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From
To
Subject: RE: Evidence
Date: Fri, 03 Dec 2010 14:19:40 +0000
Importance: Normal
There is no way that FBI is going to be willing to give that up. And it isn't in our custody. (And some of it I
have never even heard of.)
And what does that have to do with the victims' rights suit? That is just discovery for whatever the next set of
civil suits will be against Epstein.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From
Se • •
To:
Su
Here is Brad's exhibit listing of items they want us to produce.
From: Brad Edwards [mailto:brad@pathtojustice.com]
Sent: Frida , December 03, 2010 8:53 AM
To:
Cc: au asse
Subject: Evidence
Hi
Here are the items we would like to receive from you, in addition to the statements, correspondence and emails we
discussed.
Basically we are looking for the items taken in the search warrant and trash pulls, most importantly the "Massage file" and
"7 Message pads" and message machine tapes.
Also the numerous photos by the pool; 11 CD's from the kitchen; CD's, DVD's and photos from desk; VHS tapes and CD's
marked Happy Birthday.
As well as the zip CD's from the bookcase, 8mm videotapes from bookcase, compact flash cards from bookcase, the line-
ups and 16 dvd-r discs from PBSO case 05250067 Epstein case files.
EFTA00212218
Please let me know when we can expect to receive any or all of these items. Thank you.
Sincerely,
Brad Edwards
Civil Justice Attorney
Farmer, Jaffe, Weissing,
Edwards, Fistos Et Lehrman, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
.1J U
Please consider the environment before printing this e-mail.
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or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or
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IMMEDIATELY BY TELEPHONE TOLL FREE (800) 400-1098 AND DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU.
EFTA00212219
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The press headlines of "sex slave" "sex ring",.sex predator. are all tabloid fictions meant to sell
newspapers. nothing more. It was widely reported I was his sex slave. There is nothing further from the
truth. Jeffre met me when I was full , and technically and adult. He was generous kind and funny. Claims
of him are obviously a delusion of some loser- male reporter A
Jeffrey Epstein never tests ie on is 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
restarants. 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
M dmittedly 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 Jane 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 telephonebeing the means of interstate commerce. ). Jeffrey almost never on the
phone himself. Someone merely arranging an appointment. The feds 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 ). 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. A minimum
amount ofmoney, 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.
I was never the tabloid given moniker , a sex slave. Jeffrey Jeffrey did
nothin to me , but did enable me to
Hurting innocent
EFTA01124425
people by not taking the time to make sure the checklist is complete would be irresponsible ,
unprofessional and dangerous. Thepress has i oral this basic premise. Not taking the little time to
check the basic allegations. though she descrived in minute detail the dinner. From
how the presendent arrived to where he sat. however it never ever happened. Made up of total
fabrications, the press chose to ignore how easily refuted these stattements were and with reckless
disregard for the people they would hurt , took the story to the air and let it fly.
EFTA01124426
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IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
)
Plaintiff, ) CASE NO.: 502006CA026051XXXXMB
)
vs. )
)
JEFFREY EPSTEIN, )
)
Defendant. )
)
SUBPOENA DUCES TECUM
FOR DEPOSITION
THE STATE OF FLORIDA:
TO: Janusz Banasiak
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on October 7, 2009 at 2:00 p.m., at Esquire Court Reporters, 515 N
Flagler Dr., West Palm Beach, FL 33401.for the taking of your deposition in this action
and to have with you at that time and place the following:
See Schedule "A" attached.
If you fail to appear, you may be in contempt of court. You are subpoenaed
to appear by the following attorneys and unless excused from this Subpoena by these
attorneys or the Court you shall respond to this Subpoena as directed.
DATED on August , 2009.
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 EastLas Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
MOO 542075
1
EFTA00730307
Schedule "A"
Documents, writings, agreements, correspondence, schedules, diaries, personal
notes, message pads, names of "masseuses" and all other writings of any kind, related in
anyway to Jeffrey Epstein or your employment with him.
2
EFTA00730308
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IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
L.M., )
)
Plaintiff, ) CASE NO.: 502008CA028051XXXXMB
)
vs. )
)
JEFFREY EPSTEIN, )
)
Defendant. )
)
SUBPOENA DUCES TECUM
FOR VIDEOTAPED DEPOSITION
THE STATE OF FLORIDA:
TO:
YOU ARE COMMANDED to appear before a person authorized by law to
take depositions on October 8, 2009 at 4:00p.m., at Esquire Court Reporters,
1021 Ives Dairy Road, Suite 214, Building 3, North Miami, FL 33401-4321 for
the taking of your deposition in this action. You are to have with you at this time
and place those items described on Schedule "A" attached hereto.
If you fail to appear, you may be in contempt of court. You are
subpoenaed to appear by the following attorneys and unless excused from this
Subpoena by these attorneys or the Court you shall respond to this Subpoena as
directed.
DATED on August 2009.
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
EFTA00774013
Schedule "A"
Documents, writings, agreements, correspondence, schedules, diaries,
personal notes, message pads, names of "masseuses" and all other writings of any
kind, related in anyway to Jeffrey Epstein or your employment with him
2
EFTA00774014
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r
• 02m01.31-200” • •
FEDERAL BUREAU OF INVESTIGATION
Precedence: PRIORITY Date: 12/06/2006
To: Albuquerque Santa Fe RA
San Juan St. Thomas RA
From: Miami
Squad PB-2, PBCRA
Contact: SA
b6
b7C
Approved By:
Drafted By:
Case ID #: 31E-MM-108062 (Pending)
Title: JEFFREY EPSTEIN;
WSTA - CHILD PROSTITUTION
Synopsis: To set leads for captioned investigation.
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'
PBCRA obtained information from
the City of Palm Beach Police Department (PBPD) I
F Epstein
Following the ;eceipt of the case files from the PBPD,
PRrRA henan interviewinal b6
I who reported a similar b7C
b7D
series of events. In particulard. [described how contact
was made via telephone, primarily' I
_ c-lorlor sc-- 310-MR- gino0.2-- Sil
EFTA00790994
•I
To:
Re:
Albuquerque Am: Miami
•
31E-MM-108062, 12/06/2006
b6
b7C
b7D
MPF by rn 1- In
nd some
r
I On most
instances. Ens ei n1
example,' Epstein
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 weri addressed
to E stein and others were addressed tol
Additional messages recovered during the search
con aine ext confirming appointment times.
During the PBCRA's investigation,
that) 'would contact i
2
EFTA00790995
y
To: Albuquerque Atm: Miami •
Re: 31E-MM-108062, 12/06/2006
'The investigation revealea aka
the flights to Palm Beach,' could contact somi of
via rail nhnna The atIO m q nu, ocri dAnrp that
b6
b7C
b7D
In addition to the home in Palm Beach, Epstein also
maintains a residence in the U.S. Virgin Islands, New York and
New Mexico.
To date, the PBCRA continue& to develop witnesses and
victims from across the United States. Due to the media coverage,
unknown status of the state investigation, vulnerability of the
young female victims, and political influences, the AUSAs and
Case,Agents have a target date of January 2007 for indictment.
Based on the ongoing criminal investigation, the PBCRA
is requesting the assistance in establishing Epstein's criminal
activity utilizing interstate commerce and the travel in
interstate commerce to engage in illicit sexual conduct and
prostitution. Prior to conducting captioned leads, it is
requested that the lead agents) contact SAI
FBI Miami, West Palm RA, I or SAJ
'tor investigative direction and
questions.
3
EFTA00790996
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Memorandum
SubjectDate
Re: Operation Leap Year April 17, 2007
ToFrom
R. Alexander Acosta, United States Attorney
Jeff Sloman. First Assistant United States Attorney
W
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
EFTA00229842
transcript of one of the girls, and sex toys.
In sum, the PBPD investigation showed that girls from a local high school F3 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 E stein's home in Palm Beach where they would meet
Epstein's chef and Epstein's assistant—usually in the kitchen. The assistant normally 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 or a towel. He would remove the clothing 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. F4 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.
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 the PBSAO indictment was reported in the
papers, and 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.
IL The Law of the Offenses Charged U
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. None of the statutes or their penalties changed during the time period
charged (early 2004 through mid-2005), although many have changed since then. I use the language of
the statutes as they appeared while Epstein was committing the offenses.
In addition to conspiracy charges, there are five statutes related to sexual activity that have been
violated. First, Epstein traveled in interstate commerce with the intent to engage in illicit sexual
conduct, in violation of 18 U.S.C. § 2423(b). Second, Epstein and his assistants used a facility of
interstate commerce to induce or entice minors to engage in prostitution and sexual activity for which
EFTA00229843
any person can be charged, in violation of 18 U.S.C. § 2422(b). Third, Epstein transported
in interstate commerce with the intent that engage in sexual activity for which a person can
be charged, in violation of 18 U.S.C. § 2421. For these three offenses, knowledge of the victim's age
does not need to be proven, although a reasonable belief that a person is over 18 is an affirmative
defense to a limited portion of § 2423(6). F6
In those instances where Epstein and/or the assistants knew the ages of the girls (or had reason to
know their ages but willfully blinded themselves to that knowledge), they can be char ed with sex
traffickin , in violation of 18 U.S.C. § 1591(a)(1). In such instances, and
also can be charged with benefitting from their participation in a venture engaged in human
sex trafficking, in violation of 18 U.S.C. § 1591(a)(2).
Epstein and his assistants also can be charged with violations of the money laundering statutes,
specifically promotion money laundering, in violation of 18 U.S.C. § 1956(a)(3), and causing a money
transmitting business to transmit funds intended to be used to promote or support unlawful activity, in
violation of 18 U.S.C. § 1960(a).
A. Violations of the Mann Act: 18 U.S.C. §§ 2421-2423
1. Knowledge of Age Is Not Required.
The Mann Act criminalizes traveling in interstate commerce to engage in "illicit sexual conduct,"
(§ 2423(b)), using a facility of interstate commerce to entice a minor to engage in sexual activity or
prostitution (§ 2422(b)), and transporting a person to engage in sexual activity (§ 2421). Sections
2423(6) and 2422(6) require a minor victim, but they do not require that the defendant know that the
victim is a minor.
For example, in December, the Fourth Circuit issued its opinion in United States v. Jones , 471
F.3d 535 (4th Cir. 2006). Jones was charged with transporting a minor across state lines for sexual
purposes, in violation of Section 2423(a), which reads:
A person who knowingly transports an individual who has not attained the age of 18 years
in interstate or foreign commerce . . with intent that the individual engage in prostitution,
or in any sexual activity for which any person can be charged with a criminal offense,
shall be fined under this title and imprisoned not less than 5 years and not more than 30
years.
Jones argued that the term "knowingly" in that section required the Government to prove that Jones
knew the age of the victim. The Fourth Circuit soundly rejected the argument, citing the other circuits
reaching the same conclusion. Jones , 471 F.3d at 538-39 (citing United States v. Griffith , 284 F.3d
338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v.
Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173 (3d Cir.
1982)). Instead, the court concluded that the Government need only prove that the defendant
"knowingly transported" someone. The Government must also prove that the person transported was, in
fact, a minor, but need not prove that the defendant was aware of her minority. In conducting its
analysis, the Jones Court relied upon cases interpreting sections of Title 21 relating to the distribution of
drugs to a minor. See Jones at 540. Those cases have held that the Government must prove only that
the defendant knowingly distributed the narcotics to someone who happened to be underage.
While the Eleventh Circuit has not addressed the question posed by Jones , it has addressed 21
U.S.C. § 861(a)(3) and has reached the same conclusion in approving the district court's instructions to
the jury:
Section 845 of 21 U.S.C.A. provides that anyone who knowingly or intentionally
distributes controlled substances to a person under twenty-one is subject to enhanced
penalties. . . . [T]he court instructed the jury that it is not an essential element of the
crime that the person who distributes be knowledgeable that the person to whom he
distributes is under twenty-one years old; it is the distribution that must be knowing,
EFTA00229844
although it is an essential element that the person to whom the distribution is made is
under twenty-one.
United States v. Pruitt , 763 F.2d 1256, 1261 (11th Cir. 1985). In reaching this decision, the Eleventh
Circuit relied upon the Third Circuit's Hamilton decision, supra :
There is, however, a precise analogue to this statute, 18 U.S.C.A. § 2421 et seq. (White
Slave Traffic Act), which prohibits the interstate transportation of persons in order to
engage in immoral practices including prostitution, and which provides enhanced penalties
for the knowing transportation of persons under the age of eighteen years. Under this
statute, knowledge of the victim's age is not an element of the crime; the "knowing"
component applies to the transportation itself.
Id. at 1262 (citing Hamilton ). See also United States v. Williams , 922 F.2d 737, 739 (11th Cir. 1991)
(using same rationale to decide that Government need not prove knowledge of age for a charge of
knowingly employing, using, persuading, inducing, enticing, or coercing a person under eighteen years
of age in the commission of a drug offense).
In United States v. Taylor , 239 F.3d 994 (9th Cir. 2001), the Ninth Circuit addressed a
defendant's assertion that knowledge of minority is required to convict him of transporting a minor for
purposes of prostitution. The Ninth Circuit held that the "more natural reading of the statute, however,
is that the requirement of knowledge applies to the defendant's conduct of transporting the person rather
than to the age of the person transported." Id. at 997. In Taylor , the defendant argued that the court
should analogize the statute to the transportation of hazardous waste, which requires a showing that the
defendant knew the waste was hazardous. The Ninth Circuit rejected that suggestion:
in contrast, the transportation of any individual for purposes of prostitution or other
criminal sexual activity is already unlawful under federal law. 18 U.S.C. § 2421. Under
18 U.S.C. § 2423(a), the fact that the individual being transported is a minor creates a
more serious crime in order to provide heightened protection against sexual exploitation of
minors. As Congress intended, the age of the victim simply subjects the defendant to a
more severe penalty in light of Congress' concern about the sexual exploitation of minors.
Cf. United States v. Figueroa , 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal
statute's language is unclear, its scienter requirement is presumed to be met once an
individual forms the requisite intent to commit some type of crime).
. . . Ignorance of the victim's age provides no safe harbor from the penalties in 18 U.S.C. §
2423(a). If someone knowingly transports a person for the purposes of prostitution or
another sex offense, the transporter assumes the risk that the victim is a minor, regardless
of what the victim says or how the victim appears .
Id. (emphasis added; additional internal citations omitted). Cf. United States v. Wild , 143 Fed. Appx.
938, 942 (4th Cir. 2005) (the parties agreed that, to prove a violation of § 2423(a), the United States had
to show that (1) the defendant transported the victim in interstate commerce; (2) the defendant did so
knowingly and with the intent that the victim engage in prostitution; and (3) the victim was under the
age of 18 at the time she was transported).
This reading finds additional support in the Mann Act itself using the doctrine of "expressio
unius est exclusio alterius" (to express or include one thing implies the exclusion of the other). Section
2423(g) creates an affirmative defense to one portion of a violation of Section 2423(b). For purposes of
that subsection alone, a defendant may raise an affirmative defense, which he must prove, 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." 18 U.S.C. § 2423(g). The inclusion of that affirmative defense
shows that Congress considered the issue and decided that the United States does not have to make an
initial showing of knowledge of age for violations of 2423(6). Congress likewise considered the same
issue for the other portions of the Mann Act and reached the same conclusion. If Congress had intended
EFTA00229845
to place the burden of proving age on the United States — or if it had decided that it should create an
affirmative defense to those charges — it could have done so. Congress' use of similar offense language
for the other sections of the Mann Act shows that Congress likewise did not intend to require proof of
knowledge of age to violate those sections either. See Gustafson v. Alloyd Co., Inc. , 513 U.S. 561, 570
(1995) (noting the "normal rule of statutory construction" that "identical worth used in different parts of
the same act are intended to have the same meaning").
In United States v. Scott , 999 F.2d 541, 1993 WL 280323 (6th Cir. 1993), the defendant argued
that the Mann Act was unconstitutional for failing to include a requirement that the Government prove
the defendant's knowledge of the age of the minor. The Sixth Circuit rejected the argument. First, it
found that "[k]nowledge that a girl is under 18 years of age when transported interstate is not part of the
proof required of the government in order to sustain a conviction under 18 U.S.C. § 2423. The
government proved, as it must, that [the victim] was in fact a minor at the time of the interstate
transportation . . . The Mann Act does not require more." Id. , 1993 WL 280323 at *6 (citation
omitted). The Sixth Circuit then stated:
it does not offend due process for Congress to draft a statute that does not require the
prosecution to show that a defendant believed the victim to be under the age of 18 when
she was transported interstate, because the law has traditionally afforded minors
substantial protection from others. . . . Similarly, the Constitution does not require that a
defendant be provided a defense of mistake of age when accused of a Mann Act violation
involving a minor.
Id. (citations omitted).
This approach is consistent with the law of statutory rape, which generally holds that a
defendant's good faith mistake as to the victim's age is no defense. In United States v. Ransom , 942
F.2d 775 (10th Cir. 1991), the Tenth Circuit addressed a federal statutory rape provision, which
provides: "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 has not attained the age of
12 years, or attempts to do so, shall be fined under this title, imprisoned for any term of years or life, or
both." Id. at 775 (quoting 18 U.S.C. § 2241(c)). The defendant asserted that a "reasonable mistake as
to age defense" should be read into the statute or, alternatively, that the statute was unconstitutional for
failing to include such a defense. The Tenth Circuit rejected the arguments, noting that "the majority of
courts that have considered the issue have rejected the reasonable mistake of age defense to statutory
rape absent some express legislative directive." Id. (citations omitted). Further, the "Supreme Court
has recognized that the legislature's authority to define an offense includes the power `to exclude
elements of knowledge and diligence from its definition.'" Id. (quoting Lambert v. California , 355
U.S. 225, 228 (1957)). The Tenth Circuit also agreed with the legislative history, finding that the statute
"protects children from sexual abuse by placing the risk of mistake as to a child's age on an older, more
mature person who chooses to engage in sexual activity with one who may be young enough to fall
within the statute's purview." Id. at 777 (citing Nelson v. Moriarty , 484 F.2d 1034, 1035 (1st Cir.
1973)). The Ninth Circuit addressed similar arguments in United States v. Juvenile Male , 211 F.3d
1169 (9th Cir. 2000), and reached the same conclusions.
As discussed in Ransom , Epstein and his assistants were the "older, more mature person[s]" who
chose to engage in sexual activity and prostitution with young girls. The risk of mistake regarding the
ages of those victims should lie with the targets.
2. Coercion and Enticement: 18 U.S.C. § 2422 [Counts to 1
Whoever, using the mail or any facility or means of interstate . . . commerce, . . .
knowingly persuades, induces, [or] entices . . . 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 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.
EFTA00229846
18 U.S.C. § 2422(b).
The United States must show either:
First: That the Defendant knowingly used a facility of interstate commerce to persuade, induce,
or entice a person to engage in prostitution; and
Second: That the person so persuaded was under the age of 18;
or
First: That the Defendant knowingly used a facility of interstate commerce to persuade, induce,
or entice a person to engage in sexual activity;
Second: That the person so persuaded was under the age of 18; and
Third: That the Defendant could have been charged with a criminal offense under the law of
Florida based upon the sexual activity. n
The statute does not define "facility or means of interstate commerce" or "prostitution."
a. A telephone is a "facility of interstate commerce."
The Eleventh Circuit has ruled that evidence of the use of a 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).
Earlier this year, the Eleventh Circuit found that the United States adequately proved the
jurisdictional element of § 2422(b) when evidence was introduced that the defendant used both a
cellular telephone and a land-line telephone to entice a minor to engage in prostitution, even though no
evidence was introduced that the calls were routed through interstate channels. United States v. Evans ,
476 F.3d 1176, 1180 (11th Cir. 2007). The Eleventh Circuit then held:
Telephones and cellular telephones are instrumentalities of interstate commerce. Evans's
use of these instrumentalities of interstate commerce alone, even without evidence that the
calls he made were routed through an interstate system, is sufficient to satisfy § 2422(b)'s
interstate-commerce element.
Id. at 1180-81 (citations omitted).
b. "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
EFTA00229847
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). Fs 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
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) (2004). L9 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." FIO
c. "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." According to the Eleventh Circuit Pattern Jury
Instruction, 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 (2004). 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 "[e]ngages in sexual activity _F11 with a
person 12 years of age or older but less than 16 years of age." Fl. Stat. § 800.04(4)(a) (2004).
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) (2004).
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) (2004).
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) (2004). _F12
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) (2004).
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. §
EFTA00229848
800.04(2) (2004). 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) (2004).
Florida law also bars "sexual activity" between adults over the age of 24 and minors who are 16
or 17 years' old. Fl. Stat. § 794.05(1) (2004). 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 (2004).
d. Charging Decisions
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).
e. Conspiracy to Violate Section 2422(b) [Count 1]
Unlike most of the other statutes discussed herein, 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. El i
f. 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. The
current version of 18 U.S.C. § 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.
Section 2428 went into effect on January 10, 2006, so unless we can show activity continuing
past that date, it will not apply. For the relevant time period (2004 to late 2005), criminal forfeiture was
governed by 18 U.S.C. § 2253(a), which states:
[a] person . . . who is convicted of an offense under section 2421, 2422, or 2423 of chapter
117, shall forfeit to the United States such person's interest in — . . . (3) any property, real
or personal, used or intended to be used to commit or to promote the commission of such
offense.
This language also should apply to Epstein's Palm Beach home and the two airplanes.
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, and there is no provision for forfeiture of the
relevant property.
3. Traveling with Intent to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(6)
[Counts to ]
A person who travels in interstate commerce . . . for the purpose of engaging in any illicit
sexual conduct with another person shall be fined under this title or imprisoned not more
EFTA00229849
than 30 years, or both.
18 U.S.C. § 2423(b).
Thus, the United States must prove that Epstein knowingly traveled in interstate commerce and
that he did so for the purpose of engaging in illicit sexual conduct, as defined below.
a. Proof of intent to travel
In Appendix C, Epstein's attorneys assert that Epstein's trips to Florida were not undertaken for
the sole purpose of engaging in illicit sexual conduct—he traveled just to visit his home and attend
meetings, etc.— and, therefore, he lacked the requisite intent to violate Section 2423(b).
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 and "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).
Just a few weeks ago, the Eleventh Circuit addressed for the first time the issue of a "combined
motive" for traveling, and approved the following instruction:
the Government [] does not have to show that engaging in criminal sexual activity with a
minor was the Defendant's only purpose, or even his primary purpose, but the
Government must show it was one of the purposes for transporting the minor or for the
travel. In other words, the Government must show that the Defendant's criminal purpose
was not merely incidental to the travel.
United States v. Hoschouer , F.3d 2007 WL 979931, *1 (11th Cir. Apr. 3, 2007).
The decision of the Eleventh Circuit was consistent with every other circuit that has addressed
the issue:
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
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) (The district court did not err in instructing the jury that "it was
sufficient for the Government to prove that one of the [the defendant's] motives in traveling was to
engage in a sexual act with a minor."); 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. Sirois , 87 F.3d 34, 39
(2d Cir.1996); United States v. Campbell, 49 F.3d 1079, 1082-83 (5th Cir.1995) ("[I]t is not necessary
to a conviction under the [Mann] Act that the sole and single purpose of the transportation of a female in
interstate commerce was such immoral practices."); United States v. Ellis , 935 F.2d 385, 389-90 (1st
Cir.1991) (jury could consider that defendant's personal motive for bringing minor on interstate family
vacations and business trips was to have her available for sexual abuse even though there were other
purposes for the trips); United States v. Snow , 507 F.2d 22, 24 (7th Cir.1974); United States v. Harris ,
480 F.2d 601, 602 (6th Cir.1973); United States v. Cole , 262 F.3d 704, 709 (8th Cir. 2001) ("The illicit
behavior must be one of the purposes motivating the interstate transportation, but need not be the
dominant purpose," and a defendant's intent may be inferred from all of the circumstances) (citations
omitted).
EFTA00229850
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 from trash pulls, the flight
manifests from Epstein's private planes, and testimony from the girls about how the appointments were
made.
b. Illicit Sexual Conduct
The United States must prove that one of the purposes of the defendant's travel was to engage in
"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).
(i) 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.
(ii) 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,
predominantly women and girls, involving activities related to pmstitution , 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," and is meant to include prostitution,
the creation of pornography, and other [undefined] 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
EFTA00229851
of Section 2 and throughout that section. 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
postitution . . 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).
c. 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." I also have elected to treat all of these sexual massages as "commercial sex acts"
regardless of whether there was any penetration. Epstein exchanged money for the opportunity to view
underage girls in various states of undress and to masturbate in front of them. As described by the girls,
Epstein received sexual gratification from the experience and he constantly tried to "push the envelope"
to convince the girls to become more and more sexual. As R. described, when a girl refused to let
Epstein touch her, Epstein "down-promoted her" to become a recruiter.
d. Conspiracy [Count 21
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.
e. Additional Ancillary Offense [Count 31
The statute contains an additional ancillary offense making it illegal, for the purpose of
commercial advantage or private financial gain, to arrange, induce, procure, or facilitate the travel of a
person knowing that such person is traveling in interstate commerce for the purpose of engaging in
illicit sexual conduct. 18 U.S.C. § 2423(c). Once of job responsibilities, for which she was
paid handsomely, was to arrange both the appointments with the underage girls and also to arrange
Epstein's travel. Epstein's pilots testified that was the person who would call them to have them
at the airport at
ar en time and who would tell them where they would be traveling to. Accordingly, I
have charged alone with a single count of violating § 2423(c).
f. The Affirmative Defense Regarding Knowledge of Age
Section 2423(g) provides that in "a prosecution under this section based on illicit sexual conduct
as defined in subsection (O(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.
Congress's decision to include an affirmative defense to part of the statute shows that it has
considered the issue and determined that the Government does not have to prove that the defendant
knew the victims were underage for the other portions of the statute. This is consistent with the cases
interpreting various sections of the Mann Act.
EFTA00229852
Thus, for those instances where we know that a 16- or 17-year-old girl affirmatively told Epstein
that she was 18 — and it would have been reasonable for Epstein to believe that statement — I have not
charged Epstein with violating 2423(b).
g. 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 this violation as well, but, as explained
above, Section 2428 went into effect on January 10, 2006, so unless we can show activity continuing
past that date, it will not apply. For the relevant time period (2004 to late 2005), criminal forfeiture was
governed by 18 U.S.C. § 2253(a), which also applies to violations of section 2423.
4. Transportation of an Individual to Engage in Sexual Activity: 18 U.S.C. §
2421 (Counts to
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,
DataSet-10
Unknown
4 pages
Exhibit G
EFTA00095554
(Rev. 01-31-200)
FEDERAL BUREAU OF INVESTIGATION
Precedence: PRIORITY Date: 12/06/2006
To: Albuquerque Santa Fe RA
San Juan St. Thomas RA
From: Miami
Squad PB-2, PBCRA
Contact: SA b6
b7C
Approved By:
Drafted By:
Case ID It: 31E-MM-108062 (Pending)
Title: JEFFREY EPSTEIN;
WSTA - CHILD PROSTITUTION
Synopsis: To set leads for captioned investigation.
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. alone with'
PBCRA obtained information from
the City of Palm Beach Police Department (PBPD) I
pstein
I
Following the ;'eceipt of the case files from the PBPD,
ARCRA hisnan interviewinni b6
I
I who reported a similar b7C
(describe how contart bib
series of events. In particular,
was made via telephone, primarily' 1
d
3(01 p(. 31E- - 1080W-
EFTA00095555
•t
To: Albuquerque Atm: Miami •
Re: 31E-NH-108062, 12/06/2006
b6
b7C
bib
mot h/ rn t *1-1
nd some
I On most
instances Enstel
exa le, I 'Epstein
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 airis well addressed
to E stein and others were addressed tol
Additional messages recovered during the search
con aine ext confirming appointment times
During the PBCRA's investigation,l
that 'would contact i
2
EFTA00095556
To: Albuquerque 'IL: Miami •
Re: 31E-MM-108062, 12/06/2006
rune investigation reveasea tnac
the flights to Palm Beach,I A Could contact swag nfl
ni 11 h Ph canna nw avidornra that
b6
b7C
b7D
In addition to the home in Palm Beach, Epstein also
maintains a residence in the U.S. Virgin Islands, New York and
New Mexico.
To date, the PBCRA continues, to develop witnesses and
victims from across the United States. Due to the media coverage,
unknown status of the state investigation, vulnerability of the
young female victims, and political influences, the AUSAs and
Case Agents have a target date of January 2007 for indictment.
Based on the ongoing criminal investigation, the PBCRA
is requesting the assistance in establishing Epstein's criminal
activity utilizing interstate commerce and the travel in
interstate commerce to engage in illicit sexual conduct and
prostitution. Prior to conducting captioned leads, it is
requested that the lead aoent(s) contact SAJ
FBI Miami, West Palm RA, or SAl 1
Ifor investigative direction and
questions.
3
EFTA00095557
DataSet-10
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8 pages
AO 187 (Rev. 7/87) Witness List
United States District Court
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
CASE NUMBER: 08-CV-80893-CIV
Plaintiff MARRA/JOHNSON
Vs.
JEFFREY EPSTEIN, ct al.
Defendant. PLAINTIFF JANE DOE'S EXHIBIT LIST
Related Cases:
08-80119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
PRESIDING JUDGE PLAINTIFFS ATTORNEY DEFENDANTS' ATTORNEY
Hon. Judge Marra Bradley J. Edwards, Esq. Robert Craton, Esq.
TRIAL DATE(S) July 19 — July 30, 2010 COURT REPORTER COURTROOM DEPUTY
DEF. PLF. DATE MARKED ADMITTED
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
EXHIBITS EXPECTED TO BE USED
I. All applicable criminal statutes
2. All applicable Florida Statutes
3. All applicable Rules of Evidence
4. Video of Defendant, Jeffrey Epstein's home and route from
Plaintiff to Defendant's home
5. Order confirmation from Amazon.com for purchase of books
"SM 101: A Realistic Introduction," "Slave Craft: Roadmap for
Erotic Servitude-Principles. Skills and Tools" and "Training
Miss Abernathy: A Workbook for Erotic Slaves and Their
Owners"
6. Non-Prosecution Agreement
7. Jane Doe 102 Complaint
EFTA00728817
PLAINTIFF DOE. EXHIBIT LIST CONTINUATION
Dos vs. Epstein - CASE NO. 08-CV-501393•CIV-MARRAMOHNSON
DEF. PLF. DATE MARKED ADMITTED
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
Messages taken from message pads found at Defendant's home
8.
Documents related to Jeffrey Epstein produced by Alfredo
9 Rodriguez
Jeffrey Epstein flight logs
10.
Jeffrey Epstein phone records
11.
phone records
12.
Jail Visitation Logs
13.
Jeffrey Epstein's probation file
14.
All probable cause affidavits related to criminal investigation of
15.
Jeffrey Epstein
All evidence, information and documents taken or possessed by
16
FBI related to criminal investigation of Jeffrey Epstein
17. Plaintiffs and other victims' statements to the FBI related to
criminal investigation of Jeffrey Epstein
Video of Search Warrant of Jeffrey Epstein's home being
18.
executed
Application for Search Warrant of Jeffrey Epstein's home
19.
Complaint Jane Doe v. Epstein and all subsequent Amended
20.
Complaints
All records of homes, properties, bank accounts and any and all
21
records 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
25
and Jean Luc Brunel
All documents evidencing relationship between Jeffrey Epstein
26
and MC2 or any modeling agencies
27. Yearbooks of plaintiff, Jane Doe
28.
29.
30.
Affidavit and Application for Search Warrant on Jeffrey
31.
Epstein's home
EFTA00728818
PLAINTIFF DOE. EXHIBIT LIST CONTINUATION
Do* vs. Epstein —CASE NO. 08-CV-10393-CIV-MARRAUOHNSON
DEF. PLF. DATE
MARKED ADMITTED
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
Tape recording or transcript of recording of conversation
32
between Jeffrey Epstein and George Rush
Notepads found in Jeffrey Epstein's home and/or during trash
33.
pulls outside of his home during criminal investigation
The Palm Beach State Attorney's Criminal file against Jeffrey
34.
Epstein
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
38
related to Jeffrey Epstein
All statements made by Jeffrey Epstein
39.
List ofproperties and vehicles in Larry Visoski's name
40.
All of Jeffrey Epstein's Responses to Requests for Production,
41 Requests for Admission, Answers to Interrogatories in this
matter, and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-
80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-
80802, 09-81092
All discovery related responses of Jeffrey Epstein in this matter
42
and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994,
08-80811, 08-80893, 09-80469. 09-80591, 09-80656, 09.80802,
0941092
Jeffrey Epstein's Answers and Affirmative Defenses in all civil
43.
cases against him
All Complaints in which Jeffrey Epstein was a plaintiff or
44.
defendant
Jeffrey Epstein's Deposition testimony and discovery responses
45.
in this case and cases 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 Deposit. imony and discovery responses
46. pstein, Case No.
in State Court cases v. Jeffr
502008CA028051 and v. Jeffrey Epstein,
Case No. 502008CP003626XXXXMB
Jeffrey Epstein Deposition Testimony and discovery responses
47 in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case
No. 502009CA040800)000CMBAG
Any and all newspaper articles, online articles or publications
48
related to Jeffrey Epstein
Report and Analysis of Jeffrey Epstein's assets
49.
EFTA00728819
PLAINTIFF DOE, EXHIBIT LIST CONTINUATION
Doe vs Epstein - CASE NO. 08-CV-110893-CIV-MARRA/JOHNSON
DEF. PI,. DATE MARKED ADMITTED
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
Video footage (DVD) of walk through site inspection of Jeffrey
50.
Epstein's home.
Photos of all of Jeffrey Epstein's properties, cars, boats and
51.
planes
Probable Cause Affidavits prepared against Jeffrey Epstein and
52.
Audio tape of
53.
Photographs, videos and books taken in the search warrant of
54.
Jeffrey Epstein's home
Documents related to or evidencing Jeffrey Epstein's donations
55.
to law enforcement
Victim Notification Letter from US Attorney's Office to Plaintiff
56.
Expert Dr. L. Dennison Reed's Report of Plaintiff
57.
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
60.
Department relating to Jeffrey Epstein
Passenger Manifests of Jeffrey Epstein's aircraft and private
61.
plane flight logs
Passenger lists for flights taken by Jeffrey Epstein
62
Letter from Jeffrey Epstein to Alberto Pinto regarding house
63.
island project
Jeffrey Epstein's bank statements
64.
Jeffrey Epstein's tax returns
MC2 all mmunications of Jeffrey Epstein, Jeff
65. Pappas Suat, Jean Luc Brunel and
Fuller,
Amanda Grant
DVD of plea and colloquy taken on 6-30-08
66.
Transcript of plea and colloquy taken on 6.30-08
67.
Massage Table
68.
Lotions taken from Jeffrey Epstein's home during search warrant
69.
Computers taken from Jeffrey Epstein's home during search
70
warrant
71. Vibrators, dildos and other sex toys taken from Jeffrey Epstein's
home during search warrant
EFTA00728820
PLAINTIFF DOE. EXHIBIT UST CONTINUATION
Do* vs. Epstsln - CASE NO. 08-CV-80893-CIVAIARFLA/JOHNSON
DEE. PLF. DATE MARKED ADMTITED
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
72. No Contact Orders entered against Jeffrey Epstein
Criminal Score Sheet regarding Jeffrey Epstein
73.
74. Documents evidencing Jeffrey Epstein's Community Control
and Probation
75. Jeffrey Epstein's Sex Offender Registration
Jeffrey Epstein's Booking photograph
76.
CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480
77.
List of Jeffrey Epstein's House contacts
78.
Documents related to Jeffrey Epstein's investments
79
Letter from Chief Michael Reiter to Barry Krischler
80.
List of planes owned by Jeffrey Epstein
81
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-
82.
06
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-
83.
06
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-
84. 06
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-
85.
06
Letter from Guy Fronstin to Assistant State Attorney dated 4-10-
86.
06
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
91.
properties
Arrest Warrant of
92.
Police report regarding picking up money dated
93
11-28-04
List of Trilateral Commission Members of 2003
94.
Alan Dershowitz Letter dated 4.19-06 and Statute 90.410
95.
EFTA00728821
PLAINTIFF 00E, EXHIBIT LIST CONTINUATION
D0 vs. EpaWin — CASE NO. 08-CV480893-C1V-MARRA/JOHNSON
DEF. PLF. DATE MARKED ADMITTED
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
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.
Plaintiff's GED testing information and results
100.
JEGE, Inc. Passenger Manifest
101.
Hyperion Air Passenger Manifest
102.
Flight information for
103.
Passenger List Palm Beach flights 2005
104.
Jeffrey Epstein notepad notes
105.
Pleadings of Jane Doe 1 and 2 v. US case
106.
Jeffrey Epstein 5th 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,
111.
Plaintiff's school records and transcripts
112.
Victim Notification letter dated 7-9-08
113.
Plaintiff's employment records from IHOP
114.
Police report of.luan Alessi theft at Jeffrey Epstein's home
115.
Plaintiff's Medical Records from Juvenile Facility
116.
Plaintiff's Medical Records from
117.
Plaintiff's Medical Records from Wellington Regional Hospital
118.
Plaintiffs Medical Records from St. Mary's Medical Center
119.
EFTA00728822
PLAINTIFF DOE. EXHIBIT LIST CONTINUATION
Dos vs Epstein — CASE NO. 08-CV-110893-CIV-MARRA/JOHNSON
DEF. PLF. DATE
MARKED AumurrED
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
Plaintiff's Medical Records from United Health
120.
All surveillance conducted by law enforcement on Jeffrey
121.
Epstein's home
Entails received from Palm Beach Records related to Jeffrey
122
Epstein
All items listed on the Palm Beach Police Property Report Lists
123.
All items taken in the execution of the search warrant of Jeffrey
124
Epstein's 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 produced by Palm Beach Police Department prior
127
to the deposition of Detective Recarey
Photographs of all persons listed on Plaintiff's Witness List
128.
Statements, deposition transcripts, videotaped depositions and
129
transcripts taken in connection with this and all related cases and
exhibits thereto
Any and all expert witness reports and/or records generated in
130.
preparation 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.
Any 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.
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.
EFTA00728823
PLAINTIFF DOE. EXHIBIT LIST CONTINUATION
Doe vs Epstein — CASE NO. 08-CV-80893-ClIbMARRA/JOHNSON
DEF. PLF. DATE MARKED ADMITTED
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
Demonstrative aids and exhibits including, but not limited to,
143. anatomical charts, diagrams and models, surveys, photographs
and similar material 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
146. Exhibit List
By listing an Exhibit, Plaintiff is not waiving their right to object
147
to same at trial and does not waive their right to amend same.
Plaintiff reserves the right to amend this list.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this
'$ day of June 2010 via U.S. Mail and email transmittal to all those on the attached service
Bradley J. Edwards
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Telephone (954) 524-2820
Facsimile (954) 524-2822
Florida Bar No.: 542075
E-mail:
and
Paul G. Cassell
Pro Hac Vice
332 S. 1400 E.
Salt Lake City, UT 84112
Telephone: 801-585-5202
Facsimile: 801-585-6833
E-Mail:
EFTA00728824
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1 pages
Memorandum
SubjcctDate
Memorandum seeking Travel AuthorizationAugust 14, 2007
Operation Leap Year
ToFrom
, MAUSA
Northern DivisionAssistant U.S. Attorney
Chief
Northern Division
I. INTRODUCTION
This memorandum seeks travel authorization to travel to New York from August 19 to August 22,
2007, in connection with Operation Leap Year.
II. THE PROPOSED TRAVEL AND ITS PURPOSE
As you know, we plan to present a final indictment to the grand jury in approximately four weeks.
There are some essential interviews that need to be completed prior to indictment. Those have been
delayed both due to the expense and also because the target is likely to learn about them. We previously
had kept much of the investigation under wraps, which is no longer a concern. Accordingly, I propose to
travel to New York on the evenin of Sunda , Au ust 19 and returning Wednesday, August 22nd. FBI
Special Agents and also will be traveling, although they plan to stay
through the week to do some surveillance work.
First we would like to interview and/or serve target letters on two of Mr. Epstein's assistants —
and . At this time, we are debating whether or not to indict so
her interview will be helpful in determining her criminal culpability.
Second, we plan to interview one of Mr. Epstein's former personal assistants, Lesley Groff. Groff
used to hold the position now held by =, and she was responsible for making all of Mr. Epstein's
personal arrangements. In an interview, Epstein referred to Groff as his "personal cell phone." We have
recently interviewed a girl who was involved with Epstein in 2001, when Groff was a more active
participant in Epstein's affairs.
Third, we plan to interview a personal friend of Epstein, Jean Luc, who is the head of MC2
Modeling Agency. Jean Luc appears on several of the message pads. Some of the messages describe
young girls that he would like Epstein to meet (including a 16-year-old who would teach Russian to
Epstein), and another references a noted urologist who could help Epstein with his "problem." (It should
be noted that there are now three girls who mention that Epstein's penis appeared abnormal.)
Fourth, we plan to interview one of Epstein's former personal chefs. One other personal chef has
already been interviewed and was a wealth of information regarding the comings and goings of the girls.
Many of the girls describe having meals prepared for them by the personal chef.
We also are trying to make contact with persons who may have 404(b)-type evidence.
FBI will be providing the car rental, but the Office will have to bear the costs of the flight and hotel
room.
EFTA00190315
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09/16/2010 14:44 FAX SEARCY DENNEY liDoovoo4
#291874/mep IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXM BAG
JEFFREY EPSTEIN,
Plaintiff(s),
SCpTT ROTHSTEIN, individually,
B LEY J. EDWARDS, individually, and
L.M., individually,
I Defendant(s).
I /
DEFENDANT/COIJNTERPLAINTIFF'S REOUEST TO PRODUCE
TO PLADITIFF/COUNTERDEFENDANT, JEFFREY EPSTEIN
Defendant/Counterplaintiff, Bradley J. Edwards ,by and through his undersigned counsel,
recuests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that
PlIntifUColuiterdefendant, Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect
and copy each of the following documents*:
1. All statements of the Defendant, Bradley J. Edwards, pertaining to any of the
issues in this lawsuit
2. All statements of any witness you intend to use at trial for impeachment.
3. All documents* including but not limited to diaries, journals, computer database
=lends or any other written or electronically stored information that reflect or relate to any
communication to or from minor females and/or any physical contact which did or was planned
to bccur between you and any person who was a minor female" at the time of the physical
cotdact or planned physical contact including but not limited to any massage, fondling, or sexual
EFTA00722339
09/10/2010 14:44 FAX SEARCY DENNEY U1002/004
s adv. Epstein
No.: 302009CA040800XXXXMBAG
Request to Produce to Jeffrey Epstein
interaction of any kind (this should include all message pads or appointment scheduler for minor
feriales").
4. All written documents supporting the allegations in your complaint.
5. All message pads, calendars of your schedule or appointments or other documents
containing your "massage" appointments; and
6. A complete copy of each and every exhibit which you intend to introduce or have
considered introducing into evidence at trial.
"Documents" shall include, but not be limited to all non-identical copies of writings,
draWings, graphs, charts, photographs, phono-records, recordings, and/or any other data
corlimilations from which information can be obtained, translated, if necessary, by the party to
whom the request is directed through detection devices into reasonably usable form.
"Dtcuments" also include all electronic data as well as application metadata and system
metadata. All inventories and rosters of your information technology (IT) systems—e.g.,
hardware, software and data, including but not limited to network drawings, lists of computing
devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission
features), programs, data maps and security tools and protocols.
It is requested that the aforesaid production be made within thirty days of service of this
request at the offices of Searcy Denney Scarola Barnhart & Shipley, M., 2139 Palm Beach
- "minor females" is defined as females who were known by you at the time or who are now !mown to you to have
beed under 18 yearn of age at the time of your interaction with diem, and females who you now bavc mason to
believe may have been under 18 years of age at the time of your interaction with them.
2
EFTA00722340
09/16/2010 14:45 FAX SEARCY DENNEY lib003/004
Edwards adv. Epstein
Case No.: 502009CA040800=0CMBAG
Request to Produce to Jeffrey Epstein
Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation,
examination and/or copying.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Fax and U.S. Mail to all Counsel on the attached list, th 110.1)—day of 2010.
la`•
Bar No.: 169440
cy Denney Scarola Barnhart & Shipley
139 Palm Beach Lakes Boulevard
West Palm Beach. Florida 33409
Phone:
Fax:
Attorneys for
3
EFTA00722341
09/16/2010 14:45 FAX SEARCY DENNEY in004/004
Edwards
' adv. Epstein
Ca+ No.: 502009CA040800,OOOCM:BAG
Request to Produce to Jeffrey Epstein
COUNSEL LIST
Jack A. Goldberger, Esquire
Attetbury, Goldberger & Weiss, M.
25C Australian Avenue South, Suite 1400
Wet Palm Beach, FL 33401
P
Fac
il iar
Carp? M. Farmer, Esq.
Farmer, Jaffe, Weissing, Edwards, Fistos &
Le an, PL
42 N. Andrews Avenue, Suite 2
Fo Lauderdale FL 33301
Phone:
Pale
Marc S. Nurik, Esq.
Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Fort Lauderdale FL 33301
Phcine:
Fax:
Christopher E. Knight, Esq.
Joseph L. Ackerman, Esq.
Fovher White Burnett, PA.
777. S Flagler Drive, Suite 901
West Palm Beach FL 33401
Phone:
Fax'
4
EFTA00722342
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2 pages
The press headlines of "sex slave" "sex ring",.sex predator. are all 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
restarants. 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.
EFTA00584372
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. The press 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.
EFTA00584373
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June 9, 2021 PreP
AUS
• Prior to October 20, 2005 search,■ responded to an alarm code in the same
neighborhood as JE's house. JE followed another officer, who accidentally went to JE's
house instead of the house where the alarm was actually going off.
o wand the other officer walked through JE's house to see if anyone was there
before realizing that they had the wrong address. Did not get through whole
house.
• Showeavideo from October 20, 2005 PBPD SW of JE PB residence
o ecognizes the main house and recalls searching it
o pecifically remembers searching the living room, the area with photos on a
table, and the area with photos on shelves behind a desk
o id not search the second floor, but went upstairs briefly
• Showe photographs from October 20, 2005 PBPD SW of JE PB residence
o calls searching the cars and recognizes the note seized from one car
o calls searching the pantry
o calls searching the blue and yellow room
o recalls searching the room with a statute of a man holding a bow and arrow in
o ecalls searching the living room area
o eized photos from yellow room, seized photos from shelves in blue room
o eized items, including VHS tapes and CDs from dresser in living room
• Showe the physical message pads from FBI custody
o remembers seeing notepads during the search, but cannot identify these
specific notepads as the ones she saw
3501.499-005
Page 1 of 1
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00096447
EFTA01250183
DataSet-10
Unknown
36 pages
Document comparison by Workshare Compare on Monday. June 05. 2017
6:18:32 PM
Input:
Document 1 ID file://CAUsers\pparkerlDesktop101 Complaint.pdf
Description 01 Complaint
file://CAUsers1pparkerlDesktoplFirst Amended
Document 2 ID
Complaint.pdf
Description First Amended Complaint
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EFTA00615970
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page I of 31
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
COMPLAINT
CASE NO.: 1:17-CV-00616
JANE DOE 43,
U
R
V
T
I
I
V tfel IV Z 3> t del V
Plaintiff
Ls,
EFFREY EP TEIN HI LAINE MAXWELL
AND
Defendants.
FIRST AMENDED COMPLAINT
Plaintiff JANE DOE 43, by and through her undersigned counsel, for her
EFTA00615971
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2 of 31
claims against Defendants Jeffrey Epstein, Ghislaine Maxwell,
and alleges upon personal knowledge with respect to her
own acts and status, and upon personal knowledge. information and belief as to all
other matters, as follows:
1. This cause of action arises under federal statutes and jurisdiction is proper
under 28 U.S.C. *Again 1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect her
identity because this Complaint makes allegations of a sensitive sexual nature
auElthe disclosure of Pleifttifgs-nanle-publiely-willwhich, in association with her
name, would cause further harm to her.
3. At all times material to the events alleged in this cause of action the Plaintiff
4. At all times material to this cause of action Defendant Jeffrey Epstein had
multiple residences, including in New York, New York (within the Southern
District of New York) and the United States Virgin Islands. He is currently a citizen
of the United States and claims to be a resident of-/siew-Y-Orkrand the U.S. Virgin
Islands.
5. At all times material to this cause of action Defendant Jeffrey Epstein was an
adult male born in 1953.
EFTA00615972
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 3 of 31
6. At all times material to this cause of action Defendant Ghislaine Maxwell was
residing in in New York, New York and was a citizen of Great Britain and France.
7. At all times material to this cause of action was
8. At all times material to this cause of action was •
9. -1424neluding-beeaffse-A substantial part of the acts, events; and omissions
giving rise to this cause of action occurred in the Southern District of New York;}
venue is proper in that District. 28 U.S.C. *section 1391(b)(2)
2
10. 4-lat all times material to this cause of action, Defendants Jeffrey Epstein,
Ghislaine Maxwell, an -.Ina owed a
duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire
to commit intentional, criminal, fraudulent, or tortious illegal acts against her,
including any acts in violation of 18 U.S.C. §1595.
FACTUAL ALLEGATIONS
EFTA00615973
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 4 of 31
11. 4-2,At all times material to this cause of action, Defendant Jeffrey Epstein was
an adult male over 50 years old. Defendant Epstein is knownwidely recognized as a
billionaire who uses his extraordinary wealth to commit illegal sexual crimes in
violation of federal and state statutes and to employ and conspire with a group of
numerous others, including each of the named Defendants, to eenspir-e-and-assist in
committing those crimes and additional torts as well as to preteet-and-conceal his
crimes and torts of the Epstein sex trafficking group from being discovered.
12 44-Defendant Epstein displays his enormous wealth, power and influence to
his employees; to the victims procured for sexual purposes; and to the public in order
to advance and carry out his crimes and torts. At all relevant times, Defendant
Epstein owned and continues to own, directly or through nominee individuals used
to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more
helicopters. For example, he owned and-ewns(directly or indirectly) a Boeing
aircraft (of make and model B-727-31H with tail number N908JE) and a
Gulfstream aircraft
3
of make and model G-1159B with tail number N909JE He also owned
numerous properties and homes, including a 51,000-square-foot mansion in
Manhattan; a $30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island
formerly known as Little St. James in or near St. Thomas, U.S. Virgin Islandsa
EFTA00615974
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 5 of 31
mansion in London, England; a home
; in Paris, France; and a mansion in Palm Beach County, Florida. The allegations
herein primarily concern the defendant's conduct while at his townhouse in New
York; on one or more of his private airplanes; and on his private island in the
United States Virgin Islands. Epstein used all of the real and personal property
described in this paragraph to facilitate the illegal sex trafficking venture and
enterprise described in this Complaint and in furtherance of that venture and
enterprise,
a 4-4:Defendant Epstein has a compulsive sexual preference for young females
as young as 13 and as told!: as 25. Through information and belief Defendant
hed-see-with-yeung-fenieieeaaiFtueilygastein engages iusxual actsa
range every day and accicted in the deve lopment and execution ofdeveloped,
through the employment of and conspiracy with the other Defendants, a sex
trafficking schemeventure and enterprise designed to fulfill his sexual desires:
and conceal the operation of the venture and enterprise and conduct of its
participants. As part of the venture and enterprise, Epstein also provided
young females for sexual purposes to his friends in order to secure social,
business, and other contacts as well as other things of value.
14. 44:Defendant Maxwell was for decades the highest-ranking employee of the
Defendants' sex trafficking venture and enterprise. She herself recruited young,
including underage, females; oversaw and trained other recruiters on how best to
recruit girls for sex; developed and executed schemes designed to recruit young
females; and ensured that all participants of the Defendants' sex trafficking scheme
EFTA00615975
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 6 of 31
acted in certain specific ways in order to advance the purposes of the scheme and
iii, including providing young females to Epstein for sexual purposes on
a daily basis, and concealing these activities from law enforcement.
S
Recruiters were taught by Defendants Epstein-and, Maxwell to inform
targeted victims that Epstein possessed extraordinary wealth, power, resources and
influence; that he was a philanthropist who would help female victims advance their
EFTA00615976
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 7 of 31
careers and lives; and that the recruits needed only to provide Epstein with body
massages in order to avail themselves of his financial assistance and influence. In
fact, however, these representations were fraudulent.
and the Defendants did not help e*noc intend to help advance
the victims' careers. Victims were also paid to bring F'ipstein other young
females for sex and were told by Defendants Epstein, Maxwell.MIM that
those young females who brought other females would further benefit from
bringing other girls,
6
EFTA00615977
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page N of 31
a -1-97The Defendants, led primarily by Defendants Epstein and Maxwell,
fulfilled Epstein!) compulsive need for sex with young females by preying on their
4 personal, psychological, financial, and related vulnerabilities. The Defendants'
tactics included promising the victims money, shelter, transportation, gifts.,
employment, admission into educational institutions, educational tuition,
protection, and other things of value in exchange for sex. Defendants also took
possession of the victims' passports to coerce compliance with their demands.
Defendants also trafficked young females to Epstein's friends and
acquaintances in order to secure financial and other benefits as well as social,
educational, and business connections
19. 2O Defendants' sex trafficking venture and enterprise operated in a hierarchal
structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-and
itaderlings-helew. Defendants Epstein and Maxwell operated the sex traffiekinp
scheme dating back to at least the mid-nineties, and over the years perfected
theirlititisiathe roles of others, both in terms of the ability to tthe
volume of young females recruited for sex and in insulating the enterprise from
criminal investigation or prosecution.
EFTA00615978
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 9 of 31
Underlings included
unnamed co- conspirators such as various housekeepers and butlers; an airplane
pilot; and various employees, assistants and associates. Wittingly and unwittingly,
such underlings performed their respective roles with the purpose and effect of
insuring that the enterprise supplied young females to Defendant Epstein and others
for sexual purposes. At all times materials to this complaint, the venture and
enterprise was a group of two or more individuals associated in fact and deed.
20. 2-hDefendants Epstein and Maxwell, with help from assistants, associates and
underlings, recruited and procured hundreds of girls over the decades of the
operation of their scheme. Such recruitment and procurement included fraud,
coercion, threats, intimidation, fear, the threat of coercion, and a combination of
these and similar tactics. Following the Defendants' recruitment and procurement of
the young females to join Epstein in New York and the U.S. Virgin Islands, the
Defendants used fraudulent
6 promises, coercion, and threats of coercion in order to entice yeungand coerce
the females into sex and, once sexual activities ensued, to cause them to remain in
the enterprise. The Defendants also transported females in
A
interstate and foreign commerce and in ways that affected interstate and foreign
commerce. The sex acts were commercial in nature, because the Defendants
promised to provide financial and other compensation to the females in
EFTA00615979
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31
exchange for nroviding sex acts to Epstein.
22. 2-3AdditionallyJklendants_alnasstawitsle every r ngientale
that they were wealthy, well-connected and could either help or hurt the
females depending on their degree of cooperation. In fact, Defendants Epstein
and Maxwell have been known to threaten young females with physical harm,
It is unknown exactly how long Defendant Epstein and Maxwell':,
afecemeatiociecithe Defendants' criminal and illegal venture and enterprise
operated, although it was at least continuously and actively in operation from the
mid-1990's through and including the calendar year 2007.
23, 24-.Defendant Epstein has continued the venture and enterprise and
eeftspireey-up to the present time in some form or another and with additional
co-consnirators and partici . p s.
24. 2-5,In 2005, Defendant Epstein and numerous co-conspirators within the
venture and enterprise were the subjects of a Palm Beach, Florida Police
Department criminal investigation which revealed that Defendant Epstein had
engaged in
2
EFTA00615980
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31
25, 264n 2006, the Palm Beach Police Department investigation was turned over
to the FBI and the United States Attorney's Office for the Southern District of
Florida. The United States Attorney's Office investigated Defendant Epstein and his
co-conspirators for their violations of numerous federal statutes, including 18
U.S.C. *Section 1591, one of the statutory bases for this complaint.
26. 2-7-.The United States Attorneys investigation continued from 2006 through
September 2007, at which time a Non-Prosecution Agreement was signed between
Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution
of Defendant Epstein and his numerous co-conspirators, including Defendants
for identified federal sex crimes against more than 30 minors.
27. 28.From late 2006 through September 2007, Epstein's team of lawyers
negotiated with the federal government in an effort to avoid the-filing-of-thea fifty-
three-page dra€IFederal felony indictment offrom being filed against Epstein.
During these
14
EFTA00615981
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 11 of 31
negotiations, Defendant Epstein decamped from Palm Beach to New York and the
U.S. Virgin Islands in order to convey an image to prosecutors that he and his co-
conspirators had stopped committing sex crimes.
28. 29,Remarkably, however—as this case will highlight—Defendant Epstein
and his co-Defendants, including the other defendants named herein, did
8 not abandon their sex trafficking venture and enterprise even while they were
under state and federal investigation for crimes committed in violation of 18
U.S.C. *section 1591, among other laws, and even as Defendants and their
attorneys were busy arguing Epstein!) innocence and publicly defaming his
victims as liars. Rather, Defendants merely changed their stylelocation. Instead of
targeting local Palm Beach Florida high-school girls, the Defendants transported
young females from other places in the
U.S. (including the Southern District of New York) and abroad and brought them
to Defendant Epsteinns mansion in New York City and his private island in the
Virgin Islands.
29. 3&In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses
for procuring a minor for prostitution and soliciting prostitution by minors and
registered as a Sex Offender for Life.
30. 3-1-Defendants Epstein and Maxwell developed and implemented a
sophisticated system designed to insulate them from criminal and civil liability by
protecting them from potential testimony of knowledgeable subordinates.
11
EFTA00615982
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 12 of 31
3-24n 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant efkr
his home, removed computer systems that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
12
photographs of young females; scheduling books; message pads; tangible items such
as vibrators and toys; and other incriminating matter.
32. The sex recruiting and trafficking venture and enterprise designed to
procure young females for sexual purposes and to conceal those activities was
developed and fine-tuned over time, and each of the named Defendants had a
well-defined role and improved in his/her role over time, with practice and
EFTA00615983
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 13 of 31
experience. By the time Plaintiff was recruited into victimization, each
Defendant had years of experience perfecting methods of coercion,
understanding Epstein's requirements, and becoming more loyal to the
continuance and survival of the venture and enterprise. All of the Defendant's
knew about the activities of the venture and enterprise and worked in concert
for the goals of the venture and knowingly benefitted, financially and by
receiving things of value from their iarticii ation in the venture and
enterprise.
33. A typical the Defendants procured young females for sex with
Defendant Epstein was to make false promises of a modeling opportunity, offer
a better life, offer payment for a formal education, or offer other money or
consideration.
34. 'l in=Beginning in approximately October 2006 and continuing
through April 2007,
EFTA00615984
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 14 of 31
10
14
39. &Defendant Maxwell told Plaintiff she would need to provide Defendant
EFTA00615985
- Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 15 of 31
Epstein with body massages in order to reap the benefits of his and Maxwell's
connections.
40. All Defendants, including Maxwell, Epstein knew that
Plaintiff was actually being recruited for sexual purposes, andleach knowingly
and deliberately made false representations to ensure that Plaintiff would
cooperate in fulfilling Epstein's sexual desires. These false and fraudulent
representations included Defendants' telling Plaintiff that Epstein would use
his connections to have her admitted inter a similar institute, college,
universi y or school of higher learning and provide her with employment
opportunities. Plaintiff reasonably relied on these representations and had a
credible basis for such reliance, including the credible representations of
Epstein and the other Defendants that they possessed extensive political,
business, financial, social, and educational influence and connections. Epstein
and the other Defendants represented to Plaintiff in manners that were
persuasive, credible, and reasonable to Plaintiff, as they would have been to
any other person similarly situated, that they had the political, business,
financial, social, educational, and other influence and
15
connections sufficient to arrange for and insure her admission into or a
similar school of higher learning.
41, Maxwell and Epstein also threatened Plaintiff that, while they had the ability
EFTA00615986
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 16 of 31
to advance her education and career, they also had the ability to make sure that
shePlaintiff would not obtain no-formal education if
she failed to provide the sexual favors desired by Defendant Epstein or abide by the
instructions given her by Defendants Epstein and Maxwell.
-14
42. 31XPlaintiff reasonably believed that her compliance with Defendants'
demands was crucial to her physical, psychological, financial, and reputational
well-being and survival.
41,Defenflents—Maxwell and Epstein informed Plaintiff that other young
females in Defendant-Epstein's company were there net-enly-to-pcovkle-massages;
but-also to perform sexual acts, for E stein and his friends.
16
EFTA00615987
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 17 of 31
The Defendants all participated in
arranging for Plaintiff to be transported Plaintiff in interstate and foreign
commerce, and affecting interstate and foreign commerce, for these sexual purposes.
The Defendants Epstein, Maxwell, and a j
4-2
47. 44,Defendant Maxwell frequently controlled the assignment, or "rotation," of
Plaintiff and the other young females concerning the time, place and manner of the
sex acts they were told to provide to Defendant Epstein.
17
psychological, financial, and reputational harm, with-the-puipose-and-OffeGt-Og
EFTA00615988
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 18 of 31
4--3
50. 4-7,Defendant Epstein's wealth, influence, power and connections were used
by Defendants Maxwell, and both as an inducement to provide sex
(in exchange for promises of support to Plaintiff}, and as a means of threatening
punishment (sheuklin the event Plaintiff refuserefused to comply with Defendants'
instructions to provide sex to Epstein and others).
a 4.8.,In addition to Plaintiff's being trafficked on Defendant-Epstein!:s private
planeairplane, Defendants ME, Maxwell and with the knowledge of and
instruction by Defendant Epstein,
EFTA00615989
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 19 of 31
18
a 50,The relationship between Plaintiff and Defendants Epstein and Maxwell
was defined and characterized by Defendant Epstein's and Defendant Maxwell's
frequent and persistent fraudulent representations that they would provide Plaintiff
with a formal education and career advancement if she provided sex to Defendant
12
EFTA00615990
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 20 of 31
Epstein and others in the times, places and manners demanded by Defendants.
reasonably relied on thesethese representations. In fact, however, thesethese
representations were knowingly false, were not acted upon by Defendants, and
were made by Defendants Epstein a and Maxwell solely for the
purpose of maintaining
44 Plaintiffs financial dependence on, emotional vulnerability to, and sexual
compliance with DefectElantsDefendant Epstein-anE14.4exwell-a•ncl-their:q demands.
The other Defendants intentionally repeated thesethese representations and
intentionally attemptedmade statements designed to convince Plaintiff that the
representations were true and could be relied upon. These representations and
statements were made to Plaintiff in furtherance of the sex trafficking
venture and enternrice far which they were each emnlavetl
20
EFTA00615991
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 21 of 31
O.1 $4-In January 2007 as part of their illegal venture and enterprise/
Defendants sent Plaintiff from the-United-StatesNew York City, in the Southern
District of New York, to Min -pact to recruit, for a promised fee, one or
more aspiring female models supposedly for Defendant-Epstein-te-use-as-an-alleged
per-senal-assistantrEpstein to use as a personal assistant. The Defendants did not
care whether the prospective female was Qualified to work as a personal
assistant because each knew that the female recruit would be immediately
placed into the same sexually vulnerable position as Plaintiff (and the dozens of
other victims of the sex trafficking enterprise) and would be induced and
coerced into being used for sex through fraudulent representations and other
means.
EFTA00615992
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 22 of 31
57. 52as part of their ongoing scheme, Defendants inflicted serious emotional
and psychological harm on Plaintiff as a means of coercing her to continue engaging
in commercial sex acts with Epstein and others. While Plaintiff was in
=, Defendants Epstein and Maxwell informed Plaintiff that she would not be
permitted to return to the United States to receive her promised education unless she
underwent a diet and lowered her body weight
ha
58. 51:3,As part of their scheme,,Defendants Epstein and Maxwell called
Plaintiff's parents in to tell them that DefenElantsDefendant Epstein
would take good care of Plaintiff when she returned to the United State; and that
theyDefendants Maxwell and Epstein would use their connections and influence
EFTA00615993
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 23 of 31
to have her admitted to
r another well-regarded fashion school or school of higher learning,
59. As part of their scheme, Epstein and told Plaintiff that she should
fill out an application for admission to and supporting essay, and send it
to Epstein for his review. Pursuant to these instructions, Plaintiff completed an
application. and supporting essay, and sent it to Epstein. As part of his scheme,
Epstein told Plaintiff that he had reviewed these materials. His statements were
intended to convince Plaintiff and had the effect of convincing plaintiff (as they
)vomA have convinced maimulAIKuQA,
nri - tt that her admissionAi),,i
F VT was
ys
a "done deal" if she would comply with his instructions. also made the
same representations to plaintiff on Epstein's behalf. Plaintiff reasonably
relied on these representations by Epstein and =,
60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had
contacts at-and at modeling_agencies who could ensure her admission to
and advance Plaintiff's career. As part of their scheme, Epstein and
Maxwell told Plaintiff about Epstein's vast wealth and specifically identified
him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive
23
contacts, in addition to those identified above, throughout New York City and
elsewhere.
61. 54An February of 2007, in reliance on promises made by the Defendant;
Plaintiff
EFTA00615994
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 24 of 31
Plaintiff knew that if she did not
comply, Defendants Maxwell and Epstein would use their power, influence and
connections in order to ensure that Plaintiff was unable to gain admission to- or
a comparable school, and that they would destroy her career, just as they had
destroyed the careers of others who had failed to comply with their demands.
5-SDefendants Epstein and Maxwell continued to provide Plaintiff with
things of value in exchange for Plaintiff-) continued compliance with Epstein!)
4-6 sexual demands; however, they failed and refused to perform their promises to
help Plaintiff be admitted to ar another school, or to provide financial
support for
24
college admission or on-going education, false promises they repeatedly made in
order to coerce her into commercial sex acts.
fia, S&Defendants Epstein and Maxwell':,_' sexual demands on Plaintiff
continued while she was in New York or other geographicCity, in the Southern
Districtof New York, or in other locations in close proximity to the Defendants.
EFTA00615995
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Paae 25 of 31
57:In May, 2007, Plaintiff left the United States and did not return. Between
returning from in February 2007 and leaving in May 2007,
65. In and after May 2007, Defendants actively concealed and covered up
what they had done to Plaintiff and other similarly situated females.
Defendant's cover- up included efforts to intimidate witnesses who might
provide corroborating testimony to Plaintiff as well as destruction of
documents and other evidence regarding what they had done.
25
66. S&Unknown to Plaintiff, Defendants' representations and promises to
Plaintiff were all false and fraudulent. Their—threats-were-sensidered-byPlaintiff
reasonably relied on the representations and promises of the Defendants.
Plaintiff also considered the Defendants' threats against the current and future
well-beinp and safety of Plaintiff to be real and credible. All such representations,
promisesa and threats were made solely for the purpose of coercing and otherwise
EFTA00615996
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 26 of 31
inducing Plaintiff into prolonged sexual compliance. Defendants knowingly
benefitted financially and received things of value as a result of their-coercing and
inducing Plaintiff into sexual compliance and otherwise participating in their
illegal venture and enterprise.
COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO
18 U.S.C.
§ 1595
76 . 49,Plaintiff adopts and realleges paragraphs 1 through 5-86.§ above.
4-7
68, 60,Defendants individually and together, within the special maritime and
territorial jurisdiction of the United States, in interstate and foreign commerce,
and/or affecting interstate and foreign commerce, knowingly recruited, enticed,
harbored, transported, provided, maintained, patronized, solicited, threatened,
forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by
Defendants were undertaken with knowledge and/or reckless disregard of the fact
that their threats of force, fraud, coercion, and combinations of such means would
21
be used, and were in fact used, in order to cause Plaintiff to engage in commercial
sex acts. In so doing, Defendants violated 18 U.S.C. §§1591 through 1594
andW91,
A' 'onallv. Defendants Enstein. Maxwell. and ainatithalLyand
EFTA00615997
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31
together,]
In so
doing, Defendants violated18 1592. These Defendants also obstructed,
and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. 4
1592.
70. Additionally, Defendants knowingly benefitted, financially and by
receiving things of value, from participating in a venture (the Epstein sex
trafficking venture enterprise) which had engaged in acts in violation of 18
U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such
violations. In so doing, Defendants violated 18 U.S.C. § 1593A.
71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so
t Defendants violated 18 U.S.C. § 1594(a),
dokg,
27
72. Additionally, Defendants conspired with each other, and with other
persons known and unknown, to violate 18 U.S.C. § 1592. In so doing,
Defendants violated 18 U.S.C. § 1594(b),
73. Additionally, Defendants conspired with each other, and with other
EFTA00615998
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2N of 31
persons known and unknown, to violate 18 U.S.C. § 1591. In so doing,
Defendants violated 18 U.S.C. 8 1594(c).
74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594,
Defendants are subject to civil causes of action under 18 U.S.C. §
-1-59576-1,Defendatits-additionetly-prefited-from-the-sex-tr-efftelEing-ef-Plein
ebstrueted4nvestigatiens-ef-the-vielatiensauerapted-and-eenspiced-te-vielate,and
suseeeded-in-vielatiugr i-8-1447C-4*-1-541-threugh-1445,by-the-Gemmissien-ecthe
tofts-and-efimes-deser-ibed-iii-this-sernplaiiii1595 by Plaintiff, who is a victim of
their violations.
75. 62.Certain property of Defendant Epstein's was essential to the commission of
the federal crimes and torts described herein, including the use of multiple private
aircraft including a Boeing aircraft (of make and model B-727- 31H with tail number
N908JE) and a Gulfstream aircraft (of make and model G- 1159B with tail number
N909JE). Such aircraft, along with other of Defendants'
4S property, were used as means and instruments of Defendants' tortious and
criminal offenses and, as such, are subject to forfeiture.
76. (Additionally, Defendant Epstein's New York mansion, located at 9 East
71st Street, New York, New York, in the Southern District of New York, and his
private island located in the United States Virgin Islands, were used as means and
instruments of Defendants' tortious and criminal offenses and, as such, are subject to
EFTA00615999
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 29 of 31
forfeiture.
77. 4zhAs a direct and proximate result of Defendants' commission of the
aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 ct. scq.1591,
1592, 1593A, and 1594, and the associated civil remedies provided in § 1595,
Plaintiff has in the past suffered and will continue to suffer injury and pain;
emotional distress; psychological and pnychi atricpsychiatric trauma; mental
anguish; humiliation; confusion; embarrassment; loss of self- esteem; loss of
dignity; loss of enjoyment of life; invasion of privacy; and other damages associated
with Defendants' actions. Plaintiff will incur further medical and psychological
expenses. These injuries are permanent in nature and Plaintiff will continue to suffer
from them in the future. In addition to these losses, Plaintiff has incurred attorneys'
fees and will be required do so in the future.
WHEREFORE, Plaintiff demands judgment against Defendants for
compensatory and general damages, attorneys fees, punitive damages and such
other and further relief as this Court deems just and proper. Plaintiff hereby demands
trial by jury on all issues triable as of right by a jury.
Dated: Januafy-26r 201-7-.June 5, 2017.
Respectfully Submitted,
FARMER. JAFFE. WaVING. EDWARDS.
FISTOS, LEHRMAN, M.
EFTA00616000
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31
29
EFTA00616001
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31
By: A/Bradley J. Edwards Bradley J.
Edwards
BOIES, SCHILLER & FLEXNER
LLPB.5 David Boies_ David
Boies-
Alex Boies Boics Schiller & Flcxncr LLP 575
Sigrid McCawley
Meredith Schultz
HAC VICE-te-befiled
Paul G Cassell
S.J. Quinney College of Law at the University of
Utah
EFTA00616002
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31
20
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation
EFTA00616003
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31
CERTIFICATE OF SF.RVICF,
I HEREBY CERTIFY that on the 5t day of June, 2017, I electronically filed the
foregoing document with the Clerk of Court by using the CNI/ECF system. I also certify that
the foregoing document is being served this day on the individuals identified below via
transmission of Notices of Electronic Filing generated by CM/ECF
$TEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu
Attorneysfor Defendants
Jeffrey Epstein &
By: A/Bradley J. Edwards Farmer, Jaffe,
Weissi43achiasEds=Ristasn lasgaaINM:
Pr6(41GE-glee4040-111061
J,Stanley-Ilettingec
J. Stanley Pottinger PLLC Suite 100
EFTA00616004
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31
31
EFTA00616005
DataSet-10
Unknown
3 pages
Relativity Searches
11/18/2021
1.
JE
• EPS001.27924.28579 (Bill Log for
• EPS001.9109-9236 (Bill Usage to
• EPS001.9237.9293 (Epstein multi-line records for Account
• EPS001.9294-9347 (Epstein multi-line records for Account
• EPS001.9497.9551 (Epstein multi-line records for Account
• EPS002-028943 (Epstein multi-line records for Account )
• EPS002-029000 (Epstein multi-line records for Account )
• EPS002-029203 (Epstein multi-line records for Account )
• EPS002-033921 (ATT records
• EPS002-034080 (Epstein multi-line records for Account )
• EPS002-034137 (Epstein multi-line records for Account )
• EPS002-034340 (Epstein multi-line records for Account )
• EPS002-034511 (ATT records
• EPS002-034670 (Epstein multi-line records for Account )
• EPS002-034727 (Epstein multi-line records for Account )
• EPS002-034930 (Epstein multi-line records for Account )
• EPS002-110332 (ATT record
• USGME01830664 (Subpoena Request)
• USGME01840128 (black book)
• USGME01848764 (black book)
• USGME01848772 (black book)
• USVP00001032 (list of girl's names and black book)
• USVP00157304 (black book)
• USVP00193337 (Subpoena Request)
• USVP00207049 (black book)
• USVP00207989 (Listed a in Excel doc under Florida Massage)
• USVP00264892 (Listed in Black Book)
• USVP00342213 (Southern District of Florida/black book)
• USVP00343169 (black book)
• USVP00352026 (black book)
• USVP00352029 (subpoena request)
2.
JE
• CASSELL 006927
• EPS002-064013(listed in identified phone records and other phone records)
• EPS002-075002 (listed in identified phone records and other phone records)
• EPS002-075014 (listed in identified phone records and other phone records)
• EPS002-075065 (listed in identified phone records and other phone records)
EFTA00090028
• 001573 (list of girls' names and black book. Listed a in black book)
• USGME03.830664 (subpoena request)
• USVP0000081.3(black book)
• USVP00001.032 (list of girls' names and black book)
• USVP00001.095 (list of girls' names and black book)
• USVP00001.1.05 (list of girls' names and black book)
• USVP00001.234 (list of girls' names and black book)
• USVP00001.543 (list of girls' names and black book)
• USVP003.93337 (subpoena request)
• USVP0034221.3 (Southern District of Florida/black book)
• USVP00352026 (list of girls' names and black book)
• USVP00352029 (subpoena request)
JE SW:
• USGME01088970 (on list of masseuses)
3.
JE
• 1,102 hits (several clicked on were not matches)
JE SW
• USGME01088970 (listed on document with list of masseuses: associated to
4.
JE
• EPS001-1200-1204 (2007 interview)
• EPS001.1209.1255 (2007 Accurint report)
• EPS001-14683-14687 (2007 interview)
• EPS001-14688-14692 (2007 interview)
• EPS001.27924-28579 (Bill info fo
• EPS002-013073 (2007 interview)
• EPS002-013079 (2007 interview)
• EPS002-013494 (2007 interview)
• EPS002-013499 (2007 interview)
• EPS002-041015 (2007 interview)
• EPS002-041025 (2007 interview)
• EPS002-041759 (2007 interview)
• EPS002-041769 (2007 Accurint report)
• EPS002-084127 (2007 interview)
• EPS002-084544 (2007 interview)
• GIUFFRE001573 (black book; listed as
• USGME01840128 (black book)
• USGME01848772 (black book)
• USVP00000082 (2018 interview of a)
• USVP00000910 (black book)
EFTA00090029
• USVP00001032 (list of girls' names and black book)
• USVP00001095 (list of girls' names and black book)
• USVP00001105 (list of girls' names and black book)
• USVP00001225 (list of girls' names and black book)
• USVP00001234 (list of girls' names and black book)
• USVP00001346 (list of girls' names and black book)
• USVP00001543 (list of girls' names and black book)
• USVP00001556 (list of girls' names and black book)
• USVP00001590 (list of girls' names and black book)
• USVP00157304 (black book)
• USVP00342213 (DOJ letter identifying victims in 2008 and black book)
• USVP00343169 (black book)
• USVP00351961 (FL Case information for victims)
• USVP00351963 (FL Case information for victims)
• USVP00352026 (black book)
• USVP00352086 (FL Case informationivictimsheictim witnesses)
JE SW
• USGME01099266 (message pads entries)
• USGME01157771 (won't open)
EFTA00090030
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.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
/
REVISED
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:
DER PLF. DATE MARK ADMIT
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
EXHIBITS EXPECTED TO BE USED
I. All applicable criminal statutes
2. All applicable Florida Statutes
3. All applicable Rules of Evidence
4. Video of Jeffrey Epstein's home and route from victim to Epstein's
home
5. Order confirmation from Amazon.com for purchase of books
"SM 101: A Realistic Introduction," "Slave Craft: Roadmap for
Erotic Servitude-Principles, Skills and Tools" and "Training Miss
EFTA01116995
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 2 of I I
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Abernathy:
A Workbook for Erotic Slaves and Their Owners"
6. Non-Prosecution Agreement
7. Jane Doe 102 Complaint
Messages taken from message pads found at Epstein's home
8
Documents related to Jeffrey Epstein produced by Alfredo
9. Rodriguez
Jeffrey Epstein flight logs
10.
I I. Jeffrey Epstein phone records
I•hone records
12.
Jail Visitation Logs
13.
Jeffrey Epstein's probation file
14.
All probable cause affidavits related to criminal investigation
15.
of Jeffrey Epstein
All evidence, information and documents taken or possessed
16. by FBI related to criminal investigation of Jeffrey Epstein
Victims' statements to the FBI related to criminal investigation
17
of Jeffrey Epstein
Video of Search Warrant of Jeffrey Epstein's home being
18 executed
Application for Search Warrant of Jeffrey Epstein's home
19.
Complaint Jane Doe v. Epstein and all subsequent Amended
20. Complaints
All records of homes, properties, bank accounts and any and
21
all records related to Jeffrey Epstein's assets
Jeffrey Epstein's passport (or copy)
22.
Jeffrey Epstein's driver's license (or copy)
23.
EFTA01116996
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 3 of I I
DEF. PLF. DATE
NO. NO. OFFERED MARK ADMIT
TED DESCRIPTION OF EXHIBITS
24 List of corporations owned by Jeffrey Epstein
All documents evidencing relationship between Jeffrey Epstein
25.
and Jean Luc Brunel
26. All documents evidencing relationship between Jeffrey Epstein
and MC2 or any modeling agencies
27 Yearbooks of Jane Doe
28 200 igh School Year Book
29 2001 I igh School Year Book
2003 ugh School Year Book
30
Affidavit and Application for Search Warrant on Jeffrey
31.
Epstein's home
32. Tape recording or transcript of recording of conversation
between Jeffrey Epstein and George Rush
33. Notepads found in Jeffrey Epstein's home and/or during trash
pulls outside of his home during criminal investigation
34 The Palm Beach State Attorney's Criminal file against Jeffrey
Epstein
All documents related to Jeffrey Epstein's 6/30/08 conviction
35.
36. Jeffrey Epstein's criminal plea colloquy
Public records from the Department of Corrections related
37.
to Jeffrey Epstein
Records from the Florida Department of Law Enforcement
38.
related to Jeffrey Epstein
39 All statements made by Jeffrey Epstein
40 List of properties and vehicles in Larry Visoski's name
41. All of Jeffrey Epstein's Responses to Requests for Production,
Requests for Admission, Answers to Interrogatories in this matter,
and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994,
08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802,
09-81092
EFTA01116997
Edwards adv. Epstein
Case No.: 502009CA040800XX.XXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 4 of I
DEF. PLF. DATE
NO. NO. OFFERED MARK ADMIT
TED DESCRIPTION OF EXHIBITS
42. All discovery related responses of Jeffrey Epstein in this matter
and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994,
08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802
09-81092
43. Jeffrey Epstein's Answers and Affirmative Defenses in
all civil cases against him
44. All Complaints in which Jeffrey Epstein was a plaintiff
or defendant
45. Jeffrey Epstein's Deposition testimony and discovery responses
in this case and cases 08-80119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656,
09-80802, 09-81092
46. Jeffrey Epstein's Deposition testimony and discovery responses
in State Court cases LM v. Jeffrey Epstein, Case No.
502008CA02805OOOOCMB AB and E.W. v. Jeffrey Epstein,
Case No. 502008CP003620000(MB
47. Jeffrey Epstein Deposition Testimony and discovery responses
in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No.
502009CA0408007OOOCMBAG
48. Any and all newspaper articles, online articles or publications
related to Jeffrey Epstein
49. Report and Analysis of Jeffrey Epstein's assets
-o Video footage (DVD) of walk through site inspection of Jeffrey
Epstein's home.
5 I. Photos of all of Jeffrey Epstein's properties, cars, boats and planes
52 Probable Cause Affidavits prepared against Jeffrey Epstein
and
53. Audio tape of
54. Photographs, videos and books taken in the search warrant
ofJeffrey Epstein's home
55. Documents related to or evidencing Jeffrey Epstein's donations
to law enforcement
56. Victim Notification Letter from US Attorney's Office to
Victim
EFTA01116998
Edwards adv. Epstein
Case No.: 502009CA040800)OCXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 5 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Expert Dr port of Victim
57
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
60.
Department relating to Jeffrey Epstein
Passenger Manifests of Jeffrey Epstein's aircraft and private
61. plane flight logs
Passenger lists for flights taken by Jeffrey Epstein
62
Letter from Jeffrey Epstein to Alberto Pinto regarding house
63. island project
Jeffrey Epstein's bank statements
64.
Jeffrey Epstein's tax returns
MC2 emails involvin communications of Jeffrey Epstein,
65. Jeff Fuller appas Suat, Jean Luc Brunel
and Aman a rant
DVD of plea and colloquy taken on 6-30-08
66.
Transcript of plea and colloquy taken on 6-30-08
67.
Massage Table
68.
Lotions taken from Jeffrey Epstein's home during search
69
warrant
Computers taken from Jeffrey Epstein's home during search
70. warrant
71. Vibrators, dildos and other sex toys taken from Jeffrey
Epstein's home during search warrant
72. No Contact Orders entered against Jeffrey Epstein
Criminal Score Sheet regarding Jeffrey Epstein
73
74. Documents evidencing Jeffrey Epstein's Community
EFTA01116999
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 6 of II
DEF. PLF, DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Control and Probation
75. Jeffrey Epstein's Sex Offender Registration
Jeffrey Epstein's Booking photograph
76.
CAD calls to 358 EL BRILLO WAY, PALM BEACH
77.
FL 33480
List of Jeffrey Epstein's House contacts
78
Documents related to Jeffrey Epstein's investments
79.
Letter from Chief Michael Reiter to Barry Krischler
80
List of planes owned by Jeffrey Epstein
81.
Letter from Guy Fronstin to Assistant State
82
Attorney dated 1-11-06
Letter from Guy Fronstin to Assistant State
83
Attorney dated 1-13-06
Letter from Guy Fronstin to Assistant State
84
Attorney dated 2-17-06
Letter from Guy Fronstin to Assistant State
85
Attorney dated 4-6-06
Letter from Guy Fronstin to Assistant State
86
Attorney dated 4-10-06
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
91
properties
Arrest Warrant o
92.
Police report regarding picking up money
93
dated 11-28-04
EFTA01117000
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 7 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
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.
Victim's GED testing information and results
100.
JEGE, Inc. Passenger Manifest
101.
Hyperion Air Passenger Manifest
102.
Flight information for
103.
Passenger List Palm Beach flights 2005
104.
Jeffrey Epstein notepad notes
105.
Pleadings of Jane Doe I and 2 v. US case
106.
Jeffrey Epstein 51h 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
III .
Victim's school records and transcripts
112.
Victim Notification letter dated 7-9-08
113.
EFTA01117001
Edwards adv. Epstein
Case No.: 502009CA040800XXMMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 8 of II
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
Victim's employment records from
114
Police report of Juan Alessi theft at Jeffrey Epstein's home
115.
116.
117.
118.
119.
120.
All surveillance conducted by law enforcement on Jeffrey
121
Epstein's home
Emails received from Palm Beach Records related to Jeffrey
122
Epstein
All items listed on the Palm Beach Police Property Report Lists
123
All items taken in the execution of the search warrant of
124
Jeffrey Epstein's 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 produced by Palm Beach Police Department
127
prior to the deposition of Detective Recarey
Photographs of all persons listed on Victims' Witness Lists
128
Statements, deposition transcripts, videotaped depositions
129
and transcripts taken in connection with this and all
related cases and exhibits thereto
Any and all expert witness reports and/or records generated
130.
in preparation 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.
EFTA01117002
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 9 of I I
DEF. PLF. DATE
NO. NO. OFFERED MARK ADMIT
TED DESCRIPTION OF EXHIBITS
Any articles or publications of Dr. Ryan Hall
133.
134. Any articles or publications of Dr. Richard Hall
Any articles or publications of Dr. L. Dennison Reed
135.
136. All items and documentation review by Dr. L. Dennison Reed
Transcript and video (DVD) of IME of Victims
137
138 All exhibits to Dr. L. Dennison Reed's Deposition
All exhibits to Dr. Richard Hall's Deposition
139
140. All items and documents reviewed by Dr. Richard Hall
All items and documents reviewed by Dr. Ryan Hall
141.
142 All exhibits listed on the Epstein's Exhibit List
Demonstrative aids and exhibits including, but not limited to,
143.
anatomical charts, diagrams and models, surveys, photographs
and similar material including blow-ups of the aforesaid items.
144. Any-and-all-mortality-tables
145. Edwards' reserves all objections to Epstein's Exhibits
Edwards reserves the right to supplement and/or amend his
146.
Exhibit List
By listing an Exhibit, Edwards is not waiving his right to
147.
object to same at trial and does not waive their right
to amend same.
All exhibits listed by Epstein subject to Edwards' objections.
148
149. All pleadings and attachments in the action under the Crime
Victims Rights Act prosecuted by Bradley Edwards
on behalf of victims of Epstein's criminal molestations.
All attachments to Edwards' Motion for Summary Judgment.
150.
EFTA01117003
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 10 of 11
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
All time records and hourly billing documentation produced
151.
in discovery.
All deposition testimony and discovery responses by Epstein
152.
submitted in this action.
All pleadings filed by Epstein in the Rothstein
153.
bankruptcy proceeding.
All submissions by Epstein in connection with the Rothstein
154.
deposition.
All Settlement Agreements between Epstein and victims
155.
of his sexual molestations.
Plaintiff reserves the right to amend this list.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-
Service to all counsel on the attached list, th Septembe , 2013.
w com; mep@searcylaw.com
Flor No.: 169440
Se •enney Scarola Barnhart & Shipley, P.A.
21: 'alm Beach Lakes Boulevard
st Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Attorneys for Bradley J. Edwards
EFTA01117004
Edwards adv. Epstein
Case No.: 502009CA04080WOOOMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page II of II
COUNSEL LIST
Atter Goldber er & Weiss P A.
Attorneys for Jeffrey Epstein
~fre
Marc Nurik
ttomeys or e ey pstein Law Offices of Marc S. Nurik
Bradley J. Edwards, Es
Esquire Fort Lauderdale, FL 33301
anner, e, etssorg, wards, Fistos &
Attorneys for Scott Rothstein
re
ona - ai.a. e. .
Fred Haddad, Es uire
ort auderdale FL 33301
re a . .
Attorneys for Jeffrey Epstein
o au er e,
EFTA01117005
DataSet-10
Unknown
3 pages
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
)
)
Plaintiff, ) CASE NO.: 502008CA028051XXXXMB
)
vs. )
)
JEFFREY EPSTEIN. )
)
Defendant. )
)
SUBPOENA DUCES TECUM
FOR VIDEOTAPED DEPOSITION
THE STATE OF FLORIDA:
TO: KHALID ZAHIR MONROE
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on October 28, 2009 at 10:00 a.m., at Esquire Court Reporters, 44 West
Flagler Street, Miami, FL 33130 for the taking of your deposition in this action and to
have with you at that time and place the following:
All documents on Schedule "A" attached.
If you fail to appear, you may be in contempt of court. You are subpoenaed
to appear by the following attorneys and unless excused from this Subpoena by these
attorneys or the Court you shall respond to this Subpoena as directed.
DATED on September_, 2009.
3.
EFTA00602283
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
' • 75
EFTA00602284
Schedule "A"
Documents, writings, agreements, correspondence, schedules, diaries, personal
notes, message pads, names of 'masseuses" and all other writings of any kind, related in
anyway to Jeffrey Epstein or your relationship with him
2
EFTA00602285
DataSet-10
Unknown
2 pages
Precedence: ROUTINE Date: 02/06/2008
To: New York Attn:
Squad C-20
From: Miami
PB-2/PBCRA
Contact:
Approved B :
Drafted By:
Case ID #: (Pending)
Title: JEFFREY EPSTEIN;
GHISLAINE N. MAXWELL;
WSTA - CHILD PROSTITUTION
Synopsis: To set leads for captioned investigation.
Reference: 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 investigatinge, stein, apart-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- ear-old
irl who lives in Loxahatchee, Florida, in the Southern District of Florida, and who attended
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
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
M, 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 ih.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 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, occasionally,
manually fondle the vaginal area of the girl - sometimes over the panties, sometimes under the panties,
and sometimes digitally penetrating the girl's vagina. On some instances, Epstein also used a vibrator or
massager on the girl's vaginal area. 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 activit 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
EFTA00270238
him" and "has girl for toni ,il 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
for investigative direction and questions.
LEAD(s):
Set Lead 1: (Action)
NEW YORK
AT NEW YORK NY
Locate and interview a 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 any additional
minor females who may have interacted with captioned subjects.
EFTA00270239
DataSet-10
Unknown
1 pages
Memorandum
SubjectDate
Memorandum seeking Travel AuthorizationJune 20, 2008
Operation Leap Year
ToFrom
Deputy Chief -
Criminal DivisionAssistant U.S. Attorney
Chief
Northern Division
I. INTRODUCTION
This memorandum seeks travel authorization to travel to New York from June 19 to June 20, 2008,
in connection with Operation Leap Year.
II. THE PROPOSED TRAVEL AND ITS PURPOSE
As you know, we plan to present a final indictment to the grand jury in approximately two weeks.
Since our original planned indictment, we have learned about a series of victims in New York and the
possible involvement of Epstein's two New York-based assistants, Lesley Groff and The
inclusion of New York victims would be a great benefit to the indictment, and we would like to interview
some key people in New York in order to include that evidence in the indictment.
Accordingly, I propose to travel to New York on the afternoon of Thursday, June 19 to conduct
interviews on Friday, June 20, 2008. a FBI Special Agents and also
will be traveling, although they may stay Ion er.
First, we would like to interview She has been identified by two victims as
someone who recruited numerous others to Epstein's New York residence. We know that was
going to Epstein's home when she was 14, and it is possible that she was going there as early as 13. This
trip is contingent upon approval from the Justice Department of our immunity request for
Yesterday I spoke with someone at the Witness Immunity Unit who stated that we should have the
approval by early next week. fi
In addition, a witness here in the Palm Beach area came forward recently to inform the FBI about a
link between Epstein and the MC 2 Modeling Agency. The witness stated that Epstein and the head of MC
2 , Jean Luc Brunel, worked together to obtain fraudulent visas to bring potential models to the United
States. The witness stated that Epstein selected some of the underage girls to come to the United States
even though Brunel never intended to use them as models so that Epstein could engage in sexual activity
with them. Brunel's name appears on several of the message pads recovered during the search of Epstein's
home. Some of the messages describe young girls that he would like Epstein to meet (including a 16-year-
old who would "teach Russian" to Epstein). The FBI previously tried to interview Brunel, but he refused
to speak with them. The Palm Beach witness has told the FBI that a former MC 2 employee is willing to
speak with the FBI about the fraud.
Yesterday, the FBI in New York arrested two Bear Steams employees for securities fraud related to
Bear Stearns hedge funds involved in the subprime loan crisis. Epstein has been reported as one of the
creators of those hedge funds in financial news sources. The agents here are contacting the New York
agents to determine if Epstein is a target/subject of the New York investigation and also to find out whether
the two employees are cooperating and would be willing to speak with us.
For the foregoing reasons, I recommend that the Office approve the costs of a hotel room and a
flight for my travel to New York.
FI
a2Travel plans will not be made until the immunity is confirmed.
EFTA00190241
DataSet-10
Unknown
3 pages
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
)
)
Plaintiff, ) CASE NO.: 502008CA028051XXXXMB
)
vs. )
)
JEFFREY EPSTEIN. )
)
Defendant. )
)
SUBPOENA DUCES TECUM
FOR VIDEOTAPED DEPOSITION
THE STATE OF FLORIDA:
TO: KHALID ZAHIR MONROE
AKA: KHALID SALAAM
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on October 28, 2009 at 10:00 a.m., at Esquire Court Reporters, 44 West
Flagler Street, Miami, FL 33130 for the taking of your deposition in this action and to
have with you at that time and place the following:
All documents on Schedule "A" attached.
If you fail to appear, you may be in contempt of court. You are subpoenaed
to appear by the following attorneys and unless excused from this Subpoena by these
attorneys or the Court you shall respond to this Subpoena as directed.
DATED on September_, 2009.
3.
EFTA01099129
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
Florida Bar No.: 542075
EFTA01099130
Schedule "A"
Documents, writings, agreements, correspondence, schedules, diaries, personal
notes, message pads, names of 'masseuses" and all other writings of any kind, related in
anyway to Jeffrey Epstein or your relationship with him
2
EFTA01099131
DataSet-10
Unknown
14 pages
. (NY) (FBI)
To:
Subject RE: GM investigation
Paul,
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 an ---
2. On 1/4/11, a $3,000,000; (NY) (FBI) < iv>
Cc: (USANYS) oy>, (USANYS)
ov>, (NY) (FBI) < Dv>
Subject: Re: GM investigation
No problem, we will start working on what we can today. I've CC'er assistance with some of these
requests.
1
EFTA01654306
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 Ex loitation Human Trafficking Task Force
Office:
Cell: MEI
Fax:
From: (USANYS) < ov>
Sent: Monda , Februa 24, 2020 12:27 PM
To: < >: (NY) (FBI) a
Cc: r (USANYS) ; (USANYS)
ov>
Subject: GM investigation
Hi and
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 o not ave 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 Alessi interview?
Thanks in advance, and sorry to pile on, I know everyone is busy.
Alison
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Sy
2
EFTA01654307
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: (USANYS) < ov>
Sent: Monday, February 24, 2020 12:27 PM
To:
Cc: r (USANYS) < ov>; •=le (USANYS)
ov>
Subject: GM investigation
H= and -
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 t at we o not ave 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 Alessi 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
2
EFTA01654308
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