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4 pages
From: ' (USANYS) [Contractor]"
To: l apar (NY) (FBI)"
Cc: :a (USANYS)"
Subject: RE: Maxwell To-dos
Date: Tue, 06 Jul 2021 18:35:18 +0000
I have not. be around the rest of the day today and the whole week. Let me know when you're free to drop the
files off.
From:
Sent: Tuesday, July 6, 2021 2:06 PM
To: (USANYS) [Contractor] (NY) (FBI)
Cc: < )'; (USANYS)< >
Subject: RE: Maxwell To-dos
Checking in on this—Will, were you able to get these files from
From: (USANYS) [Contractor] <
Sent: Friday, July 2, 2021 10:03 AM
To: (NY) (FBI) < >;
Cc: < .>; (USANYS)
Subject: RE: Maxwell To-dos
Sure thing! — I'll be around until 230 today if you're available to drop them off.
From:
Sent: Friday, July 2, 2021 9:55 AM
To: (NY) (FBI) (USANYS) [Contractor]
Cc: •c )'; (USANYS)
Subject: RE: Maxwell To-dos
Thanks
Will, would you please coordinate getting these from S then circle up with me to discuss prepping for production?
From: Amanda Young < >
Sent: Thursday, July 1, 2021 3:23 PM
To: )< ›; (USANYS) [Contractor]
>
Cc: ) (USANYS)
Subject: RE: Maxwell To-dos
We have the files from CART.
Will, let me know a good time to coordinate to turn them over to you.
EFTA00087365
Special Agent Amanda Young
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From:
Sent: Friday, June 4, 202112:47 PM
To: Byrne, MI (NYPD) •(: >
Cc: (NY) (FBI) < >;
(USANYS)
Subject: (EXTERNAL EMAIL) - RE: Maxwell To-dos
Thanks!
From: BYRNE,
Sent: Friday, June 4, 2021 10:12 AM
To:
Cc: (NY) (FBI) ;
(USANYS)
Subject: Re: Maxwell To-dos
Sure let me check on that today when I'm in.
On Jun 3, 2021, at 21:57, > wrote:
Hi M,
Checking in again on the .avi files from CART. Any update?
Thanks,
From:
Sent: Monday, April 19, 2021 2:40 PM
To: BYRNE, (NY) (FBI) < >
Cc: (USANYS) <
Subject: RE: Maxwell To-dos
Hi
Any update from CART regarding the .avi files, please? And any luck with the review of images for
Thanks,
EFTA00087366
From: BYRNE, <
Sent: Thursday, February 4, 2021 1:24 PM
To: . (NY) (FBI) < >
Cc: >; (USANYS) <
Subject: Re: Maxwell To-dos
Hey guys,
To answer your questions:
• you should have 302's from by now.
• These photos are still under review.
• We have not forgotten about the .avi files they are also still being processed.
• Palm Beach PD Captain is the POC for this task. His phone number is (cell)
(office) and email is
We will let you know as soon as the photo and video tasks are completed. Let us know if there's anything
else.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Tuesday, February 2, 2021 4:03 PM
To: (NY) (FBI) < >; BYRNE,
Cc: < (USANYS)
Subject: Maxwell To-dos
Hi ands,
Just wanted to check in on a few tasks for Maxwell. Not a huge rush, but wanted to make sure these stay on your radar:
• Please send me the draft 302s from the 1/20 and 1/21 interviews of for review
• Review of images in FBI office for photos of
• The .avi files from Reiter (E, I know CART has been under water with the Capitol investigation, but wanted to
ping on this to make sure we don't forget it)
• Finding PBPD witness who can authenticate the message pads and other items that were seized from Epstein's
Palm Beach residence. On this, I've gone through the reports, and below are the PBPD personnel who I think
might be able to provide this testimony. If you could please get me contact information for a point of contact at
EFTA00087367
PBPD, I'm happy to hound them for contact info for these individuals (ranked in order of how likely they are to
be useful witnesses for these purposes):
o Evidence Specialist (inventory return, documentation of property receipts, and collection
and bagging of evidence — ideally we could just call her to authenticate everything that was seized from
the property)
(searched garage, towel closet and pantry off the kitchen, kitchen phone message
book, office room, green bathroom on first floor, closet by green bathroom, two bedrooms on second
floor with sex toys, pool cabana, Banasiak's living quarters)
(searched garage, towel closet and pantry off the kitchen, kitchen phone message book,
officer room, green bathroom on first floor, closet by green bathroom, two bedrooms on second floor
with sex toys, pool cabana, Banaskiak's living quarters)
(read warrant, video scene)
o CSI (photographer)
(pantry next to kitchen, yellow and blue room with photos, main entrance, blue
room with photos, sliding glass door room, cars)
(pantry next to kitchen, yellow and blue room with photos, main entrance, blue
room with photos, sliding glass door room, cars)
o (electronic devices)
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00087368
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2 pages
From: '
To: nI a
Cc: ' r
Subject: RE:
Date: Tue, 20 Jul 2021 19:43:13 +0000
Importance: Normal
Attachments: MM_1B1_Chain-of-Custody.pdf; MM_1B2_Chain-of-Custody.pdf; MM_1B3_Chain-of-
Custody.pdf; MM_1B4_Chain-of-Custody.pdf; MM_IBS_Chain-of-Custody.pdf;
MM_1B6_Chain-of-Custody.pdf; MM_IBT_Chain-of-Custody.pdf; MM_1B8_Chain-of-
Custody.pdf; MM_1B9_Chain-of-Custody.pdf; MM_IB10_Chain-of-Custody.pdf
can meet at 9:30am on Thursday 7/29. I'm going to coordinate with the local FBI office so we can do VTC.
I've attached the chains of custody for the lBs.
Her email i
Special Agent -
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From:
Sent: Monday, July 19, 20216:38 PM
To:
Cc:
Subject: [EXTERNAL EMAIL] - RE:
Thanks, Here are some options next week:
• 7/26 before 12pm or after 3pm
• 7/28 12pm to 2pm
• 7/29 before Liam
From:
;
Cc:
Subject: RE:
is traveling Wednesday for vacation. Can you suggest some days/times next week? We will have the message
pads and I'll see about gettingI copy of the chains.
Special Agent
EFTA00155166
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From:
Sent: Monday, July 19, 2021 11:37 AM
To: ;
Cc
Subject: (EXTERNAL EMAIL) - RE:
in advance of the meeting, can you please track down any and all chains of custody in FBI possession?
From:
Sent: Monday, July 19, 2021 11:26 AM
To: >; ;s
Cc:
Subject: RE:
Thanks, Does this week work for ? If so, we could do between 12pm and 4pm on Wednesday or 10:30 am
to 12pm on Thursday. If I should get some times for next week instead, please let me know. Also, can you please have the
physical message pads with you for the WebEx with just in case?
From:
Sent: Wednesday, July 14, 20215:57 PM
To:
Cc:
Subject:
Hi all,
I spoke with today. She can meet with us but may go into I local FBI office to get assistance with video
setup. I told her I would touch base with her early next week to schedule I day and time that works for
everyone. Let me know what you all are thinking on timing and I'll let her know.
Thanks,
EFTA00155167
DataSet-10
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5 pages
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
L.M., )
)
Plaintiff, ) CASE NO.: 502008CA028051XXXXMB AD
)
vs. )
)
JEFFREY EPSTEIN, )
)
Defendant. )
)
Re-NOTICE OF TAKING DEPOSITION
PLEASE TAKE NOTICE that the attorney for Plaintiff in the above-styled cause
will take the deposition of William "Bill" Riley on October 20, 2009 at 10:00 a.m. for
the purposes of discovery at the following location:
Esquire Court Reporters
515 East Las Olas Blvd.
Suite 1300
Fort Lauderdale, Florida
Said deposition will be taken before ESQUIRE COURT REPORTERS, a Notary
Public or any officer authorized to administer oaths by the laws of the State of Florida,
and a person who is neither a relative, nor employee, nor attorney, nor counsel of any of
the parties and who is neither a relative nor employee of such attorney or counsel, and
who is not financially interested in the action.
Said deposition will be taken pursuant to Florida Rules of Civil Procedure in such
cases provided. Said oral examination will continue from hour to hour and from day to
day until completed.
EFTA00618080
Case No. 502008CA028051)0O0message pads, names of "masseuses" and all other writings of any
kind, related in anyway to Jeffrey Epstein or your employment with him
2
EFTA00618082
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
)
)
Plaintiff, ) CASE NO.: 502008CA028051)OCO(MB
)
vs. )
)
JEFFREY EPSTEIN, )
)
Defendant. )
)
SUBPOENA DUCES TECUM
FOR VIDEOTAPED DEPOSITION
THE STATE OF FLORIDA:
TO: Wiliiam "Bill" Riley
5645 Coral Ridge Drive
Coral Springs, FL 33076
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on October 20, 2009 at 10:00 M., at Esquire Court Reporters, 515 East
Las Olas Blvd., Suite 1300, Fort Lauderdale, Florida for the taking of your deposition
in this action and to have with you at that time and place the following:
All computers, computer equipment, photographs,
videos and video equipment, DVDs, CDs, surveillance
equipment and recordings, documents and
EVERYTHING taken from the residence located at 358
El Brillo Way, West Palm Beach, Florida, at any time.
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.
EFTA00618083
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
Florida Bar No.: 542075
(954) 522-3456
2
EFTA00618084
DataSet-10
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4 pages
Memorandum
subject Date
Memorandum seeking Travel Authorization June 20, 2008
Operation Leap Year
10
I. INTRODUCTION
This memorandum seeks travel authorization to travel to New York from Junc 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
Cecilia Steen. 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, 2008.1 F
so will be traveling, although they may stay longer.
First, we would like to interview he has been identified by two victims
as someone who recruited numerous others to Epstein's New York residence. We know the-
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
'I may decide to stay in New York on Friday night in order to sec a college friend. If I do,
will pay for the hotel room on Friday night and any difference in the airfares.
EXHIBIT B-132
Case No. 08-80736-CV-MARRA P-008379
EFTA00224759
should have the approval by early next week!
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' Modeling Agency. The witness stated that Epstein and
the head of MC2, 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. Brunei'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' 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 Steams 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 ofa hotel room and
a flight for my travel to New York.
'Travel plans will not be made until the immunity is confirmed.
-2-
Case No. 08-80736-CV-MARRA P-008380
EFTA00224760
%AO110 I Kcv 04(07) Suttpxna In Ica,fy litforc Grand Jury
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
TO
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
Ira 07-103(WM-rues. No. OLY-55/1
SUBPOENA FOR:
EgPERSON ftI DOCUMENTS) OR OBJECTS)
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
Court at the place. date, and time specified below.
PLACE CX)1111114OOM
Grand Jury Room
United States Distract Court
701 Clematis Street DA1T. AND TIME
West Palm Beech. Florida 33401 7/1/2008 10.30 am
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):•
ALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA.
D Please see additional information on rem •
This subpoena shall remain in el In by the court or by an officer sting on
behalf of t e court
NAME., ADDRESS AND PHONE NUMBER Of ASSISTANT U S. ATTORNEY
Ann Mane C. WistsAs. Assistant U.S. Attorney
500 South Australian Avenue, Suite 400
West Per Beech, Florida 334014235
Tel (561) 8204711, ext 3047
• If erg, opplee able enter -et
Case No. 08-80736-CV-MARRA P-008381
EFTA00224761
ATTACHMENT TO GRA LY-85/I
ADDRESSED TO
PLEASE BRING THE FOLIO WING DOCUMENTS, ITEMS, AND INFORM/1
4/ '11ON WITH YOU
'1O YOUR GRAND JURY APPEARANCE:
I. Any and all notes, letters, cards, gifts, payments, photographs, or other items that you
Cecilia
Steen, Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein.
2. Any and all photographs, whether printed or digital, ofJeffrey Epstein,
, Cecilia Steen, Lesley Groff, Ghislaine Maxvit ,
other employee or associate of Jeffrey Epstein.
3. Any and all e-mails, instant messages, chats, text messages. voicemails, or telephone
messages that you have sent to and/or received from Jeffrey Epstein,
Cecilia Steen, Lesley Groff, Ghislaine Maxwell, and/or any other
employee or associate of Jeffrey Epstein.
4. A list of all telephone numbers (cellular and "land line"), e-mail addresses, screen
names, addresses, and any other contact information that you have for the following persons during
the period of January I, 2003 to the present:
a. yourself;
b. Jeffrey Epstein;
f. Cecilia Steen;
g. Lesley Groff;
h. Ghislaine Maxwell;
i. any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine
Maxwell;
j. any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine
Maxwell;
k. any person(s) who communicated with you to arrange appointments to meet
with Jeffrey Epstein and/or Ghislaine Maxwell.
5. Any billing statements for telephone service (cellular and "land line") for any
telephone you used during the period of January I. 2003 to the present.
Case No. 08-80736-CV-MARRA P-008382
EFTA00224762
DataSet-10
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5 pages
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
)
)
Plaintiff, ) CASE NO.: 502008CA028051XXXXMB AD
)
vs. )
)
JEFFREY EPSTEIN, )
)
Defendant. )
)
Re-NOTICE OF TAKING DEPOSITION
PLEASE TAKE NOTICE that the attorney for Plaintiff in the above-styled cause
will take the deposition of William "Bill" Riley on October 20, 2009 at 10:00 a.m. for
the purposes of discovery at the following location:
Esquire Court Reporters
515 East Las Olas Blvd.
Suite 1300
Fort Lauderdale, Florida
Said deposition will be taken before ESQUIRE COURT REPORTERS, a Notary
Public or any officer authorized to administer oaths by the laws of the State of Florida,
and a person who is neither a relative, nor employee, nor attorney, nor counsel of any of
the parties and who is neither a relative nor employee of such attorney or counsel, and
who is not financially interested in the action.
Said deposition will be taken pursuant to Florida Rules of Civil Procedure in such
cases provided. Said oral examination will continue from hour to hour and from day to
day until completed.
EFTA00723083
Case No. 502008CA028051)0O0message pads, names of "masseuses" and all other writings of any
kind, related in anyway to Jeffrey Epstein or your employment with him
2
EFTA00723085
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
)
)
Plaintiff, ) CASE NO.: 502008CA028051)OCO(MB
)
vs. )
)
JEFFREY EPSTEIN, )
)
Defendant. )
)
SUBPOENA DUCES TECUM
FOR VIDEOTAPED DEPOSITION
THE STATE OF FLORIDA:
TO: Wiliiam "Bill" Riley
5645 Coral Ridge Drive
Coral Springs, FL 33076
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on October 20, 2009 at 10:00 a.m., at Esquire Court Reporters, 515 East
Las Olas Blvd., Suite 1300, Fort Lauderdale, Florida for the taking of your deposition
in this action and to have with you at that time and place the following:
All computers, computer equipment, photographs,
videos and video equipment, DVDs, CDs, surveillance
equipment and recordings, documents and
EVERYTHING taken from the residence located at 358
El Brillo Way, West Palm Beach, Florida, at any time.
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.
EFTA00723086
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
Florida Bar No • 542075
2
EFTA00723087
DataSet-10
Unknown
9 pages
ftradle I.dv.ads
Direct C•7266
kActimis wrra-lav,.com
Rothstein Rosenfeldt Adler
Attorneys at Law
August 4, 2009
Via Fedex
And First Class Mail
Alfredo Rodri uez
Re: Jane Doe v. Epstein,
Our File No. 09-22784
Dear Mr. Rodriguez,
During the first part of your deposition you indicated that you would be able to
locate some documents and information to bring to the continuation of your deposition
scheduled for this Friday, August 7, 2009. Some of those things were:
• Your journals, logs, notes or personal memos that reflect the names and
phone numbers of the girls ("masseuses") that visited the house;
• The cards from the investigators that visited you on various occasions;
• Names/numbers of the cab companies or drivers used to take the girls to and
from the house;
• Name and address of Epstein's company that paid you your salary;
• Leslie Groffs address and/or phone number;
• Name of the girl that took care of the pool;
• List of all clubs where Epstein was a member;
Repay To Las Olds City Centre • 401 East Laa Olas Boulevard • Suite 1650 • FOP Lauderdale. Ronda 33301 Telaptiont (954) 512-3456 • Fax )954;527.9662
BOCA RATON • FORT LAUDERDALE • MIAMI • NEW YORK CITY • TALLAHASSEE • WASHINGTON CI C. • WEST PALM BEACH
WWW.I .CO111
3501.183-055
Page I of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00094609
EFTA01248250
' November 9, 2009
Page 2 of 3
• Full name, address and phone number for ancEn New York;
• Any copies of message pads or schedules;
• The confidentiality agreement;
• Copy of the house manual;
• Copies of documents reflecting banks where Epstein had accounts; and
• Names of any of Epstein's businesses.
Please bring whatever other related information that you have. I appreciate your
cooperation in this regard.
Very Truly Yours,
ROTHSTEIN ROSENFELDT ADLER
Bradley J. Edwards, Esq.
FOR THE FIRM
BJEfij
1012
3501.183-055
Page .2 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094610
EFTA01248251
Pagc 1 of 2
Bradley J. Edwards
From: Alfredo Rodnguez
Sent: Monday. August 10. ZUO9 1 45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
--- On Mon, 8/10/09, Bradley J. Edwards > wrote:
From: Bradley J. Edwards
Subject: Epstein
To: "-
Date: Monday, August 10, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard , Suite 1650
1013
11/8/2009
3501.183-055
Page 3 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00094611
EFTA01248252
Page 2 of 2
Fort Lauderdale. FL 33301
facsimile
1014
11/8/2009
3501.183-055
Page 4 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094612
EFTA01248253
Page 1 of 2
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Tuesday, August 11, 2009 8:43 AM
To: 'Alfredo Rodriguez'
Subject: RE: Epstein
Sure. My cell phone number is My direct line at work I'll wait to hear from you.
Thanks. Take care.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale. FL 33301
facsimile
From: Alfredo Rodriguez [mailto:
Sent: Monday, August 10, 2009 :45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
-- On Mon, 8/10/09, Bradley J. Edwards wrote:
From: Bradley J. Edwards
Subject: Epstein
To: '
Date: Monday, August I0, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
Sincerely,
Bradley J. Edwards
Partner
1015
11/8/2009
3501.183-055
Page 5 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_000946 I3
EFTA01248254
Page 2 of 2
Righstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard . Suite 1650
Fo La derd I FL 33301
facsimile
1016
11/8/2009
3501.183-055
Page 6 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094614
EFTA01248255
Page 1 of 2
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Saturday, August 22, 2009 11:23 AM
To: 'Alfredo Rodriguez'
Subject: RE: Epstein
Alfredo,
I have been trying to call you for days and it seems your phone is shut off. Is there a new number where you can
be reached? Give me a call whenever you have a chance. Thanks. Hope all is well.
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale, FL 33301
- facsimile
From: Alfredo Rodriguez [mailto
Sent: Monday, August 10, 2009 :.15 PM
To: Bradley 3. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
--- On Mon, 8/10/09, Bradley J. Edwards wrote:
From: Bradley J. Edwards <1
Sub'ect: E stein
To:
Dat . , , .
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot I wish you well.
1017
11/8/2009
3501.183-055
Page 7 of9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_000946 IS
EFTA01248256
Page 2 of 2
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard . Suite 1650
Fort Lauderdale, FL 33301
- facsimile
1018
11/8/2009
3501.183-055
Page 8 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094616
EFTA01248257
Page I of 1
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Monday. October 19.2009 11:52 AM
To: 'Alfredo Rodriguez'
Subject: Hello
Alfredo,
You have literally fallen off the face of the earth. I hope everything is ok. I want to talk to you. Please call me
ASAP. The number I was reaching you on is no longer good. Please call me when you get this email. Again. I
hope all is well.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
FL 33301
facsimile
1019
11/8/2009
3501.183-055
Page 9 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094617
EFTA01248258
DataSet-10
Unknown
35 pages
Page 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
IN RE: OPERATION LEAP YEAR
Federal Grand Jury, 07-103
West Palm Beach, Florida
May 8, 2007
APPEARANCES:
a ESQUIRE
Assistant United States Attorney
Foreperson
TESTIMONY
OF
EFTA00179399
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1 The sworn testimony of
2 was taken before the Federal Grand Jury, West Palm
3 Beach Division, West Palm Beach, Palm Beach County,
4 State of Florida, on the 8th day of May, 2007.
5 Philip w. May, Court Reporter, was authorized to
6 and did report the sworn testimony.
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EFTA00179400
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(The witness entered the grand jury room.)
having been duly sworn by the grand jury foreperson,
was examined and testified on her oath as follows:
5 EXAMINATION
6 BY
7 Q Could you start by reminding us of your name and
8 where you're employed.
9 A
10 . I work for the FBI here in West
11 Palm Beach on their violent crimes squad.
12 Q And you are one of the case agents in Operation
13 Leap Year?
14 A Yes, I am.
15 Q Did you recently participate in an interview of
16 ?
17 A Yes.
18 Q Can you tell us date of birth?
19 A was born on July 26, 1988.
20 Q And you spoke with her recently?
21 A Yes, we did.
22 Q So she was 18 at the time of the interview?
23 A Yes, I believe she was.
24 Q Who is
25 A was identified by the Palm Beach
EFTA00179401
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1 Police Department as one of the girls who had frequented
2 Mr. Epstein's house.
3 Q How exactly did the Palm Beach Police Department
4 determine that she was one of those girls?
5 A When they did their search warrant at
6 Mr. Epstein's residence, some message pads were obtained
7 at his residence, and they had several calls from a girl
8 named , and phone numbers. So they were able to
9 track back those messages back to
10 Q Did the Palm Beach Police Department try to
11 interview 7
12 A They did.
13 Q Did she agree to speak with them?
14 A No. She stated that she loved Jeffrey Epstein,
15 and that she would not say anything positive or negative
16 about what occurred.
17 Q After the FBI became involved in this
18 investigation, did you try to interview
19 A We did, as well, with no such luck, as well.
20 Q How long ago was it that you first made contact
21 with
22 A It was back in November of '06.
23 Q Did you try to serve her with a subpoena issued
24 on behalf of this grand jury?
25 A Yes, we did.
EFTA00179402
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1 Q What happened?
2 A She refused service of the grand jury subpoena.
3 But she was notified of when her appearance was expected
4 here, and a subpoena was left with her.
5 Q After that, did she obtain an attorney?
6 A Yes, she did.
7 Q Who was that?
8 A Jim Eisenberg. He's a well-known defense
9 attorney here in West Palm Beach.
10 Q Who paid for that attorney?
11 A Mr. Epstein is paying for attorney.
12 Q Now once secured the attorney, did
13 she agree to be interviewed?
14 A Yes, she did, after she was granted 6001
15 immunity. She requested immunity.
16 Q Did the justice department authorize that grant
17 of immunity?
18 A Yes, they did.
19 Q After that, did she agree to be interviewed?
20 A Yeah. It was only after she was given that
21 immunity that she would talk with us.
22 Q When did the interview take place?
23 A It took place at the end of April of this year,
24 so just a few weeks ago.
25 Q Who was present at that interview?
EFTA00179403
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A Myself; my partner, agent ; the AUSA,
2 her attorney, Jim Eisenberg, and his
3 investigator; as well as
4 Q What did tell you about Jeffrey
5 Epstein?
6 A She stated that she had met an individual by the
7 name of at a party who had asked her if she II
8 wanted to make a -few bucks by giving a man a massage. She
9 was told that Mr. Epstein preferred them to be topless, 1
10 and she agreed to go to his house to give him a massage.
11 Q How old did tell you she was at that
12 time?
13 A She stated she was 16 when she first started
14 giving Mr. Epstein massages.
15 Q Based upon your review of the evidence, is that
16 correct?
17 A No. We have phone records where
18 (phonetic), Mr. Epstein's assistant, is contacting
19 on her cell phone, or using her cell phone to call
20 cell phone starting in April of 2004, which makes
21 15.
22 Q So she said that she was 16, but your evidence
23 shows that she was 15, and she said that she was told she
24 could make a few bucks giving a topless massage?
25 A Yes.
EFTA00179404
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1 Q What else did tell you?
2 A That she went to Mr. Epstein's residence, that
3 took her there the first time, that when she went
4 upstairs she was paid $200 when she first got there by
5 Then she goes upstairs, and Mr. Epstein
6 comes in, he disrobes, puts on a towel, lays down on the
7 F
massage table and she begins to massage him.
8 She tells Epstein that she heard he likes
9 topless massages, and he told her that he did. And she
10 said, "Who wouldn't?" And she ended up taking off her top
11 during the first massage. But is clear that Mr.
12 Epstein did not at any point touch her during the massage.
13 Q But does she admit that he touched himself?
14 A Yes. On the second massage, Mr. Epstein asked
15 her to leave her phone number with . Her phone number
16 was left there. On the second massage, she returned the
17 very next day and gave him another massage. This time,
18 Mr. Epstein masturbated in front of her.
19 Q Did admit that he masturbated on
20 more than one occasion in her presence?
21 A Yes, masturbated. And I think her term was that
22 he "released," meaning that he ejaculated.
23 Q How long of a period of time did
24 tell you that she performed massages?
25 A She wasn't able to give us a number of massages,
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1 but just said that it was a lot, and that she had been
giving him massages for a year.
Q You mentioned to the grand jury that
4 said that Mr. Epstein never touched her, correct?
A Yes.
6 Q And she was very adamant about that?
7 A Yes, she was.
8 Q Were there other things that she was adamant
9 about in her interview with you?
10 A Well, she talked about what she would tell the
11 girls that -- and that she told Mr. Epstein that she was
12 18. I'm sorry, I take that back. She was told to say
13 that she was 18, and she told us that she had a fake I.D.
14 showing that she was 18.
15 So she passed that information along to the
16 other girls when she brought -- eventually she brought
17 other girls to perform massages, and that was one of the
18 things that she told -- she told us first that she. brought
19 18- to 20-year old girls. And then she stated that if the
20 girls lied, and they were underage, she told them that
21 they needed to tell Epstein that they were 18.
22 Q Have you been able to identify some of the girls
23 that brought to Mr. Epstein's home?
24 A Yes.
25 Q Were any of those girls over 18?
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1 A No, not that we found so far.
2 Q Have any of the girls told investigators about
3 what Mr. Epstein knew about their ages?
4 A I'm sorry, say that again.
5 Q Have any of the girls who came through
6 been interviewed about what Mr. Epstein knew about
7 their ages?
8 A We did interview them regarding that, and I'm
9 not sure if he asked them. They were all told to say they
10 were 18, but not on every occasion would Mr. Epstein
11 inquire about their age.
12 Q Do you want to check your records on that?
13 A Yes, could I do that?
14 Q Yes, please do.
15 A I can tell you that one of the girls that she
16 brought -- this girl told Mr. Epstein that she was in high
17 school, and actually told him her true age, which was
18 under 18.
19 Q So what told you about, that wasn't
20 really the case?
21 A No, that wasn't. Sorry.
22 Q That's all right, I just wanted to make sure
23 it's clear.
24 So told you that she had been told
25 to say she was 18, and she also told you that she had a
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1 fake I.D.?
2 A Yes.
3 Q Did she ever say that Mr. Epstein either asked
4 for her age or asked to see her I.D.?
5 A No, the topic never came up.
6 Q Did you also ask her about how appointments were
7 made?
8 A Yes. She was very clear in the fact that
9 would call her to arrange the appointments, but
10 that would call her once Jeffrey was in town.
11 Q So she was adamant that the calls only happened
12 when she was already here?
13 A Yes.
14 Q Were you made aware that Epstein's counsel was
15 informed that he was being investigated for traveling to
16 engage in prostitution, which means that the appointments
17 would have been made before the traveling?
18 A Yes.
19 Was there anything else, besides the issue of
20 age and the issue of when the appointments were made, that
21 sounded coached or that she was especially adamant about?
22 A No, I wouldn't say coached. I mean, we talked
23 about the preferences that Jeffrey discussed, as far as
24 which girls he would like to bring.
25 Once started giving massages to Epstein,
EFTA00179408
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1 told us that he liked different faces, so he would
2 ask her to bring other girls. We asked her if he ever
3 gave any preferences of what he preferred, and her
4 response was that Epstein liked girls like her, which is
5 thin and blond and attractive.
6 • And how old was she at the time?
7 A She was 15.
8 • So thin, blonde, attractive and --
9 A Young, girls like her. I guess we asked if she
10 ever made a mistake, or ever brought somebody that Mr.
11 Epstein didn't take to. She said that she had screwed up
12 and that she had brought a black girl to Mr. Epstein, and
13 that Epstein was not interested in black girls. But he
14 did pay her, and said that he wasn't a racist. He paid
15 her the $200 for her time, but did not want her to perform
16 a massage for him.
17 Q And he didn't allow that girl to perform a
18 massage?
19 A No.
20 Q Was there anything else that talked
21 about in the interview that you want to share with the
22 grand jury?
23 A I did ask her at the end of the interview if she
24 was in love with Mr. Epstein. She looked into the camera
25 and said that she loved him like a friend. But then she
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1 kind of looked into the camera and gave a wink and a smile
2 and said, "But with your money, I'd marry you any time,
3 Jeffrey."
4 Q Did she also say that she considered him to be
5 an "awesome guy"?
6 A Several times she referred to him as an "awesome
7 guy". She said that the girls begged her to come and that
8 the girls didn't have a complaint, and the girls would
9 share with her everything that happened after the massage,
10 and that Jeffrey never touched any of the girls. But as I
11 informed you, we did interview some of the girls that she
12 took, and he has touched them.
13 Q In preparation for your testimony today, did you
14 also speak with someone who is considered to be an expert
15 in these cases?
16 A Yes.
17 Q And what is that person's name?
18 A Ken Lanning.
19 Q Has Mr. Lanning been qualified to testify as an
20 expert in federal and state courts in cases that involve
21 what he calls "compliant victims"?
22 A Yes.
23 Q What does he mean by the term "compliant
24 victims"?
25 A A compliant victim is when a victim is not
EFTA00179410
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1 necessarily forced into the conduct that the offender
2 wants them to engage into, that they actually consent to
3 that kind of activity.
4 Q So that would include minors who are subjected
5 to sexual activity but weren't necessarily kidnapped or
6 forced at gunpoint, or something like that?
7 A Exactly.
8 Q Did he discuss with you the difficulties that
9 exist when you interview those types of victims?
10 A Yes. He stated that a compliant victim is often
11 times embarrassed that they went along with the behavior.
12 They are also likely to deny the behavior, especially when
13 being interviewed by investigators, that they'll deny it
14 or they'll minimize it. Sometimes it takes two, three or
15 multiple interviews to get compliant victims to either
16 trust their interviewer or realize that their interviewer
17 is not going to be judgemental.
18 Q In this case, have you found that to be the case
19 with some of the interviews?
20 A Yes, I have.
21 Q In addition to being embarrassed, sometimes
22 these victims feel guilty about the fact that they were
23 involved in this type of activity?
24 A Oh, yes.
25 Q Does Mr. Lanning also have expertise in sexual
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1 preference of offenders?
2 A Yes, he does.
3 Q Did he explain why an offender would select the
4 types of victims that are involved in this case, girls
5 between 14 and 17-years-old?
6 A This type of offender, the sexual preference he
7 has is for post-pubescent females that are physically
8 developed but not necessarily mentally matured. The girls
9 ranging in this age are sometimes inexperienced, they are
10 possibly naive, not as worldly.
11 An offender of this type could also maybe not
12 feel sexually adequate or feel competent dealing with his
13 own age group. So knowing that these girls are less
14 experienced, may focus on them as well.
15 Q In addition to their emotional immaturity, did
16 Mr. Lanning talk about whether or not younger girls are
17 easier to manipulate than grown women?
18 A Yes.
19 • Did he talk to you about "grooming"?
20 A Yeah. That's what an offender will use with a
21 compliant victim. He told us that grooming is a technique
22 where you gain the cooperation of those victims by
23 focusing on their interests and playing up to those
24 interests. It's a type of seduction, he called it. That
25 was his words for it. And we actually see this in this
EFTA00179412
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1 case.
2 Q Can you give us an example of some of the types
3 of grooming that Mr. Epstein used?
4 A With one of the girls we're going to talk about
5 today, ., it's very apparent interviewing her how
6 Epstein groomed her. She only went to three or four
7 massages at this time, that she's admitted to. We feel
8 that due to her phone conversations, the multiple calls,
9 that there may be more there. At this point she has
10 stated to us that she has performed three or four massages
11 for Mr. Epstein.
12 What he did is when she first went there he
13 played upon -- she was very shy, and he would play upon
14 that shyness. He told her that she was pretty. He asked
15 her to remove her clothing, and she would not. So he kind
16 of kidded around with her shyness and complimented her,
17 showed interest in her, talked about her boyfriend and
18 different interests she had.
19 At the end of that interview, because she did
20 not take off her clothes, he tells her that if she's
21 willing to do more, she will make more. He also tells her
22 that he would pay her if she would bring other girls. As
23 the massages increased, you can see that the next time she
24 comes he plays again to that shyness, but he gets a little
25 bit more -- I guess he sees that it's not working. This
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1 time she does comply and takes off her -- he asked her to
2 disrobe on the second massage. She takes off her blouse,
3 but she refuses to take off the bra after Mr. Epstein
4 asked her to.
5 So you can see that he tries through showing
6 interest. And then he actually -- when he sees that this
7 isn't working, he takes a more authoritative role with her
8 in the last massage. She said that throughout all of
9 these massages he was very nice, and then at the end he
10 was much more frustrated and irritated. She does get down
11 to her bra and panties on that one, he's just much
12 more authoritative.
13 So he started with the grooming process, tried
14 to get her interest, tried to use that to get her to
15 comply with removing her clothes. But as often happens,
16 at the end of this, he took over and was much more
17 forceful with his requests.
18 Have other girls described that same situation
19 where every time they went back, he tried to push it one
20 step further and one step further?
21 A Yes. Several of the girls have said that he
22 would always push for more and more.
23 Q Did Mr. Lanning explain why it is that a
24 compliant child victim cannot legally consent to the
25 sexual conduct?
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1 A Yeah. He stated that -- you know, we talked
2 about how the law protects children, and stated that we
3 hold adults accountable. When it comes to adolescents,
4 they go through normal tendencies that mature offenders
S may try to take advantage of. But the law is in place for
that reason, to protect -- in the federal law, to protect
7 those individuals under the age of 18.
8 Q And that's because of the different maturity
9 levels of the --
10 A The offender versus the victims, exactly.
11 Q Did you put together the photographs of the
12 defendants in this case?
13 A Yes, i did.
14 Q Are these photographs of the four human
15 defendants who are named in the proposed indictment?
16 A Yes.
17 Q With their names underneath them?
1
18 A Yes.
19 Q Agent, who is in the top left-hand corner?
20 A That's Jeffrey Epstein.
21 Q When was this photograph taken?
22 A Recently. There was an article that just came
23 out regarding Mr. Epstein and his connection, or his
24 personal relationship with Prince Andrew, and that was a
25 picture that was in that article.
EFTA00179415
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0 Who is in the top right-hand corner?
A That's
Q Again, this is a relatively recent photograph?
4 A Yes, that's his personal assistant.
5 Q And the bottom left-hand corner?
6 A Again, that is one of Mr. Epstein's personal
7 assistants, that's (phonetic).
8 Q Has Miss since gotten married?
9 A Yes, her name now is
10 Q And the bottom right-hand corner?
11 A That is She is, again, a
12 personal assistant to Mr. Epstein. There has been some
13 talk that she is also romantically -- or I should say
14 sexually involved with Mr. Epstein.
15 Q How old are the defendants?
16 A Jeffrey is in his mid-fifties, and the three
17 girls are in their early twenties.
18 Q Do you have a copy of the draft indictment in
19 front of you?
20 A Yes, I do.
21 Q You mentioned when we were looking at the
22 photographs that the three females work as personal
23 assistants for Mr. Epstein, is that correct?
24 A Yes.
25 Q So he is their employer?
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1 A Yes.
2 Q Are you familiar with the property located at
3 358 El Brillo Way in Palm Beach?
4 A That's Mr. Epstein residence.
5 Q And he owns that residence?
6 A Yes, he does.
7 Q Are you familiar with Defendant J.E.G.E., Inc.?
8 A Yes. J.E.G.E., Inc. is owned by Jeffrey
9 Epstein. He is the president, the owner, the sole
10 director. It's a business that is solely used for the
11 activities of one of Mr. Epstein's airplanes, which is his
12 Boeing 727. Its tail number is N908JE.
13 Q And you mentioned that he is the president and
14 the sole director. Is he also the sole shareholder?
15 A Yes, he is.
16 Q Are you familiar with Hyperion Air, Inc.?
17 A Yes. Hyperion Air, Inc. is also a business
18 owned by Mr. Epstein. He is also the president, the
19 director and the sole shareholder of that company as well.
20 That company solely does business with his other aircraft,
21 which is a Gulf Stream G-1159B. It bears a tail number
22 N909JE.
23 Q Is that a smaller aircraft than the Boeing?
24 A Yes.
25 • Just to briefly remind the grand jury about
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1 where the evidence has been collected in this case, was
2 the start of your investigation information that you
3 received from the Palm Beach Police Department?
4 A Yes, it was.
5 Q And that included evidence seized during a
6 search of Mr. Epstein's home at El Brillo way?
7 A Yes.
8 Q Also controlled calls that the Palm Beach Police
9 Department placed?
10 A Yes.
11 Q And interviews of girls and other people by the
12 Palm Beach Police Department?
13 A Yes, as well as trash pulls that the Palm Beach
14 Police Department conducted on Mr. Epstein's residence.
15 Q Then when the FBI became involved, the FBI did
16 additional interviews of girls and of recruiters?
17 A Yes.
18 Q They obtained phone records?
19 A Yes, we have.
20 Q And records of payments?
21 A Yes.
22 Q Did this grand jury also subpoena travel
23 records?
24 A Yes.
25 Q Including the flight manifests of the planes
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1 owned by Hyperion and J.E.G.E.?
2 A Yes.
3 Q Did you also get corporate documents related to
4 those two planes?
5 A Yes, we have.
6 Q Once you had obtained all of this information,
7 did the FBI analyze the data, specifically the call
8 information and the flight information to put together a
9 pattern of activity by the defendants?
10 A Yes, we did.
11 Q So you have a series of phone calls coming from
12 these three assistants who were on the board, the two
13 girls who have been identified through this investigation?
14 A Yes.
15 Q When you spoke with those girls, did any of them
16 tell you that they had developed some sort of a personal
17 relationship with the assistants so that they were just
18 chatting over the telephone?
19 A No, not at all.
20 Q All of them said what about the phone calls?
21 A Said that the phone calls were made to set up
22 appointments for Mr. Epstein.
23 Q And the girls referred to it as appointments to
24 work, is that right?
25 A Yes, they were appointments to work. There is
EFTA00179419
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1 one exception, We're going to talk about her
2 probably next week. She did say on one or two occasions
3 that had called her when she had gone out
4 to California on a trip, I believe. But that is the only
5 time that that was ever mentioned. In fact, we asked, and
6 those phone calls were made for the purpose of setting up
7 appointments for Mr. Epstein.
8 Q Is the investigation continuing?
9 A Yes, it is.
10 Q Are you still trying to locate and interview
11 more girls?
12 A Yes.
13 Q Let's turn to the specific evidence reporting
14 the overt acts and offenses relating to Jane Doe's 1
15 through 5. I know that every member of the grand jury has
16 a copy of the draft indictment before them, and also a
17 chart.
18 Do you have a copy of that chart as well?
19 A I do.
20 Q Do you have photographs of the five girls that
21 we are going to talk about today?
22 A Yes.
23 Q And these are photographs of the people that we
24 are calling Jane Doe's 1 through 5?
25 A Yes.
EFTA00179420
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1 Q And Jane Doe Number 1, you have previously
2 testified about her?
3 A Yes, I have, that's
4 Q Jane Doe Number 2?
5 A That is
6 Q Jane Doe Number 3?
7 A That is
8 Q Jane Doe Number 4?
9 A
10 Q And Jane Doe Number 5?
11 A That is
12 JUROR: The purpose of Epstein's business with
13 his planes, did he transport?
14 THE WITNESS: To travel around.
15 JUROR: So it wasn't like a business of
16 transporting other people?
17 THE WITNESS: He flew other guests, sometimes
18 unaccompanied, sometimes accompanied.
19 JUROR: and , do you have
20 any evidence that they started young, like the rest
21 of the recruits?
22 THE WITNESS: we have evidence that they are his
23 personal assistants employed by him, not that it was
24 anything like what we were discussing.
25 JUROR: There was an allegation that was made
EFTA00179421
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1 earlier, back in February, during one of these
2 discussions, about a specific act that was performed.
3 Can I ask about that? We were told back in February
4 that one of the girls when interviewed had alleged
5 rape, and I hadn't heard about that allegation
6 recently.
7 THE WITNESS: That's probably Jane Doe Number 6.
8 We're going to talk about her, that he forcibly put
9 her on the table and penetrated her. Yeah, she will
10 be coming up. We're going to do her probably next
11 week. She'll be the first one we'll talk about.
12 BY
13 Q So turning to Jane Doe Number 1, I. You
14 testified about her earlier before this grand jury,
15 correct?
16 A Yes, I did.
17 Q And she also testified before this grand jury,
18 correct?
19 A Yes.
20 Can you remind us of her date of birth?
21 A She was born on , 1986.
22 Could you briefly refresh the grand jury's
23 recollection of how she was recruited?
24 A She was approached on a beach by and
25 Tony Figurello (phonetic). They approached her on a beach
EFTA00179422
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1 and asked her if she wanted to perform massages for
2 Mr. Epstein and make some money.
3 Q From the review of the phone records that you
4 have received, were you able to identify a telephone
5 number associated with Tony Figurello?
6 A Yes.
7 Q In fact, has Tony Figurello been interviewed?
8 A Yes, he has.
9 Q And has he admitted to being a recruiter for Mr.
10 Epstein?
11 A Yes, recruiter and driver.
12 Q If you could take a look at Overt Act Number 2,
13 which appears on page five. That states, "On or about
14 March 12, 2004, defendants Jeffrey Epstein and
15 caused Jane Doe Number 1 to travel to 358 Brillo Way of
16 Palm Beach, Florida."
17 Can you tell us what evidence you have regarding
18 that?
19 A We have reviewed phone records for and
20 that indicate the calls took place, as well as phone
21 records for Tony Figurello and and calls that took
22 place on or about those dates. We've also looked at a
23 flight manifest, and were able to show that Mr. Epstein
24 arrived the day before, on the 11th. We also have
25 statement where she describes the sexual activity that
EFTA00179423
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1 took place.
2 Q On that date, March 12 of 2004, described
3 going to Mr. Epstein's house and performing a sexual
4 massage?
5 A Yes, on or about that day.
6 Q On or about that date, what did state
7 about being paid?
8 A She was paid $200.
9 Q And that relates to Overt Act Number 3?
10 A Yes.
11 • And she stated that Mr. Epstein is the person
12 who gave her that?
13 A She told us that in her statement.
14 Q If you could take a look at Overt Act Number 95,
15 which is on page 17. On or about February 6, 2005,
16 Epstein had Jane Doe Number 1 to make one or more
17 telephone calls to Jane Doe Number 2.
18 First of all, who is Jane Doe Number 2?
19 A That would be ., our youngest victim.
20 Q Can you tell us what evidence you have related
21 to that overt act?
22 A we have the girl's statements that calls were
23 made. We also reviewed the phone records that indicated
24 that there was telephonic contact between the numbers
25 belonging to and
EFTA00179424
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1 Q And in the statement of both girls, did they
2 describe that is the person who called
3 looking for someone to come and work at Mr. Epstein's
4 house?
5 A Yes.
6 Q Looking at Overt Act Number 96. On or about
7 February 6, 2005, Epstein caused Jane Doe Number 1 to
8 transport Jane Doe Number 2 to 358 El Brillo Way.
9 What is the evidence related to that?
10 A Again, the statements of and support
11 that as further evidence, and also reviewing the phone
12 records they indicate that there was telephonic contact
13 between and and and
14 Q Overt Act Number 97, on or about February 6,
15 2005, Epstein made a payment of $300 to Jane Doe Number 2
16 and a payment of $200 to Jane Doe Number 1.
17 What was the evidence of that?
18 A Both and stated in their statements
19 that was paid $300, and was paid $200 for
20 bringing
21 Q Did explain why she was paid $300?
22 A Yes, she was paid $300 because she performed her
23 massage. Mr. Epstein digitally penetrated and used a
24 massager on vagina.
25 Q After this date, after February 6, 2005, was
EFTA00179425
Page 28
1 $300 found in .'s purse when it was searched at her
2 school?
3 A Yes, it was, by a school administrator.
4 Q If you could look at Overt Act Number 117, which
5 is on page 19, and that states that on or about March 30,
6 2005, caused one or more calls to be made to a
7 telephone used by Jane Doe Number 1.
8 What evidence do you have related to that?
9 A We reviewed the phone records of and
10 that indicate this.
11 Q And Overt Act 120, on or about March 31,
12 caused one or more calls to be made to a telephone used by
13 Jane Doe Number 1.
14 A Again, we reviewed the phone records that
15 indicated there was telephonic contact between the numbers
16 belonging to and
17 Q Then we have Overt Act Number 122, which is also
18 March 31, that Epstein and caused Jane Doe Number 1
19 to make a call to a telephone used by Jane Doe Number 2.
20 What evidence do you have related to that?
21 A We have phone records that we have reviewed
22 belonging to and . In this case, we also have a
23 voice mail that was provided to us by the Palm Beach
24 Police Department, a voice mail of leaving a voice
25 mail message on phone.
EFTA00179426
Page 29
1 Q And Overt Act Number 123 refers to April 1st.
2 What evidence do you have related to that?
3 A We have reviewed the phone records of and
4 that indicate telephonic contact was made on this
5 day. We also again have another recorded voice mail by
6 , left on phone.
7 Q These later calls, the March-April calls, are
8 those the controlled calls that the Palm Beach Police
9 Department was involved in?
10 A There was controlled calls placed to
11 cell phone and to place of work by , under the
12 supervision of the Palm Beach Police Department.
13 Q And the voice mail message that you referred to
14 of calling , what information was leaving
15 in that voice mail message?
16 A was asking for to get back in touch,
17 that she had set up an appointment for at Epstein's
18 house on the following day, on that Saturday at around
19 10:30 or 11:00.
20 Q In addition to the phone records, was there
21 anything that the Palm Beach Police Department found that
22 also confirmed that this appointment actually was made.
23 A As I mentioned earlier, the Palm Beach Police
24 Department was doing trash pulls on Mr. Epstein's
25 residence. In there, there were two messages or notes in
EFTA00179427
Page 30
there on Epstein's personalized stationary. On it it
said, " with on Saturday at 10:30, and on
Saturday with at 10:30." That's the exact message on
4 the two notes that were found in his trash when they
5 retrieved it on April 8.
6 Q If I could direct your attention to Count Number
7 Five, which appears on page 26. That is the charge of
8 enticement of a minor, referring to Jane Doe Number 1, and
9 Mr. Epstein and Miss are charged.
10 I know that you talked about the telephone
11 traffic. The calls between and Tony Figurello, did
12 they fall within that March 7 through March 11 time
13 period?
14 A A review of their telephone records do indicate
15 that there were phone calls made during that time.
16 Q And Jane Doe Number 1 actually went to Mr.
17 Epstein's home?
18 A Yes, and performed a massage for him in the
19 nude.
20 Q And she was paid for that?
21 A Yes, she was paid $200.
22 Q And he masturbated in front of her, correct?
23 A Yes, he did. I would like to include that
24 took upstairs for that massage, and she also
25 set up the massage table and arranged the oil and lotions
EFTA00179428
Page 31
1 for to do that massage.
2 Q And also, just so it's clear, how old was
3 at that time?
4 A She was 17.
5 : Are there any questions about
6 either how that evidence was presented or about the
7 charges related to Jane Doe Number 1? Seeing no
8 questions, we'll turn to Jane Doe Number 2.
9 BY
10 Q You previously mentioned that that was 9
11 A Yes.
12 Q Let's turn to Count Number Six, which is on page
13 26, which is the enticement of . If you could tell
14 the grand jury about the evidence related to that.
15 A date of birth is-, 1990.
16 Q So during this period of February 5, 2005 to the
17 6th, how old was she?
18 A She was 14.
19 Q Can you remind the grand jury about the evidence
20 related to the enticement of
21 A As we stated earlier, we talked about the
22 telephone calls. We have shown that the facility of
23 interstate commerce was used by the telephone calls made
24 by their cell phones. We examined specifically
25 and . Those calls were made to
el
EFTA00179429
Page 32
1 set up and arrange appointments for Mr. Epstein to have
2 his massages.
3 Pertaining to during the massage that
4 occurred on those dates, February 6, in particular, I
5 think I have discussed with you before what occurred on
6 that, that he fingered -- and that was his term for
7 it -- and that he used a massager on her.
8 He did masturbate during that massage, and she
9 believed he ejaculated because he wiped off his penis with
10 a towel. She was paid $300, and we know that she was 14
11 at the time.
12 Q If we could turn to Count Number 43, which
13 appears on page 31. Count 43 is one of the travel counts.
14 If you could tell the grand jury, did a trip occur on
15 March 31, 2005?
16 A Yes, we have flight records that indicate a
17 flight occurred on that date.
18 Q What type of plane was used?
19 A I'm going to refer to the J.E.G.E., Incorporated
20 aircraft as just the Boeing 727. If we talk about the
21 Hyperion Air, Incorporated aircraft, which is the Gulf
22 Stream, I will just say the Gulf Stream. So on that date
23 he did travel on his Boeing 727, on 3-31.
24 Q And Mr. Epstein was aboard the plane on that
25 day?
EFTA00179430
Page 33
1 A Yes, he was.
2 Q With respect to the March 31st trip, was there
3 evidence of him setting up the appointment with prior
4 to that trip?
5 A We do have telephonic contact between and
6 , as well as and on the day before
7 and the day of travel.
8 Q And even though that appointment was never kept,
9 that never went to that appointment, you have the
10 notes that were retrieved from the garbage that showed
11 that Mr. Epstein was expecting to show up for that
12 appointment?
13 A Yes.
14 Q Anything else with respect to that particular
15 count?
16 A We also have the controlled calls and the voice
17 mails.
18 Q Turning to Count Number 60, which appears on
19 page 34, that is the attempted enticement of
20 during the period of March 30 to April 1.
21 Again, at that point, . was how old?
22 A She was 14.
23 Q And we had talked about the telephone calls that
24 were used. One of the things that is relevant to this
25 particular count was that in addition to the fact that
EFTA00179431
Page 34
1 . was 14, did you interview a girl who went with
2 when she went to Mr. Epstein's house back in
3 February?
4 A Yes, we did, that would be
5 Q And Serena was interviewed?
6 A Yes, she was interviewed by the Palm Beach
7 Police Department.
8 Q What did . say about appearance?
9 A That she was the youngest looking girl that
10 came.
11 Q When you talked with , did talk about
12 girls that Mr. Epstein liked in particular?
13 A Yes.
14 Q And was . one of those girls?
15 A Yes, she was one of his preferences. also
16 told us that Mr. Epstein said to her on one occasion, "The
17 younger, the better."
18 Q And there was never any attempt to get
19 I.D. or to confirm her actual age?
zo A No.
21 Q As we discussed before, never actually went
22 to that point, right, so that is just an attempt?
23 A Yes.
24 : Are there any questions from the
25 grand jury? Seeing no questions, we'll see you next
EFTA00179432
Page 35
1 week. Thank you.
2 (Witness excused.)
3
4
5
6
7
8 CERTIFICATE OF REPORTER
9
10 I CERTIFY pages 1 to 35 is a true transcript of
11 my shorthand notes of the testimony of
12 before the Federal Grand Jury, West Palm
13 Beach, Florida, on the 8th day of May, 2007.
14 Dated at West Palm Beach, Florida this 23rd day
15 of May, 2007.
16
17
18
19
20 Philip W. May, Court Reporter
21
22
23
24
25
EFTA00179433
DataSet-10
Unknown
6 pages
500-NY-3027571 Serial 640
FD.302 (Rev 54-10) -: of E-
FEDERALBUREAU(WINVEBUGKUON
Cute oremry 09/17/2021
, date of birth (DOB) , was interviewed
pursuant to a proffer agreement at SDNY 1 Saint An rews Plaza New York NY.
Present for the interview was attorney along
with AUSA AUSA and Detective . After
being advised of the identity of the interviewing Agents and the nature of
the interview, provided the following information:
*** is shown the "black book" (72-mm-113327-1k9)***
states that she recognizes this. She previously described this as
MAXWELL's contact book. recognizes the color and the size and the
format. The other contact books were bigger and a pastel color. All of
MAXWELL's books were smaller. recognizes the black color and the
smaller font. EPSTEIN's font was bigger.
has seen this book previously. This is one of MAXWELL's books,
there were a few of them. The smaller font is familiar. has opened
it before but may not have used the numbers out of it. may have
been told by someone that this is MAXWELL's book but not sure. was
tasked with updating EPSTEIN's book which was bigger. may have
told about EPSTEIN's book. is not sure if she has ever seen
MAXWELL with this book or if she just talked about it.
There was a confidentiality notice with EPTEIN's book because of the names
in them. does not recall using this book to call and make massage
appointments. The specific contacts in the book don't stand out. This book
was seen in the small office behind the kitchen referred to as MAXWELL's
office. This is where recalls seeing it.
Names that stand out in this book are CAROLE RADZIWILL and JEAN LUC BRUNEL.
She recalls that RADZIWILL came to MAXWELL's home in New York and she
Inwstigation on 08/20/2021 m New York, New York, United States (In Person)
Filed SOD-NY-3027571 Ihtedraled 09/16/2021
by
This document contains neither recommendations nor conclusions of the FBI It is the progerty or** FM and is loaned to yam agency: it and as contents arc not
lobe distributed outside your agency
3524-016
Page I of6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009529
EFTA00159388
FIT.302a(Rev 54.10) 50D-NY-3027571 Serial 640
50D-NY-3027571
ContinualionofFD-302 of (U) Interview of on 08/20/2021 par 2 of 6
published a book. Her and EPSTEIN discussed the book. does not
recall seeing her with ESTEIN.
Both MAXWELL and EPSTEIN knew BRUNEL. He is very close to EPSTEIN and he
had an apartment in EPSTEIN's New York apartment building.
recalls seeing this book in other houses, perhaps in the New Mexico
house. recalls gathering EPSTEIN's books from the Virgin Island but
does not recall gathering MAXWELL's.
*** is shown the message pads with sticky note book $4 (31E-mm-
108062 182-36)***
states the sticky note on page 5 could be her handwriting but not
sure. Upon further inspection states, she does not think these
notes are hers.
recognizes these books and the carbon copies and the messages.
would leave messages for EPSTEIN in the pantry in the kitchen.
recalls seeing more than one of these pads. Some were kept in a
drawer.
EPSTEIN went by "JE" on the pads and the staff would refer to him in the
book as "Mr Epstein". Some of the staff taking messages was
and the house manager ALFREDO RODRIGUEZ. sees a lot of "AR" in the
book. RODRIGUEZ was later fired.
would not recognize other staff members hand writing but she
understands how they would sign ("Mr Epstein").
recognizes the name came for massages and brought
other girls for massage. She was pregnant at one point when she came over.
recognizes JEAN LUC BRUNEL.
recognizes MOSCOVITZ to be EPSTEIN's doctor in Palm Beach.
recognizes DARREN to be EPSTEIN's lawyer.
would still have an obligation to schedule massages even when she
wasn't at the house. refers to the 2" to last page where there is a
message left for
3524-016
Page 2 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009530
EFTA00159389
FD402a (Rev 54.10) 50D-NY-3027571 Serial 640
50D-NY-3027571
ContimmionaMMI2of (U) Interview of 0, 08/20/2021 " se 3 of 6
*** is shown the message pads with sticky note book 61 (31E-mm-
108062 1B1-2AC)***
recognizes that the book is in November and states that EPSTEIN
would have been there around that time.
recognizes HARVEY WEINSTEIN's name in the book and states it
triggered her ( cries). EPSTEIN encouraged a victim of WEINSTEIN's
to talk to an attorney but it turned out that the attorney was an attorney
for WEINSTEIN. EPSTEIN would bring these pretty model girls around these
business men to further his business.
states that some of the handwriting in this book looks like hers but
she is not sure.
states that the last page looks like her handwriting, all of the
notes on this page. She recognizes the way she writes her "P", "N" and "7".
*** is shown the message pads with sticky note book $3 (31E-mm-
108062 1B1-2AC)***
recognizes MANUELA and states he worked in EPSTEIN's New York
office.
recognizes GLEN DUBIN and states he is the husband of EVA ANDERSON
(the former girlfriend of EPSTEIN).
recognizes DR HENRY GERETCKI. states he owns an island in
the British Virgin Islands and visited this island with EPSTEIN and
JEAN LUC BRUNEL.
recognizes her handwriting on a message on 1/7/05. She recognizes
the number "7" and that its singed by stating "that's me".
recognizes the message on 1/8/05 signed IIII stating "that's me...this
entire page is from me" down to 1/9/05.
recognizes the next page to be her handwriting starting with the
message on 1/9/05 from states the rest of the notes after
are also her handwriting. States had a sister.
the next page to be her handwriting starting with the message on
3524-016
Page 3 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_0000953 I
EFTA00159390
FD402a (Rev 54.10) 50D-NY-3027571 Serial 640
50D-NY-3027571
ContinuaiwnofFD-302of (U) Interview of on 08/20/2021 pug
, 4 of 6
1/9/05 from states all notes on this page are her
handwriting.
states all of the messages on the next page are her handwriting
starting at 1/10/05 from JEAN LUC BRUNEL.
states all of the message on the next page starting at 1/10/05 from
JEAN LUC BRUNEL are her handwriting.
states the next page the second message on 1/11/05 from MAXWELL that
took that messages. states the next 2 messages on that page
are from her as well.
states the first 2 messages on the next page were taken by her
starting at 1/20/05 from MAXWELL.
states the next page starting at 1/24/05 the top 2 messages were
taken by her.
states the next page all of the messages were taken by her. The
date on the second message is 1/24/05.
states on the next page that messages 1,2 and 4 are her
handwriting. She states message i3 is likely her handwriting as well.
states the next page starting at 1/26/05 that all of these messages
were taken by her.
states the next and last page of this book are all messages taken by
her. This page starts at 1/26/05.
*** is shown the black binder marked "Book 10" (50D-NY-3027571-
1B19)***
is shown the black binder marked "Book 10" and asked to just look at
the outside of it. states that this is one of the binders that was
at MAXWELL's house with different pictures inside of them. The photos are
of travel with EPSTEIN or photos of naked girls or women or in their
underwear. They were categorized. These books were made at
request thinks. does not recall the color or the stickers
on the outside but she remembers the plastic sleeves with CD's and
3524-016
Page 4 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009532
EFTA00159391
FD.302a (Rev 5440) 50D-NY-3027571 Serial 640
50D—NY-3027571
Comilimmio„frp.Miof (U) Interview of On 08/20/2021 p,s, 5 of 6
thumbnails of the pictures. She does not recall how the outside was labeled
with stickers or not. On the spine of the binder she recognizes stickers
marked ZORO (EPSTEIN's ranch, could be photos from his trip),
) and
*** is shown two black binders marked "Book 11" 6 "Book 18" (SOD-
NY-3027571-1219)***
is shown the black binders marked "Book 11" 5 "Book 18" and asked to
just look at the outside of them. states these are large office
binders with plastic sleeves. On the spine of the binder she recognizes
stickers marked PB GIRLS (Palm Beach), 727 (one of his planes), IIII
III and (could be but she is
not sure).
recognizes that these binders could have been kept in MAXWELL's
house where she worked. They should have been inside of her office inside
of the house. The office had two rooms in it. The first room had about 3
desks for either-, and MAXWELL. The second room was
smaller and had a large printer/copier inside of it. It was a professional
photo printer. There were also cabinets inside of this room. These binders
would have been store in one of these cabinets. There were multiple shelves
containing binders.
MAXWELL would come into the office and sit at her desk. MAXWELL would print
sometimes to put these photos in EPSTEIN's homes and to document EPSTEIN's
life. would photograph the women in nude poses at EPSTEIN's
request. did it to . EPSTEIN said it was ok and
thought maybe it was for Victoria's Secret.
is asked the difference between the professional masseuses and the
not professional masseuses coming to the houses.
states the professional ones carried themselves different and gave
massages to and others in the house.
The not professional masseuses appeared to be young. In the moment
didn't think of age. Sitting here today thinks they appeared to be
underage because of their style of dressing (jeans and t-shirt), they were
casual, their immature behavior, not professional manor, their physical
3524-016
Page 5 of6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009533
EFTA00159392
FD402a (Rev 54.10) 50D-NY-3027571 Serial 640
50D—NY-3027571
ContimmionaMMI2of (U) Interview of 0, 08/20/2021 p,s, 6 of 6
appearance was that of a teenager. would have to escort them
upstairs. visual observations and feeling that someone is younger
than her. On one occasion asked for a tutor for for her
SAT's. told a story once of her speeding and her parents having to
come pick her up and she couldn't drive anymore after that. saw
lots of girls face to face. thinks they were 16-19, 19 and 20.
was about 21-22 years old and they felt younger than her. Over time
can now analyze that they were underage.
discussed a conversation with EPSTEIN the first time that she met
him at his house for dinner. EPSTEIN asks how old she is and if she
is 18 and he probed it further that she was over 18. was surprised
because she was married.
EPSTEIN presented himself to everyone like he wouldn't cross the line.
had the impression that EPSTEIN didn't want anyone under 19 but he
didn't say that. said once that if someone lied to him about their
age it wouldn't matter because he would still be in trouble.
3524-016
Page6a6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009534
EFTA00159393
DataSet-10
Unknown
2 pages
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 DEPOSITION
THE STATE OF FLORIDA:
TO: Cheri Pierson,
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on October 7, 2009 at 9:00 a.m., at ROTHSTEIN ROSENFELDT ADLER
401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301, .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 September &, 2009.
Bradley J. Edwards
WasOQ--
Rothstein Rosenfeldt Adler For The Court
401 EastLas Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
Florida Bar No.: 542075
EFTA00726190
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
EFTA00726191
DataSet-10
Unknown
11 pages
Memorandum
Subject
Operation Leap Year: Second Addendum to September 13, 2007 I a
Prosecution Memorandum
USAO No. 2006R01181 Pe/e & VO
Z/11/o4
To From
R. Alexander Acosta
United States Attorney AUSA, Northern Region, WPB
First Assistant U.S. Attorney
Deputy Chief, Criminal Division, West Palm Beach
Chief, Criminal Section I, Northern Division, WPB
This memorandum addresses the changes made to the Operation Leap Year indictment
package, which incorporate comments from the last review. Some changes are stylistic and others
are substantive. For strategic reasons, I would like to present the indictment to the grand jury on
Tuesday, September 25, 2007.
The first section of this memorandum discusses the stylistic changes and the second section
discusses the substantive changes, including the new victims who have been added.
[NB: THIS MEMORANDUM WAS AMENDED ON FEBRUARY 19, 2008 TO CORRECT
THE NUMBERING OF THE JANE DOE'S IN ACCORDANCE WITH THE THIRD
ADDENDUM TO THE PROSECUTION MEMORANDUM)
A. Stylistic Changes
The biggest stylistic change appears in the overt acts section of Count 1. In the original
EFTA00234505
indictment, the overt acts were limited primarily to "dry" yet specific events - telephone calls and
airplane flights. The revised version is much more vivid in terms of the sexual acts described, but
it is more vague in terms of date allegations because, with few exceptions, the victims cannot
provide specific dates of when they traveled to Epstein's home. •
I have renumbered the Jane Does so that they are numbered in chronological order based
upon the start of their contact with Epstein or ME
B. Changes to Parties and Charges
At Matt Menchel's request, I removed the corporate defendants, JEGE, Inc., and Hyperion
Air, Inc.
I removed the charge related to the transporting of for criminal sexual
activity (18 U.S.C. § 2421) [former Count 59]. I then revised the "Manner and Means" section of
Count 1 to include the following:
It was further part of the conspiracy that Defendant JEFFREY
EPSTEIN would a minor females to engage in lewd conduct with
Defendant to satisfy Defendant JEFFREY
EPSTEIN'S prurient interests.
I also added overt acts where engaged in sexual activity with one of the victims.
In the introductory section, I listed all of the Florida statutes implicated by Epstein's activity.
Then, for each substantive count of enticement (18 U.S.C. § 2422(b)), I listed the specific criminal
activity that Epstein engaged in with the minor. For those cases where the activity did not fall within
some of Florida's narrow language, I referred simply to enticement to engage in "prostitution" to
invoke the broader federal usage of that term.'
'As explained in the original prosecution memorandum, there is no federal definition of
prostitution, but the Supreme Court has defined the term as "indiscriminate lewdness for hire."
2
EFTA00234506
For the same reason, in Count 1, I list the object of the conspiracy as the enticement of
minors to engage in prostitution.
The agents and I reviewed the evidenced related to former Counts 17 through 50 (Travel to
Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b)). Rather than charge every trip where there
was telephone contact with girls prior to Epstein's travel to Palm Beach, we have selected four trips
where there is substantive evidence that an appointment was made - usually in the form of notes
retrieved in trash pulls or notes from message pads. and I conferred with MI
about these charges. Despite the arguments of Epstcin's counsel, in light of binding
Eleventh Circuit precedent, Drew feels comfortable proceeding on all counts. In consideration of
the desire to charge more conservatively, I have removed the majority of the counts and have limited
these charges to the four trips. Charts showing the telephone and travel activity are attached.
C. New Victims and Charges
ane Doe
Jane Doe # 2 was identified by M. as the person who brought her to Jeffrey Epstein's
house for the first time. JD#2's name also appears on several message pads recovered from JE's
home.
JD#2 was interviewed at her home in West Palm Beach. JD#2 reported that she was brought
to JE's home byllit[Jane Doe #l].2 JD#2 was 14 when she was brought to JE's home in 2001.
JD#1 told JD#2 that she could make $300 for giving a massage to a man in Palm Beach. JD# 1
2 Jane Doe #1 was brought to JE's home by Ghislainc Maxwell after Maxwell met her at
Mar a Lago. Jane Doe #1 was 15 at the time of her first contact with JE and remained in contact
with him until she was approximately 20 when JE sent her to Thailand to live. Jane Doe #1 now
lives in Australia.
3
EFTA00234507
instructed JD#2 to dress sexy and that the man would ask her to take her shirt off but she could keep
her bra on.
JD#I and JD#2 went to Epstein's house and went upstairs together to the bedroom area.
Epstein met them and he was wearing a towel. Epstein told JD#2 that she was pretty and asked how
old she was. JD#2 began saying fourteen, then stopped and said seventeen. Epstein said, "So,
you're really fourteen. Don't worry we won't tell anyone."
JD#2 and JD#1 both started massaging Epstein while he was lying face down. After some
time, Epstein instructed JD#2 to take off her shirt and pants, which she did, remaining only in her
bra and panties. JD#1 completely undressed. JD#2 sat on the couch while Epstein and !Dill
engaged in sexual intercourse directly in front ofJD#2, and looked at JD#2 while they were having
sex. Epstein paid $300 to JD#2 at the end of the session, and ask for her cell phone number. Several
more massages were scheduled via
On JD#2's second visit, she was led upstairs by who placed towels on the massage
table. JD#2 undressed to her underwear. Epstein entered; JD#2 massaged him; and when he turned
onto his back, Epstein began masturbating and fondling JD/42's Epstein again paid her $300.
JD#2 estimates that she went to Epstein's home more than 100 times during the three years
she was involved with him. would call from New York to arrange appointments, which
usually occurred in the evening. JD#2 stated that after some time she began performing the
massages totally nude. On two occasions JD#2 was paid $400 when she pinched Epstein's nipples
while he masturbated. JD#2 stated that Epstein always ejaculated and described his penis as unusual
because his urethra was on the side of the penis instead of at the tip.
On one occasion, Epstein introduced another female into the session. Epstein had sexual
4
EFTA00234508
intercourse with the other female while that other female performed oral sex on JD#2. [NB: We
believe that this was probably but cannot be certain.] JD#2 believes this occurred while
she was still 14. Epstein regularly fondled JD#2's breasts. On two occasions he tried to touch her
vagina and he tried to use a massager on her vagina, but JD#2 refused. After that Epstein reduced
her payments from $300 to $200 per session. JD#2 became so nervous about Epstein's advances that
she started taking Xanax before the sessions.
Because of JD#2's unwillingness to engage in more sexual activity, Epstein asked her to
bring friends who might be interested, especially younger friends. Epstein paid JD#2 $100 for each
friend she brought. JD#2 received gifts from Epstein, including Victoria's Secret bras and panties,
massage oils and Jvlassage for Dummies. [JD#2 still had the book and gave it to the agents.] Epstein
also gave JD#2 two concert tickets and asked her to fly to Paris with him on a business trip.
JD#2 brought her best friendia, who performed several massages. UMW is
the person who actually brought M. to Epstein's house.]
On one occasion when JD#2 was approximately 16, called JD#2 and told her that
Epstein wanted to photograph her. JD#2 went to Epstein's house and took several
nude photos of JD#2 at various places in Epstein's home and by the pool. used a digital
camera and paid JD#2 $500 for posing. also told JD#2 that Epstein takes pictures ofthe girls.
JD#2 noted that Epstein had many laptop computers.
JD#2 stopped going to Epstein's house in June 2003 after she had gotten pregnant and moved
away. JD#2 went back a few times in spring/summer 2004 after the birth of her child, but stopped
going to Epstein's home before her 18th birthday.
We have not yet been able to get JD#2's telephone records and records only go back
5
EFTA00234509
to 2004. There are four messages recovered from message pads, but some refer to JD#2's
"recruiting" work rather than her own sexual activity. Accordingly, until we get JD#2's telephone
records, 1 am unwilling to charge a substantive 2422(b) count related to JD#2 (because of the
difficulty of proving the use of a facility of interstate commerce to induce the prostitution.) There
is sufficient evidence to prove a substantive 1591(a)(1) offense related to JD#2 because of the
evidence of Epstein's travel, which affects interstate commerce, Epstein's knowledge ofJD#2's age,
and the existence of commercial sex acts.
ane Doe #3
Jane Doe #3 was brought to Epstein's home by Jane Doe #2 when JD#3 was 15 years' old.
JD#3 met JD#2 at a party, and JD#2 told JD#3 and that they could make money providing
massages to Epstein. JD#2 and JD#3 went to Epstein's home by taxi. JD#2 took JD#3 upstairs,
Epstein entered wearing only a robe. Epstein removed the robe and lay face down. JD#2 and JD#3
undressed to their underwear. Both started massaging Epstein's back and he asked JD#2 to leave.
Epstein turned over and began masturbating, but he did not touch JD#3. JD#3 told Epstein that she
had just turned 18 (although she was really 15). Epstein paid JD#3 $200 for that first massage and
then had her dropped off at a Shell gas station near Okeechobee Blvd. and the Turnpike. Prior to
leaving Epstein's house, JD#3 gave her telephone number to one of Epstein's assistants. JD#3 said
that would usually call to ask if JD#3 was available or if she had other girls that she could
bring. Sarah usually called before they traveled to Palm Beach. JD#3 estimates that she went to
Epstein's house over 25 times from 2003 to 2004 and provided about 10 to 15 massages. At first
Epstein masturbated and fondled JD#3's breasts, but he became more and more sexually aggressive.
6
EFTA00234510
Epstein instructed JD#3 to pinch his nipples. On one occasion, Epstein brought another female into
the room (believed to be ). Epstein instructed JD#3 to straddle the female and touch the
female's breasts. At the same time, Epstein used a vibrator on the female until the female climaxed.
Epstein paid $200 for all the massages (including the one that involved the other female). On one
occasion, Epstein used the massaging device on JD#3 and on other occasion he touched her vagina.
JD#3 stated that Epstein tried to hide his penis from JD#3 while he masturbated.
Although JD#3 started going to Epstein's home in mid-2003, we only have phone records
from 2005 (we have located an older cell phone number for JD#3 and have subpoenaed those
records). From January 2005 to October 2, 2005, JD#3 received 21 calls from and
made 11 calls to Based upon the telephone activity, 1 have charged a violation of Section
2422(b). 1 have si ql charged a violation of 1591(a) because 1 don't believe we have adequate
evidence of willful blindness of JD#3's true age.
NB: In an interview following preparation of this memorand um, JD#3 was asked about
the girls that she recruited. JD#3 explained that she tried to bring Epstein girls who worked
with her at a strip club who were adults. Epstein rejected the adult females, not even taking
them upstairs for a massage. JD#3 says that Epstein stated that "he did not care for" those
older girls. This is interesting because Epstein apparently used the same words when he
rejected a 22-year-old brought by JD#3 says that Epstein rejected the adult females
but accepted the underage girls whom she brought. JD#3 also stated that Epstein would call
her over and over asking for "new girls." When she wasn't able to provide new girls, Epstein
would become so frustrated that he would hang up on her.
7
EFTA00234511
Jane Doe #12)
Jane Doe #12 met Jeffrey Epstein during her junior year at Palm Beach Central High School;
when JD#12 was 17 years' old. JD#12 was recruited by told JD#12 that she could
make $200 for performing a massage in her underwear. =took JDff12 to Epstein's home and
led JD#12 up to the bedroom. =left before Epstein entered. Epstein entered wearing a towel
and laid face down. JD#12 performed the massage in her bra and panties. When Epstein turned over
he began to masturbate. JD#12 became uncomfortable and ended the massage. Epstein asked JD#12
if she had "any friends that would do this?" and that she could make money recruiting. JD#12 was
paid $200 - the money had been placed on the table before the massage started. Epstein told JD# 12
to leave her phone number. JD#12 left her number with who said they would be back in 3
weeks and she [ would call JD#12.
On JD#12's second visit, she brought Jane Doe #13. They went upstairs together and Epstein
entered wearing a bathrobe. The girls undressed to their underwear and started massaging Epstein's
back. At some point JD#12 left, leaving JD#13 alone with Epstein. After some time, JD#13 came
back downstairs with $200 for herself and $200 for JD#12.
On the third visit, JD#12 went alone and massaged Epstein wearing only her panties. Epstein
said, "God, you're so sexy." When Epstein turned over he tried to place the back massager on
JD#12's vagina but JD#12 pulled away. Epstein the digitally penetrated JD#12's vagina. Epstein
also took JD#12's hand and forced her to touch his penis, which JD#12 describes as "little." JD#12
was paid $300 on that occasion.
On another occasion, Epstein had JD#12 straddle him while he masturbated and he again
8
EFTA00234512
digitally penetrated her vagina. During one conversation Epstein told JD#12 that he paid $600 to
a girl to allow him to perform anal sex. JD#12 told Epstein that she was 17 and still in high school.
Epstein told JD#12 that he would take her to Los Angeles when she turned 18, and would get her
a place to stay.
During the nine-month period of August 19, 2004 through May 30, 2005, JD#12 received
approximately 13 calls from Ellgell phone and 11 calls from the Epstein residence. JD#12 also
placed 14 calls to ell phone and 20 calls to Epstein's residence.
Based upon the documented telephone activity, knowledge of age, and sexual activity, I have
charged substantive 2422(b) and 1591(a)(1) counts related to JD#12.
IN= [Removed from Indictment — See Third Addendum'
inn
UM was recruited bys to travel to Epstein's home to provide a massage. She
went to Epstein's home in 2004, after she had turned 16 inkbrougliallpto Epstein's house
and brought her upstairs to Epstein's bedroom then left and Epstein entered. oegan
massaging Epstein, when he turned onto his back, he began masturbating, and tried to reach down
the pants ofelillik He was unable to do so, because her jeans were so tight. Epstein then reached
undereshort t-shirt to fondle her breasts. When he climaxed, the session ended. Epstein
paid both —and -$200 each.
'never performed another "massage" for Epstein, but she did recruit two other girls.
One has not yet been interviewed, and the other iffillffirwho was discussed in the original
Pros Memo.
Becauslaterformed only one massage and remained fully clothed, I have not charged
9
EFTA00234513
any substantive offenses related to her, but I have included overt acts related to her massage and her
recruiting telephone calls with 1=
a [Removed from Indictment —See Third Addendum'
a
was recruited by gm to go to Epstein's home in early 2005, while she was
16 years' old...told"... that Epstein might try to touch her during the massage, but she
could say noealso toll. that Epstein would probably masturbate during the massage
and instructed"... that, if Epstein asked how old she was, she should say she was 18.
41
.e. reports that Epstein never asked her age...drove the two of them to Epstein's house
and ledigaiNfupstairs. set up the massage table and left. Epstein began the
massage facing downwards. When he turned over, he started to masturbate and repeatedly tried to
touchlines bottom and breasts. Afte, pulled away several times, Epstein became
frustrated, threw $200 or $300 on the massage table and left. Epstein toktillirot to bring
back.
A few months late needed money and agreed to return to Epstein's house. The
same events occurred. led her upstairs. Epstein began the massage facing downwards and
then turned over and began masturbating. Epstein again tried to touch's breasts and
bottom and when refused, he ended the massage, paid $200 and left. ea never
was asked to return.
Based upon these events, I have only alleged overt acts related to and no
substantive charges. ler's story is important because it makes clear that Epstein was not
interested in pure "massages," and the acts with the other girls were not just massages that got out
10
EFTA00234514
of hand. If a girl was uninterested in sexual contact, she was not invited back.
NOTE: I have attached the first pros memo, which contains all of the information regarding
the other girls. The only revisions are amending the Jane Doe numbers associated with each girl.
11
EFTA00234515
DataSet-10
Unknown
76 pages
(USAFLS)
From: (USAFLS)
Sent: hursda ua '
To: N.:
Subject: ist o names
From: (USAFLS)
Ser riii.1:43111 .
To:t N.;
Subject: List of names
Here are the names of people I am intending to keep in the indictment:
eyewitness info only)
- initials only. not' listed Jane Doe
Not all will be in substantive counts, but they will be mentioned in the oven acts.
Assistant U.S. Attorney
1668
08-80736-CV-MARRA F014604
EFTA00223748
(USAFLS)
From: (USAFLS)
Sent: h r February 14 2 8 2. P
To: N.:
Subject: I now you hate d when I o this,but. . .
I always seem to notice something new when I go through these records. In notes, he shows 'payment to
Golden Cab on 6/17/05. Can you call and see if they have any reco s or any trips tcrEl Brillo Way? Or a Dennis
working there? And that long string of unknown numbers on cell phone. Could those be 'group of lines for
Yellow Cab?
Thanks.
I am almost finished with the changes to the girls we are keeping. I will send that to you and then when I finish the new
girls, I will send that portion.
Assistant U.S. Attorney
1670
08-80736-CV-MARRA F014605
EFTA00223749
(USAFLS)
From:
Sent:
To:
Subject:
Here are the names of people I am intending to keep in the indictment:
eyewitness info only)
— initials only, not 'listed Jane Doe
II
Not all will be in substantive counts, but they will be mentioned in the overt acts.
I
Assistant U.S. Attorney
1672
08-80736-CV-MARRA •014606
EFTA00223750
. (USAFLS)
From: (USAFLS)
Sent:
To:
Subject: RE DOBs
Hi guys - sorry to bother you. On some of the new girls I don't have dobs.
Martell
Dicenso (the 302 says her dob is 84 5/2007)
and do we have 'phone number?)
Have you guys ever talked to or Should I include them?
Assistant U.S. Attorney
1674
08-80736-CV-MARRA ♦014607
EFTA00223751
M, Ann Marie I. (USAFLS)
From: (USAFLS)
Sent: hursda February 14. 2008 1:21 PM
To:
Subject: Epstein Indictment
I In - I didn't send the indictment yet. I was just asking tor input on who to include and who to exclude.
How old was w hen she went Vl jilt
From:
Sen 14, 2008 1:00 PM
To: (USAFLS)
Subject: RE: Epstein Indictment
Hey Marie,
There was no indictment attached to your email. Can you send it again.
In addition to the two calls from
we have two telephone calls from
%I to on her cell /04 at 1:35 pm and 5/2/04 at 10:32 am,
to Shawn Haught's (boyfriend) telephone on 03/04/2004 at
9:46 am and 2:30 pm.
Message pads reflect 10 Inning 03/11/2003 ending 03/01/2006. Individuals identified as
taking the messages are and Alfredo Rodriguez.
From: (USAFLS) [Ann.Marie. j.gov]
Sen 1 AM
To: N.;
Subject: RE: Epstein Indictment
F Y I jell me what you think. Also. can you pu i u essages from and see if you can tell
what the dates are and ‘s.ho took the messages?
at we has only two phone calls with ' 4/23/04 and 5/2/04
rue>
561
From: (USAFLS)
Sen ruary 14, 2008 11:22 AM
To:
Subject: Epstein Indictment
1678
08-80736-CV-MARRA I-014608
EFTA00223752
Hi Myesha — Our server was down for 'few hours this morning. so I am very behind on my revisions. I wanted
to talk about which iris we should drop.
and I. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by . here are my thoughts. We c and S.
very easily. Both only gave I or 2 massages and did not disclose their ages. ill S. is good witness
because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its plie s
I think we should drop I because I don't believe she will ever be completely zuthful about the amount of
sexual activity that occurred. (She is the girl that one of the witnesses described as 'I virgin on graduation
day.")
That only leaves . the soccer player who cried for the entire interview. I think that she may be worth
keepisWe have such good documents evidence related to her - message bads, car rental records. 156 calls
with . and 2 calls with (we have very few phone calls with =, so this is
M).
What do vou think?
Assistant U.S. Attorney
1679
08-80736-CV-MARRA F014609
EFTA00223753
. (USAFLS)
From:
Sent: hursda Febru r 14. 2008 1 00 PM
To: (USAFLS)
Subject: pstein Indictment
■
Hey Marie,
There was no indictment attached to your email. Can you send it again.
In addition to the two calls from on her cell 10/04 at 1:35 pm and 5/2/04 at 10:32 am,
we have two telephone calls from to Shawn Haught's ( boyfnend) telephone on 03/04/2004 at
9:46 am and 2:30 pm.
Message pads reflect 10 messa es from beginning 03/11/2003 ending 03/01/2006. Individuals identified as
taking the messages are and Alfredo Rodriguez.
From: (USAFLS) [Ann. 1
Sen • ru • 1 AM
To: N.;
Su act: RE: Epstein Indictment
FYI -fell me ■ you think. Also. can you pull the messages from and see if you can tell
what the dates arc and who took the messages? Thanks.
And • ) • at we have only two phone calls with MP 4/23/04 and 5/2/04
From: (USAFLS)
Ton ruary 14, 2008 11:22 AM
To:
Subject: Epstein Indictment
Hi Myesha — Our server was down for' few hours this morning. so I am very behind on my revisions. I wanted
to talk about which we should drop.
and I. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by M. here are my thoughts. We c and S.
very easily. Both only gave I or 2 massages and did not disclose their ages. S. is good witness
because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its pie
I think we should drop I because I don't believe she will ever be completely zuthful about the amount of
sexual activity that occurred. (She is the girl that one of the witnesses described as virgin on graduation
day.")
That only leaves . the soccer player who cried for the entire interview. I think that she may be worth
keeping. We have such good documentary evidence related to her — message pads. car rental records, 156 calls
1686
08-80736-CV-MARRA I-014610
EFTA00223754
with and 2 calls with (we have very few phone calls with M, so this is
key).
hat do ou think?
I
Assistant U.S. Attorney
561
1687
08-80736-CV-MARRA 1-014611
EFTA00223755
(USAFLS)
From:
Sent: Thur F 14, 2008 12:37 PM
To: (USAFLS)
Subject: Epstein Indictment
I'm not supposed to be involved in n tantive decisions until I get word from on h h'. However, my gener
thoughts are that you are correct 5 of th Vence and will be I good witness, although
reluctant one. Am I correct to assume that and I. are still in? Their past history of commitment will
have to be dealt with and it won't be easy. but I agree that they should be lite fact that their commitments were
post-Epstein is good but his going to try to destroy them. Is in as well? I thought that she was
truthful. What about M 7
'
From: (USAFLS) [mailto
Sen 2008 11:22 AM
To:
Su • ect: Epstein Indictment
Hi Myesha — Our server was down for I few hours this morning, so I am very behind on my revisions. I wanted
to talk about which girls we should dro .
and I. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by . here arc my thoughts. We can dm and S.
very easily. Both only gave I or 2 massages and did not disclose their ages. good witness
because she shows that, if you aren't willing to do more sexual activity. Epstein stops the massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its prejudice.
I think we should drop I because 1 don't believe she will ever be completely truthful about the amount of
sexual activity that occurred. (She is the girl that one of the witnesses described as'i virgin on graduation
day:')
That only leaves the soccer player who cried for the entire interview. I think that she may be worth
keep' such good documentary evidence related to her — message pads, car rental records, 156 calls
with . and 2 calls with (we have very few phone calls with . so this is
key).
What do you think?
Assistant U.S. Attorney
1690
08-80736-CV-MARRA F014612
EFTA00223756
(USAFLS)
From: (USAFLS)
Sent: Thur d Februa 14 20 81 41 M
To: N,
Subject: RE. EpsteinIndictment
FYI - len me you think. Also. can you pull the messages from and see ilyou can tell what the
dates are and 11. oak the messages? Thanks.
And am I correct that we have only two phone calls with M.' 4/23104 and 5/2/U4
ssistant .S,
56I 209-1047
From: .IICSAFLS)
ruary 14, 2008 11:22 AM
To:
Subject: Epstein Indictment
Hi Myesha — Our server was down for' few hours this morning, so I am very behind on my revisions. I wanted to talk
about which girls we should drop.
M and I are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by . here are my th e cal drop I.T eld MI S. very easily.
Both only gave 1 or 2 massages and did not disclose their ages. S. is good witness ause s e shows that, if
you aren't willing to do more sexual activity. Epstein stops the massage and doesn't want to see you anymore. She seems
like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
I think we should drop I because I don't believe she will ever be completely truthful about the amount of sexual
activity that occurred. (She is the girl that one of the witnesses described as 'i virgin on graduation day.")
That only leaves Il.. the soccer player who cried for the entire interview. I think that she may be wort in .
We have such g document evidence related to her — message pads, car rental records. 156 calls with.
and 2 calls with (we have very few phone calls with • so this is key).
What do you think?
SLY
1702
08-80736-CV-MARRA •014613
EFTA00223757
From:
Sent:
To:
Subject:
FYI — Tell me what >nu think. Also. cairtill the messages from il and see if you can tell what the
dates are and who took the messages?
And am I correct that we have only two phone calls with 4/23/04 and 5/2/04
I. Mark VAIN&
Assistant U.S. Attorney
561 209-1047
From: (USAFI.S)
Sen • February 14, 2008 11:22 AM
To:
Subject: Epstein Indictment
Hi Myesha - Our server was down for' few hours this morning, so I am very behind on my revisions. 1 wanted to talk
about which girls we should drop.
and I. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by , here are my th e c drop and S. very easily.
Both only gave I or 2 massages and did not disclose their ages. S. is I good witness because she shows that, if
you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems
like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
I think we should drop I because I don't believe she will ever be cornuietely truthful about the amount of sexual
activity that occurred. !Ps the girl that one of the witnesses described as' virgin on graduation day.")
That only leavesoo the soccer player who cried for the entire interview. I think that she may be wo
We have such g documentary evidence related to her — message palmnal records, 156 calls with
and 2 calls with (we have very few phone calls with so this is key).
What do you think?
Assistant U.S. Attorney
1794
08-80736-CV-MARRA II-014614
EFTA00223758
(USAFLS)
From: (USAFLS)
Sent: illhursc ruary . 2008 11:22 AM
To:
Subject: Epstein Indictment
Hi Myesha — Our server was down for' few hours this morning. so I am very behind on my revisions. I wanted to talk
about which girls we should drop.
and are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought byM.
here are my th e cal drop and S. very easily.
Both only gave 1 or 2 massages and did not disclose their ages. S. is I good witness because she shows that, if
you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems
like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
I think we should drop I because I don't believe she will ever be completely truthful about the amount of sexual
activity that occurred. (She is the girl that one of the witnesses described as 1 virgin on graduation day.")
That only leaves the soccer player who cried for the entire interview. I think that she may be worth pin .
We have such good document evidence related to her - message pads. car rental records, 156 calls with
and 2 calls with (we have very few phone calls with so this is key).
What do you think?
I Marie Villafatia
Assistant U.S. Attorney
1706
08-80736-CV-MARRA I-014615
EFTA00223759
(USAFLS)
From: (USAFLS)
Sent: February 12, 2008 4:33 PM
To: N.
Subject: Te ne numbers
Can you 'mail me your summary chart, too? The Excel spreadsheet.
Thanks.
Assistant U.S. Attorney
561 209-1047
1713
08-80736-CV-MARRA F014616
EFTA00223760
(USAFLS)
From: (USAFLS)
Sent: Tuesday February 12. 2008 4 33 PM
To: N
Subject: elephone numbers
Can you e-mail me your summary chart, too? The Excel spreadsheet.
Thanks.
Assistant U.S. Attorney
1714
08-80736-CV-MARRA F014617
EFTA00223761
. (USAFLS)
From: (USAFLS)
Sent: U M. ri iary -i l 2008 3 19 PM
To:
Subject: Telephone charts and phone records
Hi 11- Im im i get thiament package finalized. C's to me the final telephone charts for all of
the d . and Also, do you have all o f records electronically? Maybe we can
search for phone numbers for some of the new girls, even though we don't have their phone records yet.
Also, can you check on the lead to New York? Ideally. I would like to turn the package in on Thursday, so I need to know
if we can include any of those girls.
When you have I chance. please give me I call. I am in the U.S. Attorney's Office
Assistant U.S. Attorney
561 sai
1717
08-80736-CV-MARRA ♦014618
EFTA00223762
.(USAFLS)
From:
Sent: r 08208 PM
To: (USAFLS)
Subject: e. hone call info
Ill fax it in 5 min(what fax U?)
Fro (USAFLS) <
To: N.
Sent: Fri Feb 22 14:07:06 2008
Subject: Phone call info
Hi - Can you "nail or
the ni dictment today. I think
air the dates of the calls? I can add them to
is going to try to finish her review over
the weekend.
Thanks.
II Marie
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax
156n
08-80736-CV-MARRA 1-014619
EFTA00223763
USAFLS
From: (USAFLS)
Sent: lila
i.wi
eb rt ,t082.10 PM
To: N
Subject: : hone ca info
Thanks
y
500 S. Austra Ian Ave, Suite 400
West Palm h FL 33401
Phone 5
Original Messa
From: Kuyrkendall, IN.
Sent. • Fliiiiiiiiiii2008 2:08 PM
To: (USAFLS)
Subject: Re: Ph!!!M!!!!Millo
I11 fax it in 5 min(what fax II)
From: (USAFLS) <
To: Kuyrkendall, N.
Sent: Fri Feb 22 14:07:06 2008
Subject: Phone call info
Hi - Can you l[mail or the dates of the calls? I can add them to
the in is ment today. I think is going to try to finish her review over
Illr
the weekend.
Thanks.
II Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax
1562
08-80736-CV-MARRA 1-014620
EFTA00223764
(USAFLS)
From: (USAFLS)
Sent: n ry , 2:07 PM
To: N.
Subject: one ca m o
Hi Nesbitt — Can you Imail or fax me the dates of the calls? I can add them to the indictment today. I think
is going to try to finish her review over the weekend.
Thanks.
IAssistant
Marie Villafatla
U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach. FL 33401
Phone
Fax
1564
08-80736-CV-MARRA F014621
EFTA00223765
From:
Sent:
To:
Subject: of the FedEx records
last name is or and her phone number is (this may be an office number, not
ce phone number). They also show another corporate name: "Max Hotel Services Corp."
They show' phone number for Epstein and Eric Gany as
They have an Imail address for as: and show her phone number as
The notes show that the Max Hotel Services Corp credit card was declined and then they shos n
a with company name "NYSG LLC"
They want us to be more specific about individual shipment records. so we will have to comb through what they
gave us to identify specific shipments.
lam running to lunch but will be back this afternoon.
Thanks.
I Marie VillafaAa
Assistant U.S. Attorney
500 S. Australian Ave. Suite 400
West Palm Beach. FL 33401
Phone
Fax
1567
08-80736-CV-MARRA F014622
EFTA00223766
(USAFLS)
From: (USAFLS)
Sent: n aiiiiriary 25. 2008 11 24 AM
To: (USAFLS)
Subject: uestion regarding use of Grand Jury
Thank you. &reline. It is most appreciated.
I Mark' rub:law
Assistantli.S. Atturne)
500 S. Australian Ave. Suite 400
West Palm Beach. FL 33401
Phone 561 209-1047
Fax
From: M, (USAFLS)
Sett : nd F 5, 2008 11:23 AM
To: (USAFLS)
Sub ect: RE: Question regarding use of Grand Jury
Marie:
I see no need to change grand juries. Indeed, changing grand juries might suggest that something untoward
occurred, which is not the case.
Nor do I see' requirement to give 1404(b) tape instruction. Let's not forget dig the role of the grand is to
investigate, and it is wholly apEropriate that I grand jury in good faith pursued I line of investigation that does
not lead to indictment. That is very different matter from presenting information pursuant to 404(b), to prove
motive, lack of accident, etc.
I share your instinct that just dropping six victims, and the draft proposed indictment, might call for some
explanation, or at least acknowledgement, to the grand jury. It's always dicey, and not really desirable, to
explain and share legal strategies with the grand jury. Perhaps you can simply tell them that the old draft
proposed indictment is being withdrawn, and II ifferent set of facts is being pursued, and ask them if they can
set aside what they heard previously, and base determination of probable cause solely on the new evidence. If
any of them indicat inability to do so, perha they should li excused from consideration of this case; if that
leaves you without I quorum, then you have I basis to go to I new grand jury.
I hope this helps; I'm available by phone as well.
Cctralitie,
1546
08-80736-CV-MARRA I-014623
EFTA00223767
From: (USAFLS)
Son
bli ruary 25, 2008 9:59 AM
To: (USAFLS)
Su Question regarding use of Grand Jury
Hi — I have received two conflicting points of view regarding this question, so I thought I should ask
the..Here
exp is my situation:
1 have been involved in' long-term investigation of I ild exploitation case. Throughout the investigation, I
have prese ed evidence and testimony to Grand Jury I Some of that evidence and testimony related to six
r
victims (ofI total of 19 victims), including the live testimony of one of those victims. I also began presenting
evidence related to what I called '"draft proposed indictment." For various reasons, the indictment has been
delayed about 9 months. And, r other strategic reasons, we have decided to drop the six victims referenced
above, and replaced them with different six victims.
The question is now raised as to whether I should continue presenting to Grand Jury', with' 404(b)-type
instruction related to the evidence of the six dropped victims and some sort of instruction regarding the initial
"draft proposed indictment", or whether I should presenti Grand Jury B, excluding any testimony regarding
those six victims. One other consideration — Grand Jury is due to expire in August, and I anticipate that the
investigation will continue for quite some time after indi ant. It is possible that the 6 dropped victims will be
re-added in 'superseding indictment.
Thank you.
I Marie Villafafia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
Tracking:
1547
08-80736-CV-MARRA 1-014624
EFTA00223768
(USAFLS)
From: (USAFLS)
Sent: Monde Februa 25 2008 11 23 AM
To: (USAFLS)
Subject: uestion regarding use of Grand Jury
Marie:
I see no need to change grand juries. Indeed, changing grand juries might suggest that something untoward
occurred. which is not the case.
Nor do I see 'requirement to give' 404(6) 'Ape instruction. Let's not forget thil the role of the grand is to
investigate, and it is wholly aprpriate that 'grand jury in good faith pursued I line of investigation that does
not lead to indictment. That is very different matter from presenting information pursuant to 404(b), to prove
motive, lack of accident, etc.
I share your instinct that just dropping six victims, and the draft proposed indictment, might call for some
explanation, or at least acknowledgement. to the grand jury. It's always dicey, and not really desirable, to
explain and share legal strategies with the grand jury. Perhaps you can simply tell them that the old draft
proposed indictment is being withdrawn, and lil ifferent set of facts is being pursued, and ask them if they can
set aside what they heard previously, and base determination of probable cause solely on the new evidence. If
any of them indicatt inability to do so. perhags they should lif excused from consideration of this case; if that
leaves you without I quorum, then you have I basis to go to I new grand jury.
I hope this helps: I'm available by phone as well.
Cc:wait/4e.
From: (USAFLS)
Sonjilt• February 25, 2008 9:59 AM
To: (USAFLS)
Su : Question regarding use of Grand Jury
Hi - I have received two conflicting points of view regarding this question. so I thought I should ask
the . Here is my situation:
ir i
I have been involved in' long-term investigation ofI ild exploitation case. Throughout the investigation. I
have presc d evidence and testimony to Grand Jury Some of that evidence and testimony related to six
victims (of total of 19 victims), including the live testimony of one of those victims. I also began presenting
evidence re ated to what I called '"draft proposed indictment." For various reasons, the indictment has been
delayed about 9 months. And, for other strategic reasons. we have decided to drop the six victims referenced
above, and replaced them with' different six victims.
1552
08-80736-CV-MARRA F014625
EFTA00223769
The question is now raised as to whether I should continue presenting to Grand Jury'. with' 404(b)-type
instruction related to the evidence of the six dropped victims and some sort of instruction regarding the initial
"draft proposed indictment", or whether I should presenti Grand Jury B. excluding any testimony regarding
those six victims. One other consideration — Grand Jury is due to expire in August, and I anticipate that the
investigation will continue for quite some time after indi ment. It is possible4hat the 6 dropped victims will be
re-added in 'superseding indictment.
Thank you.
I Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
1553
08-80736-CV-MARRA F014626
EFTA00223770
(USAFLS)
From: (USAFLS)
Sent: n a ary 25. 2008 9 59 AM
To: (USAFLS)
Subject: Question regarding use of Grand Jury
Ili — I have received two conflicting points of view regarding this question, so I thought I should ask
the . Here is my situation:
I have been involved in 'long-term investigation ofI 1 ild exploitation case. 'Throughout the investigation. I
have preseled evidence and testimony to Grand Jury Some of that evidence and testimony related to six
victims (of 'total of 19 victims), including the live testimony of one of those victims. I also began presenting
evidence related to what I called tdraft proposed indictment." For various reasons, the indictment has been
delayed about 9 months. And, for other strategic reasons, we have decided to drop the six victims referenced
above, and replaced them with 'different six victims.
The question is now raised as to whether I should continue presenting to Grand Jury', with' 404(b)-type
instruction related to the evidence of the six dropped victims and some sort ofinstruction regarding the initial
"draft proposed indictment", or whether I should presentIL Grand Jury B, excluding any testimony regarding
those six victims. One other consideration — Grand Jury is due to expire in August. and I anticipate that the
investigation will continue for quite some time after indi ent. It is possible that the 6 dropped victims will be
re-added in, superseding indictment.
Thank you.
I Marie Villajafia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
Tracking:
1556
08-80736-CV-MARRA F014627
EFTA00223771
(USAFLS)
From: (USAFLS)
Sent: lionc , ary 25, 2008 12:00 PM
To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS). Garcia. Rolando (USAFLS), Mi.
Karen (USAFLS)
Cc: Braden, Myesha
Subject: Epstein
Hi all —I wanted to raise an issue with you regarding the presentation of the Epstein indictment. 1 have been
Il e West Palm Beach Tuesday grand jury in the past. which has included presentation of testimony from
and agent testimony regarding girls who will no longer be referenced in the indictment.
I have conferred %ith and Heck regarding whether to stay with the same grand
jury or present to Id), gran jury. They agree that I should present to the same grand jury with some sort
of instruction regarding not relying on evidence/testimony regarding those girls.
That is my intention. I would like to present on March I l a'. Epstein will be in town on March 10'h foliate
court hearing and hopefully we will be able to keep track of his whereaboup until the following day. is
reviewing the package now, so it should be in Miami by Monday, March 3"
Also. I invited Myesha to be present for the grand jury proceedings, but she is waitin
a. about her level of involvement in the case. She is available on that date, so, if
this, she will be able to attend.
decide
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave. Suite 400
West Palm Beach, FL 33401
Phone
Fax
Tracking:
1542
08-80736-CV-MARRA I-014628
EFTA00223772
(USAFLS)
From: (USAFLS)
Sent: ry 26, 2008 10 05 AM
To:
Subject: paten'
Hi Myesha — I won't even tell you about how today is starting off badly on this case (politics, of course, not
facts). But, in any event, the word is that CEOS is going to undertake an "independent review" of the case and
meet with Epstein's attorneys some time next week. My supervisor is finishing tI review of the indictment
package and I know she caught some typos. Wls .i I finish those revisions, I will mail to you the entire
indictment package, and you can find out what = wants to look at. I have one real concern, however. As
you know, there are several girls that are still unknown to the defense. I want to avoid trait possibility that those
names might be disclosed. Should 1 redact the names of all of the girls from the pros memos that I send to you?
Thank you. Myesha.
I
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
t520
08-80736-CV-MARRA .014629
EFTA00223773
(USAFLS)
From: (USAFLS)
Sent: gr ay, xuary 2 . 2008 9:41 AM
To: Sloman, Jeff (USAFLS)
Cc: Senior, Robert (USAFLS)
Subject: RE: Confidential
Why would we possibly let him keep the same deal after all he has put us through? And after we have
discovered 6 new girls. plus another 3 probable victims in New York?
UFO* Pala&
Assistant U.S.
500 S. Australian Ave. Suite 400
w est Palm Beach. Fl. 33401
l'h, me 561 209-1047
I :IN 561
From: Sloman, Jeff (USAFLS)
Sent: Tuesday, February 26, •
To: Senior, Robert (USAFLS); (USAFLS)
Subject: Confidential
FYI
From: Sloman, Jeff (USAFLS)
Sent: Monday, February 25, 2008 7:43 PM
To: JLefkowit2@kirkland.com
Cc: Oosterbaan, Andrew
Subject: Epstein
Jay,
The Section Chief of DOJ's Child Exploitation Obscenity Section (CEOS) notified me today that
he will review the matter involving your client Jeffrey Epstein. The Section Chief has indicated
that he is ready to proceed immediately, and I understand you are in the process of providing
him this week with' summary of issues to be reviewed, and expect to meet with him next
week.
The Section Chief also indicated that you would be calling this Office regarding the upcoming
March 3, 2008 court date in the Fifteenth Judicial Circuit, in and for Palm Beach County. As you
know, the Agreement entered into by your client originally provided that the United States
1522
08-80736-CV-MARRA 1-014630
EFTA00223774
Attorney's Office for the Southern District of Florida (this Office) would defer prosecution if
your client pled guilty to enumerated state charges by October 26, 2007. Since then, that date
has been postponed for' number of reasons. At this juncture, it would not be reasonable to
keep the current March 3ldate as I deadline for compliance with the Agreement. That said,
this Office is very concerned about additional delays. Despite this concern, I want to assure
you that if counsel for Mr. Epstein meets with CEOS next week (the week of March 3$, this
Office will extend the time for compliance with the Agreement to provide CEOS time to
engage in' thorough review.
It goes without saying that in the event that CEOS decides that' federal prosecution should
not be undertaken against Mr. Epstein, this Office will close its investigation. However, should
CEOS disagree with Mr. Epstein's position, Mr. Epstein shall have one week to abide by the
terms and conditions of the September 24, 2007 Agreement as amended by letter from United
States Attorney Acosta to Jay Lefkowitz.
Jeffrey,. Sloman
First Assistant U.S. Attorney
Southern District of Florida
Tracking:
1523
08-80736-CV-MARRA 1-014631
EFTA00223775
(USAFLS)
From: (USAFLS)
Sent: 008 428 PM
To:
Cc: (U AFL )
Subject: To the Civil Rights Chief
That is fine. Just please send licopy to me for my file.
II Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Original Message
From: Weinstein, David (USAFLS)
Sent. 7, 2008 4:22 PM
To: (USAFLS)
Cc: enior, obert USAFLS
Subject: Re: To the Civil Rights Chief
IMP If
Bob have you had
and I discussed this yesterday. Jeff made some edits to your
a wants to send it out under Bob's signature.
chance to review Jeff's email?
From: (USAFLS)
To: Weinstein, David USAFLS
Cc: Senior, Robert (USAFLS)
Sent: Wed Feb 27 16:16:36 2008
Subject: RE: To the Civil Rights Chief
Hi David -- Have you had chance to talk to Bob about this? I think my window
It
is close to "opening" and don't want the bad guys to come up with another
reason for delay.
Thank you.
II Marie
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phon
Fax 47
1499
08-80736-CV-MARRA 1-014632
EFTA00223776
Original Message
From: Weinstein, David (USAFLS)
Sent 2008 5:03 PM
To:
Cc: enior, USAFL ; (USAFLS); Garcia, Rolando (USAFLS)
Subject: Re: To the Civil Rights Chief
Timing is everything. Right now I am at the NAC attending the Criminal Civil
Rights Seminar.
Your letter seems to cover everything, but I want to chat with Bob about it
before we send it out. It should probably be addressed to Stephan Curran, who is
the Deputy assigned to cover our District.
Bob an talk Monday when I get back and w can send out the letter.
Since shop is involved and has been for il while, they will hopefully agree
with our your conclusion.
DSW
From: (USAFLS)
To: Weins ein, USAFLS
Cc: Senior, Rober SAFLS); (USAFLS); Garcia, Rolando (USAFLS)
Sent: Thu Feb 21 15:56:01 2008
Subject: To the Civil Rights Chief
Hi David - I was just perusing the U.S. Attorney's Manual looking for an answer
on another case and I noticed that Section 9-75.030 (regarding Coordination of
Child Sex Abuse cases) says that cases involving violations of 18 USC 1591
(related to child sex trafficking) are supposed to be coordinated with CEOS and
the Civil Rights Division.
According to Section 8-3.120, prior to presentation to the grand jury, the U.S.
Attorney is supposed to advise the Civil Rights Division in writing of the
following:
Identity of the targets of the investigation;
The factual allegations to be investigated;
The statutes which may have been violated;
The United States Attorney's assessment of the significance of the case and
w ther the case is one of "national interest," and
( The U.S. Attorney's proposed staffing of the matter (including whether
C it Rights Division attorney should be assigned to work directly on the
matter).
Here is my proposal for such 'written notification:
Dear : Pursuant o USAM Section 8-3.120, I write to inform
you of an ongoing investigation child exploitation matter that may result in
charges of violat' f 18 U.S. Large
stein, Marcinkova, and W
eirPO*I
The investigation
Ili t has revea ed a effrey pstein would use his
Mg
•
:500
08-80736-CV-MARRA I-014633
EFTA00223777
assistants (Kellen, Marcinkova, and to arrange appointments with minors to
engage in commercial sexual activity. ommunications were made via telephones.
Once appointments were made, stein would travel to the Southern District of
Florida, where he maintained residence, and the minors would travel to his home
in Palm Beach where the sexualractivity would occur. The Office anticipates
charges of violations of Title 18, United States Code, Sections 371, 2422, 2423,
and 1591. The investigation of the case by the City of Palm Beach Police
Department has resulted in press coverage because of the titillating nature of
the facts, but we see t s case as similar to other "sex tourism" cases charged
by our office, and not matter of "national interest" as' defined by the U.S.
Attorney's Manual. WitIrrespect to staffing, the Office has consulted with the
Child Exploitation and Obscenity Section, and we anticipate that the case will be
staffed by at least one Assistant United States Attorney from our West Palm Beach
office and at least one CEOS Attorney.
If we determine that the case should be presented for an indictment, I copy will
be provided to you.
David - If you need any more info, please let me know. Also, the indictment is
currently being reviewed by my supervisor. If you want to send the draft to
Civil Rights now, please let me know.
Thank you.
ll Marie
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Tracking:
1501
08-80736-CV-MARRA FO14634
EFTA00223778
(USAFLS)
From: Weinstein. David (USAFLS)
Sent: Wednesda Februa 27, 2008 422 PM
To: (USAFLS)
Cc: enior. o e ( S)
Subject: Re: To the Civil Rights Chief
Bob, Jeff, Alex and I discussed this yesterday. Jeff made som edits to your
proposed letter a wants to send it out under Bob's signaturI.
Bob have you had
Ifchance to review Jeff's email?
From: (USAFLS)
To: WeIns ein,
Cc: Senior, Robert (USAFLS)
Sent: Wed Feb 27 16:16:36 2008
Subject: RE: To the Civil Rights Chief
Hi David -- Have you had chance to talk to Bob about this? I think my window
II
is close to "opening" and don't want the bad guys to come up with another
reason for delay.
Thank you.
llMarie Villafaha
ssistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phon - 47
Fax
Original Message
From: Weinstein, David (USAFLS)
Sent , 2008 5:03 PM
To:
Cc: !Ttl,,Tobert USAFLS ; (USAFLS); Garcia, Rolando (USAFLS)
Subject: Re: To the Civil Rig is ie
Timing is everything. Right now I am at the NAC attending the Criminal Civil
Rights Seminar.
Your letter seems to cover everything, but I want to chat with Bob about it
before
DataSet-10
Unknown
11 pages
#291874/mep IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800)OOO(MBAG
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:
DEF. 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
EFTA01140114
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
Jeffrey Epstein phone records
II.
Sarah Kellen's phone 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.
EFTA01140115
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 3 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
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 Jane Doe
2002 Royal Palm Beach High School Year Book
28.
2001 Royal Palm Beach High School Year Book
29
2003 Palm Beach Gardens High School Year Book
30.
Affidavit and Application for Search Warrant on Jeffrey
31.
Epstein's home
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 of properties 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
EFTA01140116
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 4 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
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
09-81092
Jeffrey Epstein's Answers and Affirmative Defenses in
43.
all civil cases against him
All Complaints in which Jeffrey Epstein was a plaintiff
44.
or 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 Deposition testimony and discovery responses
46
in State Court cases LM v. Jeffrey Epstein, Case No.
502008CA028051XXXXMB AB and E.W. 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
502009C A040800XXXXMBAG
Any and all newspaper articles, online articles or publications
48
related to Jeffrey Epstein
Report and Analysis of Jeffrey Epstein's assets
49
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 planes
51
Prob Affidavits prepared against Jeffrey Epstein
52.
and
Audio tape of Haley Robson
53.
Photographs, videos and books taken in the search warrant
54.
of 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
56.
Victim
EFTA01140117
Edwards adv. Epstein
Case No.: 502009CAC140800XXXXMBAG
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. L. Dennison Reed's Report 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 mails involving communications of Jeffrey Epstein,
65. Jeff Fuller, Maritza Vasquez, Pappas Suat, Jean Luc Brunel
and 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
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
EFTA01140118
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
TED DESCRIPTION OF EXHIBITS
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 Vanessa Zalis
89
Ted's Sheds Documents
90.
Documents related to property searches of Jeffrey Epstein's
91
properties
Arrest Warrant of Sarah Kellen
92
Police report regarding Alexandra Hall picking up money
93.
dated 11-28-04
EFTA01140119
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 Dana Burns
103.
Passenger List Palm Beach flights 2005
104.
Jeffrey Epstein notepad notes
105.
Pleadings of lane Doe 1 and 2 v. US case
106.
Jeffrey Epstein 5h Amendment Speech
107.
Reiter letter to Krisher dated 5-1-06
108.
Jail receipts of Jeffrey Epstein
109.
Alexandra Hall 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.
EFTA01140120
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 8 of 11
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Victim's employment records from MOP
114
Police report of Juan Alessi theft at Jeffrey Epstein's home
115.
Victim's Medical Records from Milton Girls Juvenile Facility
116
Victim's Medical Records from Dr. Randee Speciale
117
Victim's Medical Records from Wellington Regional Hospital
118
Victim's Medical Records from St. Mary's Medical Center
119
Victim's Medical Records from United Health
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.
EFTA01140121
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 9 of I I
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
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 Victims
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 Epstein's Exhibit List
142
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. mo rtality-tables
Edwards' reserves all objections to Epstein's Exhibits
145
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
All pleadings and attachments in the action under the Crime
149. 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.
EFTA01140122
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page I 0 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
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 molestation.
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, i 2014.
Jack S ola/
law.com; mep@searcylaw.com
Fl rid tar No.: 169440
ear• Denney Scarola Barnhart & Shipley, P.A.
9 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Attorneys for Bradley J. Edwards
EFTA01140123
Edwards adv. Epstein
Case No.: 502009CA040800)ODOCIVIBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 11 of I I
COUNSEL LIST
Jack A. Goldberger, Esquire
jgoldberger®agwpa.com;
smahoney®agwpa.com Phone: (954)-467-6767
Atterbury, Goldberger & Weiss, P.A. Fax: (954)-467-3599
250 Australian Avenue South, Suite 1400 Attorneys for Jeffrey Epstein
West Palm Beach, FL 33401
Phone: (561)-659-8300 Marc S. Nurik, Esquire
Fax: (561)-835-8691 marc@nuriklaw.com
Attorneys for Jeffrey Epstein Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Bradley J. Edwards, Esquire Fort Lauderdale, FL. 33301
staff.efile®pathtojustice.com Phone: (954)-745-5849
Farmer, Jaffe, Weissing, Edwards, Fistos & Fax: (954)-745-3556
Lehrman, FL Attorneys for Scott Rothstein
425 North Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire
Phone: (954) 524-2820 tonja®tonjahaddad.com;
Fax: (954) 524-2822 Debbie®Tonjahaddad.com
Tonja Haddad, P.A.
Fred Haddad, Esquire 315 SE 7th Street, Suite 301
Dee@FredHaddadLaw.com; Fort Lauderdale, FL 33301
haddadfm®aol.com Phone: (954)467-1223
Fred Haddad, P.A. Fax: (954)-337-3716
One Financial Plaza, Suite 2612 Attorneys for Jeffrey Epstein
Fort Lauderdale, FL 33394
EFTA01140124
DataSet-10
Unknown
3 pages
From: ' c
To: ' (USANYS) [Contractor]"
Cc: '
Cc: (USANYS) ::a
Subject: FW:
Would you please add the attached documents to the to be produced discovery folder and to 3500
and witness folders on the Epstein share?
Thanks,
From:
Sent: Tuesday, July 20, 2021 3:43 PM
To: (USANYS)
)
Cc:
Subject: RE:
can meet at 9:30am on Thursday 7/29. I'm going to coordinate with the local FBI office so we can do VTC.
I've attached the chains of custody for the 1Bs.
Her email is
Special Agent -
FBI New York Field Office
EFTA00089860
Child Exploitation/Human Trafficking
Desk:
From: (USANYS) c )
Sent: Monday, July 19, 2021 6:38 PM
To: (NY) (FBI) < >;
)<
Cc: (NYPD)c
Subject: [EXTERNAL EMAIL] - RE:
Thanks, Here are some options next week:
• 7/26 before 12pm or after 3pm
• 7/28 12pm to 2pm
• 7/29 before 11am
From: sc >
Sent: Monday, July 19, 20211:52 PM
To: (USANYS) < >;
Cc:
Subject: RE:
is traveling Wednesday for vacation. Can you suggest some days/times next week? We will have the message
pads and I'll see about getting a copy of the chains.
Special Agent -
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From: (USANYS)
Sent: Monday, July 19, 2021 11:37 AM
To: (NY) (FBI) < >; )
Cc: (NYPD)
Subject: [EXTERNAL EMAIL) - RE:
in advance of the meeting, can you please track down any and all chains of custody in FBI possession?
Thanks,
From: (USANYS)
Sent: Monday, July 19, 202111:26 AM
To: ;
Cc:
Subject: RE:
EFTA00089861
Thanks, Does this week work for ? If so, we could do between 12pm and 4pm on Wednesday or 10:30 am
to 12pm on Thursday. If I should get some times for next week instead, please let me know. Also, can you please have the
physical message pads with you for the WebEx with just in case?
From:
Sent: Wednesday, July 14, 20215:57 PM
To: I (USANYS) <
)
Cc:
Subject:
Hi all,
I spoke with today. She can meet with us but may go into a local FBI office to get assistance with video
setup. I told her I would touch base with her early next week to schedule a day and time that works for
everyone. Let me know what you all are thinking on timing and I'll let her know.
Thanks,
EFTA00089862
DataSet-10
Unknown
4 pages
Relativity Searches
11/18/2021
1.
JE
• EPS001.27924.28579 (Bill Log for
• EPS001.9109-9236 (Bill Usage for
• 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 (An records
• 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 as 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
•
• 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)
EFTA00089982
• GIUFFRE001.573 (list of girls' names and black book. Listed as 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.
E
• 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 for
• 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
• USVP00000910 (black book)
EFTA00089983
• 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)
UPDATE
5.
JE
• EPS001.27924.28579 (listed in bill log for phone
6.
JE
• EPS001.1200.1204 (listed in 2007 interview of
• EPS001-1259-1259 (2007 Accurint of number)
• EPS001.14663-14687 (listed in 2007 interview of
• EPS001-17528-17655 (Cingular records for
• EPS002-013073 (listed in 2007 interview of
• EPS002-013494 (listed in 2007 interview of
• EPS002-013499 (listed in 2007 interview of
• EPS002-030229 (listed in phone records for (Skagen))
• EPS002-030347 (listed in phone records for [SKellen))
• EPS002-032249 (listed in phone data for
• EPS002-032309 (listed in phone data for
• EPS002-041015 (listed in 2007 interview of
• EPS002-041077 (listed in 2007 Accurint report)
• EPS002-041759 (2007 interview of
• EPS002-041821 (2007 Accurint report)
• EPS002-049417 (toll data for
• EPS002-049455 (toll data for
EFTA00089984
• EPS002-084127 (2007 interview of
• EPS002-084544 (2007 interview of
• EPS002-137514 (toll data for
• EPS002-137627 (toll data for
• USVP00000082 (2018 interview of
• USVP00207989 (listed on FL Massage list for =0)
• USVP00342183 (phone records for-)
• SVP00342186 (phone records for
• USVP00342439 (phone records for-)
• USVP00351961 (2007 interview of
• USVP00351963 (2007 interview of
• USVP00352086 (FL Case information/listed in interview of
• EPS001.1261-1272 (would not open/don't know what it contains)
• EPS001.1273.1286 (would not open/don't know what it contains)
• EPS001-14683-14687 (2007 interview of )
• EPS001.17528.17655 (phone records for
• EPS001.20471.20657 (would not open)
• EPS002-013073 (2007 interview of )
• EPS002-013079 (2007 interview of )
• EPS002-013494 (2007 interview of )
• EPS002-013499 (2007 interview of )
• EPS002-030241 (phone records for
• EPS002-030359 (phone records for
• EPS002-041079 (2007 Accurint report)
• EPS002-041091 (2007 Accurint report)
• EPS002-041823 (2007 Accurint report)
• EPS002-041835 (2007 Accurint report)
• USGME01848764 (black book)
JE SW
• USGME01099266 (message book entries)
EFTA00089985
DataSet-10
Unknown
5 pages
Relativity Searches
11/18/2021
1.
JE
• EPS001.27924.28579 (Bill Log f
• EPS001-9109-9236 (Bill Usage to
• EPS001.9237.9293 (Epstein multi-line records for Account
• EPS001-9294-9347 (Epstein multi-line records for Accoun
• 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 Aocount Ell
• EPS002-033921 (ATT record i
• EPS002-034080 (Epstein multi-line records for Account
• EPS002-034137 (Epstein multi-line records for Account
• EPS002-034340 (Epstein multi-line records for Account la
• 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 records
• 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 as 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)
EFTA01653838
• GIUFFRE001573 (list of girls' names and black book. Listed as in black book)
• USGME01830664 (subpoena request)
• USVP00000813(black book)
• USVP00001032 (list of girls' names and black book)
• USVP00001095 (list of girls' names and black book)
• USVP00001105 (list of girls' names and black book)
• USVP00001234 (list of girls' names and black book)
• USVP00001543 (list of girls' names and black book)
• USVP00193337 (subpoena request)
• USVP00342213 (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 nterview)
• EPS001.1209.1255 (2007 Accurint report)
• EPS001.14683.14687 (200 interview)
• EPS001.14688-14692 (2007 interview)
• EPS001-27924-28579 (Bill info for
• 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
• USVP00000910 (black book)
EFTA01653839
• 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)
5.
JE
• EPS001.27924.28579 (listed in bill log for phone
6.
JE
• EPS001.1200.1204 (listed in 2007 interview of
• EPS001-1259-1259 (2007 Accurint of number)
• EPS001.14683-14687 (listed in 2007 interview of
• EPS001-17528-17655 (Cingular records for
• EPS002-013073 (listed in 2007 interview of
• EPS002-013494 (listed in 2007 interview of
• EPS002-013499 (listed in 2007 interview of
• EPS002-030229 (listed in phone records foil
• EPS002-030347 (listed in phone records for■
• EPS002-032249 (listed in phone data for
• EPS002-032309 (listed in phone data for
• EPS002-041015 (listed in 2007 interview of
• EPS002-041077 (listed in 2007 Accurint report)
• EPS002-041759 (2007 interview of
• EPS002-041821 (2007 Accurint report)
• EPS002-049417 (toll data for
• EPS002-049455 (toll data for
• EPS002-084127 (2007 interview of
• EPS002-084544 (2007 interview of
EFTA01653840
• EPS002-137514 (toll data for
• EPS002-137627 (toll data to
• USVP00000082 (2018 interview of
• USVP00207989 (listed on FL Massage list for
• USVP00342183 (phone records for
• SVP00342186 (phone records top
• USVP00342439 (phone records tor
• USVP00351961 (2007 interview a
• USVP00351963 (2007 interview of
• USVP00352086 (FL Case information/listed in interview a
• EPS001.1261-1272 (would not open/don't know what it contains)
• EPS001-1273-1286 (would not open/don't know what it contains)
• EPS001.146833.14687 (2007 interview of
• EPS001.17528.17655 (phone records for
• EPS001.20471.20657 (would not open)
• EPS002-013073 (2007 interview of
• EPS002-013079 (2007 interview of
• EPS002-013494 (2007 interview of
• EPS002-013499 (2007 interview of
• EPS002-030241 (phone records foi
• EPS002-030359 (phone records fo
• EPS002-041079 (2007 Accurint report)
• EPS002-041091 (2007 Accurint report)
• EPS002-041823 (2007 Accurint report)
• EPS002-041835 (2007 Accurint report)
• USGME01848764 (black book)
JE SW
• USGME01099266 (message book entries)
UPDATE
7.
JE
• EPS001-27924-28579 (phone records tor
• EPS001-9109.9236 (phone records foi
• EPS001-9497-9551 (Epstein multi-line records for Accoun
• EPS001-9552-9608 (Epstein multi-line records for Account
• EPS001.9609.9661 (Epstein multi-line records for Accoun
• EPS002-029203 (Epstein multi-line records for Account
• EPS002-029258 (Epstein multi-line records for Account
• EPS002-029315 (Epstein multi-line records for Account
• EPS002-030229 (phone records to
• EPS002-030241 (phone records for
• EPS002-030347 (phone records fo
• EPS002-030359 (phone records for
EFTA01653841
• EPS002-032227 IIIM'hone analysis)
• EPS002-032249 (phone records tor
• EPS002-032287 Phone analysis)
• EPS002-032309 (phone records to
• EPS002-033921 (phone records to
• EPS002-034340 (Epstein multi-line records for Account
• EPS002-034395 (Epstein multi-line records for Account
• EPS002-034452 (Epstein multi-line records for Account
• EPS002-034511 (phone records for
• EPS002-034930 (Epstein multi-line records for Account
• EPS002-034985 (Epstein multi-line records for Account NIMIII.P.
• EPS002-035042 (Epstein multi-line records for Account
• EPS002-049417 (phone records tor
• EPS002-049455 (phone records tor
• EPS002-110332 (phone records tor
• EPS002-137552 Phone analysis)
• EPS002-137665 Phone analysis)
• GIUFFRE001573 (black book)
•
EFTA01653842
DataSet-10
Unknown
10 pages
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT,
INAND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.: 502009CA0408003OOOCMBAG
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant, JUDGE: DAVID CROW
VS.
SCOTT ROTHSTEIN,
individually, BRADLEY J.
EDWARDS, individually,
Defendants/Counter-Plaintiff,
EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury
Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of
Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits (numbered in order as they
appeared in Edwards's Revised Exhibit List):
I. All applicable criminal statutes
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 Abernathy: A Workbook for Erotic Slaves and Their Owners"
6. Non-Prosecution Agreement
7. Jane Doe 102 Complaint
EFTA01113966
8. Messages taken from message pads found at Epstein's home
9. Documents related to Jeffrey Epstein produced by Alfredo Rodriguez
10. Jeffrey Epstein flight logs
I I. Jeffrey Epstein phone records
12. phone records
13. Jail Visitation Logs
14. Jeffrey Epstein's probation file
15. All probable cause affidavits related to criminal investigation of Jeffrey Epstein
16. All evidence, information and documents taken or possessed by FBI related to
criminal investigation of Jeffrey Epstein
17. Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein
18. Video of Search Warrant of Jeffrey Epstein's home being executed
19. Application for Search Warrant of Jeffrey Epstein's home
20. Complain v. Epstein and all subsequent Amended Complaints
21. All records of homes, properties, bank accounts and any and all records related to
Jeffrey Epstein's assets
24. List of corporations owned by Jeffrey Epstein
25. All documents evidencing relationship between Jeffrey Epstein and Jean Luc
Brunel
26. All documents evidencing relationship between Jeffrey Epstein and MC2 or any
modeling agencies
27. Yearbooks of Jane Doe
28. 2002 Royal Palm Beach High School Year Book
29. 2001 Royal Palm Beach High School Year Book
30. 2003 Palm Beach Gardens High School Year Book
EFTA01113967
31. Affidavit and Application for Search Warrant on Jeffrey 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
35. All documents related to Jeffrey Epstein's 6/30/08 conviction
36. Jeffrey Epstein's criminal plea colloquy
37. Public records from the Department of Corrections related to Jeffrey Epstein
38. Records from the Florida Department of Law Enforcement 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 Intelmgatories in 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
42. All discovery related responses of Jeffrey Epstein in 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 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. 502008CA028051XXXXMB AB and E.W. v.
Jeffrey Epstein, Case No. 502008CP003626XXXXMB
EFTA01113968
48. Any and all newspaper articles, online articles or publications related to Jeffrey
Epstein
49. Report and Analysis of Jeffrey Epstein's assets
50. Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home.
51. Photos of all of Jeffrey Epstein's properties, cars, boats and planes
52. Probable Cause Affidavits prepared against Jeffrey Epstein anc
53. Audio tape of
54. Photographs, videos and books taken in the search warrant of Jeffrey 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
57. Expert Dr. L. Dennison Reed's Report of Victim
58. Palm Beach Police Department Incident Report dated 4/20/06
59. All reports and documentation generated by Palm Beach Police Department
related to Jeffrey Epstein
60. All Witness Statements generated by Palm Beach Police Department relating to
Jeffrey Epstein
61. Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs
62. Passenger lists for flights taken by Jeffrey Epstein
63. Letter from Jeffrey Epstein to Alberto Pinto regarding house island project
64. Jeffrey Epstein's bank statements
Jeffrey Epstein's tax returns (this item not numbered on Edwards's Trial Exhibit
Listt)
' • ' • ein, Jeff Puller
EFTA01113969
66. DVD of plea and colloquy taken on 6-30-08
67. Transcript of plea and colloquy taken on 6-30-08
68. Massage Table
69. Lotions taken from Jeffrey Epstein's home during search warrant
70. Computers taken from Jeffrey Epstein's home during search warrant
71. Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during
search warrant
72. No Contact Orders entered against Jeffrey Epstein
73. Criminal Score Sheet regarding Jeffrey Epstein
74. Documents evidencing Jeffrey Epstein's Community Control and Probation
75. Jeffrey Epstein's Sex Offender Registration
76. Jeffrey Epstein's Booking photograph
77. CAD calls to 358 El Brillo Way, Palm Beach FL 33480
78. List of Jeffrey Epstein's House contacts
79. Documents related to Jeffrey Epstein's investments
80. Letter from Chief Michael Reiter to Barry Krischler
81. List of planes owned by Jeffrey Epstein
82. Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
83. Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
84. Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
85. Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
86. Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
87. Letter from Goldberger dated 6-22-06
EFTA01113970
88. All subpoenas issued to State Grand Jury
89. Documents related to the rental of a vehicle fa
90. Ted's Sheds Documents
91. Documents related to property searches of Jeffrey Epstein's properties
92. Arrest Warrant
93. Police report regardin picking up money dated 11-28-04
94. List of Trilateral Commission Members of 2003
95. Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
96. Guy Fronstin letter dated 4-17-06
97. Jeffrey Epstein Account Information
98. Jeffrey Epstein Criminal Closeout Sheet-
99. Jeffrey Epstein Polygraph Test and Results
100. Victim% GED testing information and results
101. JEGE, Inc. Passenger Manifest
102. Hyperion Air Passenger Manifest
103. Flight information fa
104. Passenger List Palm Beach flights 2005
105. Jeffrey Epstein notepad notes
106. Pleadings of _1 and 2 v. US case
107. Jeffrey Epstein 5th Amendment Speech
108. Reiter letter to Krisher dated 5-1-06
109. Jail receipts of Jeffrey Epstein
110. 'olice Report dated 11-28-04
EFTA01113971
11. Compulsory Medial Examination of victim, CMA
112. Victim's school records and transcripts
113. Victim Notification letter dated 7-9-08
114. Victim's employment records from IHOP
115. Police report of Juan Alessi theft at Jeffrey Epstein's home
116. Victim's Medical Records from Milton Girls Juvenile Facility
117. Victim's Medical Records from Dr. Randee Speciale
118. Victim's Medical Records from Wellington Regional Hospital
119. Victim's Medical Records from St. Mary's Medical Center
120. Victim's Medical Records from United Health
121. All surveillance conducted by law enforcement on Jeffrey Epstein's home
122. Emails received from Palm Beach Records related to Jeffrey Epstein
123. All items listed on the Palm Beach Police Property Report Lists
124. All items taken in the execution of the search warrant of Jeffrey Epstein's home:
358 El Brillo Way, Palm Beach FL 33480
125. All copies of convictions related to Jeffrey Epstein
126. Jeffrey Epstein criminal records
127. All documents produced by Palm Beach Police Department prior to the deposition
of Detective Recarey
128. Photographs of all persons listed on Victims' Witness Lists
129. Statements, deposition transcripts, videotaped depositions and transcripts taken in
connection with this and all related cases and exhibits thereto
130. Any and all expert witness reports and/or records generated in preparation for this
litigation by any party to this cause
132. Curriculum vitae of Dr. Ryan Hall
EFTA01113972
133. Any articles or publications of Dr. Ryan Hall
134. Any articles or publications of Dr. Richard Hall
135. Any articles or publications of Dr. L. Dennison Reed
136. All items and documentation review by Dr. L. Dennison Reed
137. Transcript and video (DVD) of IME of Victims
138. All exhibits to Dr. L. Demlison Reed's Deposition
139. All exhibits to Dr. Richard Hall's Deposition
140. All items and documents reviewed by Dr. Richard Hall
141. All items and documents reviewed by Dr. Ryan Hall
142. Demonstrative aids and exhibits including, but not limited to, anatomical charts,
diagrams and models, surveys, photographs and similar material including blow-ups of
the foresaid items.- need to see before we agree
143. Any and all mortality tables
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.
150. All attachments to Edwards's Motion for Summary Judgment.
151. All time records and hourly billing documentation produced in discovery.
152. All pleadings filed by Epstein in the Rothstein bankruptcy proceeding.
153. All Settlement Agreements between Epstein and victims of his sexual
molestations.
Epstein objects to all of the afore-referenced Exhibits on several grounds,
including, but not limited to: Relevance; Prejudice; Confusion; Misleading; Hearsay;
Impermissible/Inadmissible Character Evidence; Impermissible/Inadmissible Evidence of
other Crimes, Wrongs, or Acts; and the fact that most of the items on this list were not
EFTA01113973
provided to Epstein through discovery or otherwise in this case, in direct violation of this
Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, and
Epstein's "Exhibit A" to Bradley J. Edwards's Deposition Duces Tecum.
By listing these grounds for objection to the afore-listed Exhibits, Epstein is not
waiving his right to assert additional objections, or objections to any non-listed Exhibits
at trial.
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served,
via electronic service, to all parties on the attached service list, this September 19, 2013.
/s/ Tonja Haddad Coleman
Tonja Haddad Coleman, Esq.
Florida Bar No.: 176737
Tonja Haddad, PA
5315 SE 7th Street
Suite 301
Fort Lauderdale, Florida 33301
954.467.1223
954.337.3716 (facsimile)
Attorneys for Epstein
EFTA01113974
SERVICE LIST
CASE NO. 502009CA040800XXXXMBAG
Jack Scarola, Esq.
jsx@searcylaw.com; mep@searcylaw.com
Searcy Denney Scarola et al.
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409
Jack Goldberger, Esq.
jgoldberger@agwpa.com; smahoney@agwpa.com
Atterbury, Goldberger, & Weiss, PA
250 Australian Ave. South
Suite 1400
West Palm Beach, FL 33401
Marc Nurik, Esq.
I East Broward Blvd.
Suite 700
Fort Lauderdale, FL 33301
Bradley J. Edwards, Esq.
brad@pathtojustice.com
Fanner Jaffe Weissing Edwards Fistos Lehrman
425 N Andrews Avenue
Suite 2
Fort Lauderdale, Florida 33301
Fred Haddad, Esq.
Dee@FredHaddadLaw.com
1 Financial Plaza
Suite 2612
Fort Lauderdale, FL 33301
Tonja Haddad Coleman, Esquire
Tonja@tonjahaddad.com; efiling@tonjahaddad.com
Law Offices of Tonja Haddad, P.A.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
Attorneys for Jeffrey Epstein
EFTA01113975
DataSet-10
Unknown
4 pages
Exhibit C
EFTA00095723
1
(Rev. 01-31.2003) • •
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, alona with!
PBCRA obtained information t om
the City of Palm Beach Police Department (PBPD)I
Epstein
Following the ceceipt of the case files from the PBPD,
PACPA honan intprviPwinnI b6
I
I who reported a similar b7C
series of events. In particular,( 'described how contact b7D
was made via telephone, primarily' 1 I
•
ale.- rim.- losoto- V/
CONFIDENTIAL SDNY_GM_02050812
EFTA00095724
•1
To: Albuquerque Et: Miami
•
Re: 31E-MM-108062, 12/06/2006
b6
b7C
b7D
mat by Fnetnin
nd some
On most
instances. Eosteid
exam le, t '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 addresse
to E stein and others were addressed tot
Additional messages recovered during the search
con aine ext confirming appointment times.
During the PBCRA's investigation,'
that 'would contact i
2
CONFIDENTIAL SDNY_GM_02050813
EFTA00095725
•.
To: Albuquerque AL: Miami •
Re: 31E-MM-108062, 12/06/2006
(nle investigation revealed tnac
the flights to Palm Beach,I tould contact somi of
w4= rail nhnnm Tha mn cana N nta ovidonno 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 agents) contact SAj
FBI Miami, West Palm RA, I I or SAI
'for investigative direction and
questions.
3
L
CONFIDENTIAL SDNY_GM_02050814
EFTA00095726
DataSet-10
Unknown
2 pages
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
Florida Bar No.: 542075
EFTA00730318
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
EFTA00730319
DataSet-10
Unknown
3 pages
From: '
To: ' (USANYS) [Contractor]"
Cc: ; )
)<
Cc: (NYPD)
Subject: (EXTERNAL EMAIL] - R
Thanks, Here are some options next week:
• 7/26 before 12pm or after 3pm
• 7/28 12pm to 2pm
EFTA00089845
• 7/29 before 11am
From:
Sent: Monday, July 19, 2021 1:52 PM
To: (USANYS) >
I<
Cc:
Subject: RE:
s traveling Wednesday for vacation. Can you suggest some days/times next week? We will have the message
pads and I'll see about getting a copy of the chains.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From: (USANYS)
Sent: Monday, July 19, 2021 11:37 AM
To: (NY) (FBI) < )'; >;
Cc: (NYPD) <
Subject: (EXTERNAL EMAIL) - R
in advance of the meeting, can you please track down any and all chains of custody in FBI possession?
Thanks,
From: (USANYS)
Sent: Monday, July 19, 2021 11:26 AM
To: >; )< >;
Cc:
Subject: RE
Thanks, Does this week work fo If so, we could do between 12pm and 4pm on Wednesday or 10:30 am
to 12pm on Thursday. If I should get so or next week instead, please let me know. Also, can you please have the
physical message pads with you for the WebEx witaust in case?
From:
Sent: Wednesday, July 14, 20215:57 PM
To:' I sc >; (USANYS) < >*,
Cc:
Subject:
Hi all,
EFTA00089846
I spoke with today. She can meet with us but may go into a local FBI office to get assistance with video
setup. I told her I would touch base with her early next week to schedule a day and time that works for
everyone. Let me know what you all are thinking on timing and I'll let her know.
Thanks,
EFTA00089847
DataSet-10
Unknown
3 pages
1
(Rev. 01-31.2003) • •
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, alona with!
PBCRA obtained information t om
the City of Palm Beach Police Department (PBPD)I
Epstein
Following the ceceipt of the case files from the PBPD,
PACPA honan intprviPwinnI b6
I
I who reported a similar b7C
series of events. In particular,( 'described how contact b7D
was made via telephone, primarily' 1 I
•
ale.- rim.- losoto- V/
CONFIDENTIAL SDNY_GM_02050812
EFTA00084113
•1
To: Albuquerque Et: Miami
•
Re: 31E-MM-108062, 12/06/2006
b6
b7C
b7D
mat by Fnetnin
nd some
On most
instances. Eosteid
exam le, t '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 addresse
to E stein and others were addressed tot
Additional messages recovered during the search
con aine ext confirming appointment times.
During the PBCRA's investigation,'
that 'would contact i
2
CONFIDENTIAL SDNY_GM_02050813
EFTA00084114
•.
To: Albuquerque AL: Miami •
Re: 31E-MM-108062, 12/06/2006
(nle investigation revealed tnac
the flights to Palm Beach,I tould contact somi of
w4= rail nhnnm Tha mn cana N nta ovidonno 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 agents) contact SAj
FBI Miami, West Palm RA, I I or SAI
'for investigative direction and
questions.
3
L
CONFIDENTIAL SDNY_GM_02050814
EFTA00084115