 230 F.3d 560 (2d Cir. 2000) (defendant could be convicted of violating Section 2423(b) even though no sexual activity occurred because "minor" was really an undercover officer because the defendant had formed the necessary intent by developing a plan to cross state lines to engage in sexual acts with the minor); United States v. Root , 296 F.3d 1222, 1231-32 (11th Cir. 2002). Although the Eleventh Circuit has not addressed the issue of a "combined motive" for traveling, every other circuit that has addressed the issue has found that the proper statement of the law is: It is not necessary for the government to prove that the illegal sexual activity was the sole purpose for the transportation. A person may have several different purposes or motives for such travel, and each may prompt in varying degrees the act of making the journey. The government must prove beyond a reasonable doubt, however, that a significant or EFTA00229834 motivating purpose of the travel across state or foreign boundaries was to have the individual transported engage in illegal sexual activity. In other words, the illegal sexual activity must have not been merely incidental to the trip. United States v. Hayward, 359 F.3d 631, 637-38 (3d Cir. 2004). See also United States v. Garcia-Lopez , 234 F.3d 217, 220 (5th Cir.2000); United States v. Yang , 128 F.3d 1065, 1072 (7th Cir.1997); United States v. Meacham , 115 F.3d 1488, 1495 (10th Cir.1997); United States v. Sir»is , 87 F.3d 34, 39 (2d Cir.1996); United States v. Campbell , 49 F.3d 1079, 1082-83 (5th Cir.1995); United States v. Ellis , 935 F.2d 385, 389-90 (1st Cir.1991); United States v. Snow , 507 F.2d 22, 24 (7th Cir.1974); United States v. Harris , 480 F.2d 601, 602 (6th Cir.1973). As will be explained below, for each substantive count of violating § 2423(6), we have evidence that Epstein or one of his assistants called a girl a day or two before traveling to Florida, and called again while he was in Florida. The evidence consists of cell phone records for the assistants and the girls, the message pads recovered from the search of Epstein's home, and the flight manifests from Epstein's private planes. 2. Illicit Sexual Conduct "Illicit sexual conduct" means: (1) a sexual act (as defined in section 2246) with a person under 18 years of age that would be in violation of chapter 109A if the sexual act occurred in the special maritime and territorial jurisdiction of the United States; or (2) any commercial sex act (as defined in section 1591) with a person under 18 years of age. 18 U.S.C. § 2423(f). a. What is a Sexual Act? Title 18, United States Code, Section 2246(2) defines "sexual act" as: (A) contact between the penis and the vulva or the penis and the anus, and for purposes of this subparagraph contact involving the penis occurs upon penetration, however, slight; (B) contact between the mouth and the penis, the mouth and the vulva, or the mouth and the anus; (C) the penetration, however slight, of the anal or genital opening of another by a hand or finger or by any object, with an intent to abuse, humiliate, harass, degrade, or arouse or gratify the sexual desire of any person; or (D) the intentional touching, not through the clothing, of the genitalia of another person who has not attained the age of 16 years with an intent to abuse, humiliate, harass, degrade, or arouse or gratify the sexual desire of any person. And Chapter 109A states: "Whoever, in the special maritime and territorial jurisdiction of the United States or in a Federal prison, knowingly engages in a sexual act with another person who — (1) has attained the age of 12 years but has not attained the age of 16 years; and (2) is at least four years younger than the person so engaging; or attempts to do so" has committed a federal offense. Thus, for purposes of this case, when the victim is under the age of 16, and Epstein either digitally penetrated the girl or used a vibrator on her vagina, I have alleged that the defendant has violated Section 2423(b) when he traveled in interstate commerce for the purpose of engaging in a sexual act as defined in this statute. b. What is a commercial sex act? "The term `commercial sex act' means any sex act, on account of which anything of value is given to or received by any person." 18 U.S.C. § 1591(c)(1). The statute does not go on to define "sex act," but the legislative history of this statute makes clear that the term is to be read very broadly. The term "commercial sex act" replaced the term "prostitution" in an earlier version of the statute. Section 1591 was enacted as part of the "Victims of Trafficking and Violence Protection Act of 2000." Pub. L. 106-384, 114 Stat. 1464. In drafting that legislation, Congress noted: "The sex industry has rapidly expanded over the past several decades. It involves sexual exploitation of persons, EFTA00229835 predominantly women and girls, involving activities related to prostitution , pornography, sex tourism, and other commercial sexual services ." Id. at § 102(b)(2). The highlighted language shows that "commercial sexual services" is a broader term than "prostitution," but includes prostitution and the creation of pornography, amongst other acts. When the Sentencing Commission amended the Sentencing Guidelines to correspond with this new legislation, it replaced the term "prostitution" with "commercial sex acts" in the heading of part G of Section 2 and throughout that section. Fe The Commission gave a stated reason for the amendment: This amendment ensures that appropriately severe sentences for sex trafficking crimes apply to commercial sex acts such as production of child pornography, in addition to prostitution . It proposes several changes to § 2G1.1 . . . to address more adequately the portion of section 112(b) of the Victims of Trafficking and Violence Protection Act of 2000 . . . The amendment proposes three substantive changes to § 2G1.1. First, this amendment broadens the conduct covered by the guideline beyond prostitution to encompass all commercial sex acts, consistent with the scope of the Act.. . . . App. C, Vol II, Amendment 641 (emphasis added). The reference to child pornography is especially helpful to us, because the child pornography statutes use the term "sexually explicit conduct," which is extremely broad, and includes masturbation and the "lascivious exhibition of the genitals or pubic area of any person." 18 U.S.C. § 2256(2)(A). 3. Charging Decisions For girls who were under the age of 16, I have charged instances of travel with the intent to engage in a "sexual act" with a girl under the age of 16 and travel to engage in a "commercial sex act" with a minor. For girls who were 16 or 17 at the time, I have charged only travel to engage in a "commercial sex act." 4. Conspiracy Section 2423(e) creates a separate offense for conspiring to violate Section 2423(b), so the indictment will contain a single conspiracy count, without the allegation of overt acts, for the entire period of the conspiracy. 5. Defense Section 2423(g) provides that in "a prosecution under this section based on illicit sexual conduct as defined in subsection (0(2), it is a defense, which the defendant must establish by a preponderance of the evidence, that the defendant reasonably believed that the person with whom the defendant engaged in the commercial sex act had attained the age of 18 years." So, for those allegations involving commercial sex acts with 16- and 17-year-old girls, the defendant can come forward and present affirmative evidence that he reasonably believed that the girls were 18 or older. The defense cannot be asserted for the sex acts with girls under the age of 16. 6. Penalties and forfeiture A violation of section 2423, including the conspiracy provision of 2423(e), has no mandatory minimum sentence, and the maximum sentence is 30 years in prison, lifetime supervised release, and a $250,000 fine. Section 2428's forfeiture provision applies to these violations as well. C. Transportation of an Individual to Engage in Sexual Activity: 18 USC 2421 Whoever knowingly transports any individual in interstate or foreign commerce . . . with intent that such individual engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title or imprisoned not more than 10 years, or both. 18 U.S.C. § 2421. This traditional "Mann Act" section can be used to charge Epstein alone with transporting his girlfriend, from New York to Florida to en age in sexual activity with one of the girls. As will be explained below, one of the victims, ., estimates that she engaged in sexual activity with Epstein "hundreds of times." reports that, at some point, EFTA00229836 Epstein agreed to pay more money if she would enga e in sexual activity with while Epstein watched. Some of this activity occurred before . turned 18 and some occurred afterwards. Regardless of .'s age at the time, "could have been charged with" the following criminal offenses: • offering to commit or committing prostitution or lewdness, Fl. Stat. § 796.07(2)(e); • soliciting, inducing, or enticing another to commit prostitution or lewdness, Fl. Stat. § 786.07(2) (0; • aiding, abetting, or participating in either of the above-listed offenses, Fl. Stat. § 796.07(2)(h); or • purchasing the services of any person engaged in prostitution, Fl. Stat. § 796.07 2 i Since the transported individual is considered a "victim" under this statute, cannot be charged, so Epstein is named alone. See, e.g., United States v. Love , 592 F.2d 1022, 1025 (8th Cir. 1979) (citing Gebardi v. United States , 287 U.S. 112, 118-19 (1932)). Just as with Section 2423(b), the Government must prove that the defendant had the requisite intent prior to the travel, but the Government does not have to prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of ten years in prison. Section 2428's forfeiture provision also applies to this offense. D. Sex Trafficking: 18 USC 1591(a) Another potential charge, which probably can be used only against and others who referred or procured girls for Epstein, is human sex trafficking, in violation of 18 U.S.C. § 1591(a). Section 1591(a)(1) makes it illegal for any person to knowingly, in or affecting interstate or foreign commerce, recruit, entice, transport, provide, or obtain by any means a person knowing that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act. Section 1591(a)(2) makes it illegal for a person to knowingly benefit "financially or by receiving anything of value, from participation in a venture which has engaged in an act described in violation of paragraph (1), knowing that . . . the person has not attained the age of 18 years and will be caused to engage in a commercial sex act." The term "commercial sex act" has the same meaning as discussed above. The statute defines "venture" as "any group of two or more individuals associated in fact, whether or not a legal entity." 18 U.S.C. § 1591(b)(3). With respect to 1591(a)(2), the Tenth Circuit has stated the elements as: 1. the defendant knowingly benefitted financially from participating in a venture; 2. the acts engaged in by the venture were in or affecting interstate commerce; 3. the venture recruited, enticed, harbored, transported, provided, or obtained by any means a person; 4. the defendant knew that the person was under the age of eighteen; 5. the defendant knew the minor would be caused to engage in a commercial sex act. United States v. Wild , 143 Fed. Ar.938, 942 (10th Cir. 2005). Epstein's assistants, and Leslie Graff, could be considered people who recruited or obtained by any means girls under the age of 18 who would be caused to engage in commercial sex acts. They also could be considered people who benefitted financially from their participation in that venture based upon the salaries that they received from Epstein. We also may want to consider adding some of the "local pimps." For example, the boyfriend of one of Epstein's former assistants recruited girls for Epstein and got paid. If a girl who performed a sexual massage for Epstein brought more girls to Epstein, the original girl would get paid $200 for each "referral." These violations of Section 1591(a) carry a statutory maximum of 40 years' imprisonment, supervised release of up to life, and a $250,000 fine. 18 U.S.C. § 1591(b)(2). As discussed further EFTA00229837 below, some of the girls were told that they would only have to "model lingerie." A violation of Section 1591(a) carries a harsher penalty if the offense was "effected by fraud." There still is no mandatory minimum, but the maximum term of imprisonment is life. 18 U.S.C. § 1591(b)(2). E Money Laundering: 18 USC 1956 Epstein and his associates can face charges of promotion money laundering. Whoever, with the intent — (A) to promote the carrying on of specified unlawful activity; . . . conducts or attempts to conduct a financial transaction involving . . . property used to conduct or facilitate specified unlawful activity, shall be fined under this title or imprisoned for not more than 20 years, or both. 18 U.S.C. § 1956(a)(3). "'Conducts' includes initiating, concluding, or participating in initiating, or concluding a transaction." 18 U.S.C. § 1956(c)(2). The "term `transaction' includes a purchase, sale, loan, pledge, gift, transfer, delivery, or other disposition, and with respect to a financial institution includes a deposit, withdrawal, transfer between accounts, . . . or any other payment, transfer, or delivery by, through, or to a financial institution, by whatever means effected." 18 U.S.C. § 1956(c)(3). A "financial transaction" is: (A) a transaction which in any way or degree affects interstate or foreign commerce (i) involving the movement of funds by wire or other means or (ii) involving one or more monetary instruments, . . . or (B) a transaction involving the use of a financial institution which is engaged in, or the activities of which affect, interstate or foreign commerce in any way or degree. 18 U.S.C. § 1956(c)(4). The "specified unlawful activity" is one of the offenses listed in 18 U.S.C. § 1961(1), namely "any act which is indictable" under Section 1591(a) (sex trafficking) and Sections 2421 through 2423 (relating to white slave traffic). See 18 U.S.C. § 1961(1)(B). Epstein's property manager, Janusz Banasiak, was interviewed and served with a subpoena for records relating to his employment. Banasiak resides in the "guest house" on Epstein's property, and has access to a "Jeffrey Epstein Household Account." Banasiak uses that account to pay for various household expenses. Banasiak's practice was to withdraw $1500 at a time from the bank, and he then would keep a detailed accounting of how the money was spent and, when the $1500 was used up, he would send a copy of the accounting to Epstein's accountant and he maintained a copy for himself. A review of those records showed a number of entries that would simply have a girl's name and a round dollar amount — usually $200. Banasiak explained that on several occasions when Epstein was "in residence," Epstein or 1F 0 would ask Banasial pay one of the girls after a massage was completed. On other occasions when Epstein and M were not in Florida, would call Banasiak to say that a girl was coming to the house and Banasiak should give the girl $200 in an envelope. Banasiak stated that he would follow these instructions and that he knew that the money was for "massages," but he insisted that he did not know that sexual activity was occurring. Why Esptein would pay "masseuses" when he was out of town cannot be explained. F. Charges that Were Considered and Rejected 1. The Travel Act: 18 USC 1952 Section 1952 bans the travel in interstate commerce in aid of racketeering. So, if a person travels in interstate commerce with the intent to promote an unlawful activity—which can include prostitution, and after this travel he performs an act to promote that unlawful activity, then he has violated the Travel Act. At first blush, this appears to apply. However, the "unlawful activity" must be a " business enterprise involving" prostitution. If Epstein were a pimp who was soliciting girls for other men and was assisting him in that effort, the Travel Act would apply. However, since Epstein is using to solicit girls on Epstein's own behalf, I don't believe that Epstein's personal use of the prostitutes can be considered a business enterprise. EFTA00229838 III. Victims A. =ff - As mentioned above, parents originally brought Epstein's behavior to the attention of the Palm Beach Police Department. 1. The Sexual Activity went to Epstein's house once, on February 6, 2005, when she was 14 years old. was in the 9 th rade at Royal Palm Beach High School at the time. was recruited b cousin, was dating at the time. On February 5, 2005, and went house to watch a movie. At 10:00 pm used her cell hone to call Epstein's home. to~ heard describing to the person on the telephone. states that she was s eakin with . After hangs up, asks why was describing her. asked if she wanted to make $200 giving a massage to a very rich man on Palm Beach. began arguing because didn't want to do a massage. decided to go anyway so that she could make $200. rtes that she knew she would have to take her topp off and that Epstein would masterbate during the massage. states that knew she would have to strip down to her bra and panties and that "the more she did, the more [money] she would make." instructed that, if Epstein asked, would say she was 18 and was a senior at Wellington High School. On Febru 6, 2005, at 12:50 m called cell phone. Two minutes later, called At 1:01 pm, called Epstein's Palm Beach house and, one minute later, again called and both say that and another girl [Serena] went to house and picked her up. They drove to the Palm Beach house. A security guard asked why they were there, and said they were there to see Jeffrey. The guard let them in and they entered the house through a side door into the kitchen. Epstein and an assistant [probably arrived and the assistant led upstairs to the master bedroom where all the massages took place. was able to describe the bathroom and the pictures of naked irls the home accurately, and she describes how she and the assistant picked out massage lotions. states that the assistant told her to take her top off. Epstein entered shortly thereafter and forcefully ordered to take her pants off. removed her pants while Epstein entered the toilet area of the bathroom. Epstein returned wearing only a towel. Epstein laid face down and told to straddle him to massage his back. bare buttocks touched Epit 's lower back/top of his buttocks. Epstein asked age and where she went to school and said that she was 18 and was a senior at Wellington. Epstein got up from the massage table and went to the toilet area where he masturbated and ejaculated. Epstein then returned and laid facing up. He continued to masturbate while directing to massage his chest. Epstein then told to remove her panties and to grab a large back massager that was across the room. Epstein be the massager on vagina while he masturbated. Epstein then digitally penetrated looked at Epstein to express her dis leasure with the penetration and Epstein looked at her and sarcastically said, "What's the matter?" looked away. When Epstein ejaculated, the contact stopped. Epstein gave $300 and left to get dressed. if, also asked to leave her telephone number. dresses, went downstairs, and left with and Serena. received $200 for bringing In the car on the way home, told that Epstein "fingered" her and paid her $300. joked that they could et if they went to Epstein's house every weekend. The girls went shopping and then took home. When returned to school on Monday, she told a friend what had happened. As discussed in the introduction, rumors started flying around the school and and another girl got into a fir. One of the school administrators searched purse and found the $300. When confronted, EFTA00229839 initially stated that she earned the $300 through her job at Chik-Fil-A. She then stated she had sold drugs to :et the money, and finally admitted that she had gotten the money from Epstein. be an working with a Palm Beach Police Detective. Controlled calls were made to was initially suspicious because she had heard about the problems at the school. convinced that she wanted to return to Epstein's house because she needed more money. was recorded saying, "the more ou do, the more you make." On March 30 and 31, 2005, placed controlled calls to about setting up another meeting with Epstein. Also on March 30 and 31, 2005, and made calls to and from each other. On March 31 and April 1, 2005, called and left voicemail messages, which were recorded, to confirm a visit to Epstein's house. Epstein flew in to Palm Beach International Airport ("PBIA") on March 31, 2005. The April 1 recorded voicemail messages, were to confirm a visit to Epstein's house on "Saturday" which would have been Saturday, April 2, 2005. On Tuesday, April 5, 2005, Palm Beach Police Department did a trash pull at Epstein's home, and recovered a handwritten note, "M with Sage on Saturday at 10:30." Epstein departed PBIA on April 6, 2005. Charges Based on Activity with 1. Overt Acts • . On or about February 4, 2005, EPSTEIN, and traveled via airplane from New York, New York, to Palm Beach County. . On or about February 5, 2005, EPSTEIN and caused telephone calls to be made by M. to . On or about February 5, 2005, EPSTEIN and caused a telephone call to be made by M. to . On or about Febru 6, 2005, EPSTEIN and caused one or more telephone calls to be made by M. to . On or about February 6, 2005, EPSTEIN and cause M. to make one or more telephone calls to . On or about February 6, 2005, EPSTEIN and cause M. to make one or more telephone calls to # . On or about February 6, 2005, EPSTEIN and caused M. to transport M. to El Brillo Way, Palm Beach, Florida. . On or about February 6, 2005, EPSTEIN made a payment of $300 to M. and a payment of $200 to . On or about February 7, 2005, EPSTEIN, a, and traveled via airplane from Palm Beach County to New York, New York. • . On or about March 30, 2005, EPSTEIN and caused M. to make one or more calls to • . On or about March 30, 2005, placed a call to a telephone used by # . On or about March 31, 2005, placed a call to a tele hone used b . # . On or about March 31, 2005, EPSTEIN, a, and traveled via airplane from New York, New York to Palm Beach County, Florida. . On or about March 31, 2005, EPSTEIN and caused M. to place a call to On or about April 1, 2005, EPSTEIN and caused M. to place a call to # . On or about April 1, 2005, EPSTEIN and caused M. to place one or more calls to .7 # . On or about April 6, 2005, EPSTEIN, a, and traveled via airplane from Palm Beach County, Florida, to New York, New York. EFTA00229840 2. Substantive Counts Count Date(s) Offense Statute Defendant(s) # 2/5/05-2/6/05 Use of cellular phone to persuade or 2422(b) EPSTEIN induce . to engage in sexual activity or prostitution alluring a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructive Epstein to have the CPUs removed although they insisted that those instruction were given well in advance of the execution of the search warrant — not in response to a "leak." a has since gotten married and is now "M that is the name she used during the relevant period. ." I will refer to her as since Sometimes Epstein made the payment and asked for the phone number, sometimes it was the assistant. a lPBSAO's handling of this case was incredible, and is discussed in Appendix to this memorandum. FSThe pattern jury instruction does not address a case like this where it is alleged that the facility of interstate commerce was used to induce the girl to engage in prostitution . In such a case, the third element probably could be deleted. %In Bonner v. City of Prichard, 661 F. 2d 1206 (11th Cir. 1981), the Eleventh Circuit adopted as binding precedent all Fifth Circuit decisions rendered prior to October 1, 1981. a"Sexual activity" is defined as "the oral, anal, or vaginal penetration by, or union with, the sexual organ of another or the anal or vaginal penetration of another by any other object; however, sexual activity does not include an act done for a bona fide medical purpose." Fl. Stat. § 800.04(1)(a). a'"An 'overt act' is any transaction or event, even one which may be entirely innocent when considered alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). L9Part G contains the guidelines for calculating the offense levels for "Offenses Involving Commercial Sex Acts, Sexual Exploitation of Minors and Obscenity." F )o;an one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and it appears that at some time they were romantically involved. Maxwell also has been implicated in another act of molesting a young girl, which is discussed in the 404

EFTA01128744.pdf

DataSet-10 Unknown 2 pages

The press headlines of "sex slave" "sex ring", "sex predator". are all merely tabloid fictions meant to sell newspapers. nothing more. It was widely reported I was his sex slave. There is nothing further from the truth. Jeffrey met me when I was fully, and technically and adult. He was generous kind and funny. Claims of him purchasing me from my parents are obviously a delusion of some loser- male reporter A Jeffrey Epstein never testified on his own behalf, never! his lawyers actually made no attempt in the press to explained the facts, they merely argued whether the laws, that were clearly tortured beyond recognition in order to fit his behavior into a federal crime, applied . Testifying would have meant bringing other people into a mess of admittedly his own creation. Why, Jeffrey rarely left his house, he did not troll on the interenet. he did not drive around looking for girls, he didn't go to clubs parties or even restaurants. Being what some might call a health nut, He has never had a drink or drug. he did 90 minutes of yoga every day or resistance training, he would then shower , and begin his day, That day inevnentiably began with a massage. He would begin his work by getting on the massage table, face down BEFORE anyone was in the room, and begin making his daily calls. A massge person, recruited from either the local massge places. massuees he knew or friends of a masseeh would enter the dimly lit massage room and begin working on his calfs before he even said hello, He would most of the time , not even know who they were , he might ask their name, and who brought them, often, as the police reports show, their friends waited downstairs.. the ages of the daily massage persons ranged from young to over 60. the vast majprity in their twenties and early thirties. The message pads would show, many if not all , would call asking to see when he was free so that they could return, or they would suggest a friend. they all were told no underage girls. in fact the police report that describes the first girl who was in reality fourteen telling the police, she said she was 18. in her words, she said if I had told the truth I would not have been able to get in the house.. in her words, not his.? not one witness not one suggested that he asked for underage girls. The idea is ludicrous.. THe local strippers that willingly came as well as the girls who worked in the local massage parlors came, many later labled as the Jane doe " victims " JAne doe I , daugther of a local prostitute ran a shower with girl biz and advertised it. danced in the local strip club, admittedly some had less of a typical professsion or experience. each and every one were brought by one of their friends or acquaitences. many who brought thier frineds including the jam does in questions , brought their friends to the house. The horrifyninng experiences that they described seemed not to be so horrifying as to prevent them from bringing their best friends and returning on multiple occasions When the stories of the girl are compared, IT should have raised concerns that the language of each was almost verbatim. rehearsed amongst themselves. JEffrey was never alone in the house. there was always staff , always. not one time did any girl complain, suggest an impropriety .. NOT one time. Jeffrey is certainly does not cut a sympathetic figure , the boy genius , that people from all over the world come to hear his financial prognostications. there are no parties at the house, there is rarely even wine served ( to the dismay ofhis guests) , he is a loner. He doesn't really socialize . when the local sex crimes prosecutor , with experience of over 20 years , in palm beach , went through all the facts and claims . She in her words, said that there were no real victims here. None ".no real victims". One of the type that is forced against her will , I as a woman an unimaginable and horrific experience. These were victims only in the sense of their technical. age . Technical age. Not psychological age. Not based on years of prostitution , scams crimes etc. just birthdate. In florida though the girl might even show fake id. Relying on their word is not enough. Misrepresentaion of age , is not a defense. Not a defense. When a seventten year old , signs a contract to buy a dress on time and then doesn't pay , she cannot be held accountatble as she was not legally old enough to enter a binding contract. This was all a local matter, Jeffrey rarely left his house. I was already a stretch to attempt to turn this into a federal crime, more of a stretch to claim that arranging a massage on a telephone, giving the necessary federal nexus. ( the telephone being the means of interstate commerce. ) and a recent supreme court case stating that arranging would not be a crime. ( coercion force , changing the will of the minor required ) Jeffrey almost never on the phone himself. Someone merely arranging an appointment. The feds the suggested traveling for the purpose of underage sex. Here Jeffrey was going home to his house of 20 years. Going to his home not to Thailand ( where no local laws preventing abuse are in existance ). In the strangest twist of all , the feds required him to pay a list of girls whose actual names they would only provide AFTER he was in jail. Provide the minimum amount of money, and if THEY didn't agree, he would have to hire a lawyer for them, pay the lawyer to sue himself. And not be able to contest liability. Yes what you have read is correct , no matter how crazy it sounds. Pay lawyers to sue himself and not be able to contest the claims . In actuality when he tried to file a motion to dismiss a case from someone who could not even prove she was at the house , he was threatened with a declaration of breech. EFTA01128744 I was never, the tabloid -given moniker , a sex slave. Jeffrey did not buy me, from my parents. Jeffrey did nothing to me , but did enable me, by being kind and generous to become a successful qualified jet pilot. Before every flight I , run through both a basic and more detailed checklist. I focus on the safety of my passsengers. Hurting innocent people by not taking the time to make sure the checklist is complete would be irresponsible , unprofessional and dangerous. Thepress has ignored this basic premise. Not taking the little time to check basic allegations. For example , though she descried in minute detail the dinner. From how the president arrived to where he sat. however it never ever happened. First item on checklist , check credibility, cannot respond " check" as it was a lurid story crafted of total fabrications, the press chose to ignore how easily refuted these statements were and with reckless disregard for the people they would hurt , ignored the lack of " check" and took the story to the air and let it fly. EFTA01128745

EFTA01731558.pdf

DataSet-10 Unknown 1 pages

From: Jeffrey Epstein Sent: Saturday, January 10, 2015 11:24 AM To: Jeffrey Epstein Subject: privileged and confidentail The press versions of sex slave sex ring, underage sex*=A0 . are all fictions meant to sell newspapers. nothing more.=C24, Mr epstein never testified, never„ his lawyers never e=plained the facts they merely argues whether the law applied. =C2* Why, jeffrey never left his house, he did not troll on t=e interenet. he did not drive around looking for girls. Being what s=me might call a health nut, He has never had a drink or drug. =e did 90 minutes of yoga every day or resistance training, he would =hen shower , and begin his day, THat day inevnentiably began w=th a massage. He would begin his work by getting on the massag= table, face down BEFORE anyone was in the room, and begin ma=ing his daily calls. A massge person, recruited from eit=er the local massge places. massuees he knew or friends of a masseeh =would enter the dimly lit massage room and begin working on his calfsQ=A0 before he even said hello, He would not know who they were = he might ask their name, and who brought them, often their friends =aited downstairs.. the ages of the daily massage person ranged from young =o over 60. the vast majprity in their twenties and early thirties.in= The message pads would show many if not all , asking to see w=en he was free so that they could return, they would suggest a frien=. they all were told no underage girls. in fact the police rep=rt that describes th first girl who was in reality fourteen telling the po=ice, she said she was 18. in her words, she said otherwise she=would not have been able to get in the house. . in her words, =ot his.? not one witness not one suggeted that he asked for underage=girls. The idea is ludicrous. . THe local strippers that willi=gly came as well as the girls who worked in the local massage parlors came= many labled as " victims " . JAne doe 1, daugther =f a local prostitute ran a shower with girl biz and advertised it. d=nced in the local strip club, admittedly some had less of a typical profes=sion or experience. each and every one were brought by one of =heir friends or acquaitences. many who brought thier frineds includi=g the jane does in questions , brought their friends to the house. T=e horrifyninng experiences that they described seemed not to be so horrify=ng as to prevent them from bringing their best friends. When t=e stories of the girl are compared, IT should have raised concerns t=at the language of each was almost verbatim. rehearsed amongst thems=lves. JEffrey was never alone in the house. there was always s=aff , always. not one time did any girl complain, suggest an i=propriety NOT one time. date-last-viewed 0.0 date-received 1420889015 flags 8590195713 remote-id 134603 EFTA_R1_00004712 EFTA01731558

EFTA00074147.pdf

DataSet-10 Unknown 3 pages

From: ' (NY) (FBI)" C To: ' , "Young, Amanda N. (NY) (FBI)" Cc: Subject: RE: GM investigation Date: Thu, 05 Mar 2020 17:16:54 +0000 • I have reviewed the financial productions for Maxwell and Epstein as well as FinCEN filings regarding Maxwell. Highlights are as follows: 1. On 6/15/07, a $7,400,000 wire transfer was made from Epstein's account at Bear Stearns account to Maxwell's JP Morgan Chase Account 2. On 1/4/11, a $3,000,000 transfer was made from Epstein's JP Morgan Chase account to Maxwell's JP Morgan Chase Account #739116312. On the same day, those proceeds were transferred to Epstein's JP Morgan Chase account 3. On 7/28/11, $10,900,773.48 was wired from FSL LLC's account at Firstbank Pueto Rico to Maxwell's JP Morgan Chase Account On the same day, the following transfers totaling $10,895,644.29 were made from Maxwell's JP Morgan Chase Account a. $722,802.88 transfer to Epstein's JP Morgan Chase account b. $9,768,791.41 transfer to Epstein's JP Morgan Chase account c. $339,050 transfer to Asset Account . (I do not know the owner of that account) d. $65,000 wire transfer to George V. Delson Associates' account at Signature Bank 4. During the period of 9/10/09 through 7/20/10, three direct deposits and a check deposit totaling $22,206.52 were made from NES LLC to Maxwell's JP Morgan Chase Account . Additionally, during the period of 12/22/09 thru 3/2/10, three checks totaling $7,399.08 were written from Maxwell's JP Morgan Chase Account to NES LLC. (Please note that the first statement that was available for account Maxwell's JP Morgan Chase Account was September 2009. Previous payments from NES LLC may have been made to Maxwell.) Other than accounts held at financial institutions, I have not identified any assets. Best From: [mailto: Sent: Monday, February 24, 2020 12:55 PM To: (NY) (FBI) < MI> Cc: (NY) (FBI) Subject: Re: GM investigation EFTA00074147 No problem, we will start working on what we can today. I've CC'd for assistance with some of these requests. Mark, would you be able to give us a hand with items 2-3 on this list as requested by the AUSA's. I've performed an updated Accurint check on Maxwell search for any properties she owns with negative results. Hoping maybe you can come up with something in your searches. Thanks! Detective NYPD / FBI Child Exploitation Human Trafficking Task Force Office: Cell: Fax: From: Sent: Monday, February 24, 2020 12:27 PM To: (NY) (FBI) < > Cc: >; Subject: GM investigation Hi In connection with the Maxwell investigation, I know this is a travel week, but if at all possible, are you able to assist with the following? It would be great to get some of these in motion this week: 1) Are you able to spend some time reviewing the message pads seized from Epstein's residence, to search for any messages left by (or regarding) any of the individuals relating to the GM case? In particular, it would be helpful to know if there are messages relating to: 2) I recognize that we do not have a complete picture of Maxwell's current finances. I don't think it makes sense to request additional financial information, but it would be helpful to have a snapshot of what we already know about her current assets. In addition, it would be helpful to know if there are any significant transfers from Epstein's account to Maxwell since 2005. Along the same line, a check for more recent alerts in FinCEN would be helpful. 3) On the topic of assets, can you tell us what properties Maxwell currently owns? 4) Could you please send us the current tracking document for the hotline? It would be helpful for us to check through the leads regarding Maxwell. 5) I think we emailed about this last month, but can you let us know how you know that she has UK and French citizenship? 6) Could you please send us the notes from the interview? Thanks in advance, and sorry to pile on, I know everyone is busy. Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00074148 EFTA00074149

EFTA00269744.pdf

DataSet-10 Unknown 3 pages

Precedence: ROUTINE Date: 02/06/2008 To: New York Attn: SSA Squad C-20 From: Miami PB-2/PBCRA Contact: SA Approved By: Drafted By: Case ID #: 31E-MM-108062 (Pending) Title: JEFFREY EPSTEIN; GHISLAINE N. MAXWELL; WSTA - CHILD PROSTITUTION Synopsis: To set leads for captioned investigation. Reference: 31E-MM-108062 Serial 125 Enclosure(s): Enclosed for New York is a copy of referenced serial, FD-302 of Details: On 07/24/2006 the Federal Bureau of Investigation (FBI), Palm Beach County Resident Agency (PBCRA), began investigating Jeffrey Epstein, a part-time resident of Palm Beach, along with his personal assistants, and Ghislaine Maxwell. PBCRA obtained information from the City of Palm Beach Police Department (PBPD) that a fourteen- year-old girl who lives in Loxahatchee, Florida, in the Southern District of Florida, and who attended Royal Palm Beach High School, provided Epstein "sexual massages". The fourteen-year-old girl informed PBPD that she had been paid $300.00 by Jeffrey Epstein to perform a "sexual massage", which entailed providing a massage to Epstein while he was naked and the fourteen-year-old was wearing . During the massage, Epstein masturbated himself, Following the receipt of the case files from the PBPD, PBCRA began interviewing a series of girls, ranging in age from fourteen through mid to early twenties, who reported a similar series of events. In particular, the girls described how contact was made via telephone, primarily with , Epstein's assistant, to arrange times for the girls to "work" at Epstein's home in Palm Beach. The girls would travel to Epstein's residence, usually in the company of another girl. The girls would enter Epstein's home via the kitchen, where they would be met by Epstein and/or . The girls would be escorted up to Epstein's bedroom where a massage table was accessible. The girls were told to undress - some undressed only partially and some undressed completely. Epstein would enter the room partially dressed, usually wearing only a towel. He would get onto the massage table face down. While lying face down, Epstein instructed the girl how to massage him. After a period of time EFTA00269744 when the girl massaged Epstein's back, he would turn over and lie face up. While lying face up, Epstein would continue to instruct the girl on how to conduct the massage. Epstein also would masturbate himself and, . When Epstein ejaculated, the "massage" was over. The girls received between $200 and $300 for the sexual massages. In addition to these sexual massages, some of the girls were paid additional sums to perform more sexual activity, for example, engaging in sexual activity with another female Epstein employee, while Epstein watched. During the course of PBPD's investigation, a search warrant for Epstein's home was obtained and executed. Many of Epstein's belongings were removed from the home prior to the execution of the search warrant - for example, the computer processing units (CPUs) were removed from the house but the computer screens, keyboards, cords, etc. were left behind. The missing CPU's were never recovered. During the search, several telephone message pads were recovered. These message pads show messages taken from several of the girls who were interviewed and admitted to engaging in sexual massages or other sexual activity with Epstein. The messages contained text such as "I have a female for him" and "has girl for tonight." Some of the messages from the girls were addressed to Epstein and others were addressed to , Epstein's assistant. Additional messages recovered during the search contained text confirming appointment times. During the PBCRA's investigation, the girls related that would contact the girls while and Epstein were still in New York or elsewhere, in order to arrange "massage" times upon his arrival in Palm Beach. The PBCRA's investigation has collected the flight manifest for Epstein's two private planes during the period of January 2004 through December 2005 as well as cellular phone records for Epstein and his assistants. The investigation revealed that prior to the flights to Palm Beach, would contact some of the girls via cell phone. The massage pads show evidence that the girls responded to those telephone calls and in some instances appointment confirmations were left for Epstein. In addition to the home in Palm Beach, Epstein also maintains residences in the U.S. Virgin Islands, New Mexico and his New York residence, 9 E. 71st Street, New York, NY 10021. Based on the ongoing criminal investigation, the PBCRA is requesting assistance in establishing Epstein's criminal activity utilizing interstate commerce and the travel in interstate commerce to engage in illicit sexual conduct and prostitution. On 10/05/2007, was telephonically interviewed. advised that she and additional minor females had participated in similar activity with Epstein in the New York area. Epstein utilized the same modus operandi which has been documented in multiple interviews of minor females in the Palm Beach, Florida area. Prior to conducting captioned leads, it is requested that the lead agent(s) contact SA EFTA00269745 Kuyrkendall, for investigative direction and questions. LEAD(s): Set Lead 1: (Action) NEW YORK AT NEW YORK, NY Locate and interview , DOB . cellular telephone , Choicepoint database reflects her most recent address as . Determine from any additional minor females who may have interacted with captioned subjects. Set Lead 2: (Action) NEW YORK AT MASTIC, NY Locate and interview DOB telephone , Choicepoint database reflects her most recent address as . Determine from Rea any additional minor females who may have interacted with captioned subjects. * * EFTA00269746