EFTA00230786.pdf

EFTA00230786  U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 Facsimile: June 12, 2009 DELIVERY BY HAND Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: Pursuant to the terms of the Non-Prosecution Agreement, the United States Attorney's Office for the Southern District of Florida hereby provides you with notice that the United States Attorney has determined, based on reliable evidence, that Jeffrey Epstein has willfully violated one of the conditions of the Non-Prosecution Agreement. Specifically, on May 26, 2009, Jeffrey Epstein, through his counsel, filed a "Motion to Dismiss the First Amended Complaint or, in the Alternative, for a More Definite Statement," in the matter of Jane Doe No. 101 v. Jay Epstein, Court File No. 09-CV-80591-ICAM. "Jane Doe No. 101" was on the list provided to Mr. Epstein's attorneys of individuals whom the United States had identified as victims, as defined in 18 U.S.C. § 2255, and "Jane Doe No. 101" has elected to proceed exclusively under 18 U.S.C. § 2255. By filing the Motion to Dismiss, Mr. Epstein is contesting liability and, therefore, has violated Term 8 of the Non-Prosecution Agreement. Based upon Mr. Epstein's breach of that term, the U.S. Attorney's Office will pursue its remedies. The U.S. Attorney's Office also is continuing its review of Mr. Epstein's filings in the civil suits to determine whether additional breaches have occurred. If any are EFTA00230787 JACK GOLDBERGER, ESQ. JUNE 12, 2009 PAGE 2 OF 2 identified, they will be communicated to you in accordance with the terms of the Non- Prosecution Agreement. Sincerely, Acting United States Attorney By: Assistant United States Attorney cc: Roy Black, Esq. EFTA00230788 07/28/2011 13: 11 FAX Idlootio04 KIRKLAND & ELLIS LLP Fax Transmittal 300 North LaSalle Street Chicago, Illinois 60654 Phone: (312) 862-2000 Fax: (312) 862-2200 Please notify tm Immediately if any pages are not received. THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY BE ATTORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND IS INTENDED ONLY FOR THE USE OF THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY AT: (312) 862-2000, To: Company: Fax #: Direct #: United States Attorney, Southern District of Florida CC: Company: Fax #: Direct tt: Martin G. Weinberg, Esq. From: Date: Pages Weaver: Fax Direct Sandra Musumeci for July 29, 2011 4 Jay P. Lefkowitz, P.C. Message: Please see the attached letter, in response to your letter to Martin Weinberg of July 27, 2011, concerning Jeffrey Epstein. Thank you. Docuracna EFTA00230789 07/23/2011 13:12 FAX lit) 0 0 2/0 0 4 KIRKLAND & ELLIS LLP ANDAMATIDPARTNEWWWS 601 Lexington Avenue New York, New Yuck 10022 Jay P. LalloyeAtt P.C. To Cady: Facsinlie: latielkowitoakiddand.cat vevnv.kirkland.corn July 29, 2011 Delivery by Facsimile CONFIDENTIAL Assistant United States Attorney United States Attorney, Southern District of Florida 500 S. Australian Avenue West Palm Beach, FL 33401 Re: Jeffrey Epstein Dear Ms. Thank you for your letter of July 27, 2011 to my co-counsel Martin Weinberg concerning the request by the New York District Attorney for copies of the Non-Prosecution Agreement ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to believe that any such disclosure would violate the confidentiality agreement between your Office and Mr. Epstein as well as the provisions of Fed. R. Crim. P. 6(e). As to the NPA, you have repeatedly asserted in Doe v United States, No. 9:08-cv-80736- KAM, that the NPA was a confidential document. For instance, in paragraph 6 of Document 14, your own Declaration, you stated that the NPA contained "an express confidentiality provision!' In opposing the Motion to Unseal the NPA that was filed by Jane Doe, you stated that you had informed Judge Marra of the confidentiality provision during an earlier telephonic slat is conference occurring on August 14, 2008 which "the United States was obligated to honor," Document 29 at 1, and that "the parties who negotiated the Agreement, the United States Attorney's Office and Jeffrey Epstein, determined that the Agreement should remain confidential," Document 29 at 2. Further, you deemed the NPA "confidential," for understandable purposes, in your September 3, 2008 letter to Robert Josefsberg in which you informed him that Judge Marra had set forth procedures for providing the NPA only to those counsel and "victims" who executed a Protective Order preventing its subsequent disclosure. The New York Assistant District Attorney, Ms. Morse, is representing the prosecution in an appeal regarding a sex offender registration determination, and any disclosure of the NPA to her has the potential to result in its use in that appeal and the real risk that the appellate court will unseal it. We believe it to violate both the spirit and the most logical interpretation of the NPA, Chicago Hong KOng London Los Angeles Munich Palo Alto San Francisco Shanghei Washington D.C. Ka2 19419748.2 EFTA00230790 07/29/2011 13: 12 FAX e 003/004 KIRKLAND & ELLIS LLP A. Vitiate& July 29, 2011 Page 2 paragraph 13, for you to disclose it absent a subpoena -- which we could oppose in the jurisdiction from which it emanated. We further believe that when parol evidence supplements the text of paragraph 13 of the NPA, it is perfectly apparent from your prior submissions that you as well as we believed the NPA to contain "an express confidentiality provision" that your current willingness to disclose absent court process violates. As to the "victim list," again, not only is it confidential given its nexus to the NM, but your own prior letters tie the list to the Federal Grand Jury investigation and thus to the non- disclosure provisions of Fed. R. Crim. P. 6(e). On July 8, 2008, you wrote to Jack A. Goldberger, Esq., and informed him that on June 30, 2008, "the United States Attorney's Office provided [him] with a list of thirty-one individuals 'whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein.'" (emphasis added). On July 9, 2008, you wrote in a follow-up letter to Mr. Goldberger that "the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States was prepared to include in an indictment. This means that, pursuant to Justice Department policy, these are individuals for whom the United States believes it has proof beyond a reasonable doubt that each of them w v n enumerated offense." (emphasis added). First Assistant United States Attorney used similar language in tying the names victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. ', to Mr. Lefkowitz at 2, 3; see aiv your email to Mr. Lcfkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'individuals whom [the United States] was prepared to name in an Indictment...,'" thus clearly providing the nexus between the list and the Grand Jury investigation and its corollary, the protections from non- disclosure enumerated in Fed. R. Crim. P. 6(e). In terms of case law, the names of witnesses that either testified or were identified during Grand Jury proceedings are subjec secrecy provisions of Fed. R. Crim. P. 6(e). $se, e.g., In re Grand Jury Subpoena, Judith, 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent with these purposes, we have recognized that grand jury secrecy covers 'the identities of witnesses or jurors, the substance of testimony as well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing in re Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); sce alsq SEC v Dresser hglustr, inc„ 628 F.2d 1368, 1382 (D.C. Cir. 1980); fund for Constitutional Gov't v Nat'l Archives & Records Serif., 656 F.2d 856, 869 (D.C. Cir. 1981). Indeed, it is generally recognized that the scope of protection accorded to Grand Jury proceedings under Rule 6(e) is broad and encompasses, among other things, information such as the "victim list" at issue here: Kea. 104397482 EFTA00230791 0 7 / 29/2011 13:12 FAX 21004/004 KIRKLAND & ELLIS LLP July 29, 2011 Page 3 We construe the secrecy provisions of Rule 6(e) to apply not only to disclosures of events which have already occurred before the grand jury, such as a witness's testimony, but also to disclosures of matters which will occur, such as statements which reveal the identity of persons who will be called to testify or which report when the grand jury will return an indictment. In re Grand Jury Investigation 610 F.2d 202, 216-17 (5th Cir. 1980).1 We believe that confidentiality applies to the requested information. We believe that any non-compulsory handover of the list or NPA is inconsistent with the positions you have previously taken in related litigation. Accordingly, we request that you reconsider and decline the request of the New York District Attorney. Sincerely, P. Le owitz, P.C. Cc: Martin G. Weinberg JPL/slm Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit. Den Donner v. City of Prichard. Ala. 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 194397482 EFTA00230792  Roy BLACK BLACK HOWARD M. SREBNICK Scan A. KORNSPAN SREBNICK JESSICA FONSECA-NADER KATHLEEN P. PHILLIPS LARRY A. STUMPF KORNSPAN AARON AMNON MARIA NEYRA MARCOS BEATON, JR. JAC/OE PERCZEK STUMPF MATOIEW P. CYBRIEN MARK A.J. SHAPIRO P.A JENIPER J. SOLILIKIAS JARED NoAH Fox E-Mail: September 1, 2009 Assistant U.S. Attorney United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 RE: Jeffrey Epstein Dear M: Once again I need to send you a note about Jeffrey Epstein, mainly to keep you in the loop. we don't inadvertently violate any provision of his agreement with your office. As I am sure you are aware, Mr. Epstein has finished the incarceration portion of his sentence and is now serving the one year of community control as mandated by both his state plea and the terms of the non- prosecution agreement with the United States Attorney's Office for the Southern District of Florida. Mr. Epstein is in compliance with all terms of his community control and is applying for transfer of his supervision from the State of Florida to his primary residence, the Virgin Islands. This transfer is being requested through the Intrastate Compact for Transfer of Adult Supervision (ICAOS). The ICAOS is the mechanism for which transfers of probation and community control are effectuated. The process requires the offender to seek the approval of the sending state (in this case Florida) and, if they agree, the receiving state (in this case the United States Virgin Islands) and the United States Virgin Islands after investigation has pre-approved the transfer under the same exact conditions of supervision as imposed in Mr. Epstein's community control sentence in the State of Florida. Even though Mr. Epstein is requesting the transfer he is still at the home 201 5. Bisare Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: • Fax: • www.Royalack.com EFTA00230793 September 1, 2009 Page 2 in Palm Beach following the rules of state community control. As Mr. Epstein's lawyers, we believe that his request to administratively transfer his community control is in full compliance with both his state plea agreement and the non- prosecution agreement with the United States Attorney's Office. Nonetheless we have taken to heart your previous suggestion of erring on the side of caution and thus we are advising you of this request. I am happy to discuss this with you at any time. I did not want to set an appointment to see you on this issue since I imagine you have more pressing matters to deal with than a transfer of a state community control matter. Very I Roy Black RB/wg Black. SrebnIck, Komspan & Stumpf. PA EFTA00230794  ROY BUCK BLACK HOWARD M. SREBNICK SCOTT A. KORNSPAN SREBNICK JESSICA FONSECA-NADER KATHLEEN P. PHIWPS LARRY A. STUMPF KORNSPAN AARON AMNON MARIA NEYRA MARCOS BEATON, JR. JACKIE PERCZEK & STUMPF MATTHEW P. O'BRIEN MARK A.J. SHAPIRO —PA— JEMPER J. Soutaas JARED NOAH Fox E-Mail: February 18, 2010 Esq. Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Ms I .: Thank you for your letter of February 11, 2010. We write to update you about ongoing efforts to reach an agreement with Robert Josefsberg regarding the amount of fees and costs properly owed to him by Mr. Epstein pursuant to the NPA. On February 16, 2010 Mr. Epstein's principal civil counsel Bob Critton advised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr. Josefsberg on two occasions between now and March 1, 2010 to review Mr. Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a non- adversarial resolution of all outstanding fee issues. Mr. Critton also transmitted to Mr. Josefsberg an Agreement for Special Master to Determine Amount of Attorneys' Fees and Costs ("Special Master Agreement", signed by Mr. Epstein, containing terms and conditions previously agreed to by Mr. Josefsberg, which would mandate binding mediation before a neutral third party in the event the proposed settlement discussions did not resolve all outstanding issues in an expeditious manner. We want to assure you that Mr. Epstein fully intends to fulfill his obligations under the NPA. We regret that issues remain unresolved regarding whether all of the fees and costs being sought by the attorney representative - which now total $1,947,000 exclusive of the $526,466 already paid by Mr. Epstein - meet the criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA language, and Mr. Critton, each strongly believe that significant amounts of the fees and costs billed by Mr. Josefsberg are outside the scope of Mr. Epstein's fee- 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: • Fax: • www.RoyBlack.com EFTA00230795  Esq. February 18, 2010 Page 2 related payment obligations under the NPA. We hope that the fee-related issues can be resolved by further settlement discussions or by relying on the Special Master Agreement signed Tuesday February 16, 2010 by Mr. Epstein. Mr. Epstein and his counsel believe that these options are consistent with the NPA, are good alternatives to contested litigation, and are reasonable given the unexpected magnitude of the bills and their inclusion of charges for legal work that was clearly related to the preparation of litigation and thus outside Par 7C of the Addendum as well as for extensive work performed by attorneys from outside Mr. Josefsberg's law firm. Mr. Josefsberg previously advocated for settling outstanding issues through a Special Master Agreement nearly identical to the one executed Tuesday by Mr. Epstein. In fact, Mr. Josefsberg and Mr. Epstein had each agreed in the past to a specific Master as a third-party neutral to conduct proceedings to resolve the fee issues. However, the selected Master withdrew. We hope that the Special Master Agreement will provide a basis for a prompt resolution of any issue not resolved by the parties through further discussions. Respectfully submitted, MARTIN WEINBERG, ESQ. ROY LACK, ESQ. By /wg co: Black, Srcbnick. Kornspan & Stumpf, P.A. EFTA00230796 EFTA00230797 EFTA00230798  Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Police Case#: 05-368 (1) Defendant: Jeffrey Epstein Race/Sex: White Male DOB: 01-20-1953 Charges: Unlawful Sexual Activity with a Minor (4) counts Lewd and Lascivious Molestation From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, and Sworn taped statements were taken from five victims and seventeen witnesses concerning massages an un awful sexual activity that took place at the residence of Jeffrey Epstein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein, for which received monetary compensation. During the visit they would be introduced to , Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothin to rovide the massage. As the victims complied and provided the massages, E stein would On occasion, Epstein would introduce a massager/vibrator and rovided the masse e. On three separate occasions, Epstein had intercourse and . At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff' had touched her while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, Estated that a cousin of boyfriend and classmate at Ro 1 Palm Beach High School, worked for a wealthy man and did sexual avors for him. She also admitted that had offered her an opportunity to make money. During the beginning of the month of February 2005, xplained that she was first approached bye go with her to Epstein's house. •stated that a ong with a Hispanic female, later identified at pick her up at her father's house on a un ay. was not sure of the exact dates but knew it was a un ay. told her father that they were going shopping but in reality =drove them to Palm Beach. During the drive a e fm egoing 1113 I uifl u Wab anw o to. affirm before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230799  Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 conversation occurred between and whereas" 'eportedly told Ethat if Jeff asked her age, she should say she was eighteeni,vas later confirmed by the Ms father that picked his daughter up on February 6, 2005. According to Is father, drove a pick up truck. •described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house stated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they wanted,IM stated they were there to see Epstein. The male allowed them to continue walking up to the house. tated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortl thereafter, Epstein and his assistant, described as white female with blond hair and later identified as i , entered the kitchen. Epstein introduced himself to . nlescribed Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. _and Epstein left the kitchen leaving Mitlone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. Mvas instructed to follow upstairs. 'ecalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. Mecalled there, a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told Mto take off her clothes. stated Epstein was stem when he told her to take off her clothes. Maid she did not know what to do as e was the only one there in the room she took off her shirt leaving her bra on. Epstein had removed his towel and told the Eto take off everything. astated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. Whited she then removed her pants leaving her thon anties on. Epstein then instructed her to give him a massage pointin to a specific lotion for her to use. As began to give E stein the masse e, he told her to get on his back. tated she straddled herself on Epstein's ack whereby S aid Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed.0 massage his chest. vas now standing on the ground and resumed massaging Epstein's chest area. tated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turn to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing tests urnent was SWUM lu VI aflII in of-Florida before me this 1" day of May, 2006 by County of Palm Beach Det EM, who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230800  Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 tated there was no penetration as the Mrecal Re IEpstein ejaculating ecause he had to use the towel to wipe himself as he of off the table. Epstein then left the room and. got dressed. She went back downstairs where she met with Msaid she was paid three hundred ollars in cash from Epstein. Before she left, Epstein asked o leave her phone number. AsMand were leaving the house, latold • she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for to assist with the investi ation. At our direction conducted controlled taped phone calls to s cellular telephone . lispoke with in an attempt to arrange another meeting wit Epstein. Masked what di she need to do to make more money. gtated, "the more you do, the more you get paid." had subsently called back Nand left a voice mail message for her indicating that she had set up an appointment v for o go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated and Niname at 11:00 am. This was the time frame Shad informed El to be ready to go work at Epstein's house. On October 3, 2005, Sgt % and I went toil!! residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knot door and met wia =Sivas told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. _was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. =voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, as brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I egan e interview by asking 'M'ow she became acquainted with Epstein. that approximately two years ago, just after she turned 17 of age, she was approached by a en named et the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. a hought about the offer and agreed to meet with Jeffrey. I he foregoing Instrument was ffirnied State of-Florida before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230801  Probable Cause Affidavit Palm Beach Police Department Agency OR1F FLO 500600 nknown last name) and Tony (Unknown last name) picked up and she was taken to Epstein s house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. then left the room and informed Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Durin the massage, tated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated thatEpstein and she felt uncomfortable. old Epstein, I'll massage you but I don't want to be touched. tated she performed the massage n ed. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated toathat he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. tated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brought to see Epstein, each time she was paid $200. tated she had brought the following girls: said that at the time she brought these girls to Epstein's house they were a1114 through 16 years of age. I asked-which one was the youngest. _advised was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a e, possibly naked, and allow some touching. I asked her i as aware. She stated every girl she brought knew what to expect. She explained she knew that. want make money. She approached d explained about going to work for Jeff, agreed and arrangements were made to bring her to Epstein's house on a weekend. tated that she and (Later identified as picked up EU her house. tated that at that time she was driving a red pickup truck. They traveled tcatein's house and entered rou the kitchen door. They met with the house chef and Epstein's assistant =. Was introduced to Epstein while they were in the kitchen area. led Elipstairs and Epstein went upstairs. When the massage was over eturned to the kitchen area. stated she was paid $200.00 for bringing.to Epstein's house. tated Mtold her she was paid $300.00 for the massage. dated thatavas the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by She continued stating that she had no direct contact with Epstein I tie foregoing instrument was swui u to in -affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230802  Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 when he was going to travel to Palm Beach. aid when Epstein announces to his assistant that he is traveling to Palm Beach, would en contact to arrange girls to "work" for Epstein. stated that once her arents discovered that she was visiting Epstein, they disapproved of the encounters wi and she stopped. further stated that still tries to call house and leaves messages. Sgt entered the room and explained to at based on her own statements, she had implicated herself by bringing underage girls to Epstem's ouse. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. Asians being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with a sixteen year-old female who was brought to Epstein's residence b} We met with other at their front door. We ex ined the ongoing investigation and asked to speak with Mas we had in ormation that she had "worked" for MI Mrs.Mintroduced us to her husband and allowed us entry into the home. We sat in the dining room and met with As she was under the age of eighteen, Mrs ,wasadvised we would be speaking with her. She expresse if her daughter had information, she wanted to assist. We interviewed. who denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with pproximately eight months ago and sat in the kitchen with the house chef, but nothing happened. s ep ere present during the interview, we felt that as withholding information from us. She made several comments as to putting the entire incident behind her. eft my tel hone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked Mrs or her time and left the area. She stated she would askliagain after we left as to what happened at Epstein's ouse. I informed her that, had my telephone number and hopefully she would call. On October 4, 2005, Det and I drove to the ome and met with and During a sworn taped statement, stated approximately a year ago when she was seventeen years old, she was taken to a house by tated she knows because they both attend Royal Palm Beach High School. She was told she could make money working before me this 1" day of May, 2006 by County of Palm Beach Det who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230803  Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 for Jeff. She was told she would have ',vide a massage to Jeff. stated upon her arrival to the house she was brow t to the kitchen area by They met with the house c of who was already in the kitchen area. tated-would wait for her in the kitchen. was introduced to, Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. tated she kept her clothes on during the masse e. She advised sometime during the massage, Epstein and pulled her close to him. said she was uncomfortable bL.xt te incident involving Jeff. At the conclusion of the massage, she was pai .00 for the massage. I asked ME if she has any formal training in massages to which she r lied no. I asked her if received any monies for taking her to perform the massage. stated Ireceived money for taking her there but was unsure in the tated she returned to Epstein's house on another occasion wit d another irl, dated she waited in the kitchen with while-was taken upstairs by tated s e on y did the massage once as she was uncom orta le with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reachnilvia cell phone. A voice mail messa e on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested o call her back reference the police questionin provided the incoming telephone number as tated she inadvertently told about the police investigation because had called her to iter about how she just received a rental car from Jeff Epstein called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family a visit Epstein. asked her what was oin on at the house that the police would be asking questions. stated then called Jeff and and asked what was going on reference the ongoing police investigation. Accordin to a has since then been trying to contact her to ask about the police questions. I instructed tot to contact and do not provide any more information ton she would notify Jeff Epstein and what was transpiring. On October4, 2005, I made telephone contact with.who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with MI During a taped recorded statement tated the following: approximately a year ago, when she was sixteen years of ageaook her lit to Epstein s ouse twice. She knows because they both attend Royal Pal Beach High School. The first time she went, lalrove to the house. They entered through the kitchen area where she was i be foregoing instrument was Satan tv ur affl. tiled State-of-Florida before me this 1" day of May, 2006 by County of Palm Beach Oct who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230804  Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for .to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both d Epstein had a verbal disagreement, at which time she left without being paid. She got with ho was sitting in the kitchen and told her "let's go." Iltdvised she received no money for that day. 'so said that- had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more u do the more you get paid. Madvised that several weeks later she agreed to be taken a second time by Once they arrived at the residence,MMEllat in the kitchen and took her upstairs to e mas er bedroom again. set the mom up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and icked out a lotion for to rub on him. At one point during the massage he tried to touch her buttocks. As as wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts. then became upset again and told Epstein she didn't want to be touched. discontinued the massage and was paid $200.00. ',then went downstairs where as waiting for her. She tol he wanted to leavelliaid she never returned to the house. tated she is aware that her frier as also at the house and had a problem with Epstein. I later researched and met with her at her residence. During a sworn taped statement, tated the following: on or about November 2004, she was approached at Royal Palm Beach High School a fellow student. Ilnitsked f she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. _picked her up and drove her to a house in Palm Beach. She was browht into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School student and.......came with them. They were brought into the kitchen where she was introduced to pstein and other females. ;tated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to nib on his thighs and back. further stated during the massage, Epstein asked her to remove her clothes. Shc complied and removed her pants and blouse. laidn't remember if she had removed her bra but feels that she did. _was certain that she stayed in her thong underwear. ...continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or-affirmed &VP of Florida before me this 1" day of May, 2006 by County of Palm Beach Det who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230805  Probable Cause Affidavit Palm Beach Police Department Agency ORO FLO 500600 table, straddling Epstein to massage his back. While doing this was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised