Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Exhibits to Statement of Undisputed Facts Palm Beach Police Department Incident Report dated 4/20/06 Jane Doe 102 Complaint Correspondence from US Attorney?s of?ce to Epstein that was provided in discovery during the Jane Doe v. Epstein case AUSA Villafana email to Jay Lefkowitz dated 10/3/07 Plaintiff Jane Doe?s Notice Regarding Evidence of Similar Acts of Sexual Assault filed in Doe v. Epstein Case No. 08-cv?80893 as DE 197 (Rule 413 Notice) The Journal or ?Holy Grail? Complaint, US. v. Rodriguez, No. (SI). Fla. 2010) Email from AUSA Villafana to Lefowitz dated September 18, 2007 Receipt for sex slave books Message pads Non-Prosecution Agreement Letter from US. Attorney R. Alexander Acosta to Lilly Ann Sanchez dated December 19, 2007 Letter from FBI to E.W. and L.M. re: criminal case of Jeffrey Epstein Af?davit of Bradley J. Edwards, Esq. Property Receipt Emergency Petn. for Victim?s Enforcement of Crime Victim?s Rights, No. 80736-KAM (SD. Fla. 2008) AA. BB. CC. DD. EE. FF. GG. HH. II. 7w1 1-08 hearing transcript re: In re: Jane Doe vs. USA. Jeffrey Epstein?s plea colloquy Addendum to:_Non Prosecution Agreement Complaint file by Jane Doe against Jeffrey Epstein dated August 12, 2008 Complaint ?le by E.W. against Jeffrey Epstein dated September 11, 2008 Complaint ?le by LM. against Jeffrey Epstein dated September 1 l, 2008 Complaint filed by Jane Doe #4 against Jeffrey Epstein Article ?Jeff Epstein Sued for Repeated Sexual Assaults? dated October 17, 2007 Articles regarding Epstein settlements Discovery to Epstein and Epstein Responses invoking 5th Amendment Prince Andrew's Friend, Ghislaine Maxwell, Some Underage Girls and A Very Disturbing Story, September 23, 2007 by Wendy Leigh Notice of Deposition of Ghislaine Maxwell Con?dentiality Agreement regarding Deposition of Ghislaine Maxwell Photos of Ghislaine Maxwell from Issue 809 of the publication US Weekly dated August 16, 2010 Messages taken by Jean an Brunei Epstein?s Jail Visitor Log Sworn Statement of Maritza Vasquez taken June 15, 2010 Notice of Deposition of Jean Luc Brunel JJ. KK. LL. MM. 00. PP. QQ- ss. TT. Pages from Epstein's probation file evidencing Jean Lac. Brunel (JLB) staying at his house during that relevant period of time Jane Doe?s Motion for an Order to Show Cause Jane Musgrave, Victims Seeking Sex offender?s Millions See Painful Pasts Used Against Them, Palm Beach Post News, Jan. 23, 2010 Flight Logs Jeffrey Epstein: International Moneyman of Mystery; He?s pals with a passel of Nobel Prizemwinning scientists, CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he ?ew Bill Clinton, Kevin Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder who he is. By Landon Thomas Jr. The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair Dershowitz letters to the State Attorney's of?ce Af?davit of Michael J. isteii I Motion for Contempt ?led by Edwards in Jane Doe v. Epstein detailing the event, including Fisten af?davit attached to Motion Plea Agreement at 2, United States v. Scott W. Rothstein, No. (S.D. Fla. Jan. 27, 2010) Letter from the US. Attorney?s Of?ce to Bradley J. Edwards dated July 20, 2010 DEFENDANT BRADLEY J. EDWARDS ?8 STA TEMENT 0F UNDISPUTED FACTS Epstein 12. Edwards, er al. Case No. 50 2009 CA EXHIBIT GG PALM BEACH CCUNTY OFFICE DEPARTMENT OF CORRECTIONS OPEN-HAL wsnoa LOG - WTIZBCL CONT 122312 MAIN CENTER DWEST COUNTY DETENTION 1.3 DRUG FARM DATE TIME IN VISUOH NAME I ORGANIZATION PASS EMF.- OF VISITING .54HIIQLENDS 0817ch QCELDQ . 0 - - 11 Not maxi)? . 1 .r . Carr-e i? :1 I I I 11?4 1? [i M- ng?2 {In my 0- . {5?30 w?Q??ff/ I :01 .1 x- I TIME IN . PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG t3 wan esramion CENTER WSWORNAMEIDRGANRAHON A eliki Weissingerw SAAP David Bulterw Medical DX ?atrecha Rewhyw Trinity Staff Pablo Gonzales- DAF Mirlande Ostingw Trinity Staff Robert Humes? SAAP Sarah Korn? DAF Jessica Wall DAF - lc? 31: Control :3 WEST cou?m' DETENTION PASS if Amie Cl DRUG FARM NAME OF STAFFIINMATE Drug area; En route to Medical via gate 15. Q?Bldg. En route'to Restroom in visitation lobby. ~Bld . Drug Farm area. Drug Farm area. Drug Farm area. En route to ?Bid via ate A (J: ~44 PALM BEACH GOUNTY OFFECE DEPARTMENT OF CORRECTIONS - LOG - Comma? 0mm 0575mm: CENTER Eismcmo? QWEST COUNTY newsman anaue FARM wan-or: unmsioaemm?nowi . NAME 5:2] a Staff . enda Nu rent? Trini Staff. 3 so . Q~Bldg. De ?Garcia? Public Defender - PBSO I. En route to var ous draws to see inmates. PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL LOG CEKTRAL CONTROL CI GUN CLUB Cl BELLE GLADE C3 DRUG FARM Linda Lear United Deliva na '1 . 0 I Miriam-16.2: Ostin? Trinit Stafi I [7,7740 ?3 enda Nurent- Trinit Staff 55113 Adams {asuaiap us} PBSO Dru Farm area. ?111*? s: Ahmedl?almer /Ramdhanie I Cunningham . W: Bum, Jeffre (T-Secial). MI was sma?zaw?mg? gaazgfma If \l-?Es (,ch {arms- I 9 . Q: I Chevelle Bihtowerw Q?Bld. Deneka Cumingstar?ciav Public?efende PBSO IIM: Livingston, Douglas (EL?Dorm) . oseph ?agano- ?aralegal NM: 13952813, Jeffrey (Tn-Special). 3 Didi-09 Richard Alex-- Doctor UM: Espstein, Jeffrey (T~Special). mm mm 1 ?n Rrenda Nigrent- Trinit Sta?f - hc H?Lmn?vn . I . PALM BEACH: COUNTY OFFICE DEPARTMENT OF CORRECTIONS I at ,k OFFICIAL VISITOR LOG (A {29 GUN CLUB ~?gs'rOCIeIsIm CI BELLE GLADE DRUG FARM BATE TIME 1N it NAME OF Ii 3 ?152 a . . ,ch 10 rl?uo? ,3 - I 111% My?? PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS .- OFFICIAL VISITOR LOG - 051130333. .1 3700:0195 .CZBELLE GLADE ,cmrzue FARM - . TIME IN VISITOR oneamzmon PASS (93> 630 NAME OF WSITING. (?Li . K. :m PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS - - -- j" a GUN CLUB moms}: a: BELLE GLADE In DRUG mans VISITOR NAME 1 I I ASS NAEE OF STAFFIINMATE mamas was - .awaas I as. a? in (711: "(inbea?? lr I MS. . 131201 M32 #{Wo (13 M. A a, PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL OG Cami/1L Cam-rem c3 onus FARM a GUN erocxma VISITOR I ORGANIZATION 55? 0?7 0903 771M Mirlande Ostin - Trinit Hg; Staff PBSO L- 1 Arthur Tro 880 I I CDLUL -. a .. 16.07 Arnold Pros eriw 3.421 A BELLE Bldg. (1 M: Dru 0 tan Jefe arm 9 OF VISITING ft" {693" (2 0 {0 {a rm. ecial . PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OF ICIAL VI ITOR CG 3/ Wm CLUB 810 95 BELLE GLADE DRUG TIME IN VISITOR NAME I ORGANIZATION 0F VISITING "f7 i. 6 51.1mh F?i?hwi? p) It I I . If -- II uwssr GOUNTY panama; . . menus '1 onammnou P380 i 034; REV. We; PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG I3 BRUG FARM )Smcmas 13 WEST COUNTY DETENTION NAME OF VISITING '3 MAIN DETENTION CENTER PASS TIME OUT VISITGR NAME ORGANIZATION z: (a r4 ~11 CALL: (Bug A wk ELL ELIE (261,1 12?26-08 M175 Ostingm-Trinity .taff Bid I. 1/24: Epstein, Jeffrey '(T~Special) Dr . 1 2*2 6 ?~03 Dru Farm area . i ?S?Eec? ~11 ant~ Trinit Staff PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG 01361? (Scum; - CENTER I WTOCKADE WEST COUNTY CI ORUG FARM VISITOR NAME 1 ORGANIZATION 2? I a?l'i?ni 3 - DATE 41*;195 1?15"95 15w? kaoE. NAME OF VISITING TIME OUT ?53 0715112~26~i2?26~08 12~26~08 12~26~08 12-26~08 12-26?08 12~26~08 12~26~08 0915 0924 1142 ll 8 1212 1437 1437 Ni Paul~ Public I D.efende .Timoth Justinn'SAAP Bob Stancilr Interci Ball rt to ins acted 02 Vehicles. Mirlande Ostin Jessica Wall - DAF Bid'. Dru arm area. Sarah Korn? DAF -f Farm area. - . . PALM BEACH COUNTY OFFICE . . . . . . LOG - - - 302mm; canon? a camera swamp: a wee": COUNTY DETEWON anus FARM wsrroa NAME 1 onewzmorsz NAME Allen Wilfredo- Attorney Zoraida, Nina (Lw?orm). 12/21/Def. P330 P380 I :?Knowles: Alvin. T-48 . J. Carrero' Kevin' B?norm . -- 5 ?451?? .- 3:145": 4% 1 '33; 0' .9 ogelsbyu ?ublic Defender arious dormg to gee inmates.? atricia.Edelman~ SAAP Farm area. 12/22/08 at 'Deib Farm area12'22 O8 12 22/08 ??Do lia rlande Ost Trinit 'Staff n- SEAP ard Rm4+h_ trim a Ede Farm area. PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS LYISITOFI LOG 537% Com; 1/ Cl WEST COUNTY MAIN DETENTION CENTER DRUG PASS NAME OF /g f2 :39; 93 53/4", #293 2m A2 gm 1). 12/20/08 12/20/08 1 5? P880 (Kw: Mirlande Osting? SAAP Alberto Delpaz~ State of F1. Civil Reg Q?Bldg. Echols, Brenda Nugrent~ Trinity Staff . BSG BSO Robinson~ Deputy En route to indoor visitation. ?4 Farm area. Epstei?, Jeffrey (T?Special). In. BSO I Story Cowles- Paralegal ?5 I (L 1! 3 eliki Weisain er? rlande Osti Staff Staff Farm area. . Bid 12 {38 2 12(21108 4- Trini hr: Habichtn Trinit ray-hat; a A PALM BEACH OFFICE - - IALVISITORLQG . 7' DETENTION CENTER .2 KAEEJE WEST COUNTY 9575141101?: DRUG FARM NAME I HON PASS NME OF STAFFIINMATE . ?meow . mm: we, A . 6' Race . LI 0 SumLOAN J), PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS Wia?t 3 MAIN COUNTY DETENTION {3 DRUG FARM r? DATE TIME 1N VISITOR EAMEI ORGANIZATION NAME OF STAFFIINMATE 1 0?8 113% me? Lax/m . M1 5M3 @0314 m' 124108 ?93 12.315 mfn"11,3 1 Mama qupu-TF (gs-HZ) lat-10% 1151:) am a! u- 2, 1: {3?6 RM) um: 192% 1510 (WNML ab i FE 3:3. Eggm Watt! CDAE) (3 - {m7 gb?n?, mg; 909*?) I )1 GE .g 113% MRS .9. m0 08 1317 Slam-J VUCCNI "a as ?(mm a 7502(-3. ?2 9% (38? PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISIT OR LOG CENTRAL CONTROL Cl GUN CLUB STOCKABE {3 BELLE GLADE DRUG FARM DATE TIME VISITOR NAME I ORGANIZATIBN NAME OF STAFFIINMATE VISITING 12"05?08 123 Scott Sale? 'Attorne 3: . Rose 1 12~05~08 131 Jose Var u~ SAAP Dru Farm at l2~05-08 i313 - A 12?05?08 133 Jeff Iv 12w05~08 135 Mare Trac Public Defender F-Dorm to 12~05~08 1411 Timoth Justin? Farm area 12~05?08 l?i? Robert Humesw Farm area. 12435-08 1421 Sarah Korn~ Farm 9 12-05?438 1421 Jessica Wall DAF Fa 1444 Conrad Saddler? Pre~Trial Serv. (?756 Cutler?- ?rocess Server Esptein, Jeffrey (T?mSpecial) 112-436-438 18 rlande Ostingu T?r?fn?i f'v Chg-?3: . - . - BEACH COUNTY OFFICE - 7 . . - DEPARTMENTOF CORRECTIONS .- . . OFFICIALVISITOR LOG CI MAIN-DETENTION CENTER CIWEST COUNTY DETENTION DRUG FARM - I TIME I NAMEI. - HON I PASS NAME OF STAFFIINMATE 510 A13 1911mm M: m; - PALM BEACH OFFICE DEPARTMENT OF- connecneus. I OFFICIALVISITOBLOG. - MAIN DETENTION CENTER ?Cl WEST DRUG FARM TIME iN' VISITOR ORGANIZATION NAME OF VISITING I TIME OUT MTG M350 (14' 5?68?" 930 5306? - - . (la-43% at) (?ALLA Rah} TJC PALM BEACH COUNTY OFFICE I - DEPARTMENT OF CORRECTIONS -- . - OFFICIALVISITOR LOG- - - - - mmnaremz'o? CENTER "23' Owesrcoumnersmon DRUG FARM --VISITOR NAME I ORGANIZATION PASS - NAME OF STAFFHINMATE VISITING PALM BEACHCOUNTY OFFICE OF OFFICIAL VISIT-OB LOG- ?as/meL (Laid :3 MAIN DETENTION carter: ?memes it: wear COUNTY DETENTION c3 onus FARM DATE- 0? H0 303 TIME IN .3 VESITOR NAME I NAME OF STAFFIINMATE WSJTING . PASS an '03 3 --30' Cab (3?9 1 0 1M) 5? . M70313 ?15. (3Li] Tam: it: '0 Hots DER an?mM (A . 69 e3 8T0 Comes amtALWN 1?5 33' UM: m3 b3? Hunmwe 3 RN LL. L4) e, bro 93#939 mmv? rem?. H7 PALM BEACH COUNTY OFFICE . . . DEPARTMENT OF CORRECTIONS . - OFFICIALVISITQ LOG . . Cami,? amt DETENTION CENTER WEST COUNTY DETENTION c: onus FARM wsrroa ORGANIZATION PASS 3 11?1-08 Elta Emilcar~ Trinity Staff PBSO Q?Bmg. 11*1?08 GuillermO-Herno? ESS PBSO ~e .- . sma (1?98 {we mums 0F STAFFIINMATE VISITENG . mm our Facilitiesi Office. 23 V95 Abbe Strauss? ch Dr.' Rodri - Marcia 11w01?08 ant Jones- De Adult Ousted Office49343 - s. L. I (f 11432-413 0859 Mirlande Gsting- Trinity Staff 11-02?03 - 9914 Susan Wilkoffv? saw I 11*02-4382 0.949 .Chevell H'cower- Sm. 0950 Ste hen Alexander? PS ch Dr. 11f02w081- 0958 'Elta Emilcar~ Trinit Staff Farm area. Dru .Farm area. Es tein, Jeffrey (T~Specia1). ?Bid . 125?? La 29L 1 11-29219(930 7% My? PALM CSUNTY OFFICE DE TME 0F CORRECTIONS OFFICIAL VISITOR LOG I [a 07%? E3 DETENTEGN CENTER KSTOCKADIE Cl WEST COUNTY DETENTION DRUG FARM VISITOR NAME I PASS NAME Mirlande Gating? Trinity Staf KIM: Epstein, Jeffrey (T~Special). ?ap! Elta Emiclaru Trinit Staff Q~Bldg.' Patricia Edelman?DAF Ste hen Alexander~ PS ch Drug Farm Sto Cowlas~ Paralegal Epstein, Jeffrey (T~Specia1). j; 5' a i te-? Public Def Offisz arious dorms to see inmates. ohn Babicht- Trinit Staff Bldg. a Bad att" chool Classroom. usan Wilkoff? SAAP 3 Farm area. evelle tower? SAAP 3 Farm area. imoth Justin" SAAP Farm area. Greene~ T?Net ?Dorm . pana-una? 4 PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL vusnon LOG CENTRAL CONTROL MAW DETENTION CENTER El STOCKADE WEST DETENTWN {3 BRUG FARM DATE - TIME SN VISITOR NAME I ORGANIZATION PASS I NAME OF STAFFRNIJATE VISITING TIME OUT Edg?os. 1239 Charles Mead- Attorney . LMA Valladares, Enqria (Awnom). 1254 10?18-?08 1358 Ageht Jones? Deputy PBSO Adult custody Offi?e. Lil?1348 1358 William Paul- Public Defender PBSO Adderly, SHe?nly Jim-Dorm). 1M4 195mg 01ml film?; EPWW i OWW 1'55 ?O-Wos 173:2 Siroau Chdlas L-I T~$omrak - 1'99; H50 Lee. Exact. (NA) Vm "i??bokm o?aqm F1150 Sums $Mwh (A WI boa mos 2m? {3140. Wzl?-Ba? {vellum Pm) "Ti/?m 1+0: Swine?- 1226 [aka-0%? 0?35 Hack?EH I "Adam 9630 Wmqu JD- Jai?w-Q 07? 35 Mira @130 a I'qu/wm 1145 EWIS (Tim: {/580 'Qxewrw l??w b-oz/ 0735 @3372: i552 ?ai? Kai/wen ?/me?gc VIEW kk?-aa, ?gw?yW-a mm? was bag/WW MM I'm) 1mm 07%? LPsza, EM am 3% Wm Matt. "1138 MBOCQ (V7563 {96:50 Drab? Farm (M64, 10?20438 0806 Jay ?Badgect? - PBSO Schooi? Classroom. '{124 10-40?08" 0828 Calixte Viau- Xray Tech 37-14 Medical via gate #16. 0837 10?20?08 0915 Patrecha Newhyw Trinity Staff PBSO QiBldg. 10-40?08; 112-6} Pablo GCmuzlfie:zw DAF PBSD David Gillert Office aha DfughFam area. 1323' 70-20-438 13255 Veronique Valery- Public Def. Office UM: Shellman, Wayne (R1318). 1340 1327 Joseph Varju~ SAAP I PBSO Drug Farm area.? 10-20?08 1348 Nicole Dimasi? Sta. of F1. In?rest V-7 alder (BlDom) and {0-40?08 1408 Caitlin Bronstein PBSO mug Farm area. 10?20-08 1418 .Tnhn Dewar-.13.. nun??- PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG Ce. :?x?X?kea?k C. 0 *p?0 DATE TIME 1N WSHOR NAME .3 NAME OF r? 7g . 0w ~05 09?? 5 Ram: welO-l8-08 Linda Leary- United Deliveran?e Min PBSO I Cur Brad 104333 Emilcar? Trinit Sfaff PBSO Q?Bld . 8 s?Garcia? Public: De?fende ?9350 Cortez, {mi-15g 7' U4 (3 0f 0 E?s/d n} T?n Shula .. - afea 101-19438 Ste h'en Alexander- PS ch D-r stein 32 10?19?438 John Habicht? Trini Staff 103-19438 John Riordran? Attorne 10?10 no 1 v-m t- PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG Cl MAIN DETENTION CENTER WEST COUHTY DETENTION DRUG FARM DATE TIME IN - VISITOR NAME GRGANIZATION PASS If NAME OF STAFFIENMATE VISITING 0 I LEE I ?0 <3 @299113? ND - 3 "2 03? 15B 39:40:9ko rm 0 0? 03? VEN GALA DiPALM BEACH coumv OFFICE DEPARTMENT on: connecnous . - OFFICIAL VISITOR LOG . -- - CI MAN DETENTION CENTER- - 03mm - cannon 15 owssr comm name-non oonuo FARM one; mam: NAmaionomzzmon. - mm I Alison 'Robinsonw Attorney I ..Lr-l I I CUM: I'Mcelh'one, Murray (SASS). 1051; e: 1047-03? 0959 Jab}: Miller- Me'gene He?lfh .To see Lt: Jackson- mag 3 10-073103"; .1002?.- Finzi - Special Viso Bah Finzi . 1118 -100 2_ '-Rene_ Fin?i specie: Visit *7v1se Dan Finzi w4113 10?07?03?" 1092"" Rieherd'lviezi - speeielmeie. "Vise ma: page; mg 10~074~98? .1007 Frank Ward-u Tropical Fence I I V413 I 'On the compound-W15: Morris- 1228 10407?035 1003 15atrech'Newbv?- Trieity Page Vo?Ba?. I views-74408:" 1023' . 'Llovd Smith Jr" Vulcan Peet' Centre]. en'the eompeend'vie gate #16. 11x18 :12:00 Attorney Story Cowles - AttofneyVm: T~spencial Jeffrey Epstein 13.40- I Pablo Gonzalez I i IPBSO- bafidfGreen in Admin - Hide-0743f? "Sueanmlkeff - DAF I P330 "meg Farm .. 17; 2' MYMOB 1236 I Conrad Saddler" Pre~Trial~Se1fvice5 Robinson, 125i I Caitlin Brenstein- I I ?Drug 'Farm' area. I 1317!" 'Jeff Gibsohw ESS 9350? Central Centrezg__ 1.445 .. 13.20: :o??phivariuw-SW PBSO I Drug Farm Lat. mo ?ew?08? 1323 Chaplain maso- .oe' the compound. 1404 Sage-h Kem- PBSO - Drug Farm ?qi 10?07438" $41-53 Reba; Humes" DAF giggi- Drug Farm area. ngEi_- 10?07-08? .1505 Sarah Ferrer- seer 9330 Drug Farm hoo . loeoi?os "1506 Mm Wil?om- DAF PBSQ 23mg Farm area". . 3.528 Marci Monescalchiw Attorney L44. I 'IXMifgnelly, Tiffany (Ci?Dorm), Uqu 10?07408 1536 Darren Indvke? Attorney Lei Jeffrey (ff-Special) ?0'?ng 1?50 Wraith ?ndreu); 'ifmiik (mm/Wt 16n< m~o$ 16w Mend . am keen? .- v22 - a ion-'03 W0 Mn . geek. Gem gm - [0"7?0?5 I810 mew-?o TM PALM BEACH COUNTY OFFICE - - DEPARTMENT OF CORRECTIONS VISITOR LOG I wme Comic" 0 MAIN DETENTEON CENTER STOCKADE a wssy COUNTY DETENTION- a DRUG FARM- m?rs mm wszma ?wezommzmou- ms? . NAME vasmue- me our 0/ . . was? 0 o? IO - 10 4C. "/9582 '7 . 0407-08 5 . {?n-10L {Raw . rm {3356: i0~07~08 0809 Jay Badgett- Teacher PBSO School Classroomf 26 Jessica Wall - DAF PBSO Drug Farm area. El am?l?rinit Staff .- - . 2:330 Buildi P880 8 Office mm. x. . PALM BEACH COUNTY OFFICE . DEPARTMENT OF .. . OFFICIAL VISITOR LOG - CENTRAL cameo - MAIN DETENTION CENTER UWEST COUNTY DETENTEON ?3 DRUG FARM ems IN VISITOR NAMEIORGANJZATION - PASS #6 - NAME OF TIME our 16?06-08 0802' Jehn Habicht- Trinity Staff P330. .. Q-el-ag. I 151-4 08033 J?y Badgettw .3 School'Classroom; 1140 "10m06-08~e '0859' Gail Brem?er~ Canine Companions V-ll -Drug ?arm area. I 1107 *Patrecha Newby- Trinity Staff PBSO 3_ Q-Bldg. I Ifj?y3.- 10?06-08 mm- Rosie'ayppoutew Children and Families: $17?12 Caristopher (Damn) . 164-6 1149- Arthur Tgey? SAAP PBSO Drug.Farm area. I 1 i; 10??06-08 1202 Stofy Cowles? Paralegal . . L?l - Epstein, Jeffrey (T?Special)?. 13:5: 10-06-08' 1202'" Mirlande Osting- Trinity Staff - 13m, 10496?438 :1215' - Caitlinzeronsteinu SAAP - - . Drug Farm area. KO 10?06?08 ?121-8 Jay Ba?gettw Teacher .. 12250 - Scheol Classroom. 1303. 10~06?08 1228' Caiixte 'Viauw Kray 'feeh - inedic'al vie gate #16. .125 6' 10?06?08 1 1307 'Jak'Goldbergerw Attorney Jeffrey (Thspecial) 1339 10?06908 21316-. Damon Clark?~ Bio Meds Tech -V~ll .en route to_medical via gate #16. 1334' n.10e06-08 :1316 I Ed?in Silvaw Bio Meds Teeh anz' en route to medical via gate #16 1334 10406908 1 1325' Aniy Morse? Attorney . Sumner (RA?Dorm). 1418 a10~06303 135? Lindsay Banson? Public Defender? El?. ivarious dorms to see inmates. 10~06~08 ".1414 Jessica Wa11y- PBSO Drug Farm area._ mtg/3 ;10?06503_ '1422_"Tim0thy Justin? SAEP Drug Farm area. lto?kg :1424_' Kenneth Huxhold? SAAB 1 L/Mw?orm to see inmates. 1522 1424- 3Robert Hume?w SAAP I f' PBSO I?Diug.?arm area. 1503- Joseph Pagano~ Paralegal L13f'? -ifM: Epstein, Jeffrey (TwSpecial). ff?fq _1534 Jerrv wade~ P?blic Defender i: NM: 3mm Baptiste; Rathaniel (A?Dom). [(1950 10~06-08 1534 Darren Indvke? Attornev .- Epstein, Jeffrey (TMSpeci?l). f0" 3750 Ab?n I K- I .I fragm- 1750 ?Wemee (Pie-me?) knew mm 1013th (man! 73me 5 Jew" PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIALVISITOR LOG 1 {3 MAIN DETENTION CENTER 9 WEST COUNTY DETENTION El] DRUG FARM I ORGANIZATION NAME OF STAFF VISITING - . (9 . - f0 12,5 10:05-08 .0814 Angeliki Weissinge Drug 3am ar . 10?05?08 083? W. Holman- Deputy Lineuup room. 10435438 090? Mirlande Ost - Trinit Staff . I tein Jeffre T-S ecial I 3ohnson, veron (81809). I. .. .- Pz?xblic Dafender 5 (AVAIPAIF id'mAPr magma PALM BEACH CGUNTY OFFICE DEPARTMENT OF CORRECTIONS . OFFICIAL VISITOR LOG - Ci MAIN DETENTION CENTER DWI-EST COUNTY DETENTION I3 DRUG FARM DATE TIME Vssnoa . NAME OF VISITING rm . rm I JANE RESPONSE TO MOTION FOR PROTECTIVE- ORDER 536] CASE NO: EXHIBIT Part 3 of3 PALM BEACH OFFICE- . DEPARTMENT OF CORRECTIONS. - a 5?1, OFFICIAL VIZSITOHLOG i4 3-1 mm CENTER Jagsrocmiaf I a-wasf COUNTY a DRUG FARM 5% vasn?oa Tron .P OF STAFFIINMATE TIME OUT '3 Emu, 322,2 mt, Lam ?4 mq inrreati.? Q?uw? w: aborm_ 0% our Twmme rgnw?e: f?fiih?pfn I PALM BEACH COUNTY I - - DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR we a man oamu?nom cam-en a 7 uwesr comm 3 El DRUG FARM PASS {3 - :35; Luis Emmi . NW NAME OF VISITING m, . 3 V. 5 P. Quad - MES F) ALL . C063 0 PALM BEACH COUNT-Y OFFICE DEPARTMENT 0F CORRECTIONS .- - - VISITOR LOG 09M:ka ?am-ma. . 9mm 0275:4110? CENTER - uwssmoumv nersmou - moans FARM DATE nmsm- wanna NAMEIORGANEZATJON I PASH - NAME - TIME our {My 72a a??v - MI) 4-9404? 35/9/94: . 1/54/ 0 MM F?Mmcw fawn/1m 52??er F530 02W Page/6M 6m 0 4% Guraues? 241%? PEEK) ?rm? Firm area. 1105 '5101151085 9503* .meadam pacs? . V6522 ?chBoL 6145mm 1205 .0816 'A?ge?iki Weigsinger? SAAP - -. Drug Farm area. I - .104-13?08} .0820 93cm Habicht~ Ttinity Staff 7 - "233-50 Bldg." - "-1041-3w08-7 .10822 Patricia Edelmanw PBSO Drug Farm area. 12:15 . 1043?087 1 0133: Evelyn Wilford? Trinity Staff . wse' Q?Bldg. 101-, "10:13:08" . '0920- ?Patrecha Nevin)?? Trinity Staff 5' PBSO Q-Bld?. ,7257' 103153108?: I 11549 Christopher ?ich'era- I I I Gleason, Christopher (15?37) 11301, I 'Story Cowles? Paralegal 'L?l UM: Eiistein, Jeffrey (T?S?ecial). 1439 I iz?13 ?ixahm Osting BLDG TRINITY EMPLOYEE 34220 #111133; Paul? Public Deferider' - 9-350 1m: 'Adderly, She.ny (RAwDom). 13-27 __1300 Juan Mercado?- Pro Fitness I PBSG Zo?ker room'areaf Gym. . 1352 I 3.3.320 Ge?nevieve Hall- attorney I .1332 I/M?si: Raf?es; Katmai! I T033433 I I 1351" Cali-xte viauw XraV Tech - Z. IV?lil Medical v13 gate #16. 143.5 I 16413?08 5 135? 'I-Patrici? Edelmanw M. I I a PBSO "Drug Farm area. - may QM Er/ jaw-3&7? ,f7?lify?ue?: (45:4 Veg a, "1963237 75/1,? (g i3sz 99:37 :33 4302/ - I 2M gum" 10-;st I I?m: 19 1,455) 345/ Sane/om 13:; 3,117/- ?xmm/ an?? f/Jc? ZW 14 10 4909/ v" - an/LH x- 2953?? 1043-6?! 357/0 911%? 094?} <73 rovxsz/ ?ax-n7: 1f ?7 77-1 Pr --PALMBEACH OFFICE . ., . - -. OF CORRECTIONS 'DETENTION CENTER a: STOCKATJE WEST-COUNTY- Dsren'rtom -- DRUG FARM [we 11mm - vssnoa mmzommzmom may; NAME OF STAFFIINMATE VISITING TIME OUT mum?085: 0923' Elta-Emiicar? Trinity stat: . . - 2330 Q?Bldg. I i355 10.111408? 09.25 T. Cook- I I En route 011 the comP?und. . 0940 10-11-09 1014 'Melaniekhouryu Stafe .of FL. Crimihal 'v-u Goodman (L?Dom); Mansfield I - 1144 S,"Watsqn- Deputy . FBSO I En route to Sgt. Office. 11-58 "10:11?08 1329 Agehj: Jones- Deputv PBSO En route Adult_Cust Office. - - 1041-438 133? Conrad sa_dc_1_1er~ Pre?Tri?l sgmices P3350 3mm! Alford! Baptiste. . 140; llG?lleB-j - 1404 ?ge'n't {2351:1110w Degutv PBSO En mate t-o Adult Gust Office. 10~1l-08 . 1404 11/8 I). Hawkinsu- Beautv PBSO En route to Adult Cust??fice. 1434 O-ti?G?f} 236?1' 'Mka?nc?xc, (1m 46.? (Mm 2??an Dime: I 2113-11-0? 1?30?! Gamma-9, 1?15 X?dedm (Mm Emt?n) [Hi Ema: Form/1 - 205/- jam-03' Vilma? {21%an 2 Mm). 3/43 D115 C1 [Imam 503:7.- @1ng 1/130 a) glad Erika/5:41; 1020 7,?99 771%" Dm ?.4le 1134. 1042-08. r150 @mm W31) .leruq?i/FM?m?arm. - 953- 104sz8 . 09077, {Stephen Alexand?r- Dr, %?pstein, Jeffrey (if-Special) 1144 "1042?08. i: I 09.16 --Ei?a Emilc-arm Trinity Sfaff - PBSO Q~Bldg- - 10 10-1243 0916 Mirlande Osting~ Trinity Staff @330 Q?Bldg- 10~12-08 . H0935 Joseph-Pagano-? Paralegal UM: Epstein, J?ffrey (T~Special). 1142;? 10-;2-03 -- 0944 Timothy Justizr SAAP . ?3330 Drug Farm area. . I - ""1401 10-12433 1416 Martina Jean'mBaptistew Public Defe?der PBSO Various dorms to see inmates, ?1042?08 3.53.6 13/5 DaviSw DEputy 1 1 - 3339 . Sgt. Office* 10?12?08 1536 Story Cowles? Paralegal 13?2 Epstein, Jeffrey (TS-Special). {Dr (942.. @9 669 - Mme, ?5112 WM 9% m?ma??mm - @786 53%, bche,? -- 13?21'3? 13 m2 ?(293 ?i?55 ?wm 19 (gag! 0- T9 290M m? Cl MAW DETENTION CENTER .TEME IN VISITOR ORGANEZKHON . 'mms800? . I 0909 .0938' 0943 0954- 0912 to 209408 10m10403 Patracha-Newby~ Trinity Staff '10~10?08 10310?08" 10?l0~08 10?10w08 *10?08' ~Sto Cowles-?Paralegal Brian Balaguera- P?blic Defender Charles Durkeew Attorney Pahlo Gonzalez" DAF . - PALM BEACH COUNT-Y DEPARTMENT OF - - LOG - can!er [amid-L DWEST-COUNTY 13 DRUG FARM NME OF VISITING /7 r' a Lz'. A Q?Bldg. Epstein, Jeffrey (T-Special). 'Various dorms to see'inmates. Finzi,'Dan (lb-Dorm). _En.route to Ronni? Campbell Drug Vri dorms to see inmates. Jukich Michael L?Dom . ?2 . PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS - OFFICIALVISITOH LOG 00mm. 00010201. :3 MAIN 0850mm: CENTER I ?sroomoe ?3 WEST COUNTY oat-moon ?3 onus FARM DATE TIMEEN - -- VISITOR NAMEIORGANIZAHON I NAME TIME OUT 09?30-00 - 0814 John Habmhtu Trinity Staff 0030 anzdg. [541) 09-3043 08-36 .:Jo_seph Varju- 3MP 3 3380 Drug Farm area.? 1205 09-30-03] 90-900 Elta Trinity .St?ff 0330 (mug. [a -_09w30-00' .0902 'Patregha Newby? Trinity Staff "-0030 {@1553 09-80?03-- iiO-934 Futch~ Seotion Manm- . . PBSO -I on route to school classroom. 100.7 I 09?30?03 1125 J?ff Gibsonw E88 - 331380 en route to various dorms. . 122.4 09?30-00 .1126 gnenaraquetze? Trinity Staff . - 2050 )55?0 09*30?08 1126' Thomas 015mm Trinity Staff. I PBSO Q?Bldg. 09?30?03 1203 SEory Cowl?s?ZPAralegz?ll - - I 13:2" UK: Epstein, Jeffrey I 09430-?08 1214'? Patrick Nelson- Max" 02105.3 Assoc. .PBSO Adult Custody Office ahd school classroom. 1405- 09-30438" --1-226" rJav Badgg-mf 23030 Iga?cher PBSO School ?4313:0013, 09?30?08 1246 Ray Forneyi- Trinity Sta-ff V39 Q-"Bldg. 11530 09-30?08 1256 James Clark? Ecolab . Vvl? en route to Laundry via ?gate #16 Booking. ?1326 1403- Ravi Bannisterwf Chap-lain PBSO En route to the compound. 09?30438. 1409 . Robert Homes-Z DAEI- P830 - Drug Farm I 09?30008. 1420' Sarah Kern +1300 - 13250 0mg Farm areaQ . I 09-00?03 - . 1420 Jessica Wally-? 0M 13330 . Drug Farm area. - 3 "0940?00 1429. .. Michael Molaughlin? 0-53 .3330 En. route on the compound. ?1,536 I I 09-?30-108' 1526 Cathv 120* ?ublio Def-gnder II PBSO NM: Imperato, . I 09-30-08 1530 - Bugains~ Norse - I . I V-Q Medical. . I . - 61/30on .500 0 mm L4 mm: Wau?fw?g?m" fry/mam) {77,5 -. - . 4370:: 9! ?am?z?ew - ?fm'magZZC @552151A: ?A?glb' {0.200% jam) 4m%gq_ f5? gag?{01? 5: (4:5?wa x? i4?- ?913.0 ?99/ may, . ., L. .0: 4.165" yr; 25 PALM BEACH . DEPARTMENT (JP-CORRECTIONS LOG -- - -- (Emma Cam-1261., MAIN CENTER . wear COUNTY DETENTION - a DRUG FARM DATE 71mm VISITOR 'PAss-if NAME OF STAFFANMATE 137$, - eliki'?eiss -Ja Bad ett~ Drug Farm at . Classroom. Patrecha newt) .- Trinit Staff" . iEvenl ton? Attorne Marfi1?IRA18) and Baker VT-imoth a'eff- ?Te, 'Grav?s? SAAP School Classroom. 'Drug Farm area Michael McLau hinwESS Caitlin Bronsteinr SAAP 3On_th? compound ITDrug_Farmuarea- aSto Cowles? Paralegal. HIKE: Epstain, Mirlande Ostin Trinit Staff I-- i Tro . Drug Farm area. I FOSTER - 1/14: Quarrell, Michael (Duncan). tto a .ii't? 'a'f7a: [71 stain; Jeffrey (T?S?ecial). Carl St ens- Process Server I Epstein, Jeffrey (T-Special). A a nna? an PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS - OFFICIAL VISITOR LOG- CENTRAL CONTROL L13 MAW DETENTION CENTER STOCKADE CI WEST COUNTY CI 13866 FARM Tuwszn :34? 1358 1420 1423 '1423 .09-29~08 09~29~08 09+29_08 09429w08 VISITOR NAME I ORGANIZATION Pearson CSPT JeSSica Wally-- DAF PASS PBSO P830 PBSO ii NAME OF Drug Farm area . Drug Farm area . Robert Humes~ 'J?ff Gibsonw ESS Michael McLau Drug Farm area. on the compound: on the compound . ?30 478 PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS CONTROL 3 7 :3 MAIN DETENTION CENTER awesr COUNTY Daemon- - a onus FARM VISITOR I ORGANIZATION I II PASS NAME OF STAFFIINMATE VISITING - I ?r??/r71 rlande Us}: - Trinit taf-ffJeffre 0 581? af I . I 1336 Sto 'Crow?ls? arale al ?i stein Michael Arnesenw Stafe of FL D00~?ride -En-route to 09/27/08 1515? Gre Likes- State of FL 2300 "Pride an rout?-to Q?Bld 09727/08 I ?515_ Ra?l ?0205* State of F1 DOCwPride en route ?ai kt? .w?S7 . '09n28408 ?-'FAngeliki Weissinger~ _'_Drug Farm area. 09?28?08-' - 5 'rlande Ost Trini Staff I 09-28408 II: 1' I 09-28?08 I I El lea -IT :09?23408-- 4' O9w28~08 I 0 ?28?08 0"~2 ~08 ~28 - COUNT-Y OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG 5:1 mm DETENTION CENTER . memos awesv coumv 0275mm: a cave FARM VISITOR NAME I ORGANIZATION NAME OF STAFFIINMATE VISITING Ul. Sc Y?n?'?xn PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG mm DETENTION CENTER DWEST 00mm BETENTION a DRUG FARM DATE TIME IN VISITOR NAME i ORGANIZATION PASS NAME OF STAFFIINMATE VISITING - 0 0Q 25 a 0 {Dot-gape?) Iqchh a . - -- IPALM BEACH COUNTY OFFICE . 2- DEPARTMENT OF CORRECTION OFFICIALVISITORLOG . I . 3 :2 MAIN 9575mm: CENTER I '21 STOCKADE. awesr COUNTY DETENTION a DRUG FARM ogre [Yuma vesnoa NAME 1 PASS NAME OF vzsmus of} i ~10 mam 4M (m jug.- Ed Res. #09; waif. 0m}. 43% ?Zip- @0144}; l?nN. PALM BEACH COUNTY (Jr-Hm; DEPARTMENT CBF CORRECTIONS OFFICIAL VISBTOR LOG .- - CENTRAL GONTROL TOCKADE uwesr coumfv DETENTION a DRUG FARM E3 MAW DETENTION CENTER NAME OF .En route to ?edical (Staff)l PASS 4% (If-3 I 2+3 far i" WSWOR NAME I thia ?agginsm Nurse 51M- 02 06' 15 NWT?Epstein, Jei?rey ack Goldber'ger- Attorney Admin area to see Ms. Futch. ean Kesser? Int Wiewer M5 PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG . CONTROL 51 mm newermoucemee El STOCKADE weer COUNTY DETENTION nave FARM DATE TIME IN VISITOR NAME ORGANIZATION PASS NAME OF VISITING TIME OUT 0751 Sii?an Wilkoff? SAAP PBSO Drug Farm area. Fig? 0818 Dante Medine~ E?ublic Defender PBSO Various dorms to see inmates. 0902 09-43?08 0824;- Kaydeon Interviewer V-M Admin area to see Eris. Fetch. 0915 09?23?08 0854 Marianne Rantelaw Attorney 31/24: Verne, Ian (if?39). 0941 0943*?5 0903 Patricia E?eiman? DAF Drag Fem area. 09?23-08 0903 Elta Ergilcar? Trinitv Staff PBSO Q?Bldg. 09-23-03 0933 Tatiana Bertsehm Public Defender PBSO Helems,- Richard (BAGS) I3.630 09?23n08 0933 Brian Balaguere? Attorney Austin, Wade (RAGE) and Moeley,M (Id?Dom) 1037 09.42.3418 093? Glen WIleox? Interviewer Admin area to see Ms. Fetch. 1.043 09w23-08 1000 James Eisenberg? Attorney Hernandez, Lazaro (13-48). 10119 09?23?08 1012 E?atreche Newby? Trinity Staff e330 Q?Bldg. [44% 09?23?08 1058 Maria Capino- Interviewer Admin area to see Ms. Fetch. H39 09*23?08 1206 Darren Indyke? Attorney Lv-3 1/16: Epstein, Jeffrey (If-Special). 1401 09*23?08 1210 Jaianna Seaborne? P?blic Defender PBSG route to TwDorm to see inmates. 1255 09?23?08 1235 Conrad Saddler- Ere?Trail Services P380 25 and D~Dom to see inmates 1308 09-23?08 1240 NS Maharrey? Staff D3 PBSO glib-Dorm to see inmates 125:; 09-23-68 Marilyn Rodriquez? Interviewer Admin area to see Ms. Futeh. 1358 09?23w08 1300 Milo Trkulia-n Clergy Christ fellowship Cw? UM: Sessa, Taylor 1344 09?23?08 1308 Rev. Bannister? Chaplain PBSO various dorms on the compound. 7 09?23-08 1323 Michael McLaughlinw ESS PBSO Central Control. ?og?23mm; 1409 Sarah Korn? DAF e330 Drug Farm area. 09-23?03 1409 Jessica Wally- 3m? PBSO Drug Farm area. gem?) 1416 Felicia Everett~ Interviewer V-S - Admin area to'see Rs. Fetch 09?23-438 1423 David Casals~ Attorney Veron, Ian (T?Dorm). 3 M, 09?23338 1431 Kenneth H?xhold? SAAP P330 3 area to see imatesPALM BEACH COUNTY OFFICE '3 0F CORRECTIONS'13 MAIN DETENTION CENTER :3 STOCKABE ewes?: COUNTY DETENTION DRUG FARM NAME OF STAFFIINMATE mamas DATE -- 1N wsrron NAMEIORGANIZATIGH 4: ogjzz'zosi' 15- essiaa Wally? 330- Farm area. 09/22/08: 15 arah K?rnw DEF P380 3 Farm axea; 53 eborah Leporowski? Bil V415 Toomer, Darren (B-DormJ in medical. :09 22/08 9 Vt ga?fma/ai PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG OWme Comm COUNTY a save FARM MMN DETENTION CENTER VISWOR I ORGANIZATION OF STAFFIINMATE VISITING M, 0 2614 09/22 08 Martina JeanuBaptiste Public Defe arious do 09/22/08 Susan Wilkoff? SAAB to see inmates. Farm area. 09/22/08 Hay Badgett? School Classroom. 09/22/08 Timothy Justi?- SAAP Drug Farma area. 09/22/08 Patrecha Newb Trinity Staf? Q?Bldg. 2- Jason Creme Attorne ifM: Bass, Brian (T-37). Chri 0 her Mi?dlebrcokw Alexxon en route to L/MrDorm to check mouse trap I A orne stein, Jeffre (THS ecial). Staff . Bl Dru Farm area. stein Jeffre Dru Farm area. M?Dorm to see inmates. - PBS Animal Control IIM: Gonzalez, Crox (HmDorm) a 71M: Cnnzalez, (3?Dorm3- PALM BEACH COUNTY OFFICE: OF CORRECTIONS :3 '3 :1 MAIN emennon CENTER STOCKADE comm DETENTION . a new FARM DATE 69/19/08 WSWORNAMEIORGANQKUON _ard Shelton iSta?e of'Fla (Invest) VISITING an? Exnold, Willie Lopez, 'route to BwDorm. 1' Pre~ Trial Services Bad ettw Teacher-m I route on the compound. rnafd Wiliis ~Fern house ?Dorm to Crowles zPara?Legal Special able Gonzalez fred Miller- Public Defe?der. dbert euees~ DAF i 8: "09/19/08" -09/19/08 rug'Farm Various dorms to see inmates. .Drug Farm area. I- IIM: Defe A er Bazan Leon (SAOB). ek Steven (Tn37). Mates Brandon (?mDorm . Various dorms to see inmates. wig 0M (C: Teri/9y? 0T 3 1- (In Queen Wolkoffw SAAP Drug Mirlande?OSt Trini Q~Bldg. Linda Le U?ited'Deliverance'i Sarah Ferrere~ II ?Drug Farm area. . PBSO Q?Bldg. area. PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS 5 - OFFICIALVISITOR LOG CERTRAL caaraon ?1 MAIN DETENTION CENTER STOCKADE DWEST COUNTY DETENTION Cl DRUG FARM . DATE I VISITOR ORGANIZAHOR I PASS 42?? NAME 0F 9-20/08 Ste hen desiyn? Prof.' n12 Epstein, Jeffrey (T?Special). 9f20/08 Story Cowels- Paralegal Epgtein, Jeffrey (T~Special). 9 20 08 - . cOWleS? Parale 31 I L-3 IIM: stein, Jeffrey (TwSpeci?l). I II 4 Vi?lent Crime Task Force PBSO Perez, Jose (8318); 09/20/08 - Joseph i?agano- 2aralegal - I L-3 Epstein, Je?frey (TwSpecial) .. OQIZOIOS a Story Cowl?s~ Paralegal. Epstein, Jeffrey (T?Special). 9-1.0-232 5310 I owl}: 44.- Eoswna ?3&9 SM A Dmri, gs . . If! 63809'21/08 Lind? ez? Pub Def 2 - Elta car? 09 21 08 I I H's. 21 8. I . 09-I2U08. Mark. Solomon?Attorne I I Delana Josabal L-nDom 09/21/08 I rid Abellow Public De?e?der various dorms to see' 09 21/08 - Holman? Be 11 - Line room. 1' . 1. ?7.13? PALM BEACH couumv DEPARTMENT OF CORRECTIQNS- -. . . - .QEFIIQIALLEISITOH - smcmoia EIWEST comm! 0515:4110" t3 DRUG FARM I 3AM EETENTION CENTER OF STAFFIINMATE VESITING VISITO r/V? ettm EBCSB T?acher- 5611011 En route to ?Bid . Bid I II/l?i: Rodri ez, Sixto (BmDom). I Bid . Vario?s dorms to see inmates. Edwin Fer on? Attorne John Nowicki? 053m Peak, Ltwan (Is-mom) . Patrec?aa Newb Trinit' "Staff- Crist Baker? ?Pubiic: Defender . .. 114. WW PALM BEACH COUNTY DEPARTM NT OF CORRECTIONS LOG t3 STOGKADE uwem comm? 02121411014 c1 DRUG FARM mm a3: OF mm DETENTEON CENTER vxswoa NAME I oasmazmon - . . {a Ema MEL 6cm - WW ?lm/s VH3 33% uni 5250 ,0/3 l??'ll?ima . . - $133.5 PALM BEACH coumv DFFICE DEPARTMENT OF CORRECTIONS a WEST courmr Bergman El DETENTION CENTER 5 WSWORNAMEIORGANEKHON ta hen Lank?u- AttorneyI-"IZLI a" Parale a1 Iatrecha Newb Trinit- Staffi Headi 4 D.O.C Probation Officer Lt_' 0? P380 "3 isle - PBSO 0 Ifah Kora? DAF Jessica Wall DAF Wade? Public Befender Phillip Wallw 3.0;6 Probation O?iicer p?r?v I r5 --2 SO IKE: ?Line. ?Line ?Lineeu 'Linewt DRUG FARM STAFFIINMATE VISITING Hasters, Stephen (A?Dorm). Masters, Stephen Q?Bldg. Earney, Anthony (Hwnorm). Lin room. I room; room. room. room. I stein, Jeffre eci?l). Farm -Farm Area. Drug Farm area. Drug Farm area. l/M: Williams, UM: David, Arthur PALM BEACH COUNTY OFFICE OF CORRECTIONS 8 ICIALVISITOR- 0G - (Emma, to wow (3 MNN 1- BWESY COUNTY Q-DRUG FARM YION I I PASS NAME OF VISITING ?33 .5 I 09/16/08 Angeliki'Weissenger?SAAP Dru Farm area. 09/16/08 . John Ha?bicht? Trinity staff Q-Bldg. 09716/08 Jean FilswAimem ?ublic Defender 17M: King, James RAEB). 8 Elta Emilcar? Tfinity Staff nn {no- Trinif?v PALM BEACH DEPARTMENT OF CORRECTIONS . 0.0mm. :3 mm newsman- semen smcmaa gmwasr coumv DETENTION I: 0900 FARM 0m: TIME 04' msnon amasgaemzmos 9 - - {maps or: STAFFIINMATE vasmne TIME 007 729/ I m1tb?af 1538 'oae-iseoa- - 7/9/33 9m 50 {07513 09-15?08 I 0750.. Cai?f'lin 'Bronstein? I 9350 Drug areao 1-124 09415?03? I. "0758 .Timothy Jastin - Drug Farm area. It? 0945-03- 0759 John; ??bicht- Trinity Staff 0350 Q??Bidg. 09?15433 I 0801: Jay Badg_ett- HSSO I Classroom Teacher. 1-125 0945?03 0804 I Chevell? Bftoveru 5m PBSO 0mg ?fam ama- I 09?15?08 I 0313 Susan Wilkoffe SAAP PBSO Drug 0m area. . 09415-568 00852 Gail Bremner? I?et Care. Drug Farm area. 1111' [0908 I: Dena Faquetta? Trinity Staff - PBSO I Q?Bldg. 1335 0905?03: 0914 'Patrecha Newby? Trinity Staff 0330 04-31%. {7/3 I '09-15?03 2 1030 Jalisa v. Steele- Armour V942 Medical (. New employee) . '153'0 .1015- I A. Lvles? PBSG Retired en I'i?oute {to-Adult Custody Office. 114?} 09354.03 I. 1204 Mirlande Ostingw Trinity Staff 39350 Q?Bldg. 0945908 71208 :Arfhur Tr0y~ 3m I Drug B?am area: 1522"_ I 09915?00 3" 12315 "Story-Czowl?s? Paralegal 11M: Epstein, Jeffrey (T-Special) . 1335- 093-15408? I. 1222 Caitlin Bronstein? 13330 Drug Farm area. 09?1592003- 12:55 I Joseph Varju - SAAB .PBSO 0mg Farm area ?09?15-408 '1310 Pablo Gonzalez-? DAY PBSO Drug Fain area. - 1532 09/15/08 1&02 Sarah Kern - 3350 Drug Farm 09/1503 I 1405 _'Robe'rt Bumes 319135? Drug Farm I 09/15/08 12312 Paul William (PD) I 0330 L?Dorm 3502 09/ 15/08 1505 Alexander Edmonds :37? Intake 1530 mils-708? 1533 Jerrv Wa?e I I 9330' {mom .mmb 5m par-262 cD/rw-V [Sf-ram {1540 I I I sfm? ?f mtg?? vand?TP/I?- ?rm/,4 BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG COHTROL OMAN DETENTION CENTER CIWEST COUNTY DETENTION - El DRUG FARM TIME IN NAME ORGANIZATION PASS NAME OF STAFFIINMATE VISITING R. Torxes? De at I Sgt. Office I) I . Ind ken Attorne IFM: Esptein; Jeffrey (TMSQecial); 05f I Tri?i? "Sfaff 09' 14 .08. 1.248 Patricia .Edelman? Drug Farm area; 0 Us 8 1341 Arthur Err) de 4 Doctor stein, Jeffrey (T?Special). .. . . I Ta, N690 2.. ?r/h't PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG CEETRAL comm. MAIN DETENTION CENTER {3 STOCIUIDE BWEST COUNTY FARM {me me an vzsma NAME 1 ORGANIZATION PASS a 12 (38 1321 Pablo Gonza1e2~ DAR P330 09 12 08 1&09 Sarah Korn- DAF ?880 09 12 {38 1416 Robert Humes~l DAF Peso NAME OF STAFFH NMAYE VISIHNG TIME 01!? Drug Farm area . 5 Drug Farm area. Drug F?rm area. 0 12 68 1443 Scott'C Penney? Public Defender PBSO 09 12 O8 1528 Jack Gol?berger Attorney 2?03"] Various dorms on the compound./ Epstein, Jeffrey (T-Special). 09 13 08 isto her Modsall recess Sexver V-7 te, Antwan (waorm). 0 13 08 Jones- ant PBSO Adult Cuetod Office09/13f08 1213 Joseph Pagamra-w Paralegal 09(13/08 1 - (7 I 11 Epstein, Jeffrey (T~Special)l PALM BEACH COUNTY OFFICE . DEPARTMENT OF CORRECTIONS OFFICIAL-VISITOR LOG: Ci MAEN. DETENTION CENTER 7 ME 1N VISETOR NAME I ORGANEZATION ?3 . . Q) :0 .Qth: 3 <3 0. IO 3D. CAME tn- Swim .11 Mi- GREELJ 3 i-A?Zwaz? . SARA I . 0?72 wasn . Ga: got? 0801:? Jay Badget-t" PBCS 0820 John Staff atrec Rb Trinit Staff- QWEST COUNTY E1 DRUG FARM . I PASS - NAME OF A L) CUM Jim: 9013 - f? (n a Classroom. PBSO - P2350 ?Bid PBSO Dru Farm area. 19350- On the cand?to G/Hw?orm. Je re ecial PBSO 31d ?42; L?dorm' T-?om -V'un?m PALM BEACH OFFICE DEPARTMENT- OF CORRECTIONS - VISITOR LOG :3 mm unaware CENT-ER I 'vasrroa oaemazmon - PASS 0 . 08031 531 - Q39 WET Cd @100 1L ?mefra Cm 0 - NDR HIIBWTHO 0%1 60% BEN Na 50 n?mwm 0 W10 . Wife) if OMS I 2?37 OK. 850 2' ?2?45W10 Aims mm 2.10 STO 0* i3 couuw DETENTION DRUG FARM NAME OF STAFFIINMATE Viz-3mm CUM DOF OQLD DEUC: "Em Q?wc . m. PJTEIN C: ?r MS {330? MW. A 100 Do?m 50m mhn?n TIME OUT PALM BEACH COUNTY OFFICE - DEPARTMENT-OF CORRECTIONS I - . . I: :v .OFFICIALVISITORLQG - . .. - - "1:3 mm gamma?: CENTER Macaw auras: comm? DETENTION c3 nave FARM. NAME OF VISITING 11mm NAMEIORGAMZAIION - Us: . 5 L, '3 0300 - 93% PALM BEACH COUNTY OFFICE-3 '-GEE-wws?emea' .. amm newsman CENYEH 9512mm DEBUG FARM . PASS a: NAME grab/7?! c.5_ Gawain? m- bo OWE mf?t' ntd?uhm?r?r PALM BEACH COUNT-Y OFFICE - DEPARTMENT OF CORRECTIONS. - OFFICIALVISITOR CENTRAL STOCKADE MAIN omamsoncsmea was - mam 9~09-08 905; 0910. VWSHOHNAMEIORGANRAHON lifford racy Kartin-.Public Defender 0 1 atrecha a Trini Staff 5 i ole Jones? Public Defender ef inolich?Vulcan ?est Central te- Interview yu- 1&15" Sarah Kain? "4 Je 1 _Wall - SW.- 5 A rne or on Publi?.Defender an. [3 WEST COUNTY wws? 350DRUG FARM NAME OF VISITING en route on the compound w!Lt? Bird. and area I Q?Bldg. Various dorms to see inmates; 0n the c. ound en route to G/H-Dorm. Interview w/Nurse Whitten. Dru Farm area. I stein Jeffre ecial . Dru 'Farm area. I I Variaus dorms I M: Frazier 30311118. . er Joshua TH39 . I 8 Ar oon. SA18 . Drug Farm area. Dru Farm area. and 5 area; stein, Jeffre 22131). and Sfarea to sea_inmates1; stein Jeffre .p PALM BEACH COUNTY - DEPARTMENT OF CORRECTIONS Q63: OFFICIAL VISITOR LOG @673 CERTILAL 00100001; Cl CENTER 13 COUNTY DETENTION DRUG FAREG DATE. TEME I WSITOH NAME OF VISITING TIME OUT Mr fl FWK 6' C: 1045 at? (00% (9165} Mr; Mei)ch T?r?ku?fmg (1xe be t: I 1235 *7 QC ?02,050; . 1 99:63 - (D: 1125 0859 Mirlande os?tiggfL-gi?finfty scafgia 9330 Q?Bldg. 1351 09*06?08 0900 Stephen UM: Epstein, ?effrey 1185 09?06w08 0904 Linda Leary-- Min. PBSO Various dorms. {3924 09-06?03 0951 Elm Emilcar~ Trinity Staff Q?Bldg. 09-06?08 1203 Darren Indyke? Attorney Lw4 I/M:Epstein, Jeffrey 133? 99435433 1252 Bryagn Larsen FPL V11 Compound to check meters 1316? 69?06?08 NOD mmde D?kngu?maM-Wag 911510. {7:20 (3'6 Ef?s?/Ng a ??jb Cf; Hm :??um?i?ri (gif?bift?, ?m 3 Ba?rq/ 1&5: {194.15.}le gais (7-90? 577 05; Uffo? She?ll ?423 Edge, fang?? 0? 69 Mrs. ?rziT??t'?JS?j??D P380 -?Ue?i0/ 0910 Lyn-oz 0790 Mn 00 :41: m, P830 Dw1=0m my? 00-07438 0818 Susan Wilkoff~ 0350 Drug Mm area. 1239 09?07?08 0905 Stephen Alexangern Doctor Epstein, Jeffrey (T?Special). 09w07~00 090? Hirlande Osting? Trinity Staff 0330 09-0?-?08 1006 Rita Emilcar? Trinity Staff P880 Q?Bldg. - - 09w07-08 1216 Story Cowels- Paralegal Epstein, Jeffrey (T?Special). 1512 09-07438 1520 Nicole Sauvole- Attorney_ Albury, Jarrett 1520 Wayne Sauv?le? PI 11H: Albury, Jarrett (BmDorm). 30 7/0 WK Fa 0 P1250 1W0 7? ?rm 7/2/05; coir/w; 5m gm 9/77/13" A 72.x]: 13%: ?an 0* PALM BEACH COUNTY OFFICE - DEPARTMENT OF CORRECTIONS VSSITOFI LOG CONTROL MAIN DETENTION CENTER RSTOCKADE Ci WEST COUNTY DETENTION ?3 DRUG FARM DATE TIME 1N VISITOR NAME I ORGANIZATION PASS NAME OF TIME Giff ?497 23? 9 but my? 0147? ?lo/0? WI 2?2? V9 ?aw? - 2/225? 0? 0132:: Ms Wax/13' Fi??b 1-119 Cid-{Z} a/Ewn Mm?mm Mam 0-543 000:3) Eons?fan Dru?6 Hutu-1 33131365 as. 08 Cam/?1 thgak) 3 106:0 Dune. 046% CSAKP) p333 - Dmcu 1531 4-506 07451 CA 969% mm: I 01- 03 0750 Chevelle Hytower? SW PBSO I Drug Farm 3188- 5&5. 03 0752 Patricia Edelmahu I PBSO Drug Farm area. I 9?05?08 0754 Sysan Wilkoff? SAAP 13350 Drug Farm area. A qu 94-05?08 075? Jay Badgett~ PBSO School Teacher 1127 9?05-08 0834 John Habicht? Trinity Staff PBSO Q?Bldg. 9435?08 0902 {3/8 Maharry Deputy 21380 On the compound. 0915 9?05w08 09M Patrecha Rewbyw Trinity Staff FBSO 9-?05m08 093? Ark Arthur Harper* 3358 39850 1 En route to G/Hw?om. 1040 9-OS-08 1028 E'ablo Gamaalez~ DAF Drug Farm area, 1128 35 98 121.1 Mirlande ousting?? Trinity Staff PBSO (gang. 945?08 1206 Darien Indyke? Attornejr Epstein, Jeffry (if?Special). 1222 Michael Lumpkins~ THNetix PBSO T??om and to repair i/m?s phone. 1227 Nancy Valencia? SAAP LwDorm and T~Dom to see inmates. 9-05?08 3.258 Caitlin Bronstein- I PBSO Drug Farm area. 9?05?08 1315 Joseph Var1u~ sag? P880 Drug Farm a?rea. 9415?08 1316 Parrick Nelsorv Max Davis I Intake Booking area. 13:42 01?9?9? 5951f?? ma?a? 9ko Wm MI) {i If hid"! -. mun .. -I ., 1mg In 06 PALM BEACH COUNTY OFFICE DEPARTMENTOF CORRECTIONS VISITOR LOG I i - 0 mm DETENTION CENTER 516199?an 11:1 mercouuw DETENTEON DRUG FARM: NAME 1 PASS NAME OF STAFFIINMATE VISITING - 0 do Leonaido Taborda~ Public Defende Various dorms to see inmates. PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG I MAIN DETENTION CENTER WEST COUNTYDETENTION I3 DRUG FARM DATE. TIME iN MARIE ORGANIZJWION . PASS NAME OF STAFFIINMATE VISITING: TIME OUT r'mr/ A rt PALM BEACH COUNT-Y OFFICE CORRECTIONS . QFFICIAL - ?3 mm DETENTION CENTER 3 b?rocmne - uwssf COUNTY DETENTION t1 DRUG FARM TIME IN 753? 0313 0% )3 0m: CR VISITOR NAME I EADQW Cm mm Es.wa CHEM C119 . 0 0 SD VISITING ?55 KQBM C- 5.13M) (Pm ?5 Duhmama, 3:30 :?leetg?' umu' o1. m3 Pm): 1010 SK (WM l7. ?5 A "2.33 as :9 3q 31b QQWUES AER-L603 EUN A 38mm (.0 130 ?25? 3. '229.30, <3 6: (~53ng A NJ L, LU x. 0: 12/0 \fa PALM BEACH counw OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG L, {3 MAIN STOCKADE . BWEST COUNTY 13 08136 - PASS NAME OF STAFFIINMATE VISITING 5 (2-: Ar or I 1 In Drug Form area. Staff . Fredd I'N'unezw Simens I Electrical room. . Central Control School classroom. I . . lirote Javanadi? ESS en ioute to Intake Control. I 1129 . - Ha Greene- T-Netix En route to Tale hone Room. - - 09*02?08 Arthur er? ESS 09*02~08 Sto Cowles- ale alf En route_on the oond to various dorms. Ei?i? IIM: stein,.3effre {Tws ecial) 09-02-438 Caitlin Bronstein? SAAP Dru Farm area. I: . PALM BEACH COUNTY OFFICE - -. - DEPARTMENT OF CORRECTIONS 035?er 60323510 L3 MAIN cavemen CENTER smcmaa- - away-comm Daemon a save FARM DATE TIME 1? wsma NAME I PASS NAME OF VISITING 12 6 Jack Goldber er~ Attorne I stein, Jeffre (T-Special). 2' - . 1236 Donald Silver? Attorn? - I I I stein, Jeffre ecial). O9#02m08 1257' . Jaseph Varjum Drug Farm area 09w02?G? '13?8 Bradle Parker~ Gold C?ast Sew &-Hacc- 'Drug Farm 09-02?08" 1355 Timoth Justin-- SAAP I '3330 'Drug 09?02?08 .1414 I Sarah Kern" DAF Q- 2 P330 area via gate Farm area. "Drug Barm area. 09*02~08 1414I - Jessica Wall I .l I Drug Farm area. 09-02408 .l?40_ 'Ms; John? Pre?Trial Servicesj Ci On the 69*02w08. ?1501 Kenneth Huxhold? SAAP: IEn'route to BwDorm. 2-438 '1533 St-o Cowle Paraie 5-3' 1114: ound to various dorms. stein, Jeffre (T?Sppeial). DATE, ?a raw: 49 TIME IN 0 ~01~68- o9~01?08 09~01?03 a .0 xh?: I an Alexancier~ Doctor Michael West? SAAB PALM BEACH COUNTY OFFICE 33 - DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG CENTRAL ?mcms . DETENTION . MAIN DETENTION CENTER :3 DRUG FARM warren NAME 1' PASS it NAME OF VISITING . i??l 06 I Patrechax?ewb Tr Staff . ac). 1/3: tein, Jeffre ecial) Drug Farm area. I Esptein, Jeffrey (T?SpeCial). tein, I Jeffre Jack Goldberger? Attbruey I - .. . - PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS . - {3 MAIN DETENTION CENTER Cl STOCKADE- QWEST COUNTY DETENTSON {3 DRUG FARM NAME I oasmzmom PASS muss 0F we 3- PALM BEACH COUNTY OFFICE - DEPARTMENT OF CORRECTIONS . .. - - OFFICIAL wsn'on LOG - unkm [haw STOCKADE - Cl WEST COUNTY DETENTION E1 DRUG FARM 1 PASS NAME OF STAFFIINMATE VISITING PALM BEACH COUNTY OFFECE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG C1 MAIN AQSTOCKADE QWEST COUNTY DETENTION Ci DRUG FARM DATE TIME 3N VISITOR ORGANIZATION NAME OF . - 92223195 ?ea mg 4, ii 53' 5:33 .2 1?3" ma 4" 3? 4? L9ij 55% 1 Lg 5&8; L154. 9M . 4-. .. .. .. M. .. PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG a mum: 7 3' TDCKAQE . DWEST COUNTY DETENTIGN a DRUG FARM VISITOR NAME-I PASS it - TIME i {run 5N9 Egg-42' Cowt?s CPam 13% 085? ?0317 be, 5- ?19:23. mug FMBM if I NMC mecm (3:3 3 H22 PALM BEACH OFFICE- OF-connecm :orrw-ms'm? LOG . NS Ce/Hm COMO mm DETENTION CENTER mamas - a was? comm DETENTION a DRUG FARM was In msrroa mags; -- PASS 4: 7 .- NAME OF 3953 . 65 I. K9 GWJCA W. CPR SEMI -Q3 ?m 3? mm, (?4331? I 5335? - . PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG H. :3 mm DETENTION CENTER D??rocmas awesr COUNTY 0515mm: VISITOR NAME I ORGANIZATION Cl DRUG FARM PASS p- NAME STAFFIINMATE VISITING OUT PALM BEACH OFFICE DEPARTMENT OF connec cm Mo CI MAIN DEVENTJON CENTER - ?3430ch08 7 a WEST-COUNTY crewman a DRUG FARM "wsnoama 1 i . M: gal Illt._. A i .1 g:ng (n ?Mi-u 19? .1. 1? PALM BEACH COUNTY OFFICE - DEPARTMENT OF CORRECTIONS. OFFICIAL VISITOR LOG CENTRAL Iceman": - Cl MAIN DETENTION CENTER 5 STOCKADE QWEST COUNTY DETENTION DRUG FARM HME 1N NAME-I OHGANIZATION NW8 OF STAFFIINMATE VISITING I TIMEOUT . 08122108.- 1026 Mamie Kendal Williams~ Attorney Lu? IIM: Jud-kins, Joshua (AwDorm). . 1050 08122108 1055 Michael West-- SAAP Drug Farm larea. 08522308 1I59 Philli Hellerw P5 Dr Spencer, Cohen (8318). 1324 1159 Stor Crowles~ Fax-ale; . Epstein. Jeffrey . I Alfred Miller? I?uhlic Defender PBSO '?gzzgosy. 1203 - Patricia Edelman~ SAAP P-BSO gg 122108} 1249 Tom Hatcher- cemmumcacion] - P330 :430 I {23(225081 1250 . Jose PBSO Drug Farm -area._ I 513-02 Jack Goldber- er? Attorne Epstein, Jeffrey (T-Spec). '1-432 .. {magma- . 1302- 3 Bruce Rei-nhart-? Attorne - L-2 I Epstein, Jeffrey (T-Spec). 1-92-- I (13:12 2195 - LE 3 Kenneth Huxholdu- . 1413 {33 ?zz-{93 _}311? I) S- Mcharre -- ut .PBSO 1318 I 08(22g089 1410 3 Dustin. Moore-f WPB PD DetectiVe. ?32 5 ?g 3 {410- - R3 and Shaw - WPB 331) Detective Wm?a 3 I 08(22308 1&10 .- Sta: Crowles-f Par?le IW 08 22 08 1412 Rev. Bannister?? Cha lain. 1539 - 085221.08 5 1412 Jessi?a- Wall - DAF PBSO m} 08(22208 1412- Sarah Kornu-DAF. I PBSOI 93122108 15 8 Scott Pane -. P?lic Defender . PALM BEACH OFFICE OFHCIALVISITOR LOG. - - - CERngL_conIaon ommaemmnon CENTER Cl WEST COUNTY DETENTION E3 DRUG FARM VISITOR NAME- i NAME OF VISETING John Hahicht? Trim: Staff 350- Q-mag. Defender- Various Dorms to see inmates. erI Patrecha Newb Trinit es 350 350 1330 ~11 arious Bldg; 8 22 08 22 08 lborms.to see inmates. orne~ Public Defender: lan - Z?ro Fitness 7' arious Dorms to see inmates. ckar room 08(22/08 Av?qom?I . I . .. - PALM BEACH COUNTY OFFICE DEPARTMENT OF-connEcnoNs - - OFFICIALVISITOR LOG - Ci WEST COUNTY DRUG FARM 1:3 mun CENTER . NAME I NAME OF STAFFENMATE mamas - 39?, C: MILQAK ?:unmet Dwe .- mw?a L2. 2&3 3m CQNLES w: ?7 amt/5.03930. ((9111c3356 PALM BEACH COUNTY OFFICE DEPARTMENT-OF CORRECTIONS VISITOR LOG MAIN CENTER i1] STOCKRDE WEST COUNTY E3 DRUG FARM VISITO 0 RGANZZ A88 macaw SM. IL 0 if; . i (IVA 45AM- PALM BEACH COUNTY OF FICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG MAIN CENTER Ci WEST COUNTY f3 DRUG FARM DATE TIME IN VISITOR N352 I ORGANIZATION NAME OF WSITING 4&0 {xii} TIME OUT . . . PALM BEACH COUNTY omca ME -- I. I DEPART NTOF -. - -- - - mi?; (Wm {3 MAIN CENTER aw?st?ouuw DETENTION a DRUG FARM DATE TIME IN NAME 1? enamazmow NAME OF msmue {01; 7.33/- ISD mil ILL x74, ?5 "3 EEC) Ma'idaIE-? I?m' Patrech? Newb - Trinit a? 3 Staff' max) .- PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG Qg?La? I QANCA :3 MAIN DETENTION CENTER Viia?ocmoe NAME I ORGAMZATION PASS NAME OF VISITING f? Ca 0 WEST COUNTY DETENTION DRUG FARM TIME OUT . - . . . . PALM BEACH COUNTY OFFICE DEPARTMENT OF FICIAL VISITOR LOG Wu n? {3 mm CENTER - ?3 WEST COUR DETENTION DRUG FARM DATE '2 - TIME IN WM VISITOR NAME I ORGANIZATION . I PASS NAME OF STAFFIINMATE VISITING 25:51:33? 7(70 - - DATE - q. .. . hm? . PALMBEACH COUNTY OFFICE - . - . CORRECTIONS -. - :1 mm 0575mm: CENTER VISITOR NAME mcmn? WEST COUNTY DETENTION . ?1 DRUG FARM in PASS STAFFIINMATE VISITING 5/ K- VW PALM BEACH COUNTY DEPARTMENT OF. . Local wacowo ?3 MAIN DETENTION CENTER STOCK-JADE WEST COUNW DETENTJON DRUG FARM NAME I NAME OF STAFFIINMATE m?ai PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIALVISITOH LOG I 9 MAIN oerzamow CENTER su?srocmns E1 WEST COUNTY TIME VISITOR I ORGANIZATION PASS NAME OF VISITNG ?DRUG FARM "/36 an /24 gl?v? fizz? PALM BEACH OFFICE DEPARTMENT OF CORRE TIQM EM E: MAIN 9575:4110?: CENTER I (swamps WEST COUNTY DETENTION a anus FARM NAME PASS NAME OF STAFFIINMATE VISITING 75938 OUT Guam pmer #35 151775660 Mata?5n 72m - - art/ma {imam Sam") 77w kh. ?P?mz'm. Sagan.) you. 5' 98' 330% I pbm??a Ema 5AM 3% Cw: - 721% 6 - VN @Eu?g ASL 6533.330) . - 3 I3 fa?me?map?14L352 A wm to 1 manana om, ., . ..-. PALM BEACH COUNTY OF ICE. . -. - - . DEPARTMENT OF CORRECTIONS LOG - a. Wight DETENTIONCENTER . 13 WEST- COUNTY DETENTION C1 DRUG FARM 818388 - NAME OF STAFFIENMATE VISITIHG bi 8ng i: ?rim ?13130! 120 :3 08/12/08 0800. Timothy Neff-' 8088_ 8880 School ClaSSrong 1018 08/12/08 . 080:3 - Q??io?'??lgg??fw PBSO School Classroom. - 08/12/08 0833 .MS. Futchw Section Manager Drug Farm area. 112?. 08fl2/08' 0833 Ms..Lindsay~ Secretary PBSO Drug Farm area. 1243'_ 08/12/08 -: .0844 Adam Langi-no- Public Defgn?er I PBSO to see inmates. I I 08/12/08 -. 0853- Story (ironies-r Paralegal - I .. pstein, Jeffrey (Te-Special) 1046 I. . .. . 090.9 Eliza Emi-lcarn Trinity Staff. PBSO (If-Bldg. . lg 08g12f08. 0940 - Jerome Burdit- Sun Sentinel le3 1119.0 0940. Valerie Kalle- DAF Drug Farm' area. - a .1119 08512408 1010 - Patrecha Newbxu'TrinitZ Staff PBSO . Q~818g. . - 1020 Melvin Jensen-- Stat? of. F.1- Inv?stigoz; Various dorms to see inmat?s. 1210 08/12/08 12% Story: Crowles? Paralegal I . I L-l. Epstein, Jeffrey (T-Special). '08/12/08 1254 Caitli? Breastein+ SAAP PBSO 2, OBZIZZOB 1310 Brandon Pickensw Public Defender 38330 - 08112g08 1320 Josegh Varju~ -. . . 8880 08212/08 I 1321 Bernard Willis- Fern House V12 Andre Finlev HM 08/12/08 1326_ 88881408 0. . 55 I . PALM-BEACH cioum?v OFFICE - - -DEPARTMENTOFCORRECTIONSDETENTION CENTER - COUNTY DETENTION DRUG FABM ?nms- '1325 91412 _1515 DATE ?s/Lz/oa' Rev. Bannister? Chaplainij PASS 0F STAFFJINMATE Various dorms. TIME OUT 1520 Lg Jessi?a wall DAF 'Nic 1e saddle-'Diaz--DATA- a Goldber er? Atto E) Drug Farm area. 4 Dru _Farm area. (T?s ecial). stein, Jeffre ?x . E) PALM BEACH COUNTY OFFICE 3 - DEPARTMENT OF CORRECTIONS OFFICIALVISITOR LOG Canjm- - NANA I - MSTOCKADE Cl WEST COUNTY DEIENNON CI DRUG FARM TIME VISITOR NAME 1? ORGANIZATION I NAME OF STAFFIINMATE if") Larch) PALM BEACH CQUNTY OFFICE DEPARTMENT OF CORRECTION OFFICHAL VISITOR LOG W511 ColerA c1 man osmwou CENTER sfsrocmne [3 WEST COUNTY DETENTION Ci DRUG FARM TIME IN NAME ORGANIZAVON PASS NAME OF STAFFIINMATE TIME OUT I 2 LL an. 3:30 [Cl/39? I PLAINTIFF TO MOTION FOR PROTECTIVE ORDER 536] CASE NO: EXHIBIT Part 2 of3 PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIO QFFICMLVISITOB LOG r3 mm DETENTION CENTEH NAME I ORGANIZATTON . {w - L?o 9,55 - (1 - {3 WEST COUNTY BETENTION NAME OF ST calm DRUG FARM IINMATE VISITING m3 D?dho?r GSWH- PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTION OFFICIAL VISITOR LOG Can [3 MAIN DETENHON CENTER Cl WEST COENTY DETENTION El DRUG FARM DATE TIME IN mama NAME i ORGANIZATJON PASS NAME NMATE TIME OUT ml PALM BEACH CCUNTY OFFICE - DEPARTMENT-OF CORRECTIONS . .er I - QWEST couuw DETENTEON :3 arms FARM a MAW DETENTION 05mm TIME VISITOR NAME 3' ORGANIZATION 0V4 I @556 2g#356 3?13 I I I 013% .mw a I11 74 4F PASS NAME OF STAFFIINMATE I app/W I i'nnJ? PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIALVISITOR LOG Mm [3 MAIN DETENTION CENTER El WEST COUNTY DETENTION DRUG FARM TIME 327 ?33 3 ?5 VISITOR NAME ORGANIZATION C617 mm: A L53 9M, Kb '53 PASS NAME OF STAFFIINMATE LU (NF/mm 30000:305: 39.. 600.? ?We PALM BEACH. coumv DEPARTMENT OF connecno I OFFICIAL I QWEST county unaware a DRUG FARM :3 mm DETENTION CENTER dsrocmos? wsnon NAME I ORGANIZATION PASS NAME mm? 5mm .- PALM BEACH COUNTY OFFICE -- . . DEPARTMENT OF CORRECTIONS I II 1 LOG I I MAIN IDETENTION CENTER DWEST- COUNTY DETENTION Cl DRUG FARM - TIME vssnon oasamzmon PASS {55? . 1965:: few 34? NAME OF VISITSNG 56 PALM BEACH OFFICE IT DEPARTMENT OF CORRECTIONS omqu Vlsnoagoq. -- ID MAIN DETENTION CENTER ESTOCEQDE awe 7 c6fm1'v DEFENHON DRUG FARM vzsnon NAME oaemzzmom Am min! SEEJCLB (PD. LQQD I L. PASS NAME OF STAFFIINMATE VISITING (3 LL 1 .6). Lam-1L 6W ?3 $9 I I PALM BEACH COUNTY OFFICE - - DEPARTMENT OF CORRECTIONS CFHCIAL wsrron . - 9h - Ci vaO Cl MAW DETENTION WEST COUNTY 0836 VISITOR - NAME 00* 0n ?0 ?f (linked ~03 21? . Ahab: 23% amp: mini?? 8:06?? ~05! Cir-?r {0.5 .6 . PALM BEACH'c-oumv OFFICE DEPARTMENT OF CORRECTIONS. A L96 1 ?9qu mo . MAIN CENTER a?rocmae :1 WEST COUNTY DETENTION a DRUG FARM VISITOR 2' ORGANIZATEON NAME OF WSIWNG - I PALM BEACH OFFICE . . . DEPARTMENT OF-CORRECTIONS OFFICIALVISITOR LOG Can CE - .0 mm CENTER COUNTY DETENTION a mus mam VISITOR NAME I ORGANIZATION PASS NAME OF VISITING Bel en? La? of David 33 arthur Saxton (RA?Dorm). Crowl?smCPaza Le a1" ?1 IXM: Jeffrey Epstein (T?Special). . I I State Cf Fla Investi at Various dorms to see inmates. 0.26. Patrecha-Newb Trini 'Staff 2380 I 1009- Michelle Jackson? State of Fla. Variosu dorms to see inmates. me Ost - Trini; Staff 2330 Q-Bldg. Ivan De ut I 1 I PBSO Levi, Sheri (C?Dorm). 0 ea? DEF I Drug Farm area. I . - PBSO Drug Farm "area. SAAP . Dru Farm area. einw-DAF - . P880 -Dru Farm area. Ar? dorm 1330 G. Scott Penna PubliC Defender Evarious dorms to see inmates. - AF PBSO .?dru Farm AREA. FBSO Dru Farm area. PBSO Dru Farm area. PBSO Farm area. 3 1 PALM BEACH COHNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL vusrron LOG Ce?lml i3 WEST COUNTY BEYENTION CI MAIN CENTER CI DRUG FARM 1N VISITOR NAME ORGANIZATION PASS 4% NAME OF WSETZNG owing circled di?not leave Thef 8) Luf' Who is this pa 3% av r' . BEACH COUNTY OFFICE - - ..- CORRECTIONS. OFFICIALYISITQRLOG Cb?i?? :3 mm 0575mm CENTER 'a?rocmns uwssr ceuww DETENTION t] DRUG FARM DA TIME IN . . VISITOR ORGANIZATION PASS NAME OF- STAFFIINMATE VISITING 7-3'mt?) VL x? .1 PALM Beam-comm. OFFICE -- . DEPARTME-NTOF CORRECTIONS - .Genm- Cm u?wesr comm DETENTION r3 DRUG FARM :3 mm CENTER om 11mm: - VISITOR NAMEIOBGANIZATION NAME OF VISITING ?mas cm 3 5- "1?3 . "I?m - ?57? 3 . 2:2 . 5527 .3 I 7:f?'sa C. (2, Dim; I:an PALM BEACH COUNTY OFFICE OF CORRECTIONS OFFICIAL VISITOR LOG {3 MAIN DETENTIGN CENTER Cl WEST COUNTY DETENTION DDRUG FARM I DATE TIME IN VISITOR ORGANIZATION 943183 - NAME OF TIME OUT 7/10/15? We - W- Fom) P354 0 MC/?e?m 10% 7/020 {60' (2 {g :ELzza?f?mfIWK/Hm ff? {fa I033 7/30/08 73:2 we. W?s-r 5?}4?67 P550 0: F050 1552 ?2 Uta/<93 704/ w, 9 {1er ,gwM P050 2) a Fm?; 12:16 7/24 {65? 70$ {95+ mpg-?g, 521m: I?ng prim Pam, 15$ ,7 Lu; ?74 it 7010 mm? 5H4 mam Fag/L - 1336- 07/29/08 0756 Patricia Edelman? SW 0030 13ng Farm 0?/29/08 0020 John Habicht? Trinity Staff ?0350 Q?Bldg. I [55, 07/29/08 0845 Nancy Valencia? PBSO TwDorm. 1017 07/ 29/08 085? Elta Emilcarn Trinity Staff PBSO Q?Bldg. 0?/29/08 0902 Gaorge Dobson~ State of Fla. Investigcr lel Wright, Radar, A and Tipton, 3 .1012 O7/ngo? 0903 Darren Indyke_ Attorney I Epstein, Jeffrey {T?Spec.) 12:14 0?/29/08 0931 Angeliki Weissingerm SAAB PBSO Drug Farm area. 150; 07/29/08 1002 Patrecha Newby- Trinity Staff 20330 Quamg. 1002' 07/29/08 1046 Robert Swisher? Ellison Services 0n the compOund. 1013 07/29/08 1006 Cruz Gonzalez" Ellison Services lel on the compound. 1013 1058 Julia Adams? PBSO Drug Farm area. 1240} 1121 Arthur Troyw 3m 32330 Drug Farm area. 07/29/08 1140 Caitlin Bronstein? SAAP P030 Drug Farm area. 1(310 0?/29/08 12:25 SAAP 0330 Drug Farm [6?83 0?/29/08 1258 Dena 1?aquetta-- Trinity Staff PBSO Qw?ldg. 07/29/08 1304 Harrv Greene? Securis Telephone I PBSO MrDorm. 1330 07/29/03 1329 Jay Lefkowitzw Attorney L-2 1/24: Epstein, Jeffrey (T?Spec). 522?. 0?/29/08 1347 Evelvn Bannister? Ch?plain PBSO on the compound to various dorms. lk??g} 07/29/08 1403 Susan Hendricks~ Attornev 1' y. I Saint Phart, Rodnev ILfsu; PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS LOG I Ce?lrmt Cowd Cl MAIN DETENTION CENTER MSTOCKADE QWEST COUNTY C2 DRUG FARM VISITOR NAME I ORGANIZATTON PASS NAME OF VISITING TWIE OUT v: HTT vhf/1H5 PALM BEACH-COUNTY OFFICE DEPARTMENT OF OFFICIAL VISITOR-LOG MAIN 957mm?: CENTER VISITOR I ORGANIZA CORRECTIONS. Cg?a BWEST DETENTION- DRUG FARM PASS NAME OF STAFFIINMATE PALM BEACH COUNTY OFFICE. DEPARTMENT . MAIN DETENTION CENTER :2 WEST courmr 9575mm: :3 anus FARM wmeronemrzmon - PASS .5 TIME NAME OF STAFFIINMATE Vasmwe a PALM BEACH COUNTY CE . - DEPARTMENT OF CORRECTIONS I . - - I - OFFICIAL msrron LOG. CW Ha COMO B-WEST COUNTY mm amewnoncemen . VISITOR oaemazmou- . I - ?r {3 DRUG FARM PASS NAME OF-STAFFIINMATE WSITING 0 I - big 1 imimm +2 w: . PALM BEACH CQUNTY OFFICE DEPARTMENT OF CORRECTIONS ?gmsz i3 MAIN DETENTION CENTER UWEST COUNTY DETENTION ?3 DRUG FARM TIME iN VESITOR PASS DATE: NAME OF STAFFIINMATE wsmwe TIME our . I i - . 6 ?Hit: 1 (a U. C063 7 0:(23mm?Dar 'PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG I Cm*ra\ e; E3 MAIN DETENTION CENTER E3 WEST COUNTY DETENTION TIME IN NAMEI TION PASS . ?j Cf I DRUG FARM NAME OF STAFFJINMATE VISITING ?0 PALM BEACH COUNTY OFFICE . nw?f?i rz?m OFFICIAL VISITOR-LOG w-Mmz, (human ?3 MAIN DETENTION CENTER I UWEST COUNTY BETENTION f3 DATE I TIME IN: I I VISITOR I NAME OF STAFFIINMATE VISITING TIME OLIT I 07/22/08 - 0950' Yvette Earnsworth~ Public Defender 330 Various Dams to see jun. 1019 I 103.? Patrecha Newby? Trinity."3taff I I P1330 043162. ?1028 2 Genevieve Hallw Attornev_ Pierr?, (Awborm) Brools, 1114 _:Chfistooher Mi?dlebrooks? AlequgI- _ou ph? compound-reset mouse trans (?3925: 'Jeff Gibson? ?38 I I On the Comgound to repair gate #16. 1307 __1123" 'Michael_McLau2han? ESS ?0n the Compound to repair gate #16. -1307_ 1 92/22/53 "1138? Michael Westw P3350 .Drug Farm area. [5?50 I 0?}22f?a I1219 Story Enstgin. Jeffrev (TMSQeciai). 1320 I IIZZO 'Jack Goldberger? Attorney L?l Epstein, Jeffrey (T*Spac1a1). 1358' .1229 Robert Critton- EpStein, Jeffrey (T?Special). 1320 I .307f22/?81 Darren Indvkew Attorney L?3-l Epstein, (T?Special). Ifi?zu .1308 Joseph Variu- SAAP Drug ?arm area. I (53223 07f22/68I? McCov. Quentvne (MrDorm) 3425 07722168" J1335I Chanlain Bannister? Cha?lai? 0n the cog?ound.- Ifggf7 67/22163: 31402 Sapah Kern" II I Drug Farm area. 67/22/582: Jessica Wally? IPBSO Drug Farm area. IFIEDA ?1404: _Robert ?ames? DAF Drug Farm area. 07/22/68 .Jaso? Siegel? Attorney" Lap- 11%: Campbell,.Lemorris (muom). l0?/22/08ii 1423I G. Scott Pennev? Public Defende:_' ?Various Dor?s to'see inmates. Ik?gki) -14323 Trevor Sut?trm Attorne? I. I. L~5li Gaines, Bra?don Manic (A-Dorm)1509- 1?49. Leonardo Ta?ordow Fublic Defegdgt In PBSQ Quinn, Leon and Freeman, Randy 07/22/08 1449 Adam Langino~ Public Defender-H? 1/14: Salazar, Miguel (RAOS). $1077 .1457 Kav Galesbv? Public Defendef' Ig?z 07/22/68 1501 .Timothv Jus?nw Sm I 93397 Drug Farm area. I70 '7"?le 0% 1me (gang; {winery L-?l ?Roam In 3mm (calm/x Q1 PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS ,3 OFFICI stnon LOG 03 ?lm 03mm" Cl MAIN DETENTTON CENTER STOCKADE 9 WEST COUNTY DETENTION Cl DRUG FARM VISITOR NAME TI PASS (1 I?\n 'i?t NAME OF VISITING TIME OUT E377 ?!22/08- Mic e1 West- arm area. 0? 22/08 Susan Wilkoffusm 22 08 Ja Bad ettm Drug Farm area. School Classroom 2 Patricia Edelman~ SAAP Drug Farm area. ta Emilcarm Trinit Staff Q~Bldg. Ka 0 lesb Public Defender C?Dorm and 3 IT- iCht? Trinit Staff Q_Bldg. \r . . PALM BEACH CCUNTY- OFFICE CORRECTIONS CFEICIAL VISITOR LOG DETENTION STOCKADE qusr COUNTY Ci ORUG FARM NAME I ORGANIZATEON PASS NAME OF '3 pm 41m, Nasza .. - I PALM BEACH COUNTY OFFICE - . -- .. OFFICIALYISITORLOG - .13 MAIN DETERTION CENTER ERNEST COUNT-Y DETENTION DATE I WSITQR El ORGANIZATION PASS NAME DRUG FARM (>51 PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG MAIN DETENTION CENTER E3 STOCKADE - COUNTY DETENTION DRUG FARM TIME OUT TIME IN I NAME I ORGANIZATION PASS NAME OF STAFFIINMATE VISITING 0335 PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICJAL VISITOR LOG CENTRAL CONTROL [3 MAIN DETENTION CENTER STOCKADE GWEST COUNTY DEFEWON Cl DRUG FARM DATE IN NAME I PASS NAME OF VISITING TIME OUT 0944 Michaelanne Marie? Stata of Fla. V?ll I/m's: =1045 0N18208 1153 Deputy Haharreym Deputy PBSG ON the cempound. 121? 1155 Mirlande Ostingw Trinity Staff PBSO Q?Bldg. 1200 Story Cowlesw ParaLegal Esptein, Jeffrey 1354 123.8 Jeffrey Ivory~v ?re~Trial Services PBSO to see inmates 07/18/08 125? Julia Adams~ SAAP PBSO Drug Farm area. 1712 0?/18/08 1305 Susan Wilkoff- SAAP Drug Farm area. ljl?L 07/18/08 1300 Pablo Gonzales? PBSO Drug Farm area. 1402 07/18/08 1308 Patricia Edelmanu- SAAP PBSO Drug Farm area- MOE). 1308 Chevelle Hytowerm SAAB 9350 Drug Farm area. jog} ?lm/08 1309 Jospeh Varju? PBSO Drug Farm area. 133.8 sarah korn pbso drug farm area . 1,102 1350 scott penny pro fwdorm rmdom and s~dorm. i4??6 - 1345 Timothy Justin~ SAAP PBSO Drug E?arm area. 1400 Jessica Wally- DAF PBSO Drug Farm area. oy/Wog 1427 Rebecca Thomann? DOC Vuli UM: Trejo, Frank 1443 07/18/08 142? Tequllia Jones? DOC Trejo, Frank 1448 1439 Caitlin Bronsteim- PBSO Drug Farm area. ?gills/08 2527 Jack Goldberger~ Attainey UM: Epstein, Jeffrey T~Specia1). 715-?05 9km (mm L1 Teocca?a? inmke rm Tl?l?y-C?E? 1% 0m MP W5 mm ?lam r? 1'51; Wi Jme 66m Mme? mm {314: 1256? (ngmi mom PM (MT) L4. 'Tq??ied ko?ce, mam ?gm-bf) .010!" 7* 200i? Yr 2 {vi (damn? AA) {21.0} Tarp?) giiD?mgo (Alum?i??) .: 5Q ?rm ?3th 14:37-03 .2000 PALM BEACH OFFICE DEPARTMENT OF CORRECTIONS QEFI: LOG - [3 mm DETENTJON CENTER uwssr COUNTY DETENTION a onus FARM wsrron NAME 1? mass. NAME OF 9N - ,m 5 AV (6?0 1060 A3 ~90 18C K3 AN 0 SEEM L9 (0 . 11K: (:30 ADC . - 7 - "or - mgm- COUNTY OFFICE. . I . DEPARTMENT OF CORRECTIONS . . . - - . - MAIN HETENITIION-CENTER- umsrcoumv DETENTIGN GDRUG VISITOR NAM I ORGANIZATION PASS NAME VISITING TIME OUT PALM BEACH COUNTY OFFICE DEPARTMENT OF connecnons OFFICIAL VISITOR LOG LMW E3 MAIN DETENTION CENTER QWEST COUNTY DETENTION [3 DRUG FARM DATE TIME IN VISITOR NAME I ORGANIZATION PASS NAME. OF STAFFIINMATE VISITING TIME OUT 01:4 5?an Himaza w?mmw. 585??: hra?n :13! M930 Cum-?Zr: puntqu - Thing-L; (4330 r1. 15.69 Mar CA: 1? w) Rafa-usww P6329 om? Pam MW 0- 13.0? 003?; Wmmn; Jam?; P650 D?aa {Um 7.15:0? mac; 67am straw (saw) ,ps 5?0 DIM 11m (5?73! Julia-K MKM (W9 muc- FMA 0031; Am; diam; mwcauakl-wa asst: Mam ma ?1.15.09 07% gamma (snap) @933 ?ns?v? H555 17-15169 mass. wm- (52mm {3633 339% ?~53 '74565? 9044 (saw) @523 Own mm ?7.151529 DOST Jan, Awa- goa 5,5 WMQ ?7 is? :59? 5115? webmwo ?mam MttaDa-x Page wow? aza- $33? 15- 0905:: ng'rw? lfABIC?1-mmaJmf We jaw D355) r745: a? 0802. many: Jam? may 9-0? f; 038 (4771.3 mm 179:3" Mama him?Eva; 98:2. 25130? 273:? m- (mi: PM ma mo '7 053?1?3? C(n?rd?lii %Berb jg! ?1 -??nmz,7u {(13:21) mixing} 09.21.. raga? gm, J) . mm 34-an7 ?7"me airman af?rm 3c. mis?t}! {>5st (4W Crawb?v C?wbw?n with) Liam; {farm 2?11 wslog 66:59. 52,! w: {1m (IF- Pm M3 [cam j'7l5 0.3? Mira? WHY Adm [9:4 196.8? has? {119mg} Pf?o d.er 1433? ?pf-off miwm L-vgm Mavis? L-g- my, aglgaimm 32.5.2: ils?l (?13054;an ?t?bm'?in (.3313?) Quinn ?rm w) a ?1?9le U53 rfg?a?fb P. P3230 mg?nuts Ma} 33,3 ?(nu {?7?th it? DATE PALM BEACH COUNTY DEPARTMENT OF CORRECTIONS - LOG MAIN STOCKADE QWEST COUNTY DETENTIOK E3. DRUG FARM PASS - WSWOR NAME I ORGANIZATION NAME OF VESITING PALM BEACH COUNTY OFFICE DEPARTMENT OF OFFICIAL VISITOR LOG MAIN DETENTION CENTER Cl STOCKADE {3 WEST COUNTY DETENTION Cl DRUG FARM VISITOR NAME I ORGANIZATION PASS NAME OF VISITING TIME OUT L, LR I Ii PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL wsnoa LOG CENTRAL CONTROL i3 CENTER QWEST COUNTY DETENTIOR DRUG FARM 2. r) r? NAME OF VESETEHG I 1.9 1 ??4wa gje 14/08 0 Angelikia Weissenger0752 0759 ?atricia Edelmanu SAAP Grav 5? Dru Farm area. Te: Dru Farm.area. Calssroon Teacher. 81d Nurse Whitten in medical. I M: Es tein Jeffre 22 2 ecial Dru Farm area. Fa Farm area. Epstein, Jeffrey (T~Special). 4 1409 1542 Dru rea.? 07/14/08 0?l14/08 07fzain2 Robert Humesw DAF Jack Goldbergerw Atto: ey 5.. - - Dru - PALM BEACH COUNTY DFFICE DEPARTMENT OF CORRECTIONS If OFFICIAL VISITOR LOG - CEETR-AL com . MAIN DETENTION Xi STOCKADE I GWEST COUNTY DETENTION Cl DRUG FARM mama NAME I onamzmou PASS mass vaswme Eveel Wilford-? Trinit Staff PBSO Q~Bldg . eliki Weisse er" PBSQ Dru Farm area. Mirlande Osti - ?I?rinit Staff PBSO Bid . Elta -- Trini Staff . Jose Pa 3110- Para Le: .31 L4 T-S ecial Pa 1 - Pr ation Office-r Brown Robert (F?Dom . PBSO I Jose James A?Dorm lWri (F 1 stein Jeffre T-S ecial . p. PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG CENTRAL CONTROL 3 mm DETENTION CENTER CI WEST COUNTY E3 DRUG FARM NAME. PASS NAME OF VISITING TIME OUT 1046 ONIZXOS 1231 An eliki Weisse er - 1313 039 a ano at: a stain effre I PBSO Dru Farm area . PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG CEHTRAL CORTRO 8 MAIN DETENTION CENTER STOCKADE I WEST COUNTY DETENTION 13 DRUG FARM DATE: 07 1/08 0? 11/08 07/11/08 07 11/08 07x12 1242 1342 1414 1414 142? 1&52 1524 1534 If) f?fg jg??L 75% ?aharrey Deputy Susan Wilkoffm SAAP Sarah Korn? DAF Jessica Wall DAF Kenneth Huxhold? SAAP risto her Chien BUR PBSO P380 P330 P350 lel 9330 r? av <16 NAME OF STAFFJINMATE VISITING Various dorms to see inmates. Drug Farm area. Drug Farm area. Drug Farm area. TwDorm. KIM: Williame, {DuDorm). Epstiea, Jeffrey (T*Special Mgmt). Jack Geldber er- Attorne Wade~ Public Defender Jer Various dorms to see inmates -uv .13- .w'J .) -. f33cm: PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG CENTRAL CONTROL CI mm DETENTION camera 454 srocmue CI WEST COUNTY DETENTION Cl DRUG FARM VISITOR NAME I ORGANIZATION PASS NAME OF STAFFIINMATE VISITING TIME. OUT 73 1123 PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG amend l3 MAEN DETENTION CENTER KADE {3 WEST COUNTY ?3 DRUG NAME I ORGAMZATION PASS 0 $6 . (7650 8110:. JTEM 71) f3st "7 06% FBJO QF 7 AU. Gib/2s? 0 ,3 7 DATE NAME OF 15% 023?) {017 . - 06% NW Nic?20;? 50.09 A?hi.? PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG coum'v DETENTION NAME 0? STAFFIINMATE VismNG :23 mm: DETENTION CENTER ?sgocmos TIME 1N VISITOR NAME 1 ORGANIZATION PASS ens m/ vs a. 571m \I?Ek??m 7 9 Nib Nathan EON WQN M32WALL CW: :3 anus mm cz?'msaa/ .C /77 . . Pawtrw [fl/?25; {gun a may/r4? PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG CENTRAL CONTROL ?3 MAW DETENTION CENTER ?smomne :3 WEST coumv DETENTION DRUG FARM WSWORNAMEIORGAMZSHON ?zeeom/ PASS NAME OF STAFFIINMATE VISITING . W?u u-ll'u" CL Jay Bedgettw Teacher John Habicht- Trinity Staff . Bl . Intake Control. Elta Emilcar~ Trinit Staff ff Mr. Ha er? ESS Lawrence ew De ut Pablo Gonzalez? DAF _line~u room. Drug Farm area. 07/03/08 on~ Attorne Va um SAAP De of Correction Darren Indyke? Attorney Fer IIM: Pullens, Cleo (D?Dorm). Dru Farm area. Bid . Epstein, Jeffrey (?~Special Mgmt). 07/08/03 0?/03/07/08/08 Pu li fender Evelyanennington? Public Defender Varioous dorms to see inmates. Intake Booking area. Robert Homes? DAF Drug Farm area. Jessica Wall DAF Sarah Drug Farm area. PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG CONTROL MAIN CENTER STOCKADE Cl WEST COUNTY DETENYION E3 DRUG FARM DATE 07l08{08 07/08/08 07 08 08 NAME 1? ORGANIZATION Kenneth Huxhold? SAAP pass P350 L4: L42 NAME OF STAFFIINMATE LwDorm to see inmates. TIME OUT 3 ?538 Darren Indyke- Attorney Epstein, Jeffrey (T?Special Mgmt). i! !l Jack Goldher er~ Attorney Guy Lewis Attorney 07/08/08 Mi 11 a1 Te n? Attorne PALM BEACH OFFICE DEPARTMENT OF CORRECTIONS OFFICIALVISITOH LOG 60077277., cam/2.0L, ?3 MAW DETENTION CERTER STOCK-ADE WEST COUNTY DETENTION E3 DRUG FARM DATE, TEME 7731700 NAME enema/anon PASS 4: WE OF 010mm; TIME OUT 1210:? 0:335? Eve/qr) Uz/?rc/ P7350 750/737 Quc??m 1113 ?7 3g 06:90 630w, K650 ?72:77:57 37704: 7? 452mm,? [33{1,1370 Ms?. 6 @2143 77ch . 1 7 1W3 7/7/?03 772/5. (7 $5373 5474'! 1913 7/7 07:27 a/?hm 7760. . 550 5/774: 7? ,0;sz 4/7/03 07,20 fwd?" 7,9052) 940% <27 5; 7/7/05? 0770 [m xii/54.770 5050 4/7/19? <1 7/7/20 07.70? PM ??v?am 5700/9 [1995 0 714/08 07% Maw KJGJ 9580 Mug/Wm Mean- mg 7/7/00 0758 Susan 0:111:03? my 9030 Drug Farm area. ?mt/(5 - 7/7/03 0805 Jay Badgett~ School Classroom- 115? 7/ 7 /03 0314' Terry Graves? 3m P350 Drug Farm area- 1136 05; 7/7/03 0826 John Habich?t- Trinity Staff 0030 003mg. 084? Elta Emilcar? Trinity Staff PBSO Q?Bldg. Em "1/7/08 0859 Andre Gonzalez? ESS PBSO to gate. #68 buzzer not marking . 7am f? 7/7 /03 0859 Thomas nohezty- ESS 0350 0 *7/7/08 0911 Newby? Trinity Staff P330 Q-uBldg. W) 7/7} 0944 Ronv 'Horeston? Florida Public Utilrites 011 the compound. ?9.35 7/7/03 0957 magmas. Ostiag? Staff 0300 i; .3. 7/7/08 1014 Jeff Gibson? ?85 I 79380 on the compound. (7 1/ L52 7/7/08 1023 Caitlin Bronstein~- 0350 Brag Farm area. ?1723'; 7/7/88: 1213- Caitlin Bronstein PBSO Drug 1mm area. 7/7/00 1217 Patricia Edelman? SAAP 77030 Drug Farm area. ?303 7/7/08 1313 Darren Indykew Attorney Epstein, Jeffrey (T~Special Marat}. 129-7 h?t't- 0' PALM BEACH OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL wsrron LOG CORTROL Cl MAW CENTER E3 WEST COUNTY DETENTION Cl DRUG FARM VISITOR NAME i. ORGANIZATION PASS {Staff NAME OF STAFFIINMATE VISWING Li 9 Adult Gust Office. . i?ar IIM: air}, Jeffrey Hgmt). At: 1/151: tein, Jeffrey (if-?Special Hgmt) Teiu? Atto . tein, Jeffrey (CD?Special Hgmt). I I?ch . PALM BEACH COUNTY DEPARTMENT OF CORRECTIONS - VISITOR LOG CENTRAL CONTROL MAIN DETENTION CENTER Cl DRUG FARE WEST COUNTY DETENTION OF ST NAME I ON Bid . McCo (MrDorm) and che (B?Dorm). Mirlanda Osti -- Trinit Staff Bid . Jose Pa an0* 9arale al stein, Jeffrey (T~Mgmt). 0 ?9 h} c: 72.1,: DELI I - Tri Staff Joann Graham? MSW (Social WorkerSharon Williams~ United Deliverance Mirlande Os: Trinit; Staff Elta Emilee - Trini Staff I ste Je fre . iff Visitation area. 1 Ste Jef PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS OFFICIAL VISITOR LOG @M?abc, MAIN DETENTION CENTER GWEST COUNTY DETENTION DRUG FARM VISITOR PASS NAME OF IZNMATE VISITING CL. Ar/?k PALM amen COUNTY DEPARTMENT OF CORRECTIONS 5 CENTER . ?recms' - Vuwssr COUNTY 0575mm norms FARM DATE I 13MB 3N: . VISITOR I ta ma: .1 75250;" I am 7 ?33?49 I ((47715 T. I maoa' 300' mm M: 34-501 A rm: milk? (:31 ?wk. ma. 35 LA W?elif-DK- . \sz. "Mm: 10:90- GK - I ?sw? m? 02 (L . ?roxv??i?- nM. 3? ?599% oval??3 *1de (?mew-L - I ?8 I won; 3?3 rm. 45": Mg,? mm; 'x - - PALM BEACH COUNTY OFFICE DEPARTMENT OF CORRECTIONS - OFFICIAL VISITOR. LOG {3 WEST COUNTY DETENHON am!? o?mnmw CENTER _-?srocmna ?1 DRUG FARM: DATE .nms VISITOR name; oasmzmou PASS. .. I J) Mablih?; {g vl ?)wanm 131?: Mm 9C, V'l $9.452 140% mg. AM 6%80 M5. K9.?n (my: (?76.30 .9 402.998" Hg . ?nk! mas 94.4 9&0 0 '03-?03 . Ff? 7-0130" .1 3Aa+aciae.- an 0g? {3,9 .0. boa-w m. 7~0?~0 25702 3.42 3514mt!" Lawrs (Aw if? 595 60f 2 . :41 'W?ff/rg; I db -c>oHM NAME OF VISITING 174. gm ~65: 649. PALM BEACH COUNTY . DEPARTMENTOF CORRECTIONS. 3' MW . :3 MAIN DETENTION CENTER STOCKADE - awestcoubm' a DRUG FARM gt; . - r35. TIME IN NAME 1 ORGANIZATION PASS NAME OF 3C: 1200 1306 eliki Weissinger~ SAAB Joseph Yazju~ Drug Farm area. P350 ?9350f L?Bso sza Drug Farm area. -Drug Farm area. 141? 1417 '1445 -1451? '1506' L0 .Sarah'Kornw DAF Jessi?a Wall DAF -Cha lain Bannister"- Drug Farm area. Drug'Farm_area. on the 1M: Epstein, Jeffrey (T~Special Mgmt). Scott Penney" Public Defender -Darren Ind e~ Attorney CXW pl? 49% l. 6 es b) PALM BEACH COUNTY OFFICE DEPARTMENT OF CDRRECTIONS LOG Wade MAIN CENTER STOCKADE DWEST COUNTY DETENHON ?3 DRUG FARM VISITOR ?we I '1 PASS NAME OF VISITING TIME. OUT - area. Robert Humesw Ja Bad Darren In ke? Attorney Drug arm area. School Calssroorn. UM: Epstein, Blood Drive. T~Control I I: McCo QuBldg. Jeffrey ("f?Special Mgmt) . larical Elta Emilcar- Trinit - Staff ?1113? E88. Lar - eni Probation Officer Patrecha Newb Trinit Staff Jerrv -n?v AT 1120 Visitor. I-izfarmatio 02/20/09 inmate 513375101, JEFFREY 313325112; JEFFREY 53335111,. mm?- 50325113. .1151?31031}~ 132?52500, 3131513103? . 015315111. 353-51213? 59315121, 1131:0135??- EPSTEIN. 31531311ng . 505115110} JEFFREY 00535111, 3535113 023mm 313575101, JEFFREY 323-11301, 3133212132 21337131111 JEFFREY: I 33715111135333.3371? 93151121230115? 133713113, JEFFREY 133113111, JEFFREY 3315111, IEFFREY . 113151-4115? STEIN, IEFFREY 372101,- JEFFREY 3?1?5120; - 133%" 4151:3115? - 7 JEFFREY .. .TEIN. JEFFREY - war Inmate: JEFF TM Cell Date 10/091?08 10/11/03 1 0110103 10120103 1013-1103 I 1 1102103 1 000103 1 1/13/08 11120203 1112?7203 12104103? 12/21/03 I 12/18/01; 12122100 Iii/28108 0003/03 01/04/09 01110109 0211 1109' 01217309 01113109 01124109 01225100 01131209 021012139 02107109 02103309 02114209 02313109 02122209 Period 2 Nil-(J U- AN-b-MhbJ-hm lulth-?u ?mm WCINKOVA . "03000030313002 01211010200 '7 NADIA . 1:10:03 0151:0151 i? Relatio 1: 1123123 - - - . "713314;: KELLER-584M . - .. ., - . 0' ?"1300 . 9 I .9 ?my 70 i 02300120020300? 0" ?02200130020300?i?? 1512310? 0' '1 3133123 ?15334-13 I 312100 A "111001.4- 3121113 "Wi?ixk?wg 1:05.121 "13113113 Smggim?i I 0113000001002? "mo 13313111 #121115 ?02013033001002; 031L112 $2101) $60?$25 8135103311 10mm 301 366 3331395103: YORK, NY I, 301 E. 30121051143; 1.000221. 301 00 ST 81): 1333072012201? 3013 66TH ST 03321.40 NEW YORK 301' 50030? 313: NEW YORK, - 301 5 00111 3110123140 NEW YORK 301 06031" 30-10130; - 301 5'66 32? 313' 212w 2012mm 301 ?00 3'1 1w 3'01 005-3230911310 YORK, NY 301-13 66 s? 323' 112W YORK. NY 301 5 102151.? NY 30130032000150} YORK 11? 00 ST 835? mm, NY 30175 65012611030371: 2(3ka 14? 30: 50 ST 313? NEW YORK, NY 30: 06 51-31)" New YORK. NY 301. 06.01 NY 10X. 301 13.. 66TH ST. 231311413 13.1?. 301 E. 05311 ST, 2133140 NY. 30: 3.061315%. @1246 MY.- 301 5.06311512333146112. i 301 391146; My. 3.01 E. 66TH ST. 301 2.0021133: 211311413 mi 301 5.0071131 131512401113. 30: 8.0621131". 351333310203. 06m 32. 251333146 {Address . 301E 66 ST 89? NEW YORK, NY 301 66TH ST AFTMG NEW YORK 3 1.5003231351115311 YORK. NY V181 V151 02-21-355PECIAL 1/131 02.203551113131201. ms: 02-21-35 02.2125, 02-21?35 02-21 ~35 02?21-35 A 02-21-35 02-21?35 0242 1 35 0221-35 02-21?35 02-21-35, 02-21435 3?25?79 2-2165 2-21?35 2.21035 22 1-33 221?35 2-2 1 -35 1 2?21?35 2221-35 - 2-21-35 2-2035 Visitor Information For? Inmate JEFF-EPSTEIN azaakosz . Page: 2 Inmate: I - Ceil Date Period Child Visitor-(s) Relation Identification City 2? Comment 393mm; JEFFREY . TM 03mm 4 "o NADIA 301 55 ST 313? NEW YORK, NY 02-2145 . i KELLER, SARAH 30': 3 55m 81?- 31.4vamv - 393mm, JEFFREY TM {18;?28l03 2 - 0 mam . FRND 301 66 ST 313? NEW YORK, NY 92-21-35 . - - SARAH . 301 66TH ST 3 2403mm - 1 IGOR zmowav 15 KINGLET AWBOROMJ 5255313134; 35%?ng TM ..os;30ies 4 9 NADEA Fawn .30: 66 ST 30? 02?21-35 - - KELLER, SARAH 302 66TH ST 3 leoa'zmowev . 15 KINGLET AVEMARLBOROINJ 39375131. JEFF-REY TM 092044303. 2 o. mm; FRND 301 66 ST 80? NEW-YORK. NY 02-21485 FELL-EN, SARAH 30: 66TH ST 393135133,- JEFFREY . bmsr?s 3 {i NADIA ERND- 301 66 NEW YORK, hi? 0243-35 . KBLLEN. SARAH 301 65TH ST LAWRENCE .VESOSKI I :31 PINE POINT ROAD JEFFREY . Tiv': wk??zoa - 4 ?9 MAkcmxovA Mum FRND 301 55 ST 30" NEW which? 92-2 was - KELLEN. SARAH - 30.1 65m ST LAWRENCE VISOSKI 11.31'Pm5 POENT ROAD WPB 1527:3325? TM.- 09:: HOS - 2 MARCINKOVA NADIA FRND 301.- 5 66 ST 39? NEW YORK, NY 02.21-35 - 301E66THST314GINYINY - . . . 100R zmovmv . 15 103191353?. AVE . i . . EPSTEIN, Arm-mm, TM 63/1320; 4 '6 MARCINKOVA FRND 391866 ST 313' NEWYORKNY 02-21-35 KELLEN, SARAH 301 2 55133 3146943393? . IGOR zmovzsv ?5 AVE macaqm SPSTEIN. Erma? b?rns'zo? - 4 mum FRND - 30: 66 81)" NEW YORK. NY 02321?35 - 5- - KELLEN, SW 361 667B ST 3 IGOR zmowsv 15 mam? AVE MARLBOROM . - TM min-3108 4 {a - may. FRND 301 56 ST 39: NEW YORK, NY 02.2 145 KELLEMSARAB 3012 66TH . -- IGOR zmovmv IS mam? AVE MARLBOROM psrx-zm, 323mm;- TM - 09:28:03 2 NADIA FRND 301 866 ST 313? Nsw?voax, NY 02?: 335 #375133,- nzmzev? TM 09.320108 _4 ?5 NADLA - mm 30: 665180 NEW . 92.23 .35 SARAH KELLER 301 6651? 3 MG NEW YORK, NY 95mm, TM -- A owz'sxo's 2 MARCMOVA NADIA FRND 301 663789? 3353;360:134, NY 02-23-85 SARAH KELLER - 30: 66 ST 3240 NEW YORK, NY 9006mm 243 RIVERSIDE DR #1092 95mm.- JEFFREY: TM a: b? MARCENKOMEA NADIA FRND 39: a 66 ST YORK. NY 02.2 2 -35 95712ij 35133213? 1. TM 19/132108 2 NADIA FRND 30; 66 ST 313' NEW NY 92-2: -35 . SARAH KELLEN SMAE AS ABOVE 93359:, 32259353: - TM I-0i04!08 4 '0 A MARCINKOVA 31mm M. - - - .. Visitor I?formation For Inmate 02/26/09. 'j - . inmate Cen Date Chiid- Visitor-(s) . 0 505mm. JEFFREY EPSTEIN, JEFFREY 20.010504. JEFFREY 593mm. JEFFREY- EPSTEIN, JEFFREY EPSTRIN. Liar-ms? I 59mm. EPSTEIN. JEFFREY JEFFREY 5. 1312:3535 35mm. JEFFREY - STEIN. JEFFREY - JEFFREY 3 JEFF EPSTEIN- . Period TM ems/03 2 TM 9mm 4 0702208 4 TM 07112100 4 emms 2 TM 0709/03 4 TM I 07124208 2 TM ?owz?imz' '2 TM 07/31/08. 2 03/02/03 I I 4 00107003 2 TM 03/09/03 4 032?14/08- i TM 03/05/03 4 TM 08291103 2 LAWRENCE VISOSKJ IGOR ZINOWEV IGOR ZWOVIEV LAWRERCE Vis?skii IGOR zmovusv RGGER NR IGOR 20000150? JEAN RENE LAWRENCE wsosx: 0 IRMA SARAH KELLEN 200R ZINCIVIEV MARCWKOVA MADE SARAH I. IGOR Mcmova NADIA SARAH KELLBN IGOR zmomsv MARCINKOVA mom- SARAH 1-. KELLEN 160R ZINOVIEV SARAH KELLEN DOUGLAS A MARCINKOVA NADIA SARAH RELLEN LAWRENCE mom - mm IGOR zmovrgv MARCINKGVA 00mm KELLER, SARAH LAWRENCE WSOSKJ JR MARCINKOVA RADIAL KBLLEN, SARAH JEAN LUC BRUNEI. . aw?, Hm Relation Identi?cation City! Comment FRND ms m: FRND - PRND . km) RD WPB. FL. 15- KINGLET AVE MARLBORO, NJ 1:31 Pm??Rbm'rRD m, 151.. 15 IQNGLET AVE MARLBORO. NJ 1131004000me we, FL. N3 FRND .15 mm? AVE NJ. WAY PALM BEACH PAS 373450;:0113 saLiICI?ai. STUAR 13' '2?ng 0:00 2-5.60 -- - 30: 301 66,3585 NEW YORK NY 301 a 5m; new YORKRENEW YORK. NY . 301 56TH ST #146 NEW YORK, is AVE MARBORO, NJ - 301 66 ST 39? NEW YORK, NY 30:. 56TH ST #146 NEW YORK, i5 KINGLET AVE MARBORO. NJ 301266 ST 013? NEW YORK, w? 301 56TH ST NEW YORK, 15 KINGLET AVE N3 30: 66 ST 315? NEW-YORK, NY 301 5mg ST #140 NEW YORK3?1" 313- NEW YORK, NY 301 5 50m ST #240 NEW YORK. I 131 PINE POINT RD WPB, FL. 301 66 ST 80? NEW YORK. NY 15 KINGLET AVE. MARLBORO, 301 66 ST sir NEW YORK. NY 301 66TH ST 3240mvm I {31- PINE POINT RDIWPB 301 603? NEW YORK. NY 301 66TH ST3I4GINYINY SAME mm?" 02-05-50 02-05-60 02-05950 03? 22-45 1 2?12?2007 2?2 I ~85 024 I ~85 02~2 i 435 02-21-85 02~2 1?85 {12-21-85 02-21-85 92-21-85 02-21-35 (32?23-85 JANE RESPONSE-TO MOTION FOR PROTECTIVE. ORDER 536} CA SE NO: 08-CV-801 EXHIBIT I Part 1 of3 ?v w. DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, er 05!. Case No. 50 2009 CA EXHIBIT IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION men 2008 CAOZ 80 58 1 Plaintiff, . NOTICE OF SERVICE OF I - . FIRST SET OF - vs. I . . INTERROGATORIES T0 DEFENDANT k/ JEFFREY EPSTEINCOPY Defendant. RECEIVED FOR FILING SEP 1 1 2098 PLEASE TAKE NOTICE that the Plaintiff, E.W., 'b elm-Iona: ear. undersigned I I. . . ROLLER - .ool'msel, has propounded unto the Defendant, Jeffrey numbered .1 through 16, inclosive, to be answered in writing, under oath, pursuant to the applicable'Flozida Rules of Civil Procedure. . I HEREBY CERTIFY that a true and correct copy of the aboVe and foregoing has been provided together with. service of the Complaint herein. - THE LAW OFFICE OF BRAD EDWARDS ASSOCIATES, LLC - Attorneys for Plaintiff 2028 Harrison Street - Suite 202 Hollywood, Florida 33020 Telephone: 954414-8033- Jay Howell, Esquire Florida Bar #225657 JAY HOWELL ASSOCIATES, PA. Co~Counsel for Plaintiff 644 Cesery Boulevard - Suite 250 Jacksonville, Florida 32211 Telephone: 904?680-1234 By: Brad Edwards Florida Bar #542075 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA - CIVIL DIVISION CASE NO.: aw, Plaintiff} - - PLAINTIFFS FIRST SET or I vs. INTERROGATORIES TQ DEFENDANT JEFFREY EPSTEIN, Defendant. COMES NOW the Plaintiff, E.W., by and through her undersigned eouosel, and propouods unto the Defendant, Jeffrey Epstein, her First Set of mterrogatories, numbered 1 through 16, inclusive, to be answered in writing, under oath, pursuant to the applicable Florida Rules of Civil Procedure. I I HEREBY CERTIFY that the original and one true and correct copy of the above and foregoing has been provided together with service of the Complaint herein. THE LAW OFFICE OF BRAD EDWARDS ASSOCIATES, LLC Attorneys for Plaintiff 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Jay Howell, Esquire Florida Bar #225657 JAY HOWELL ASSOCIATES, PA. Co-Counsel for Plaintiff 644 Ceser Boulevard? Suite 250 Jacksonville, Floi?ida 32211 Telephone: 904-680-1234 Brad Edwards Florida Bar #542075 DEFINITIONS 1. The term "document" as used herein means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether different from the original by reason of any notation made on such copy or draft or otherwise. including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e? mail, electronic computer ?les, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, intero?ice communications, offers, notations of any sort of conversation, telephone calls, meetings or other bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modi?cations, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, micro?che, micro?lm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every. kind, whether or not the document is out of your possession, custody or control. The term "correspondence" as used herein is de?ned to mean any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, reports, notes, telegrams and interof?ce communication. - - 3. The term "relating to" as used herein is de?ned to mean evidencing, referring to, pertaining to, consisting of, re?ecting, concerning, or in any way logically or factually connected with the matter discussed. 4. The phrase "describe and explain" and the term "state" as used herein are. intended to and shall be interpreted to request a ?ll and fair statement of the fast or matter being described and explained, including a statement of all facts, statements, events and circumstances necessary to understand and evaluate the fact or matter being described and explained. 5. The term "identify" as used in each of the following lnterrogatories requesting an identi?cation of documents is intended to be interpreted to request and require: A. The date of the document; The originator of the document; (I. The type of document; The addressee of the document, if any; E. Identi?cation of persons to whom copies of the documents were ?lrnished; F. Details as to the custody of the document on the date the lnterrogatories are answered; - G. Speci?c page numbers where the information requested may be found, if appropriate; or, alternatively, documents may be identi?ed by numbering each such document and referring to the number in the answer and providing a true copy of each such numbered document with the Answers to lnterrogatories. 6. The term "identify" as used in each of the following Interrogatories requesting the identi?cation of persons is intended to be interpreted to request and require for each witness known: - - A. The ?ll] name of the individual; B. The last known address and phone number of the individual; C. The last known place, address and phone number of employment of the individual; D. The substance of the witness' knowledge or information relating to the I information requested. INSTRUCTIONS Before answering the following Interrogatories, will you please make such inquiries of your agents, servants, employees andfor attorneys as will enable you to make full and true answers to the following, in accordance with the applicable Florida Rules of Civil Procedure. Additionally, if more space is required, please use a separate sheet of paper. and attach same behind the sheet where the respective question appears. FIRST SET OF INTERROGATORIES TO DEFENDANT (If answering for another person or entity, answer with respect to that person or entity, airless. otherwise stated.) - i. What is the full name and Florida address of the person answering these interrogatories, and, if applicable, the person's of?cial position or relationship with the party to whom th interrogatories are directed? . - 2. What is the current name, address, and telephone number of each person that resided or worked within the home located at 358 El Brillo Way, West Palm Beach, Florida between 2001 to the present. Indicate approximate dates when each resided or worked within the home. For each working within the home, please also indicate title or job position. 3. List each telephone number used by you or your assistants to call minor females directly, or indirectly, for the purpose of scheduling a massage to take place at your house located at 358 El Brillo Way, West Palm Beach (includes landlines, cell phones, and private jet or airplane lines). For each cell phone, list the provider. . Last known name, address, and telephone numbers of all persons that may have any knowledge about any of the allegations in the Cemplaint, including, but not limited to, friends, acquaintances, employees, or others to whom you have spoken about the subject matter which forms the basis of this Complaint or who have observed such activity. Provide a complete list of the names of all victims provided to you or your attorneys as a result of, or in contemplation of, the federal non-prosecution agreement that you ultimately signed (including all minor females identi?ed as victims, potential victims, or witnesses). Provide a complete list of the names of all known or suspected minors with whom you had sexual activities from 2002 to date, including all girls introduced to you, directly or indirectly, by the Plaintiff. 7.- Describe with as much speci?city as possible where you I resided from August. 2002 through the present (this interrogatory is meant to include time spent at each of your houses since August 2002). - 8. List of all employees, servants, cleaning staff, personal staff or assistants employed by you or your companies who worked out of or visited your residence in West Palm Beach between August 2002 and the present, including their dates of employment, their job duties, and their last known address and telephone numbers. -9. State with as much Speci?city as possible when you met the Plaintiff, and include in your answer the fellowing: the circumstances and location of how and Where you met, describe the nature of your relationship; describe how many occasions she was with you at your residence located at 358 El Brillo Way in West Palm Beach, Florida. 10. Was there ever an employment or business relationship between you and the Plaintiff, and if so speci?r the duration of this and how this relationship ended, including the name of the remuneration to Plaintiff and what evidence or documentation exists of that relationship. - - 11. Did yen ever ask the Plaintiff to introduce you to minor females and/or to bring minor females to your house in West Palm Beach, Florida and if so, when did this occur, and I what was she asked by you to do, and what did you tell her about the reason-for her to bring these other minor girls. - - 12. Did you ever engage in sexual activity of any kind whatsoever with the Plaintiff, and include in your answer what type of sexual activity took place, where it took place, and the dates or general time?'ame when this activity occurred. - 13. 14. 15. Were there parameters or instructions by you to the Plaintiff as to the types of girls to bring to your West Palm Beach, Florida house, including age range, what they would be asked-to do, body type or socio-eoonomic background? - - Describe any words or actions that you made to assure the Plaintiff that sexual activity with you was proper or appropriate? Describe What age you thought the Plaintiff was when you ?rst had sexual activity with her,?including your reasons for that belief. 16. State the facts upon which you rely for each af?rmative defense in your answer. I have read the foregoing Answers to Interrogatories and do swear that they are true aild -_correct. Jef??ey Epstein, Defendant STATE OF FLORIDA ss. COUNTY OF - The foregoing instrument was acknowledged before me this day- of 2008, by JEFFREY EPSTEIN, who is personally known to me or who has produced as identi?catidn. My Commission Expires: Signature of Acknowledger Typed/Printed Name of Aoknowledger. Title or Rank Serial Number, if any IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA E.W., CASE NO. AD Plaintiff, v. JEFFREYEPSTEIN Defendant. DEFENDANT T0 ng OF INTERROGATORIES Defendant, JEFFREY by and through his undersigned counsel, serves his responses and objections to Plaintiff?s September 11, 2008 First Set of lnterrogetories, served with the Complaint, attached hereto. Certi?cate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and US. Mail to the following addressee on this lei day of November, 2008: Brad Edwards, Esq., Counsel for Plaintiff Jay Howell, Esq. Brad Edwards and Associates, LLC Jay Howell 8. Associates, RA. 2028 Harrison Street, Suite 202 544 Cesery Boulevard Hollywood, FL 33020 Suite 250 954414-8033 Phone Jacksonville, FL 32211 954?924~1530Fax 904?680-1234 Phone 904~680~1238 Fax Co-counsel for Plaintiff E.W. v. Epstein Page 2 BURMAN, CRITTON, COLEMAN, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach. FL 01 (561) 842-2820 (561) 515-3148 Fax Robert Critton, Jr. Florida ar #224162 Micha J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) By: E.W. v. Epstein Page 3 JEFFREY TO FIRST SET OF- lnterrogatory No. 1. What is the full name and Florida address of the person answering these interrogatories, and, if applicable, the person's of?cial position or relationship with the party to whom the interrogatories are directed? Answer: Jeffery Epstein, Defendant 358 El Brillo Way, Palm Beach, Florida I Robert D. Critton, Jr., Attorney for Defendant 515 N. Flagler Drive, Suite400 West Palm Beech, FL 33401 Interrogatory No. 2. What is the current name, address, and telephone number of each person that resided or worked within the home located at 358 El Brillo Way, West Palm Beach, Florida between 2001 to the present? Indicate approximate dates when each resided or worked within the home. For each working within the home, please also indicate title or job position. Answer: Defendant objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "approximately August 2002 and continuing until approximately September 2005.? Plaintiff?s interrogatory seeks information for a time period between 2001 until present. Without waiving his objections, Defendant identi?es the following persons: Emgloyee Jug ?irg Termination Ryan Dionne Chef 10/1/02 2/28/03 David Mullen Chef 8/2/04 10/24/05 Brent Tindall Chef 3/7/03 7/1/04 Mark Tafoya Chef 10/31/05 12/23/05 Adam Perry Lang Chef 6/8/98 7/31/02 Janusz Banasiak House manager 1/24/05 Active Michael Friedman House manager 9/25/03 4/30/04 Rosalie Friedman House manager 9/25/03 4/30/04 Louella Rabuyo House keeper 11/16/04 Active Alfredo Rodriguez House manager 9/1/04 2/10/05 Michael Liffman Butler 11/9/02 Adriana Ross Assistant 1/6/05 3/3/06 E.W. v. Epstein Page 4 Brahakmana Mellawa House manager 4/21/04 8/2/04 Jayarukshi Mellawa House keeper 4/21/04 8/2/04 Juan Alessi House manager 1/1/92 1/2/03 Maria Alessi House keeper 5/4/94 1/2/03 Sarah Kellen Assistant 2001 Active lnterrogatory No. 3. List each telephone number used by you or your assistants to call minor females directly, or indirectly, for the purpose of scheduling a massage to take place at your house located at 358 El Brillo Way, West Palm Beach (includes- landlines, cell phones, and private jet or airplane lines). For each cell phone, list the provider. Answer: Defendant invokes his Fifth Amendment Privilege against self- incrimination. lnterrogatory No. 4. Last known name, address, and telephone numbers of ail persons that may have any knowledge about any of the allegations in the Complaint, including, but not limited to, friends, acquaintances, employees, or others to whom you have spoken about the subject matter which forms the basis of this Complaint or who have observed such activity. Answer: Defendant invokes his Fifth Amendment Privilege against self? incrimination; attorney-client and work product privilege. lnterrogatory No. 5. Provide a complete list of the names of all victims provided to you or your attorneys as a result of, or in contempiation of, the federal non~ prosecution agreement that you ultimately signed (including all minor females identi?ed as victims, potential victims, or witnesses). Answer: Defendant invokes his Fifth Amendment Privilege against self- incrimination. lnterrogatory #5 is also objectionable in that it seeks information pertaining to the ?federal non?prosecution? agreement which according to its terms is to remain confidential. As well, the interrogatory seeks information regarding alleged minors who are not parties to this suit and, as such, subject to privacy rights and laws. lnterrogatory No. 6. Provide a complete list of the names of all known or suspected minors with whom you had sexual activities from 2002 to date, including all girls introduced to you, directly or indirectly, by the Plaintiff. Answer: Defendant invokes his Fifth Amendment Privilege against self~ incrimination. As well, the interrogatory seeks information regarding alleged minors who are not parties to this suit and, as such, subject to privacy rights and laws. E.W. v. Epstein Page 5 lnterrogatory No. 7. Describe with as much speci?city as possible where you resided from August 2002 through the present (this interrogatory is meant to include time spent at each of your houses since August 2002). Answer: Defendant objects as the interrogatory is cverbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence. Plaintiff's Complaint alleges a time period of ?approximately August 2002 and continuing until approximately September 2005.? Without waiving his objections, Defendant responds for the August 2002 September 2005 time frame: Little St. James, US. Virgin islands lnterrogatory No. 8. List of all employees, servants, cleaning staff, personal staff or assistants employed by you or your companies who worked out of or visited your residence in West Palm Beach between August 2002 and the present, including their dates of employment, their job duties, and their last known address and telephone numbers. Answer: Defendant objects as interrogatory #8 is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence. Plaintiff?s Complaint alleges a time period of ?approximately August 2002 and continuing until approximately September 2005.? Plaintiff?s interrogatory seeks information regarding persons who have absolutely no connection to or personal knowledge as to the allegations in this action. Without waiving his objections, Defendant identifies the following persons and information sought for the August 2002 September 2005 time period: See list set forth in response to lnterrogatory No. 2 lnterrogatory No. 9. State with as much speci?city as possible when you met the Plaintiff, and include in your answer the following: the circumstances and location of how and where you met, describe the nature of your relationship; describe how many occasions she was with you at your residence located at 358 El Brillo Way in West Palm Beach, Florida. Answer: Defendant invokes his Fifth Amendment Privilege against self- incrimination. lnterrogatory No. 10. Was there ever an employment or business relationship between you and the Plaintiff, and if so specify the duration of this relationship and how this relationship ended, including the nature of the remuneration to Plaintiff and what evidence or documentation exists of that relationship. E.W. v. Epstein Page 6 Answer: Defendant invokes his Fifth Amendment Privilege against self~ incrimination. Interrogatory No. 11. Did you ever ask the Plaintiff to introduce you to minor females andior to bring minor females to your house in West Palm Beach, Florida and if so, when did this occur, and what was she asked by you to do, and what did you tell her about the reason for her to bring these other minor girls. Answer: Defendant invokes his Fifth Amendment Privilege against self- incrimination. Interrogatory No. 12. Did you ever engage in sexual activity of any kind whatsoever with the Plaintiff, and include in your answer what type of sexual activity took place, where it took place, and the'dates or general timeframe when this activity occurred. Answer: Defendant invokes his Fifth Amendment Privilege against self~ incrimination. lnterrogatory No. 13. Were there parameters or instructions by you to the Plaintiff as to the types of girls to bring to your West Palm Beach, Florida house, including age range, what they would be asked to do, body type or socio?econornic background? Answer: Defendant invokes his Fifth Amendment Privilege against self- incrimination. lnterrogatory No. 14. Describe any words or actions that you made to assure the Plaintiff that sexual activity with you was proper or appropriate? Answer: Defendant invokes his Fifth Amendment Privilege against self- incrimination. Interrogatory No.15. Describe what age you thought the Plaintiff was when you ?rst had sexual activity with her, including your reasons for that belief. Answer: Defendant invokes his Fifth Amendment Privilege against self- incrimination. lnterrogatory No. 16. State the facts upon 'which you rely for each af?rmative defense in your answer. Answer: State the facts upon which you rely for each affirmative defense in your answer. E.W. v. Epstein Page 7 No af?rmative defenses have been asserted by my attorneys; however, I do not intend to waive my Fifth Amendment privilege against selfeinoriminetion. I have read the foregoing Answers to lnterrogatories and do swear that they are true and correct. Jeffrey Epstein, Defendant STATE OF FLORIDA PALM BEACH COUNTY I The foregoing instrument was acknowledged before me this day of 2008, by JEFFREY EPSTEIN, who is personally known to me or who has produced as identification. My Commission expires: Signature of Notary DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISP UT ED FACTS Epstein Edwards, 32? .422. Case No. 50 2009 CA 040800MMBAG EXHIBIT Sex offender Jeffrey Epstein settles seven more lawsuits Page 1 of 2 Print this page Close Sex offender Jeffrey Epstein setties seven more iawsuits By JANE MUSGRAVE Palm Beach Post Staff Writer Updated: 9:37 am. Sunday, June 13, 2010 Posted: 12:41 pm. Saturday, June 12, 2010 sex offender Jeffrey Epstein is steadily ridding himself of court battles with dozens of worsen who claim he paid them for sexually charged messages when some were as young as 14. in court papers filed late Friday, his attorneys said he has settled lawsuits with seven more women who sued him for abusing them. The terms of the settiernents are confidential. Neither his attorneys i?iOl? those representing the women were immediateiy availabie for comment today. The settlements come rooghiy six weeks before Epstein is to compiete his year-Ioog probation. On duty 21, a year after he was released from the Paim Beach County jaii after serving 13 months of a 18-month sentence, he is to be free to leave his Palm Beach mansion without teliing probation officers where he is going or how long he?ll be gone. However, despite his court~ordered house arrest, records show he has gone to work each day and ?own regularly to New York City to meet with lawyers and to his home in the Virgin lsiands. With the latest settlements, he has now paid 13 women to drop their claims against him. He has also inked agreements with another t2 women who sought damages without filing suit. He stiil faces three tederai lawsuits and four are pending in state court. One of the federai cases is scheduled to go to trial on July 19. As part of a piea deai to avoid federal oriminai charges, he agreed to plead guilty to two sex-related charges in state court. He aiso agreed not to contest women's claims in civil iawsuits. However, with some seeking as much as $50 miliion, he was ailowed to argue that they deserved far less than they were seeking. He also agreed to pay attorneys to represent women in settiemeht taiks it they didn't formaiiy fiie lawsuits. He recentiy settled a lawsuit with the Miami law firm that represented 12 women who elected not to file suit. The firm, Podhurst Orseck was demanding $2 million, in addition to the $500,000 Epstein had aiready paid. White Epstein initially balked, a confidentiai settlement in that lawsuit was announced Monday. Find this article at: Print this page Ciose 9/14/2010 Sex offender Jeffrey Epstein settles seven more lawsuits Page 2 of 2 9/ 14/2010 Jeffrey Epstein settles sex abuse lawsuits with two more victims; terms confidential Page 1 of 1 stir-re titrint this page Ciose Jeffrey Epstein settles sex abuse lawsuits with two more victims; terms con?den?al By itrtt?itELE eseese DAILY NEWS STAFF WRITER Updated: 7:18 pm. Wednesday, June 23, 2010 Posted: 7:16 pm. Wednesday, June 23, 2010 Two young women who alieged abuse by sex offender Jeffrey Epstein settied their iawsuits Iate Wednesday with him under a confidential agreement. Attorney Spencer Kuvin confirmed that his ciients, 8.8. and settled their cases, but he couid not disciose any details or amounts. "My clients are happy that the Whole process is over and that they have resolved their differences with Mr. Epstein," Kevin said. ?They want to put this whoie matter behind them and hopefully heal from the probierns that they?re suffering from.? 8.8. and CL were among nearly two dozen young women who have sued Epstein for damages, ciaiming they were lured to Epstein?s Pairn Beech mansionas minors to give him sexuaiiy charged massages and sometimes more. CL. and BB. both were 15 at the time of their encounters with Epstein, 57'. Most of the lawsuits have settled. There are four victims with cases pending. Jane Doe is set for triai duty 19 in federal court. After serving 13 months in jail on criminai charges of soiiciting prostitution and procuring a minor for prostitution, Epstein is serving one year of probation at his El Brilio Way home. Find this artists at: Print this page Close 9/14/2010 DEFENDANT BRADLEY J. EDWARDS ?8 STA TEMENT 0F UNDISP TED FACTS Epstein v. Edwards, et al. Case No. 50 2009 CA EXHIBIT JEFF EPSTEIN SUED FOR SEXUAL ON TEEN - Page I of I JEFF SUED FOR SEXUAL 0N TEEN 8y DAREH GREGORIAN Last Updated: 5:00 AM. Cooper 17?. 200? Posted: 5:00 AM. Goober 200? The big?time Manhattan moneyrnan who's agreed to piead guiity for soliciting underage prostitutes at his Florida estate is being sued for repeatedly sexualiy assaulting a teenaged girl in his Manhattan mansion, teiling her "You have a tight butt like a baby." in papers ?led in Manhattan Supreme Court, Maximilia Cordero said site was only 16 when she was introduced to -- arid seduced by ?etfrey Epstein, 54. Cordero, now 22, said she was introduced to Epstein back in 2000 by an acquaintance in her 405 named Sherrie, who told her she had a "super wealthy" who oouid hetp "develop a modeling career," the suit says. Cordero went to go meet Epstein at his grand 5t,000 square foot mansion on E. Street, where he greeted her in his bathrobe, the suit says. He gave her a tour of his home, showing her his statue ofa dog with a statue of dog feces next to it, and then "lured" her into his "massage room." Epstein ailegedly toid her he was the money for Victoria's Secret and could get her into the iingerie chain?s tamed catalogue it she was "rrice to him." am t6 years old and just want to modei," the suit quotes tier as saying. Epstein then took off his rope and started pushing her head toward his groin, saying, ?if you want me to hetp you then you have to heip me," the suit says. When he was ?nished, her told her to come back sometime "with her 14, 15 and 16 year oid girifriends.? tove girls your age," the suit quotes him as saying. The suit says Epstein kept setting the teen. who suffered from mentai problems, promising to help her with her career, and she kept goier over to see trim and engaging in "bizarre and unnatural sex acts." "i love how young you are. You have a tight putt itke a baby," he's quoted as saying. It's unclear when the relationship ended, but it iett Cordero with "severe and serious injuries to various and diverse parts of her person" and "physical and emotionai inturies.? the suit seeks unspecified money damages. Cordero?s iawsuit was filed by her much cider boyfrieod, lawyer Wiiliam Unrocit. The pair have been involved in litigation before. Umoch sued a neighbor who accused him of having a relationship with an underage girl Cordero. Ajudge found the neighbor's statement was iibelous because Cordero was not underage when she started seeing Unroch. Epstein, who owns property around tire world and has palied around with the likes of Bill Clinton, Prince Andrew and Daily News owner Mort Zuckerman, has agreed to piead guiity to soiiciting prostitution in Fiorida. Florida prosecutors said some of the prostitutes were underage, but Epstein maintains he thought they were t8 or older. in return for the plea, Epstein is expected to receive an 18 month prison term. Cordero's suit is the ?rst in an expected slew of iawsuits against Epstein. The Post reported eariier this week that he couid face iegai action from up to 40 different women. NEW YORK POST is a registered trademark of NYP Holdings. inc, NYPOSTCOM NYPOSTONUNECOM and are trademarks of NYP Holdings, inc. Copyright 2010 NYP Headings, Inc. rights reserved. Privacy terms of Use 9/15/2010 DEFENDANT BRADLEYJ EDWARDS STATEMENT OF UNDISP UTED FACTS Epstein v. Edwards, er at. Case No. 50 2009 CA 040800XWMBAG EXHIBIT 0H ?fe. Case Document 1 Entered on FLSD Docket 04/14/2008 W9 0W 0 'ELsc to April 14, 2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 3'9- MIAMI 08~CV~80380-Hurley-Hopkins JANE DOE NO. 4, Plaintiff, vs. EPSTEIN, Defendant. COMPLAINT Plaintiff, Jane Doc No. 4 (?Jane? or ?Jane Doe?), brings this Complaint against Jeffrey Epstein, as follows: Parties Jurisdiction and Venue 1. Jane Doe No. 4 is a citizen and resident of the State of Florida, and is sui juris. 2. This Complaint is brought under a ?ctitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. ?1332(a), as the matter in controversy exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. 6. This Court has venue of this action pursuant to 28 U.S.C. ?1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this District. HERMAN a MERMELSTEIN, P. A. .. 1 1cf6 I Case Document 1 Entered on FLSD Docket 04H 4/2008 Page 2 of 6 Factual Allegations 7. At all relevant times, Defendant Jeffrey Epstein (?Epstein?) was an adult male, 52 years old. Epstein is a ?nancier and money manager with a secret clientele limited exclusively to billionaires. He is himself a man of tremendous wealth, power and in?uence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL. The allegations herein concern Epstein?s conduct while at his lavish estate in Palm Beach. 8. Upon information and belief, Epstein has a sexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or ab out 2002-2003, Jane Doe, then approximately 15 years old, fell into Epstein?s trap and became one of his victims. 9. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. ll). Epstein?s scheme involved the use of young girls to recruit underage girls. Haley Robson, a Palm Beach Community College student from Loxahatchee, Florida recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The young girls would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Ms. Robson, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered generally $200 to $300 per ?massage? session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein?s plan. HERMAN a Maamensram, P. A. ZofB 1 Case Document 1 Entered on FLSD Docket 04/14/2008 Page 3 of 6 1 1. Epstein?s plan and scheme re?ected a particular pattern and method. The underage victim would be brought . to the kitchen entrance of Epstein?s mansion, where she would be introduced to Sarah Kellen, Epstein?s assistant. Ms. Kellen would then bring the girl up a ?ight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. The girl would then ?nd herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then perform one or more lewd, lascivioas and sexual acts, including masturbation and touching the girl?s vagina. 12. Consistent with the foregoing plan and scheme, when Jane Doe was approximately 15 years old, she was recruited by Haley Robson to give Epstein a massage for monetary compensation. lane was brought to Epstein?s mansion in Palm Beach, to the kitchen entrance. Once there, Jane was introduced to Sarah Kellen, who led her up the ?ight of stairs to the room with the massage table. In this room, Jane was directed by Epstein to remove her clothes and give him a massage. Jane initially kept her panties and bra on, and complied with Epstein?s instructions. Jane was paid by Epstein for this massage. 13. Jane returned on many occasions to the Palm Beach mansion to provide Epstein with massages. On these occasions, Epstein engaged in sexual contact and activity with the minor Jane, which included, among other things, directing Jane to remove all her clothes, masturbating during the massage, and digitally penetrating Jane?s vagina. Jeffrey Epstein often used a vibrator on the minor Jane during the massage. This sexual abuse continued for approximately three years. 14. As a result of these encounters with Epstein, Jane experienced confusion, shame, HERMAN ti MERMELSTEIN, P. A. 3of8 Case Document 1 Entered on FLSD Docket 04/14/2008 Page 4 of 6 humiliation and embarrassment, and has suffered severe and emotional injuries. COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 16. Epstein tortiously assaulted Jane Doe sexually. Epstein?s acts were intentional, unlawful, offensive and harm?il. 17. Epstein? 3 plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. 18. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane. 19. As a direct and proximate result of Epstein?s assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, and emotional damages. WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper. COUNT II Intentional lnfliction of Emotional Distress 20. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 21. Epstein?s conduct was intentional or reckless. 22. Epstein?s conduct was outrageous, going beyond all bounds of decency. 23. Ep stein? conduct caused severe emotional distress to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and HERMAN a. MERMELSTEZIN, P. A. dof? 3 Case Document 1 Entered on FLSD Docket 04/14/2008 Page 5 of 6 damage to Jane Doe. 24. As a direct and proximate result of Epstein?s inientional or reckless conduct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and ?lrther relief as this Court deems just and proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: April [@2008 Respectfully submitted, HERMAN MERMELSTEIN, PA. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305~931w2200 Fax: By: Jeffey M. Herman iheman?lhemanlaweom Florida Bar No. 521647 Stuart S. Memelstein smennelstein@hennanlaw.com Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 ahorowitz@hennanlaw.com HERMAN ii P. A. 5uf6 . Case Docu?enkicwa??g?r Doc tamed herein neither reptaoe nor supplement the tiing, and se a! Conference of the United States in Se - ERSE OF THE The 38-44 civil cover sheet and the information con except as provided by iocai the Court for the purpose 0 rules of court. This form, approved bythe Judioi initiating the civil docket sheet. INSTRUCTIONS ON THE REV DEFENDANTS 1(a) JEFFREY EPSTEIN JANE DOE NO. 4, COUNTY OF RESIDENCE OF FIRST LISTED MARION COUNTY (EXCEPT 1N U.S. CASES) ATTORNEYS (IF W037 04/ silo/virgin ?lms is) ATTORNEYS NAME, ADDRESS. AND TELEPHONE NUMBER) Herman Mermeistein. PA. 18205 Biscayne Blvd., Suite 2218, Miami. FL 33160, (305) 9314200 (cl) CIRCLE COUNTY WHERE. ACTION AROSE: PALM BEACH II. OF JURISDICTION CITIZENSHIP OF PRINCIPAL PLACE AN EN ONE BOX FOR (PLACE AN ONE BOX {For Diversity Case 0813!) AND ONE FOR DEFENDANT PTF DEF PTF OEF Incorporated of Principai Piece of 4 4 1. 1.1.3. Government i2} 3. Federal Question Citizen of This State 1 CI 1 Business in This State Plaintiff (US. Government Not a Party) Citizen of Another State in 2 2 Incorporated and Principe: Piece of El 5 5 E3 2. U.S. Government 4. Diversity Citizen or Subject of a Foreign Country E2 3 E2 3 Business in Another state Defendant {indicate Citizenship of Parties in Item Iii} Foreign Nation {3 6 6 IV. CAUSE OF THE 1.1.3. STATUTE UNDER WHICH YOU ARE FELING AND WRITE A BRIEF STATEMENT OF CAUSE. DO NOT CITE STATUTES UNLESS DIVERSITY.) BWERSITY UNDER 28 U.S.C. ?1332(a) FOR SEXUAL ASSAULT We. days estimated (for both sides) to try entire case V. 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TAX SUITS c: 245 Ton Product a ?come: cinema {It on: Mammusasother? :2 no LoborMsoagomeni {Declaratory norm 290 Ail 0359:8931 Property C: Rights Reponina a. Disdosore toroefama?on 0' Act :3 am rams (us. Piainii? orDei'endenti no RelwayLaborAd a OW Lamrmam an ins-mu Pany so use rso-a E1 791 Empioyeo Rot inc. Security no a VI. 1. Original [3 2. Removed from t} 3. Remandeo from El 4. Refined 6. Multidistrict Litigation 7. Appeal to District Judge from Proceeding State Court Appeiiate Court 5. Transferred from another district (Specify) Magistrate Judgment Vii. REQUESTED CHECK iF is A CLASS ACTION OEMAND {3 Check YES only if demanded in YES 3N E3 UNDER F.R.C.P. 23 com Ialnt: JUR DEMAND: NO Vill. RELATED (See instructions): (SEE. AWACHED) CASHS) 3F ANY JUDGE KENNETH A. MARRA DOCKET NUMBER os-cv-ao1 JUDGE KENNETH A. MARRA DOCKET NW sao NAYURE OF ATTORNEY OF necono A, FOR OFFICE USE ONLY: Receipt No. Amount: Date Paid: M?fp: 57/2 27? 7 Jane Doe 2 v. Jeffrey Epstein Jane Doe 3 v. Jeffrey Fostein DATE 14/qu 09' 5 UNITED STATES COURT SIF 1~2 REV. 9l94 DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et Case N0. 3 50 2009 CA 040800WMBAG EXHIBIT IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO.: L.M.., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Plaintiff, L.M., by and through her undersigned counsel, sues the Defendant, Jeffrey Epstein, and alleges: 1. This is an action in an amount in excess of $15,000.00, exclusive of interest and costs and is Within the jurisdictional limits of this Court. 2. This Complaint is brought under a ?ctitious name in order to protect the identity of the Plaintiff, L.M., because this Complaint makes allegations of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, the Plaintiff, L.M. (hereinafter referred to as ?Plaintiff was a resident of Palm Beach County, Florida. 4. At all times material to this cause of action, the Defendant, Jeffrey Epstein, had a residence located at 358 E1 Brillo Way, West Palm Beach, Palm Beach County, Florida. Page 1 of 12 5. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he currently resides in West Palm Beach, Florida at the Palm Beach County Jail and has the intention to remain in Florida. This is substantiated by the residence that he maintains at 358 El Brillo Way, West Palm Beach, Florida where he spends the majority of his time, and intentions to remain at that address permanently are further evidenced by his statements to the Court during his State Plea colloquy on June 30, 2008, case number O6CF009454AMB, taken before the Honorable Judge Dale Pncillo, wherein he indicated that after his release from Palm Beach County Jail he intends to reside permanently at his home at 358 El Brillo Way, West Palm Beach, Florida, and he plans to work in West Palm Beach, Florida as Well. 6. At all times material to this cause of action, the Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. At all times material, the Defendant, Jeffrey Epstein, owed a duty unto Plaintiff to treat her in a non?negligent manner and to not commit intentional or tortions or illegal acts against her. 8. All of the allegations within this Complaint occurred in West Palm Beach, Florida. FACTUAL ALLEGATIONS 9. Upon information and belief, the Defendant, Jeffrey Epstein, has demonstrated a sexual preference and obsession for minor girls. 10. The Defendant, Jeffrey Epstein, developed a plan, scheme, and criminal enterprise that included an elaborate system wherein the then minor Plaintiff was brought to the Defendant, Page 2 of 12 Jeffrey Epstein?s residence by the Defendant's employees, recruiters, and assistants. When the assistants and employees left the then minor Plaintiff and other minor girls alone in a room at the Defendant's mansion, the Defendant, Jeffrey Epstein, himself would appear, remove his clothing, and direct the then. minor Plaintiff to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiffs sexual organs, using vibrators or sexual toys on the then minor Plaintiff, coercing the then minor Plaintiff into sexual acts with himself, and digitally penetrating the then minor Plaintiff. He would then pay the Plaintiff for engaging in this sexual activity. 11. The Plaintiff was first brought to the Defendant, Jeffrey Epstein?s mansion in 2002 when she was a fourteen-year old in middle school. 12. The Defendant, Jeffrey Epstein, a wealthy financier with a lavish home, signi?cant wealth, and a network of assistants and employees, used his resources and his in?uence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior. 13. Beginning in approximately July 2002 and continuing until approximately September 2005, the Defendant, Jeffrey Epstein, coerced and/or enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, sexual misconduct and masturbation of the Defendant, Jeffrey Epstein, in the presence of the then minor Plaintiff, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant, Jeffrey Epstein, committed numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, Page 3 of 12 sexual battery, solicitation of prostitution, procurement of a minor for the purposes of prostitution, and lewd and lascivious assaults upon the person of the then minor Plaintiff. 14. In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant, Jeffrey Epstein, instructed, coerced and otherwise induced the then minor Plaintiff to bring him numerous other minor children for the purposes of further satisfying his deviant sexual attraction to minors. Defendant, Jeffrey Epstein, used his money, wealth and power to unduly and improperly manipulate and in?uence the then minor Plaintiff to bring him these other minor girls in exchange for money. This in?uence led the then minor Plaintiff away from the life of a middle school aged child and into a delinquent lifestyle. 15. The acts referenced above in paragraphs 10 through 14, committed by Defendant, Jeffrey Epstein, against the then minor Plaintiff were committed in Violation of numerous criminal State statutes condemning the sexual exploitation of minor children, prostitution, sexual performances by a child, lewd and lascivious assaults, sexual battery, contributing to the delinquency of a minor and other crimes, speci?cally including, but not limited to, those criminal offenses outlined in Chapters 794, 800, 827 and 847 of the Florida Statutes, as well as those designated in Florida Statutes ?796.03, ?796.07, ?796.045, ?796.04, ?796.09, ?39.01, and ?827.04. 16. The above?described acts took place in Palm Beach County, Florida at the residence of the Defendant, Jeffrey Epstein. Any assertions by the Defendant, Jeffrey Epstein, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and Page 4 of 12 abuse of a minor child. The Defendant, Jeffrey Epstein, at all times materiai to this cause of action, knew and should have known of the Plaintiffs minority. 17. The above~described acts were perpetrated upon the person of the then minor Plaintiff regularly and on numerous occasions. 18. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution. 19. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, Jeffrey Epstein, for numerous federal offenses, Defendant, Jeffrey Epstein, additionally entered into an agreement with the Federal Government acknowledging that LM. was a victim of his conduct. 20. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein?s illegal conduct. The Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal front denying the acts alleged in this Complaint, and must effectively admit liability to the Plaintiff. COUNT I Sexual Exploitation, Sexual Abuse and/or Sexual Assault of a Minor 21. The Plaintiff repeats and realleges paragraphs 1 through 20 above. 22. Defendant, Jeffrey Epstein, tortiously assaulted Plaintiff sexually on numerous occasions between approximately July 2002 and approximately September 2005, and further Page 5 of 12 sexually exploited her and contributed to her delinquency during that time. Defendant?s acts were outrageous, egregious, intentional, unlawful, offensive and harmful. 23. The sexual assaults were in Violation of the numerous state statutes described in paragraph 15 above, and the assaults and acts of exploitation were committed by Defendant, Jeffrey Epstein, willfully and maliciously. 24. As a direct and proximate result of Defendant, Jeffrey Epstein?s assaults on the Plaintiff, the Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, trauma, mental anguish, humiliation, embarrassment, loss of selfuesteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and expenses and the Plaintiff will in the future suffer additional medical and expenses. The Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, L.M., demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, attorney?s fees, and such other and further relief as this Court deerns just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 6 of 12 COUNT II Cause of Action Pursuant to Florida Statute 796.09 25. The Plaintiff adopts and realleges paragraphs 1 through 20 above. 26. The allegations contained herein in Count II are a separate and distinct legal remedy. 27. Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff was an economically disadvantaged and impressionable minor. 28. Defendant, Jeffrey Epstein, used his vast wealth and power to coerce Plaintiff into prostitution and/ or coerced her to remain in prostitution. 29. Defendant, Jeffrey Epstein coerced Plaintiff into prostitution in one or more of the following ways: A. Domination of her mind and body through exploitive techniques; B. Inducernent; C. Promise of greater ?nancial rewards; D. Exploitation of a condition of developmental disability, cognitive limitation, affective disorder, and/or substance dependency; E. Exploitation of human needs for food, shelter or affection; F. Exploitation of underprivileged and vulnerable economic condition or situation; G. Use of a system of recruiting other similarly situated minor girls to further coerce and induce Plaintiff into the lifestyle of prostitution; and Page 7 of 12 H. Exploitation through demonstration of abundant wealth and power to impress a young and vulnerable then rninor Plaintiff and to coerce her into prostitution. 30. As a direct and proximate result of the offenses committed by Defendant, Jeffrey Epstein, against Plaintiff pursuant to Florida Statutes ?769.09, the Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, trauma, mental anguish, humiliation, embarrassment, loss of self?esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then. minor Plaintiff incurred medical and expenses and the Plaintiff will in the future suffer additional medical and expenses. The Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, L.M., demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, attorney?s fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT Intentional In?iction of Emotional Distress 31. The Plaintiff adopts and realleges paragraphs 1 through 20 above. Page 8 of 12 32. The Defendant, Jeffrey Epstein?s conduct towards the then minor Plaintiff was intentional and reckless. 33. The Defendant, Jeffrey Epstein, deliberately and recklessly inflicted mental suffering upon the then minor Plaintiff. 34. The Defendant, Jeffrey Epstein?s conduct was outrageous in character, and so extreme in degree, going beyond all bounds of decency. 35. The Defendant, Jeffrey Epstein?s intentional, deliberate and reckless conduct caused severe emotional distress to the Plaintiff. Defendant, at the time he committed these numerous sexual assaults on Plaintiff, had a specific intent to harm the then minor Plaintiff and his conduct did so harm the Plaintiff 36. As a direct and proximate result of the Defendant, Jeffrey Epstein?s intentional and reckless conduct, the Plaintiff has in the past suffered and in the future will continue to suffer physical injury, pain and suffering, emotional distress, trauma, mental anguish, humiliation, embarrassment, loss of self~esteeni, loss of dignity, invasion of her privacy and other damages associated with the Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and eXpenses and the Plaintiff will in the future suffer additional medical and expenses. The Plaintiff has suffered a loss of income, a loss of the capacity to earn income in. the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, L.M., demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, attorney's fees, and such other and further relief as this Page 9 of 12 Court deerns just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT IV Civil Remedy for Criminal Practices 37. The Plaintiff realleges paragraphs 1 through 20 above. 38. The allegations contained herein in Count IV are a separate and distinct legal remedy. 39. The Defendant, Jeffrey Epstein, participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statutes 40. The Defendant, Jeffrey Epstein, participated in this pattern of criminal activity by engaging in at least two of the following acts of criminal misconduct with the same or similar intents, results, accomplices, Victims, and methods of commission within a ?ve year period: A. Procuring for prostitution, or causing to be prostituted, any person who is under the age of 18 years in Violation of Florida Statutes Chapter 796; B. Forcing, compelling, or coercing another to become a prostitute in violation of Florida Statutes ?796.04; C. Acts of battery in violation of Florida Statutes Chapter 784; D. Act of Lewdness in violation of Florida Statutes Chapter 800; Page 10 of 12 E. Sexual performance or exploitation of a child in Violation of Florida Statutes ?827.07l; and P. Other crimes involving contributing to the delinquency of a child, sexual abuse of a child, and coercing a child into prostitution. 41. Under the Defendant, Jeffrey Epstein's plan, scheme, and enterprise, the Defendant, Jeffrey Epstein, paid employees and underlings to repeatedly ?nd and bring him minor girls in order for the Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and sexual misconduct. 42. The Plaintiff was the Victim of the Defendant, Jeffrey Epstein's plan, scheme, and enterprise. The Plaintiff was called on the telephone and transported. by various individuals to the Defendant, Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, enticed to commit acts of prostitution, battery, and sexual exploitation. The Defendant, Jeffrey Epstein, conspired with his assistants and employees and various adults and minor children in order to accomplish his enterprise of seeking out, gaining access to, and exploiting minor children such as the Plaintiff. 43. After introducing Plaintiff into prostitution, he enticed her to remain in prostitution and be a part of his deviant sexual lifestyle through exploitive techniques, such as offering additional money to Plaintiff in exchange for her bringing him additional rninor girls to sexually abuse and commit sexual crimes against. WHEREFORE, under the provisions of Florida Statutes Chapter 772, the Plaintiff, L.M., demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, treble Page 11 of12 damages, costs and attorneys? fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. DATED this 10th day of September, 2008. THE LAW OFFICE OF BRAD EDWARDS ASSOCIATES, LLC Attorneys for Plaintiff 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954~414~8033 Facsimile: 954?924?1530 Jay Howell, Esquire Florida Bar #225657 JAY HOWELL ASSOCIATES, PA. Co~Counsel for Plaintiff 644 Cesery Boulevard Suite 250 Jacksonville, Florida 32211 Telephone: 904680-1234 Facsimile: 904680-1238 By: Brad Edwards Florida Bar #542075 Page 12 of 12 DEFENDANT BRADLEY .I EDWARDS ?8 STA TEMEN 0F UNDISP UT ED FACTS Epstein v. Edwards, er al. Case No. 50 2009 CA EXHIBIT IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION ?mg zooscm 80 58 mane ID E.W., Plaintiff, vs. PY I JEFFREY EPSTEIN, RECEIVED FOR FILING .SEP 1 1 ans De 'endant. 0. (h omanKAEgmigagfL-E? elmtomt mister?: Plaintiff, E.W., by and through her undersigned counsel, sues the Defendant, Jeffrey Epstein, and alleges: 1. This is an action in an amount in excess of $15,000.00, exclusive of interest and costs and is within the jurisdictioaal limits ofthis Court. 2. This Complaint is brought under a ?ctitious name in order to protect the identity of the Plaintiff because this Complaint makes allegations of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, the Plaintiff, E.W. (hereinafter referred to as "Plaintiff"), was a resident of Palm Beach County, Florida. 4. At all times material to this cause of action, the Defendant, Jef?ey Epstein, had a residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida. Page I of 12 5. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he currently resides in West Palm Beach, Florida at the Palm Beach County Jail and has the intention to remain in Florida. This is substantiated by the residence that he maintains at 358 El Brillo Way, West Palm Beach, Florida where he spends the majority of his time, and intentions to remain at that address pennanently are ?n'ther evidenced by his statements to the Court during his State Plea colloquy on June 30, 2008, case number 06CF009454AMB, taken before the Honorable Judge Dale Pucillo, wherein he indicated that after his release from the Palm Beach County Jail he intends to reside pennanently at his home at 358 El Brillo Way, West Palm Beach, Florida, and he plans to work in West Palm Beach, Florida as well. 6. At all times material to this cause of action, the Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. At all times material, the Defendant, Jeffrey Epstein, owed a duty unto Plaintiff to treat her in a non-negligent manner and to not commit intentional or tortious or illegal acts against her. 8. All of the allegations within this Complaint occurred in West Palm Beach, Florida. FACTUAL ALLEGATIONS 9. Upon information and belief, the Defendant, Jeffrey Epstein, has demonstrated a sexual preference and obsession for minor girls. 10. The Defendant, Jeffrey Epstein, developed a plan, scheme, and criminal enterprise that included an elaborate system wherein the then minor Plaintiff was brought to the Defendant, Page 2 of 12 Jeffrey Epstein?s residence by the Defendant?s employees, recruiters, and assistants. When the assistants and employees left the then minor Plaintiff and other minor girls alone in a room at the Defendant?s mansion, the Defendant, Jeffrey Epstein, himself would appear, remove his clothing, and direct the then minor Plaintiff to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiffs sexual organs, coercing or forcing the then minor Plaintiff to perform oral sex on him, using vibrators or sexual toys on the then minor Plaintiff, coercing the then minor Plaintiff into sexual acts with himself or others, and digitally penetrating the then minor Plaintiff. He would then pay the Plaintiff for engaging in this sexual activity. 11. The Plaintiff was first brought to the Defendant, Jeffrey Epstein?s mansion in 2002 when she was a fourteen-year old in middle school. 12. The then minor Plaintiff was a vulnerable child without adequate parental support at all times material to this Complaint. The Defendant, ef?'ey Epstein, a wealthy ?nancier with a lavish home, signi?cant wealth, and a network of assistants and employees, used his resources and his in?uence over a vulnerable minor child to engage in a systematic pattern of sexually eXploitive behavior. 13. Beginning in approximately August 2002 and continuing until approximately September 2005, the Defendant, Jeffrey Epstein, coerced, induced andfor enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misoonduct. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, forcing the then minor Plaintiff into oral sex, sexual misconduct and masturbation of the Defendant, Jeffrey Epstein, in Page 3 of 12 the presence of the then minor Plaintiff, handling and fondling of the then minor Plaintiff?s sexual organs for the purpOSe of masturbation, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant, Jeffrey Epstein, committed numerous criminal sexual offenses against the than minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, coercing a minor into a life of prostitution, and lewd arid lascivious assaults upon the person of the then minor Plaintiff. 14. In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant, Jeffrey Epstein, instructed, coerced and otherwise induced the then minor Plaintiff to bring him numerous other minor children for the purposes of further satisfying his deviant sexual attraction to minors. Defendant, Jeffrey Epstein, used his money, wealth and power to unduly and improperly manipulate and in?uence the then minor Plaintiff to bring him these other minor girls in exchange for money. This in?uence led the then minor Plaintiff away from the life of a middle school aged child and into a delinquent lifestyle. 15. The acts referenced above in paragraphs 10 through 14, corrimitted by Defendant, Jeffrey Epstein, against the than minor Plaintiff were committed in violation of numerous criminal State statutes condemning the sexual exploitation of minor childreh, prostitution, sexual performances by a child, lewd and lascivious assaults, sexual battery, contributing to the delinquency of a minor and other crimes, speci?cally including, but not limited to, those criminal offenses outlined in Chapters 794, 800, 827 and 847 of the Florida Statutes, as well as those designated in Florida Stamtes ?796.03, ?796.07, ?796.045, ?796.04, ?796.09, ?39.0l, and ?327.04. Page 4 of 12 16. The above-described acts took place in Palm Beach County, Florida at the residence of the Defendant, Je?i?ey Epstein. Any assertions by the Defendant, Jeffrey Epstein, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of the Plainti??s minority. 17. The above-described acts were perpetrated upon the person of the then minor Plaintiff on numerous occasions. 18. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution. 19. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, Jeffrey Epstein, for numerous federal offenses, Defendant, Jeffrey Epstein, additionally entered into an agreement with the Federal Government acknowledging that E.W. was a victim of his conduct. 20. The Plaintiff is included in the list of victims identi?ed by the Federal Government as victims of the Defendant, Jeffrey Epstein?s illegal conduct. The Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint, and must effectively admit liability to the Plaintiff. Page 5 of 12 COUNT I Sexual Exploitation, Sexual Abuse and/or Sexual Assault of a Minor 21. The Plaintiff repeats and realleges paragraphs 1 through 20 above. 22. Defendant, Jeffrey Epstein, tortiously assaulted Plaintiff sexually on numerous occasions between approximately August 2002 and approximately September 2005, and further sexually exploited her and contributed to her delinquency during that time. Defendant?s acts were outrageous, egregious, intentional, unlawful, offensive and harmful. 23. The sexual assaults were in violation of the numerous state statutes described in paragraph 15 above, and the assaults and acts of exploitation were committed by Defendant, Jeffrey Epstein, willfully and maliciously. 24. As a direct and proximate result of Defendant, Je?i'ey Epstein?s assaults on the Plaintiff, the Plaintiif has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, trauma, mental anguish, humiliation, embarrassment, loss of self?esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and expenses and the Plaintiff will in the future suffer additional medical and expenses. The Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the ?ltere. WHEREFORE, the Plaintiff, E.W., demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, attorney?s fees, and such other and further relief as this Page 6 of 12 Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT II Cause of Action Pursuant to Florida Statute 796.09 25. I The Plaintiff adopts and realleges paragraphs 1 through 20 above. 26. The allegations contained herein in Count II are a separate and distinct legal remedy. 27. Defendant, Je??rey Epstein, was a wealthy and powerful man, and Plaintiff was an economically disadvantaged and impressionable minor. 28. Defendant, Jeffrey Epstein, used his vast wealth and power to coerce Plaintiff into prostitution and/or coerced her to remain in prostitution. 29. Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one or more of the following ways: A. Domination of her mind and body through exploitive techniques; B. Indueement; C. Promise of greater ?nancial rewards; D. Exploitation of a condition of deveIOpmental disability, cognitive limitation, affective disorder, and/or substance dependency; E. Exploitation of human needs for food, shelter or affection; F. Exploitation of underprivileged and vulnerable economic condition or situation; Page 7 of 12 G. Use of a system of recruiting other similarly situated minor girls to War coerce and induce Plaintiff into the lifestyle of prostitution; and H. Exploitation through demonstration of abundant wealth and power to impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution. 30. As a direct and prekimate result of the o?enses committed by Defendant, Jeffrey Epstein, against Plaintiff pursuant to Florida Statutes ?769.09, the Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and expenses and the Plaintiff will in the future suffer additional medical and eXpenses. The Plaintiff has suffered a loss of income, a loss of the capacity to earnincome in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, E.W., demands judgment against the Defendant, Jef?ey Epstein, for compensatory damages, attorney?s fees, and such other and further relief as this Court deems just and preper, and hereby demands trial by jury on all issues triable as of right by ajury. Page 8 of12 COUNT Intentional In?iction of Emotional Distress 31. The Plaintiff adopts and realleges paragraphs 1 through 20 above. 32. The Defendant, Jeffrey Epstein?s conduct towards the then minor Plaintiff was intentional and reckless. 33. The Defendant, Jeffrey Epstein, deliberately and recklessly in?icted mental Suffering upon the then minor Plaintiff. 34. The Defendant, Jeffrey Epstein?s conduct was outrageous in character, and so extreme in degree, going beyond all bounds of decency. 35. The Defendant, Jeffrey Epstein?s intentional, deliberate and reckless conduct caused severe emotional distress to the Plaintiff. Defendant, at the time he committed these numerous sexual assaults on Plaintiff, had a speci?c intent to harm the then minor Plaintiff and his conduct did so harm the Plaintiff. 36. As a direct and proximate result of the Defendant, Jeffrey Epstein?s intentional and reckless conduct, the Plaintiff has in the past suffered and in the future will continue to suffer physical injury, pain and suffering, emotional distress, trauma, mental anguish, humiliation, embarrassment, loss of self~esteem, loss of dignity, ievasion of her privacy and other damages associated with the Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and expenses and the Plaintiff will in the future suffer additional medical and expenses. The Plaintiff has suffered a loss of income, a loss of the capacity to Page 9 of 12 earn income in the ?ltere, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WREFORE, the Plaintiff, E.W., demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, attorney's fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT IV Civil Remedy for Criminal Practices 37. The Plaintiff realleges paragraphs 1 through 20 above. 38. The allegations contained herein in Count IV are a separate and distinct legal remedy. 39. The Defendant, Jeffrey Epstein, participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statutes 40. The Defendant, Jeffrey Epstein, participated in this pattern of criminal activity by engaging in at least two of the following acts of criminal misconduct with the same or similar intents, results, accomplices, victims, and methods of commission within a ?ve year period: A. Procuring for prostitution, or causing to be prostituted, any person who is under the age of 18 years in violation of Florida Statutes Chapter 796; B. Forcing, compelling, or coercing another to become a prostitute in violation of Florida Statutes ?796.04; C. Acts of battery in violation of Florida Statutes Chapter 784; Page 10 ofl2 D. Act of lewdness in violation of Florida Statutes Chapter 800; E. Sexual perfonnance or esploitation of a child in violation of Florida Statutes ?827.071; and F. Other crinies involving contributing to the delinquency of a child, sexual abuse of a child, and coercing a child into prostitution. 41. Under the Defendant, Jeffrey Epstein?s plan, scheme, and enterprise, the Defendant, Jeffrey Epstein, paid employees and underlings to repeatedly find and bring him minor girls in order for the Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and sexual misconduct. 42. The Plaintiff was the victim of the Defendant, Jeffrey Epstein's plan, scheme, and enterprise. The Plaintiff was called on the telephone and transported by various individuals to the Defendant, Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, enticed to commit acts of prostitution, battery, and sexual exploitation. The Defendant, Jef?'ey Epstein, conspired with his assistants and employees and various adults and minor children in order to accomplish his enterprise of seeking out, gaining access to, and exploiting minor children such as the Plaintiff. 43. After introducing Plaintiff into prostitution, he enticed her to remain in prostitution and be a part of his deviant sexual lifestyle through exploitive techniques, such as offering additional money to Plaintiff in exchange for her bringing him additional minor girls to sexually abuse and commit sexual crimes against. WHEREF ORE, under the provisions of Florida Statutes Chapter 772, the Plaintiff demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, treble Page 11 of12 damages, costs and attomeys? fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. DATED this Lam day of September, 2008. THE LAW OFFICE OF BRAD EDWARDS ASSOCIATES, LLC Attorneys for Plaintiff - 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Facsimile: 954-9244 530 ay Howell, Esquire Florida Bar #225657 JAY HOWELL ASSOCIATES, PA. Co?Counsel for Plaintiff 644 Ceser Boulevard Suite 250 Jacksonville, Florida 3221 1 Telephone: 904-680? 1 234 Facsimile: 904?680-1238 Brad Edwards Florida Bar #542075 Page 12 ole DEFENDANT BRADLEY J. EDWARDS ?8 STA TEMEN OF UNDISP UT ED FACTS Epstein v. Edwards, 63? (22. Case No. 50 2009 CA OAOSOOWMBAG EXHIBIT TT us. Department of Justice United States Attorney's Office Southern District of Florida in Fort Lauderdale 500 East Broward Blvd. 7th Floor Fort Lauderdale, FL 33394 Phone: (954) 356?7255 Fax: (954) 356-7336 July 20, 2010 Farmer Jaife Weissing, et at 425 N. Andrews Ave. Suite 2 Ft. Lauderdale, FL 33301 Re: United States v. Scott W, Rothstein Case Number 2009R02739 and Court Docket Number: Dear Farmer Jaffe Weissing, et al: Bradley J. Edwards was fonvarded to our office by law enforcement as a victim (or potential victim) in the above mentioned criminal case. You have been identi?ed to receive noti?cations for Bradley J. Edwards. We will continue to provide you with updated scheduling and event information as the case proceeds through the criminal justice system. The enclosed information provides instructions for accessing the Victim Noti?cation System (VNS) Call Center and VNS web site. Charges have been filed against deiendant(s) Scott W. Rothstein. The lead prosecutor for this case is LAWRENCE The main charge is categorized as Other White Collar CrimefFraud. Defendant Rothstein has been charged with Conspiracy to Violate the RICO Statute, in violation of Title 18, United States Code, Section 1962, Conspiracy to Violate the Money Laundering Statute, in violation of Title 18, United States Code, Section 1956, Conspiracy to Violate Mail and Wire Fraud Statutes, in violation of Title 18, United States Code, Section i349 and substantive Wire Fraud in violation of Title 18, United States Code, Section i343. Paul Schwartz and Jeffrey Kaplan are also prosecutors assigned to this case. The Crime Victims? Rights Act gives victims of criminal offenses in Federal court certain rights, including: (1) The right to be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any public court proceeding, involving the crime, or of any release or escape of the accused; (3) The right not to be excluded from any such public court proceeding. uniess the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any pubiic proceeding in the district court involving release, plea, or sentencing. (5) The reasonable right to confer with the attorney for the Government in the case; (6) The right to fuli and timely restitution as provided in law; (7) The right to proceedings free from unreasonable delay; and (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. Please be aware that many criminal cases are resolved by a plea agreement between the United States Attorney?s Office and the defendant, You should also know that it is not unusual for a defendant to seek to negotiate a plea agreement shortly before a trial is scheduled to begin, Plea agreements can be made at any time and as late as the morning of trial, leaving little or no opportunity to provide notice to you of the date and time of the plea hearing. if the court schedules a plea hearing in this case, we will use our best efforts to notify you of available information as soon as practicable. if you want to inform the prosecutor of your views regarding potential plea agreements, or any other aspect of the case, please contact the prosecutor assigned to this case or me. We will make our best efforts to ensure you are provided the rights described above. it is important to keep in mind that the defendant(s) are presumed innocent until proven guiity and that presumption requires both the Court and our office to take certain steps to ensure that iustice is served. While our of?ce cannot act as your attorney or provide you with iegai advice, you can seek the advice of an attorney with respect to these. rights or other related legal matters. Defendant Scott W. Rothstein has been sentenced by the Court. The Court ordered the defendant to the following: Incarceration of 50 yearls) Followed by Supervised Release of 3 year(s) Special Assessment of $500.00 The Case involving deiendant(s) Scott W. Rothstein has been scheduled for a hearing on August 30, 2010, 09:00 AM at Fort Lauderdale Division, United States District Court Clerks Of?ce, 299 East Broward BouleVard. Room 108, Fort Lauderdale, FL 3330? before Judge James Cohn. (Restitution hearing) On January 27, 2010, defendant Scott W. Rothstein, pled guilty to the charges listed below. Any remaining counts will be disposed of at the time of sentencing. As a result of the guilty plea, there will be no trial involving this defendant. Number gf Charge Disgosition Charges 1 RICO - prohibited activities Guilty 1 Laundering of monetary instruments Guilty 2 Fraud by wire, radio, or television Guilty 1 Attempt and conspiracy fraud Guilty Because of the Court's schedule, hearing dates could change on very short notice. if you plan on attending, you may want to call the VNS Call Center or check the web site to con?rm the date and time. Please note, there is a 24-hour delay in information transfer to the web site. The Victim Notification System (VNS) is designed to provide you with information regarding the case as it proceeds through the criminal justice system. You may obtain current information about this case on the VNS web site at or from the VNS Call Center at (1?866-365?4968) 1666-2284619) (international: 1602?2132767). in addition, you may use the Call Center or lntemet to update your contact information and/or change your decision about participation in the noti?cation program. If. you update your contact information to include a current email address, VNS will send information to that email address. in order to continue to receive noti?cations, it is your responsibility to keep your contact information current. You will use your Victim identi?cation Number '2886297? and Personal identification Number (PW) ?2175' anytime you contact the Call Center and the ?rst time you log on to the VNS web site. in addition, the ?rst time you access the VNS lnternet site, you will be prompted to enter your last name (or business name) as currently contained in VNS. The name you should enter is Weissing, et ai. Remember, VNS is an automated system and cannot answer questions. if you have other questions which involve this matter, please contact this of?ce at the number listed above. Sincerely, Wares: ?tted: Ciearetha Wright Victim Witness Specialist un- DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, er 01!. Case No. 50 2009 CA OAOSOOWMBAG EXHIBIT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 'Case Nos JANE DOE, flaintitf vs. I JEFFREY EPSTEIN, Defendant I COMPLAINT Parties, Jurisdictien and Venue COMES Now the Plaintiff, Jane Doe, and brings this Complaint against the Defendant, Jeffrey Epstein, and states as follows: 1. This is an action for damages in an amount in excess of $50,000,000.00, exclusive of interest and costs. 2. This Complaiat is brought under a fictitious name in order to protect the identity 70f the Plaintiff, Jane Doe, because this Complaint makes allegations of sexual assault and child abuse ef a then minor. 3. At all times material to this cause of action, the Plaintiff, Jane Doe, was a resident of Palm Beach County, Florida. 4. At all times material lo this cause of action, the Defendant, Jeffrey Epstein, was a I I resident of the State of New York. I 5. At all times material to this cause of action, the Defendant, Jeffrey Epstein, had a residence located in Palm Beach County, Florida. Page 1 ofll 6. At all times material to this cause of action, the Defendant, Jeffrey Epstein, was an adult male born in 1953. I This Court has jurisdiction of this action and the claim set forth herein pursuant to I28 U.S.C. ?1332(a) as the matter in controversy exceeds $75,000.00, exclusive of interest and costs and is between citizens of different states. I 8. This Court has venue of this action pursuant to 28 U.S.C. ?139l(a') as a .?substantial part of the events or omissions giving rise to the claim occurred in this district. 9. At all times material, the Defendant, Jeffrey Epstein, owed a duty unto Plaintiff; Jane Doe, to treat her in a non-negligent manner. and to not commit intentional 0r tortious or illegal acts against her. Factual Allegations 10. Upon information and belief, the Defendant, Jeffrey Epstein, has demonstrated a sexual preference and obsession for minor?girls. He eagaged in a plan, scheme, and enterprise in which he gained aocess to economically disadvantaged and other minor girls, such as the Plaintiff, Jane Doe, sexually assaulted these girls, andfor coerced them to engage in prostitution, I and in return gave these minor girls money. 11. The Defendant's plan, scheme, and enterprise included an elaborate system wherein the then minor Plaintiff and other minor girls were brought to the Defendant, Jeffrey Epstein's residence by the Defendant's employees and assistants. When the assistants and . employees left the then minor Plaintiff and other minor girls alone in a room at the Defendant?s I mansion, the Defendant, Jeffrey Epstein, himself would appear, remove his clothing, and direct the than minor Plaintiff to remove her clothing. would then perform meet more lewd, gPageZOfiI? Iascivious, and sexual acts, including, but not limited to, masturbation, touching of the then I minor Plaintiff?s sexual organs, using vibrators or sexual toys on the than minor Plaintiff, and digitally penetrating the then minor Plaintiff. 12. The Plaintiff, Jane Doe, was ?rst brought to the Defendant, Jeffrey Epstein?s mansion in early 2003, when she was a fourteen-year old in middle school. 13. The Defendant, Jeffrey Epstein, a wealthy ?nancier with a lavish home, signi?cant wealth, and a network of assistants and employees, used his resources and his in?uence over a vulnerable minor child to engage in 'a systematic pattern of sexually exploitive behavior. 1 14. Beginning in approsimately February 2003 and continuing until approximately June 2005, the Defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct These acts included, but-were not limited to, fondling and and illegal sexual touching of the than minor Plaintiff, sexual misconduct and masonbation of the Defendant, Jeffrey Epstein, in the presence of the than minor Plaintiff; and encouraging the then minor Plaintiff to become involved in . prostitution; Defendant, Jeffrey Epstein, committed numerous criminal sexual offenses against I the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, procurement of a minor for the purposes of prostitution, and lewd and lasoivious assaults upon the person of the than minor Plaintiff. - 15., Defendant, Jeffrey Epstein, used his money, wealth. and power to unduly and I improperly manipulate and influence the then minor Plaintiff. I I 16. The acts referenced above in paragraphs 10 and 15, committed by Defendant, Jeffrey Epstein, against. the than minor Plaintiff, ane Doe, were committed in violation of - Page3ofll humorous criminal State and Federal statutes condemning the sexual exploitation of minor children, prostitution, sexual performances by a child, lewd and lascivious assaults, sexual battery, contributing to the delinquency of a minor and other crimes, speci?cally including, but not limited to, those crimes designated in 18 USC ?2241, ?2242, ?2243, ?2421, and ?2423, criminal offenses outlined in ChapterBOO of the Florida Statutes, as well as those designated in Florida Statutes ?796.03, ?796.07, {7796045, ?796.04, ?39.01, and ?827.04. - - 17. The above?described acts took place in Palm Beach County, Florida at the residence of the Defendant, Jeffrey Epstein. Any assertions by the Defendant, Jeffrey Epstein, that he was unaware of the age of the then miller Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and ahuse? of .a minor child. The Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should hairs known of the Plaintiff-Jane Doe?s minority. 18. The ahove~described acts were perpetrated upon the person of the than minor Plaintiff regularly and on dozens of occasions. I 19. In June 2008, in the Fifteenth lodicial Circuit in Palm Beach County, Florida, the Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes insolviag the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution. 20. As a condition. of that plea, and in exchange for the Federal Government not prosecuting the Defendant, Jeffrey Epstein, for amorous federal offenses, Defendant, Jeffrey I, Epstein, additionally entered into an agreement with the Federal Government to the following: ?Any person, who While a minor, was a victim of an offense ehumerated in Title 18, United States Code, Section?ZZSS, will have the same rights to proceed under section 2255 as she would Pages ofll have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For I - purposes of implementing this paragiaph, the United States shall provide Mr. Epstein?s attorneys with a list of individuals Whom it was prepared to name in an indictment as victims of an - enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidential-y burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identi?ed victims in the same position as they would have, been had Mr. Epstein been convicted at trial. No more; no less?. . 21. The Defendant, Jeffrey Epstein, is thus estopped by. his plea and agreement with the Federal Government from denying the acts alleged in this Complaint, and mast effectively admit liability to the Plaintiff, Jane Doe. COUNT I . Sexual Exploitation, Sexual Abuse and/or Sexual Assault of a Minor 22. The Plaintiff, Jane Doe, repeats and realleges paragraphs 1 through 21 above. 23. Defendant, e??rey Epstein, tortiously assaulted Plaintiff, Jane Doe, sexually on dozens of occasions between approximately February 2003 and approximately June 2005, and thither sexually. exploited her and contributed to bet delinquency during that time. Defendant?s acts were outrageous, egregious, intentional, unlawful, offensive and harmful. I 24. The sexual assaults were in violation of the animations state and federal statutes described in patagraph 16 above, and the assaults and acts, of exploitation wereeommitted by Defendant, Jeffrey Epstein, willfully and maliciously. 25. As a direct and proxixnate result of Defendant, ef?ey' Epstein?s assaults on the Plaintiff, Jane Doe, the Plaintiff has in the past suffered, and will in the ?iture suffer, physical PageSofll' . injmy, pale. and suffering, emotional distress, trauma, mental anguish, hmniliation, embarrassment, loss of self?esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, effrey Epstein, controlling, manipulating and coercing her iato?a II perverse and unconventional way of lifelfor a minor. The then minor Plaintiff incurred medical and expenses and the Plaintiff, Jane Doe, will in the future suffer additional medical and expeases. The Plaintiff, ane Doe, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity, to enjoy life. These injuries are pennaaent in nature and the Plaintiff; Jane Doe, will continue to suffer these losses in the, future. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, ethey Epstein, for compensatory damages, punitive damages, attorney?s fees, and such other and . further relief as this Court deems just and proper, and hereby demands trial by jury on. all issues triable as of right by a jury. COUNT II Cause of Action Pursuant to 18 USC ?2255 26. The Plaintiff, Jane Doe, adopts and realleges paragraphs through 25 above. The allegations contained herein in Count Ii are a separate. and distinct legal remedy. 28. Asa condition of the Defendant, Jeffrey Epsteia?s criminal plea, and in exchange for the Federal Govermnent not prosecuting the Defendant for numerous federal offenses, the I Defendant, Jeffrey Epstein, additionally entered into an agreement with the Federal Government - to the followings f?AIny person, who while a minor, was a victim of an offense enmerated in I-Pageoofll Title 18, lJnited States Code, Section 2255, will have the same sights to proceed under section 2255 as she woldd have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein?s attorneys with a list of individuals'whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary bordens if any a . Plaintiff must meet, shall consider that it is the intent of the parties to place these identi?ed . I victims in the same positionlas- they would have been had Mr. Epstein been convicted at trial. I No?more; no less?. I - I 29. The Plaintiff, Jane Doe, was a victim of one or more offenses enmerated in Title .18, United States Code, Section 2255, and as such asserts a cause of action against the I'Defendaht, Jeffrey Epstein,.pursuant to this Section of the United States Code and the agreement . I . between the Defendant, Jeffrey Epstein, and the United States Government. 30; Pleasant to the agreement, the Defendant, Jef?ey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, Jane Doe, and assach he must effectively'admit liability unto the Plaintiff, Jane Doc. 31. As a direct and proximate result cf the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, the Plaintiff, Jane Doe, has in the past suffered, and will in the metre suffer, physical injury, pain and suffering, emotional distress, trainee, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of ?her privacy and other damages associated with I- Defendant, Jeffrey Epstein, controlling, leanipulating and coercing her, into a perverse and unconventional way of?life for a minor. . The then minor Plaintiff medical and .I Page 7 of 11. expenses and the Plaintiff, Jane Doe, will in the ?lture suffer additional medical . and expenses. The Plaintiff, Jane Doe, has suffered a loss of income, a loss of the cahacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are pennanth in natlzre and the Plaintiff, Jane Doe, evill continue to suffer these losses in the ?ltere. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages, attorney?s fees, and such other and '?n'ther relief as this Court deems just and proper, and hereby demands trial by jury on all issues friable as of right by a jury. COUNT Intentional Infliction of Emotional Distress - 32. The Plaintiff; Jane Doe, adopts and 'realleges paragraphs 1 through 25 above. 33. The Defendant, Jef??ey Epstein?s conduct towards the then minor Plaintiff was intentional and reckless. 34. The Defendant, Jeffrey Epstein, deliberately and recklessly inflicted mental suffering upon the then minor Plaintiff. I 35. The Defendant, Jef?'ey Epsteln?s conduct was outrageous in character, and so extreme in degree, going beyond all bounds of decency. 36. The Defendant, Jeffrey Epstein?s intentional, deliberate and reckless conduct caused severe emotional distress to the Plaintiff, Jane Doe. Defendant, at the time he committed these numerous sexual assaults on Plaintiff, Jane Doe, had a Speci?c httent to barre the then minor Plaintiff and his conduct did so harm the Plaintiff. I. 37. As a direct and proximate result of the Defendant, Jeffrey Epsteia?s intentional - and reckless conduct, the Plaintiff, Jane Doe, has in the past suffered and in the future will I continue to suffer physical injury, pain and suffering, emotional distress, traama, mental anguish, hmniliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The than minor - Plaintiff incurred medical and expeases and the Plaintiff, Jane Doe, will in the future suffer additional medical and expenses. The Plaintiff, Jane Doe, has suffered a loss of income, a loss of the capacity to earn income in the ?xture, and a loss of the - capacity to enjoy life. These injuries are pennanent in nature and the Plaintiff; Jane Doe, will continue, to suffer these losses in the future. MEREFORE, the Plaintiff, ane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive daraages, attorney?s fees, and such other and ?irther relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. IV Civil Remedy for Criminal Practices ?38. The Plainti?? realleges paragraphs 1 through 25 above, 39. I The. allegations contained herein in Count IV are a separate and distinct legal - remedy. - Page 9 40. The Defendant, Jeffrey Epstein, participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statutes 41. The Defendant, Jeffrey Epstein, participated in this pattern of criminal activity by engaging in at least two of the following acts of criminal misconduct with the same or similar intents, results, accomplices, victims, and methods of commission within a five year period: Procurng for prostitution, or causing to he prostituted, any person who is under the age of 18 years in violation of Florida Statutes Chapter 796; (13) Acts of battery in violation of Florida Statutes Chapter 784; Commercial sexual exploitation of a child in violation of Florida Statates ?827 .071. 42. Under the Defendant, Jeffrey Epsteia?s plan, scheme, and enterprise, the Defendant, Jeffrey Epstein, paid employees and onderlings to repeatedly ?nd and bring him minor girls in order for the Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and sexual misconduct. 43. The Plaintiff, Jane Doe, was the victim of the Defendant, Jeffrey Epstein's plan, scheme, and enterprise. The Plaintiff, Jane Doe, was called on the telephone and transported by various individuals to the Defendant, Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, enticed to commit acts of prostitution, battery, and sexual exploitation. The Defendant, Jeffrey Epstein, compired with his assistants and employees and various adults and minor children in order to accomplish his enterprise of seeking out, gaining access to, and exploiting sniper children such as the Plaintiff, Jane Doe. Page 10 ofll WI-IEREFORE, under the provisions of Florida Statutes Chaptei? 772, the Plaintiff, Jane Doe, demands judgment against the I Defendant, Jeffrey Epstein; for compensatory damages, treble damages, costs and attomeys' fees, and such other and further relief as this Court deems . just and proper, and hereby demands trial by jury on all issues triable as if right by a jury. Dated; Auguet 12: 2008 Telephone: Respectfully submitted, . THE LAW OFFICE OF BRAD EDWARDS ASSOCIATES, LLC 1 Brad Edwards Florida Bar #542075 . 2028 Harrison Street. . Suite 202 Hollywood, Florida 33020 954-414~8033 Facsimile: 9544-9244530 'Pagellofll DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein 12. Edwards, et a1. Case No. 50 2009 CA EXHIBIT SS DISTRICT COURT SOUTHERN OF FLORIDA CASE NO. 09603 UNITED STATES OF AMERICA, Plaintiff, V, SCOTT W. Defendant. 'Pt'?tf??A AGREEMENT The United. States of America and. SCOTT (hereinafter referred to as ?the defendant?) enter into the ?I?oiiowing agreement: .1 . The defendant agrees to plead guilty to the five count Information, which ehet-gesthe defendant it} Co em? 1 with a. Rae-keteering 00123133 racy, in Vioietion efTithe 18;, United States Code, Section I 962(d); i3} Count" 2 with (3011spi1?eey Money Laundering, in Violation 18, Uoited States Code, Section 1956(1)); in Count 3 with Conspiracy to Commit Mail. Fraud and Wire Fraud, in violation of'Title- 18, United. States Code, Section 1349; and in Counts 4 and :3 with Wire Fraud, in violation otTitle 18, United. States Code, Section 1343. 2. The is aware that the Sentence will be inrueosed by the Court after considering the Federal Sentencing and Poiicy Statements; (hereinafter ?the Sentencing Ciuideiines?) in an advisory capacity. The defendant acknowledges; and. understands that the Court wilt compute an edvieory'sentenee under the Sentencing Guideiinee- and that the applicable advisery guidelines will" be determined by the Court relying. in part on the resuits of a Pre~$eutehee In vesti gatien by the Court?s probation off: ee, which investigation will commence after the guilty-plea has been entered. The defendant is also aware that, under certain circumstancess, the Court may depart from. the applicable advisory guideline range and impose a sentence that. i3 either more Settere or less severe than the advisory guidelines range. The Court is permitted to tailor the 'ttl?timate sentence in light of other-steztotory concerns. Knowingthese facts, the-detendant understands and atknowledges?ttmt the Court has the authority to impoee any sentence "Within and up to the statutory lita'Ximum authorized by low for the o't?fenseo identi?ed in paragraph .1. and. that the defendant may 1339; withdraw the plea solely a result "of the seiiteltee imposed. 3. The defendant also 'undei'stends and acknowledges 01251 the Court may impose a statutoiy maximum term of.imprisonnfient oft-1pm twenty years for each of the offense-s set foyth in Counts. l. through 5, for a total ot?up to one years, 'l?ollowed by a term of up to three year}; o'l?oupervised release for each offense. In addition to a term of imprisonment arid supervised release, the Court may impose a line of up to $250,000.00 with respect to the offenses set :toz't'h in Counts. I, 3, 4, and 5, and may impose a fine with reSpeet to the offense set forth in Count 2. of the'gteater of $500,000.00 or twice the value ot?the property involved in the money laundering trans-actions. 4. The defendant further understands end acknowledges that, in addition to any sentence- imposed under paragraph 3 of this agreement, a special assessment in the amount with respect to each oftlze offenses; set forth in counts; 1 tl'n?ougli S, for a total of$500.00, will be imposed on the defendant, Which will be paid. by the defendant at. the time of entry of this plea. 5. "the defendant further understands and acknowledges that, i. addition. any sentence imposed under paragraphs 3 and 4 ot'this agreement, that restitution 111er be imposed as; part ot?thet sentence. The detendant agrees; that. tor-purposes; of triggering the mandatory restitution of Title 18, United States Code, Section the offenses to which the defendant is pleading guilty under this agreement in this case are ?effensee against pi?ope?y? and were ?Committed by fraud and deceit,? as those terms are understood within Title 18, United States Code, Semi-on The defendant accordingly understands and acknowledges {hates a result ofhie plea. of guilty pursuant. to the terms of the plea agreement in this case the Court may order that he pay restitution pureueni to the provisions ofTitle l8, United States Code, ESec'tio'ns 3663A and 3664. following the entry cfhis guilty plea, The defendant agrees to take? all necessary Steps to make the following property available, as partial satisfaction ofen'y restitution Order entered in this case: all property subjeci to the posolnlormetion Protective Order in this matter; and all. property identi?ed in the Bill. of Perticulare for l'i?orii'eiture. 6. The defendant further understands; and acknowledges that, in addition to any sentence impoeed under paragraphs 3, 4 and. 5 ol?thi-s agreement, forfeiture may be 'i'i'nposed as; part of that sentence. "The defendant-agrees to the forfeiture ofall. ofhis right, title and interest to. all assets listed in the Information and lisied iu the Bill of I?miculare, and?or their substitutes (hereinafter ?the assets?), whether controlled in'diviclu-aily or through deli'enclant?s wholly owz?ied or partially Owned corporations or which are suhj ec?t 't'o forfeiture pursuant to Ti'z?le 8, oiled States- Code, Sections 1963, 982(a)( Tl.) end/or The defendant agrees to assiet the United. States in. achieving- forfeiture ofthe assets and agrees to assist. the United States; with forfeiture of same, such assistmice to include truthful testimony, especially to the extent that {he aeseis are in the names of corporations or other entieies or individuals}. The defendant knowingly and volm?iterily waives any right to a jury trial or any other adversarial proceeding regarding the assets and waives; any calico about i?bz?feimre proceedings, whether edmii'iistretive orj The cie?ienclant further Waives any Statute. of limii?e?i?imns with rte-Spec: to the commencement of such forfeiture proceedings, whether administrative or judicial. The defendant also waives; any defenees to the forfeiture, including any claim ofexoessive ?ne or penalty under the Eighth Amendment. The defendant also agreeS-to waive any appeal of the lbrtoiture. The defendant ?nt'lrer acknowledges that the property cannot, either in Whole or in part, be used. to satisfy any obligation the defendant may have for any 'Eg?ecleral, state or local taxes, interest emclfor.? other penalties which 313/ now exist or which may come into existence. 7. The Office of the United States; Attorney for the Southern Dis-trier (hereinafter ?this Of?ce?) reserves the right to inform the Court and the probation of?ce of all there pertinent to the Sentencing process, "including all relevant information concerning the offenses committed, whether charged or not, as well oonoernzing the defendant and the defendant?s background. Subject only to the express terms of any agreedwpon sentencing '1"eeorn..1nendartione contained in this agreement, this Of?ce further reserves the right to make any reoom'mendation as; to the quality and quantity of p?uniShment. 8. The United States agrees that it "will recommend at sentencing that the Court reduce by three levels the advisory sentencing guideline level applicable to the defendant?s offense, pursuant to Section 3131.! of the Sentencing Guide-lines, based. upon the dethndant?s recognition and af?rmative and timely acceptance of personal responsibility. However, the United States will nor be required to make this sentencing recommendation if the defendant: (1) {oils or refuses: to make full, accurate and. complete clisolosmre to the probation office of the oiroumstonoee the relevant offense oondnet; (2) found to have misrepresented facts to the government prior to entering this plea agreement; or (3) commits any misconduct after entering, into this plea agreement, mung pamm mg} 0.1 Lzmomlun JG 3101? 3:90p {1015;ngch ?rguswam?u mid $ng 5.0 snap at]; ?1.0 81? 3:0 umxlmog 9:41.10} 335130 alimony $331213 31.1.; 0.1 umom; 211213}: LlaJep 3:41 Kc; .1313 puoo ?11830 mo Eugmm?? uxaqymg mg}. mg Klch? magnum 1134mm; sgLnapuqyap mp SQAIOSQJ mamam?a sum, 'mepmpp m1; Kc; papuawtuoam soumum :(me asodde 0.1 qus?gmql saAmsm gumuummg m1} ?zazxamoq maximum ta asocido 01 393.131; momma/m?) ?(zzgm moqe .10 gig-sq 0} unog sq; ?q pammp 5:5 [mm asquo 311.1 18113 mam u; ?0 1 ammuwno? up pure mew-333p mp, Lizoq ?q 5 111110,? spam {zone-pugunuooar 13 ?mmumsm? ?1meusgap @1911 ?g spam uognapttmuutoom 13 Mason 01 533110;) 01.13. media [333% 1291a mmpqum 3?61? Kraut umpuajap @1111 3mm. ?moqe .qdrajfhmad u; pa?pagmounota $313 pm; unapm?p 3qu ?19mm 9.1; ug sq; pm?msgp A9133 m1ch (am pm; 3.11103 my; [10 Eiugpugq 3; ?asgmquo .10 uraumm??'e 01312141103 at.? 03 3931211.: at}; 113g}. uogepuamwmn} ?11k?: 1mg Jammy. spa-1213.19me Etnapqup 9:11.10 some uog'eqmd am ?maumlemo? my; 10:: put; 10m 2101103139151 '9 s; ?3:313:10 uogazeqom 9m .10 ?mamumw? 9m ?Aammw mmpqup alt] Lung 3:91sz mzaulgsa 11mg @1139qu ?mic-mm Amt :umpuopp mp, 112111 aaumuas .10 3mm ?ugoumuas agqeqmd 31;; 3:0 mmugsm {(1113 map, meme 0311-3 unepuqlzap :9qu $11.10;) sq} Aq mag 3.9K 101.1 55911 mum,th m1; Imam wemu s; GILL '6 ?gwgogp .10 rigg'ma gmuzatuumxxo? ?ue o1 .10 slueummls; 93:121.} Emma. .10 ammggo {12.19139} 10 911215; 12 Eng-unmet) {391313;} 1cm 1m} ?ngpn'lou?; 12. The United States agrees that it will not oppose defendant?s zfequest'thet the Court recommend to the Bureau that the defendant be desiguated to the lowest security level. fee-ilily deemed appropriate by the Bureau of Prisons. 13. I The defendant is; aware that Title l8, United States Code, Section 3742 affords the defencleiit the right to appeal the sentence .iltipesed. in this case. Acknowledging this, and in. exchange lb]: the undertakings made by the United States; in this plea agreement, the defendant hereby waives all rights conferred. by Section 3742 to appeal any sentence imposed, incleding any restitution order, 01' to appeal the emamet in which the eentence was imposed, unless the sentence exceeds the maximum permitted by? statute or is the result O'li?an upward departure and/or a. variance from the guideline range that the court: eetablishes at sentencing. The. defendant :l?urtihe'zr "Lmde?rstands that nothing in this agreement shall effect the government?s right. and/01' duty to appeal as set forth i1} Title 18, United States Code, Section 374.203). However; if the United States appeals the defendant?s; Sentence pursuant to Section 3742(b), the defendant shell be released from the above waiver oil~ appellate rights. By signing this agree-menu the defendant acknewledges that he has discussed the appeal waiver eet ffOl?tl}. in. this ag'ifeen'rent with his attorney. The defendant further agrees, with {he United States, to request that the district Court enter a specific ?nding that the defendant?s waiver ol?his right to appeal the sentence to be imposed in this case was knowing and veluntmy. 14. The defendant 'l'iirther weivee any right to file any motion or make any claim, whether under 28 USC. ??2255, 2254, 2241, or any other provision of law, it) collaterally attack his conviction, his Sentence 01* the manner in which sentenee was imposed, sentence exceeds the maximum permitted 'by etatute. '1 5.. The defendant con?rms that he is guilty efthe offense see-Which he is pleadii'1g- guilty; that his decision. {to piead guilty is the deeigion that he has made; and 111211 ?ile?lmdy has fereech Sweetened, or coerced him ?11210 pleading guilty. The defendant affirms that he has dismissed the matter ofpieadieg gui It}! in {he aboeewrefererleed caees thoroughly with his; attorney. The defendant further affine}; 312121123 diseuseiens with his attorney have included disezlssien 0fpo'ssible defenses that; he may raise iftl'z'e case were to go to mm, Well as peSSi-ble iseues and arguments that hemay raise at genteneieg. The defendant additionaily af?rme that he is setiefi with the repreSe?ntetion provided by his; The defendant affirms {hat he is; entering into this agreem ent knowingly, volilritarily, and inteliigentiy, and Wiih the bene?t of full? complete, and effective assistance by his attorney. The defendant accordingly agrees that by entering into this agreement he waives any right to file any motion 91' make: any claim, Whether under 28 122543 2241 or any other provision Of law, that contests the effectiveness of" counsel-?53 mpresm?ation up t0 the: time of the entry of his guilty pleas. . 1.6. This is the entirrs: agreement and understanding b?tween the United States and the defendant. There are no ethar- agreements, promises, represemations, 01? understandings, amass maintained in a Eeizter from the United. States A?omey'k Of?ce executed by all. parties and 00111336? prior to the: change of plea. JEFFREY H. SLOMAN ATTORNEY f? r, 2" ?ft Date: PAUL SCHWARTZ ASSISTANT STATES ATTORNEY Date? AS 818mm UNITED ATTORNEY 9? Dateiig?wm kg) UNITED .. Dam: my?? ?y 1127551531; FOR I Zr?: ,gcli?fj?TT W. Oi? FACTS The United States of America. and W. enter into the following stipulated statement of fleets in aujpport oi" the defendant?s plea-of guilt-y: Had this case proceeded to trial, the government wouldhaVe presented. eviden which would have established beyond a it'eassoaable doubt that from in or about 2005, 't?li?i?ough in or about November 2009, Ibeir?eodant RO'l?HS?i?li?iN conspired. wi ti}. persona known and unknoWn to the United States Attorney, to nae the law ?rm, Rothsteio, Rosenfeidt and Adler P.A.. (hereinafter? referred to a. criminal Enterprise order to conduct a pattern of racketeering activity. Such. pattern of racketeering activity included criminal acts wliiel'i violated mail :tii?aud, wire fraud, money laundering and conspiracy statutes. The government would have peeaented avid ence at trial which would have involved witness; teatimony' and documentary and. electronic evidence seized pursuant to a search warrant. The government?s trial evidence would have established the following: Dezt?eadant ROTHSTEIN was an attorney admitted to p'raetice law in. Florida. He was the Chief Executive Officer and Chairman of REA. "In or about 2005., Defendant and other eo?eonspirators initiated a aolieine to geaeate criminal prOcee-ds fraudulent acts. Deiendant induced investors through the {18? 01" false Statements to loan. money to himself and ?ctitious borrowers in return for promissory notes. He solicited bridge loans on behalf ot?pui?ported clients that is, he inform individuals; that clients desired to borrow funds; for business deals and in return would agree to pay high rates oi" interest. .l.)efendant was aware that no such clients or toque-eta for business ?nancing actually existed. Defendant and. eoweonspirators also solicited investors to purchase purported con?dential settlement agreements. Such settlement agreements. were falsely presented as having been reached between. putative defendants based upon claims of sexual l?laressn?lent endfer whistle~ blower actions. The investors were tl?elsely informed that such settlement agreements were pram litigation and therefore there was no pending litigation. or court oversight. Detendent and other eemceuspiraters relied upon the purported success 01:" REA, the existence (rtectual RRA civil matters and his standing in. the community to lure potential tweeters in order to convince them to make such investn?tents. The investors were falsely informed that the confidential settlement agreerrtents were available for purchase. The purported settlements were allegedly available in amounts ranging, from O't?thcusands ctde'llers to millions ot?dol tars an coul be purchased at a. discount and repaid to the itweswrs at :ETace value over time. For instance, in or about late 2009, a potential investor was solicited by Defendant andt'cr to purchase a- p?urpertcd settlement in the amount 01f$450,000. The settlement was alleged to be paid to the- purported plaintiff in three installments each, over the course of three ment?h-s. The payment sclaed ulc was alleged to insure the con?dentiality e-fthc settlement. The purpOrtcd plaintiff allegedly had agreed to accept an immediate in satisfaction Of?t'llti settlement agreement. In order to thcilitate the cmc, the investor received a fraudulent settlement agreem cent which set "forth the tem'zs of the civil settlement, but the names of the purported plaintiff and defendant were excised due to the alleged con?dentiality of the settlement. The government would :l?urthez' establish that in order to Facilitate and perpetrate the scheme, Defendant and created 100% and it?re?ttdulent settlement agreemetlts. bank statements, assignments of settlement agreements, sale and. transfer agreements and personal guarantees, among other documents. Defendant and other cowecnspiretors; falsely informed. fut/testers that the purported confidential. settlements were either negotiated on behalf of clients of ERA or had been referred by other law firms. The" investors were falsely informed that the purported eettlements Were baeed Upon sexual end/er Whistle-"blower (citii 421m) actions agaizret eemcratedefend-ants. Defendant and ether ccvcenspiratcrs eStebl lashed and. maintained trust accounts at several- ?nen'cial institutions in order to receive the investor funds and to give-the appearance-0f legitimacy and security. False and ?ctitious trust account bank balance steterrients were created along with purported ?lock Such letters allegedly reflected. that the funds in the trust accounts; would be disbursed only to sapceiitic .iiwestors. ingrea?l :l?umis were disbursed among and. between. the Varieus trust accounts and elsewhere by interstate wi re transfers and other means in order to facilitate, promote and conceal the ?end, to launder the proceeds derived there?rom, and to enrich and. his and his cei?cc'uspiretcrs created zl?raudulent cn?line bankirrg documents to thriller mislead investors and. to l?cilite?ie the fraud. Defendant and e0~con$piraters also initiated and. conducted a. separate scheme to defraud clients chRA in 0rd er to perpetuate the ?Ponxi? scheme. Such clients had retained RRA to institute- ancl tile '21 civil lawsuit. Unknown to the clients, RRA settled the lawsuit and had obiigatecl the clients to pay $500,000 to the defendant. in order to perpetrate the fraud and deceive the cl i cute, defendant created false and fraudulent court purportedly gated. by a Federal District Chart Judge which faleely alleged that. the clients of RRA. had prevailed in the lewenit and were owed. 21 udgement of approximately $23 million. The :tiraudulent court order also falsely stated that the defendant. had trzme?i?erred ?elds; to the Cayman Islands for the purpose of secreting the assets. Defendant and other cowconspirazoz's falsely advised the clients on several occasions that in order to recover the funds, they had to post bonds to be held in the RRA trust account. Defendant and (?ller cowconspira?tors caused the clients to wire "?z?aos'fcr a total of approximately $57 millim over several years to a trust account controlled by defendant plurportedly to satisfy the bonds. Defendant and other cowconspirators were queseioned by the clients as to the progress of {the alleged. lawsuit. In ardez? to delay the return of funds to the clients, defendant fi'audulen'tily created a. liaise federal court Order purportedly issued. by a. United States Magistraie lodge ordering RRA. 'to return the transmitted foods by" a later date. Defendant and other cowemspirators utilized funds obtained elsrough the ?Ponzi? scheme-to supplement and support the operation and activities to expand by the hiring of additional attorneys and support staff, to {Fund salaries and bonuses, and. to acquire larger an more elaborate of?ce-space and equipment in ord or to. prom etc the ongoing scheme and to enrich the persona] Wealth ol?pexrsons employed by and associated with RRA. Defendant ROTHSTEIN and "other co?conspira??ors engaged. in the below described conduct in order to ?aeil itaic the activities o'ftlle Enterprise and. to conceal and promote the scheme to de??aud. investors. Defendant and caller cowconspirators utilized funds illegally obtained elsm'lg'h the ?Poozi? scheme to make contributions to local, state and federal political. candidates, in a designed io conceal the {me source of such limes and to circumvent state and federal laws governing the limitations and contribution of such funds. Defendani and. other distributed lavish gills? i'i'ic'luding esotic cars, jewelry, boats, loans, cash and bonuses, to individuals and to members of RRA in order to engender goodwill and loyalty and to create {he appearance of a. successful law firm. Defendant and other made large charitable contributions to publicst private cl'las'ritablc institutions, including hospitals and other legitimate charitable and nonpro?t. organizations, using funds derived l?ron'i the ?Ponsii? scheme. ?Ponzi? scheme funds were also used to provide grammes to higlwenlciog members ofpolicc agencies in order to curry favor with such police personnel and to deflect law enforcement scrutiny of REA. Defendant and other co?conspira?tors {utilized fonds obtained through the ?l?onzi? scheme in order to purchase controlling interests in restaurants located in the Southern District of Florida. Such restaurants were used in part as a mechanism to giVe gratuities to individuals, including politicians, business associstcs and in order to :t?oste'r goodwill and loyalty, as locations to soliciipotentiol investors and as secure locations for conspiratorial"meetings. Defendant and other co~conspirators ailsooiatcd with well known politicians, in public forums and elsewhere, in order to gain grcoicr notoriety and. to create ?the appearance of Wealth-and legitimacy. Such acts were calculated in pans-to enhancedefendant and other ecu-?conspirators ability to solicit potential investors in the ?Poms? scheme. Defendant and other used funds derived from the ?Fonz? scheme to maintain the appearance of affluence and. wealth, by purchasing expensive real and personal property, in order to convince poicotial investors of the legitimacy of mid of the purported investment opportunities. Dc'lr?eiidarit purchased expensive real property, personal property, business info-rests, vesselsi 'vehioles and other indicis of success and wealsh. The government?s evidence would eeteblsiclt that Defendant and co? conspiratorsg through the use of RRA as the criminal Enterprise: knowingly and intentionally "engaged ill the above-described pattern. oftraclceteeting activity in order to gent-irate proceeds for their enrichment through various criminal activities, mall ?tted, wire fraud and. money lauodlering. The government?s evidence would establish that the activities ofthe Enterprise affected interstate commerce through the tram-mission of?mdc'emong and between. ?nancial institutions and across: state'- boml'clm?les, among other means. The Enterprise maintained ot?lil in l3-.roward County, Florida, and elsewhere and the pattem ofracketeering activity emanated from the Southern District of Florida. tweeters were solicited through wire and mail transmissions through. the United States and elsewhere. In order to further the fraud scheme, Defendant and. other cowconspiretors caused to be transmitted wire in interstate cod foreign. commerce, inctuding an interstate Wire trancil?er sent from TD Bank to Gibraltar Bank on. or about December 2, 2008 and an interstate wire transfer Sent to TD Bank {from JP Morgan Chase on or about Octooer 16, 2009. The proceeds derived from scheme were lemwdered through the accounts maintained at several ?ttaociel. institutions it} ot'der to promote, carry on and conceal the criminal activities of RRA. Had the forfeiture portion 0th the case proceeded to trial, the government would have established, at leaet by a preponderance of the evidence, the Standard of proof required for sentencing, that the properties; listed for forfeiture in the forfeiture allegations; orl"the loforma'tioo and it} the Bill of Particulate 'l'lor [Forfeiture were properly sought for 't?cn'feiturc becauee the defendant acquired. or maintained an interest therein or were derived from proceeds obtained directly and indirectly through the com ofthe above?described racketeering activity. The government would. have further established that the properties; were involved it} and/or were traceable to the 6 111021651 laundering activity described above:, and that. web properties were also the: proceeds of, or ware: deifin 11301171, the mail and} wire .?fmt'zd activity described above. The undersigrmd hereby $ti-pulate and agree that the aforesaid them are true and correct and {hat they encompass: all of the necessary {?laments to establish the guiit 0f the defendamt to tha charges of Conspiracy To Vioiatc the RICO Act-, in violation o'fTitlt?x I United. States Code, Section Cl?rzspimcy to Commit Money Launderi'ng, in Violation of'??e ?1 8, United States Cadet, Section 195601); Compiracy to Commit Mail'me and. Wire Fraud, in violation o?i?Tit-lc 18, United States Code, Seation 3349; and Wire Fli?c'l'tld, in. violation of- Tii?le 18, United States Code, Section 1343. H. SLOMAN U'Nm?laan SMTES .. Km?; (A :6 - SCHWARTZ UNITED ATTORNEY . r: Date: .. - KAPLAN STATES AVTORNEY Date:g?j?wj? Vim!erng 15/; STATES AS 3131'." 'i . Date: *5 .WZWW .1 :33? 3? 3r DEFENDANT DEFENDANT BRADLEY J. EDWARDS STATEMENT OF UNDISP TED FA TS Epstein v. Edwards, et al. Case No. 50 2009 CA EXHIBIT U.S. Department of Justice Uni?ed Slates Attorney Southern District qulorido 500 South Australian Ave, Suite 4 00 West Palm Beach. FL 3340! 82!??872?! Facsimile: done 30, 2008 os worms On use 30, 2008, Jeffrey Epstein (hereinafter referred to as ?Epsteio) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felo'oy sch-citation ofprostitotion) and 796.03 (procurement ofminors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. and 2008~cf? and was sentenced to a term of twelve months? imprisonment to be followed by eighteen months? of Commuoiiy Control 1, the ?rst six months of which must be served imprisoned at the Palm Beach County Detention Facility. in light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. ?ll/yaw. One such condition to which Epstein has agreed is the following: ?Any person, who While a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have bad, if Mr,: Epstein had been tried federally and convicted of an enumerated offense. For poip oses of implementing this paragraph, the United States shall provide Mr. Epstein?s attorneys with a list of individuals Whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentisry burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identi?ed victims in the, same position as they would have Been had Mr. Epstein been convicted at trial. No more; no less.? Initials ofleffrey Epstein initials oflack Goldberger - wavw?ll NOTEFICATEON OF IDENTIFIED VICTIMS JUNE 30, 2008 PAGE 2 OF 3 Through this letter, this Offi oe hereby provides Notice that the individuals identi?ed below are individuals Whom the United States was prepared to name as a victim of an enumerated offense. Identified individoeis R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By? A. MARIE VILLAFANA ASSISTANT U.s. ATTORNEY I have received this Noti?cation from my attorney, aok Goldberger, Esquire, have reed it and discussed. it with my attorney, and I hereby acknowledge that it accurately sets forth my understanding and agreement with the Office of the United States Attorney for the Southern District of Florida regarding the noti?cation and rights of identi?ed victims. I Initials of Jeffrey Epstein Initials of Jack Goldberger OF IDENTIFIED JUNE 30, 2008 PAGE 3 OF 3 VICTIMS understand that an exact copy of this Noti?cation will be provided to each identi?ed individual, exdept that the names of all other identi?ed individuals will be redacted, and I hereby waive any evidential"); challenges to the introduction of a copy of this documen?iweven g?n redacted form?"imam bergwgen any identi?ed individualfigd myself. E3 g: fl? (matedstein as? g. is? ?5 lg Wit?llessed by: g; 31 3 Jack 5- 3' $3 DEFENDANT BRADLEY J. EDWARDS STA TEMENT 0F UNDISP UTED FACTS Epstein v. Edwards, 61? al. Case No. 50 2009 CA EXHIBIT RR UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. Plaintiff, vs. JEFFREY et Defendant. Reiated Cases: 08?80119, 08?80232, 08~80380, 08-80381, 08-80994, 08430811, 08-80893, 09-?80469, 0980591, 09-80656, 0960802. 09-81092 I PLAINTIFF JANE EMERGENCY MOTION FOR A HEARING, FINDING THAT EPSTEIN IS IN CIVIL CONTEMPT OF THE TWO ORDERS FORBIDDING HARASSMENT AND INDIRECT CONT-ACT, FOR APPROPRIATE SANCTIONS AND ADDITIONAL REMEDIES INCLUDING REFERRAL FOR CRIMINAL CONTEMPT Plaintiff, Jane Doe, through undersigned couneei. hereby ?les this emergency motion for a hearing and for an immediate ?nding that Epstein stands in civ? contempt of Judge Merra's order forbidding indirect contest with Jane Doe and Judge Palermo?s order forbidding harassment of Jane Doe. Jane Doe asks for this Court for remedies and sanctions to provide for her safety and to insure that Epstein foitows this Court?s orders (and an order of the state court), inoiuding a referral to the US. Attorney?s Of?ce for prosecution of criminal contempt. To put the matter bluntly, defendant Epstein is intimidating Jane Doe in violation of three judicial no-conteot orders. Last evening, he had a "private investigator" tail CASE NO: OB-CV-BOBQS-MARRNJOHNSON Jane Doe following her every move, stopping when she stopped, driving when she drove, refusing to pass when she pulled over. When Jane Doe ultimately drove to her home, the ?private investigator? then parked in his car approximately 25 feet from Jane Doe?s house and ?ashed his high beam lights intermittently into the home. Even more threateningly, at about 10:30 pm, when Jane Doe ?ed her home in the company of retired police of?cer employed by Jane Doe?s counsel, the "private investigator? attempted to follow Jane Doe despite a request not to do so. The retired officer was successfully able to take evasive action and has placed Jane Doe in a secure, undisclosed location last night. Other harassing actions against Jane Doe aiso occurred yesterday. Given the circumstances of this case, it is obvious that intimidation from the ?private investigator? was instigated by billionaire Epstein. Epstein thus stands in clear vioiation of two, separate orders from this Court, one long-standing and one entered yesterday. First, a year ago, this Court stated that it "finds it necessary to state clearly that Defendant is under this court?s order not to have direct or indirect contact with any plaintiffs . . . Order, Case no. 9:08-ov-80119, doc. #238 at 4-5 (emphasis added). Second, on top of this order, yesterday this Court entered another order directing Jane Doe and Epstein "not to communicate, speak or harass one another in any way.? Order, Case no. spew-80893, doc. #193 at 2 (emphasis added). Epstein?s intimidation-by~surrogate also violates a no-oontact order entered during the course of his guilty pieas on June 30. 2008, before Palm Beach Circuit Court Judge Deborah Dale Pucillo, who ordered Epstein ?not to have any contact, direct or CASE NO: indirect? with any victims. She also expressly stated that her no~contact order applied to ?all of the victims." To protect her safety and to insure respect for court orders, Jane?s Doe?s counsel accordingly request, on an emergency basis: First, the Court should schedule an emergency hearing today, either in court or via telephone, to consider whether Epstein stands in civil contempt of the Court?s orders; Second, the Court should ?nd that Epstein stands in civil contempt of two separate orders of this Court; Third, the Court should then hear from Jane Doe directly and impose such civil contempt sanctions as it ?nds will enable Jane Doe to return safely to her home or other place of safety without facing the threat of any further harassment or intimidation. Fourth, as part of the sanction for Epstein's civil contempt, the Court should expand its current protective order to forbid Epstein or his agents from having any contact whatsoever, direct or indirect, with Jane Doe, but also with any of her family members or friends, as well as with any persons who have been identi?ed by Jane Doe as possible witnesses in her case, without ?rst seeking speci?c approval of the Court. Fifth, the Court should direct Epstein?s legal counsel to file with the Court in advance of the mediation on Tuesday morning a certi?cation that they have explained to him the consequences of any additional violations of the courts orders. crass no: Sixth, Epstein should be directed not to have any agents attempt to foiiow or surveil Jane Doe as she leaves the courthouse after the settlement conference on Tuesday or after any other court hearing; Seventh, this Court should initiate criminal contempt sanctions against Epstein for the violations of its two orders under Fed. R. Crim. P. 42(a), by referring a criminal contempt action to the US. Attorney?s Of?ce for the Southern District of Florida; Eighth, the Court should also refer this matter to the US. Attorney?s Of?ce for the Southern District of Florida for investigation of possible oriminai offenses, including witness tampering in violation of 18 U.S.C. 1512(b) as well as its position on violations of the conditions of Epstein?s non-prosecution agreement; and Ninth, the,Court should refer this matter to Palm Beach Circuit Court Judge Deborah Dale Pucillo?s criminal division presiding over Epstein?s probation for consideration by her of whether Epstein has vioiated her order as weil. I Tenth, the Court should refer this matter to Epstein's probation officer for determination of any violations of his probation. Eleventh, the Court should request that Epstein pay a fine to Jane Doe?s counsel in the amount of $18,000 to cover any and alt costs associated with relocating Jane Doe and keeping her safe through her trial date. Because Epstein?s blatant defiance of this Court rte-harassment order appears to be designed by him to intimidate not oniy Jane Doe but also other witnesses in the case other young girls that he sexually abused), Jane Doe is filing this Emergency Motion Under Seal. CASE NO: 08-OV-80893-MARRNJOHNSON BACKGROUND Counsel for Jane Doe proffer the foilowing facts as officers of the Court. They proffer that they could prove these facts at any evidentiary hearing which the Court might decide to hold. Counsel for Jane Doe further represent to this Court that they have a genuine concern about the physical safety of their client. Facts Leading Up to the Entry of Three Protective Orders The Court is familiar with the general circumstances of this case, which involves Jane Doe?s lawsuit seeking signi?cant compensatory and punitive damages from billionaire Jeffrey Epstein. The Court is also aware that Epstein has pled guilty to state sex charges on June 30. 2008. When he pled guilty before Palm Beach Circuit Court Judge Deborah Dale Pucillo, she ordered Epstein ?not to have any contact, director indirect? with any victims. She aiso expressly stated that her no-contact order appiied to ?sit of the victims.? The relevant transcripts have been filed with this Court. (See case no. doc. #113 at 3 and exhibits thereto.) To avoid any uncertainty about the scope of this state court order, several of the piaintiff/victims with suits pending against Epstein before this Court ?ied a motion for an order prohibiting defendant or his agents from communicating with them directly or indirectly. (Case No. 9:08-cv-80119, doc. #113.) Epstein opposed these requests as "neediess, unwarranted and excessive.? Doc. #127 at 5. This Court, however, firmly overruled Epstein?s objections. On Juty 3t, 2009, this Court entered its own {to-contact order (in addition to the state court order). ruling: CASE NO: In light of Defendant's response to Plaintist motion for no contact order, suggesting that the state court?s order only applies to some victims and that parties are always allowed to contact each other directly, the Court finds it necessary to state clearly that Defendant is under this court?s order not to have direct or indirect contact with any plaintiffs, regardless of the intended scope of the state court court?s order. Order, Doc. #238. at 4~5 (emphasis added). Recently, with the case nearing trial, the Court ordered Jane Doe to attend a settlement conference on July 6, 2010. Jane Doe had concerns that the upcoming settlement conference, demanded by Epstein, was going to be used to harass and intimidate her. See Plaintiff Jane Doe's Motion for Modi?cation of Magistrate Judge Patermo?s Order Schedule settlement Conference, doc. #187. After a response from Epstein (dos. #191), the Court modi?ed its order regarding the settlement conference to avoid harassment of Jane Doe. Signi?cantly, in the final paragraph, the Court (Palermo, J.). starkty commanded: The parties are instructed not to communicate, speak or harass one another in any way. Any violation of this Order will not be tolerated. The parties are instructed to GOVERN THEMSELVES ACCORDINGLY. Case no. 9:08~cv~80893, 000. #193 at 2 (itaiio added, capitalization in original). This Order was entered at 3:29 p.rn., EDT, according to the PACER message sent to counsel in the case. Intimidating Activities on the Evening of July 1, 2010 in spite of three court orders forbidding contact and harassment of Jane Doe, Epstein has (once again?) shown his unwillingness to fotlow the rules. On the evening 1 For two other examples of Epstein?s unwiilingness to foiiow the same rules that apply to other iitigants, see Plaintiff's Motion in Limine to Prevent Improper Use of the 5?h Amendment, doc. 6 CASE NO: of July 1, 2010, sometime after the issuance of this Court?s most recent order, Jane Doe left her house to go to the store and noticed a car (infiniti SUV, license tag following her everywhere she went. Feeiing frightened, she pulled into a driveway in a nearby neighborhood at one point to aliow the car to proceed past her, but the car pulled into the neighborhood and stopped nearby. it was clear the person in the car was following her and was intentionally making his presence known. Jane Doe pulled out of the driveway and headed home, with this other car tailing close behind. Once Jane Doe arrived to her house, she went inside and the person foiiowing in the in?niti parked across the street outside her home. Jane Doe called her attorney expressing her fear and asking what could be done to protect her. She observed that the car kept creeping cioser to her home every once in awhile. This intimidation of Jane Doe was so serious that, alerted by Jane Doe?s counsei, a retired police of?cer called the poiice. The police responded to Jane Doe?s borne and confronted the man in the car. The man told the poiice that he was ?private investigator.? However he would not tell the police who had hired him, only that he was hired to ?watch? Jane Doe. The name of the investigator appears to be Thaddeus Knowles. The police reported these facts to Jane Doe, but advised her that they did not have a legal basis to order him to leave the public street. (The police are also preparing a report on the incident.) Counsel for Jane Doe then arranged for the retired police of?cer to go to Jane Doe?s home. This retired officer arrived at Jane Doe?s home at approximately 10 pm. #178 (recounting Epstein's misuse of the Fifth Amendment during his deposition); doc. #190 (recounting Epstein?s violations of discovery orders). 7 CASE NO: OHNSON He immediately saw a car parked 25 feet from Jane Doe?s home, facing her home. He also observed the purported ?private investigator? in the car intermittently ?ashing his high beam tights into Jane Doe?s home. The investigator was also intermittently attempting to videotape anyone inside the home. The retired police of?cer took videotapes of the investigator lighting up the interior of the home with his high beam lights, and also took photographs of this harassing action as well. The videotape and photographs could be provided quickly to the Court upon request. After consulting with Jane Doe, the retired police of?cer determined that Jane Doe felt iike a prisoner in her own home and that she believed her physical safety and that of her family was threatened if she remained there. She further believed that this intimidation was being orchestrated by defendant Epstein. Jane Doe is not involved in other litigation and is not aware of any other person who would want to do something like this to her. Also, in the last 48 hours, Jane Doe has received telephone calls from two ex?boyfriends that investigators were at their homes, knocking on their doors and trying to talk to them about Jane Doe apparently because of this case. And, of course, Jane Doe?s settlement conference is just four days away and her trial is two?- andwhalf?weeks away. In light of Jane Doe?s concerns, the retired police of?cer believed that it was best to take Jane Doe from her home. He advised Jane Doe to pack a suitcase and leave the home with him. At approximateiy 10:30 pm, the retired police officer then took Jane [Joe in his car and puiled up next to the ?private investigator.? The retired police officer advised the CASE NO: investigator that Jane Doe was leaving the home to go to another location and that he should not attempt to follow them. Nonetheless, the investigator attempted to follow the retired police of?cer as they drove away from Jane Doe's home. The retired police of?cer then took evasive action and was abie to elude his pursaer. As a result of these activities, Jane Doe feels very threatened. She knows that she was followed for much of the day. She also know that this was not surreptitious surveillance by someone who was trying to discovery something about her, but rather quite visible surveillance by someone whose manifest intent was to make she that Jane Doe knew she was being followed. Thus, when she pulled over, he patted over; when she parked, he parked visibly close by. The only reason for such activities couid be to intimidate her on the eve of the court-ordered mediation. It may aiso be worth noting that Jane Doe is a petite young woman, physically smaller and younger than the male private investigator who has been following her. Past Intimidation of Witnesses By Epstein The Court should be aware that this is not the ?rst time Epstein has used scare tactics to intimidate witnesses. indeed, as the Court is aware, despite numerous civil suits being filed against Epstein for sexual abuse, none of the victims in those cases have felt able to proceed to trial. Counsel for Jane Doe have been advised that many of these victims were afraid to take their cases all the way to trial. Jane Doe remains one of only three victims who has had the temerity not to settle her case against Epstein but stand on her right to a jury trial. CASE NO: I in determining who is responsible for the intimidation that took place last night, this Court can consider all of the circumstances, including other documented examples of harassment by Epstein:2 Previous use of ?investigators? to scare witnesses: The use of ?investigators? to aggressivety harass his victims is not new to Epstein. as investigators have in the past aggressively followed key witnesses to intimidate and scare them. See Palm Beach Police Department Incident Report at p. 86 (Attached as Exhibit A). Victim~to~victim communication: One of Epstein?s sexual abuse victims was relayed a message from another victim speaking on Epsteis?s behalf regarding the criminal investigation of Epstein in 2006: ?Those who help will be compensated and those who hurt will be dealt with." See Palm Beach Poiice Department Incident Report, id. at page 83. Witness tampering during the fedora! investigation: During the FBI investigation of his sexaai abuse of young girls. Epstein intimidated and harassed other possible witnesses against him namely Sarah Kellen, and Nadia Marciskova. indeed, this intimidation was so serious that federal prosecutors prepared draft federai charges against him for witness tampering charges. (Attached as Composite Exhibit B) Ultimately, for reasons that are unciear, these charges were not ?ied. Threats Against Jane Doe 102: Epstein has even tracked down adverse witnesses as far away as Australia in the past to send the message not to testify against 2 The Federal Rules of Evidence do not apply to this motion and. in any event, the federal rules authorize the Court to consider other bad acts in reaching a conciusion about disputed events. See Fed. R. Evid. 404(k)). 10 CASE NO: OHNSON him regarding his illegal sexual exploits. See Complaint of Jane Doe 102 v. Epstein (attached as Exhibit C) Threats Against Alfredo Rodriguez: Jane Doe is not the only person to have received this impression that she is at risk if she does not accede to Epstein?s demands. The Court is familiar with Aifredo Rodriguez, an employee of Epstein who kept a ?black book" of the names of minor girls Epstein? was sexually abusing. See Criminal Complaint, US. v. Rodriguez, No. (doc. Rodriguez stated that he was afraid that Jeffrey Epstein would make him "disappeai? unless he had an ?insurance policy? the black book). Id. at 3. Please find, for the Court's consideration as well Exhibit D, the affidavit of the retired officer that assisted in protecting Jane Doe. The Court can consider all of this information as circumstantial evidence pointing to only one conclusion: that defendant Epstein is trying to intimidate Jane Doe before her upcoming settlement conference and trial. This is clear violation of the three court orders outlined above. THE COURT SHOULD TAKE APPROPRIATE STEPS TO RESPOND TO THE VIOLATION OF ITS ORDERS AND TO ALER THE STATE COURT TO A POSSIBLE VIOLATION OF ORDER Defendant Epstein is thumbing his nose at three separate court orders, two from this Court and one from the state court. The threatening message billionaire Epstein is trying to send to Jane Doe is obvious: settle this case next week or you are in danger. This is not the way in which a civil case should be litigated. The Court should not allow defendant Epstein's wealth to be deployed to pervert the course of justice. In entering 11 CASE. NO: its most recent no harassment order, Judge Palermo indicated that ?[a]ny violation of this Order will not be tolerated.? Jane Doe respectfully requests that the Court carry through on this promise and make it possible for her to return safely to her home. Jane Doe accordingly requests the following actions on an emergency basis: ?rst, the Court should schedule an emergency hearing today, July 2, 2010, either in court or via telephone with counsel for Jane Doe and Epstein to learn whether Epstein will challenge any of the foregoing facts and the conclusion that he stands in civil contempt of this Court?s orders and, if so, how to resolve those factual questions rapidly. As part of that hearing, counsel for Epstein should proffer whether Epstein will deny that he instigated the harassment that took place last night and answer questions about his involvement or whether instead he will refuse to answer such questions on grounds that they might incriminate him.3 The Court should thereafter conduct such further fact-?nding as it deems necessary to reach a conclusion about whether Epstein has violated the Court's orders, giving both Jane Doe and Epstein an opportunity to be heard. m, the Court should find that Epstein stands in civil contempt of two separate orders of this Court: (1) Judge Marra's long-standing direction ?that Defendant is under this court?s order not to have direct or indirect contact with any plaintiffs," Order, case no. doc. #238, at 4~5 (emphasis added), and (2) Judge Palermo?s 3 it, as Jane Doe suggests, the Court ultimately proceeds first by way of civil and then only tater by way of criminai contempt, Epstein would be entitled to invoke the Fifth Amendment only in the later criminal contempt proceedings. See Romero v. Drummond Co, Inc, 480 F.3d 1234, 1243 (t?i?h Cir. 2007) (noting that the right to remain silent attaches to criminal contempt proceedings). Of course, in any civil proceeding, the finder of fact can draw an adverse inference from an invocation of the Fifth Amendment. 12 CASE NO: order yesterday that Jane Doe and Epstein ?are instructed not to communicate, speak or harass one another in any way, Order, case no. 9:08-cvw80893, doc. #193, at 2 the Court should then impose such civil contempt sanctions as it finds, after the hearing, will enable Jane Doe to return safely to her home (or, if necessary, other place of safety) without facing the threat of any further harassment or intimidation. See Serra Chevrolet, Inc. v. General Motors Corp, 446 F.3d 1137, 1147 Cir. 2006) (?Civil contempt may be imposed in an ordinary civil proceeding upon notice and an opportunity to be heard?). As part of thatdetermination, plaintiff Jane Doe respectfully requests an opportunity to be heard directly by the Court (either in person or via telephone) so that the Court will have the bene?t of her specific concerns in crafting appropriate sanctions and remedies to make her feel safe to return to her home and to prevent further intimidation at the hands of Epstein. EM, as part of the sanction for Epstein?s civil contempt, the Court should expand its current protective order so that forbids Epstein or his agents from not only having any contact whatsoever. direct or indirect, with Jane Doe, but also with any of her family members or friends, as well as with any persons who have been identified by Jane Doe as possible witnesses in her case, without first seeking Specific approval of the Court. ?fth, the Court should direct Epstein?s legal counsel to tile with the Court in advance of the mediation on Tuesday morning a certification that they have explained the requirements of all of these orders with him and have explained to him the serious consequences that could follow from of any additional violations of these orders. 13 CASE NO: OB-CV-80893-MARRNJOHNSON Epstein should be directed not to have any agents attempt to follow or surveil Jane Doe as she leaves the courthouse after the settlement conference on Tuesday or after any other court hearings or trial proceedings. Seventh, this Court should initiate criminal contempt sanctions against Epstein for the violations of its two orders and provide notice to Epstein that the criminal sanctions could include a possible term of imprisonment. Criminal contempt sanctions are appropriate here because ?the criminal contemnor has done that which he has been commanded not to do. The criminal contemnor?s disobedience is past, a completed act, a deed no sanction can undo. Accordingly, the criminal sanction Operates not to coerce a future act from the defendant for the bene?t of the complainant, but to uphold the dignity of the law, by punishing the contemnor?s disobedience.? United Minor Workers of America v. Bagwell, 512 US. 821, 845 (1994) (internal citations omitted). The dignity of the law needs to be upheld; this Court need to act to insure Epstein understands that, despite his vast wealth, he remains equal to everyone else in the eyes of the law. in short, this Court needs to stop Epstein from flouting its orders and intimidating Jane Doe; Because the contempt took place outside the presence of the Court, the Court should proceed in nonsummary fashion. See Fed. R. Crirn. P. 42(a); United States v. Baldwin, 770 F.2d 1550, 1553 (11tln Cir. 1985). The procedures for suchnonsummary criminai contempt are well settled. As the Eleventh Circuit has explained, federal court may punish contemptuous conduct that occurs outside its presence only after giving notice of the essential facts constituting the charged criminal contempt, 14 CASE NO: requesting that the contempt be prosecuted by an attorney for the government. and affording other procedural protections.? Romero v. Drummond 00., inc, 480 F.3d 1234, 1242-43 (1 Cir. 2007). The Court should therefore begin the process by referring this matter to the U.S. Attorney's Of?ce for the Southern District of Florida or, if that office declines to pursue the matter, such other attorney as may be appropriate. See Fed. R. Crim. P. Eighth, because Epstein?s actions appear to implicate possible witness tampering, in violation of 18 U.S.C. 1512(b), and possibly other federai offenses, the Court should additionally refer this matter to the US. Attorney?s Office for the Southern District of Florida for a criminal investigation. mg, the Courtshould refer this matter to Palm Beach Circuit Court Judge Deborah Dale Pucillo?s criminai division presiding over Epstein?s criminal probation for consideration by her of whether Epstein has violated her order as well. mm, the Court should refer this matter to Epstein?s probation officer for determination of any violations of his probation. Eleventh, the Court should request that Epstein pay a fine to Jane Doe?s counsel in the amount of $18,000 to cover any and ail costs associated with relocating Jane Doe and keeping her safe through her trial date. CONCLUSION The Court should hold a hearing on an emergency basis, find Epstein to be in contempt of the Court?s orders, and impose sanctions and take other steps as outlined 15 CASE NO: OHNSON by Jane Doe to secure her safety and to permit her to return to her home without harassment by Epsteio. We respectfully request this Court to seat this Motion and all responses be SEALED. DATED: Julv 2, 2010 Bradley J. Edea?z?ds FARMER, JAFFE, EDWARDS, FISTOS 8 LEHRMAN, PL. 425 North Andrews Avenue, Suite 2 Fort Lauderdele, Florida 33301 Telephone (954) 524?2820 Facsimile (954) 524?2822 Florida Bar No.: 542075 Email: brad@pathtojustice.com and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801685-5202 Facsimile: 801-585-8833 E-Mail: cassellp@iaw.utah.ede CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 2, 2010 i electronically filed the foregoing document with the Cierk of the Court using I also certify that the foregoing document is being served this day on ail parties on the attached Service List in the manner speci?ed, either via transmission of Notices of Electronic Filing generated by or in some other authorized manner for those parties who were: ?giigothorized tom receive electronicatly filed Notices of Electronic Filing; -- ?1 ?77m ?~12 Bradley J. Edwards . 16 CASE. NO: Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Jqoldberqer@aqua.com Robert D. Critton, Esq. Isidro Manual Garcia isidroqarcia@bellsouth.net Michael Jamess Pike Pau! G. Cassell cassellp?law.utah.edu 17' UNITED STATES COURT Southern District of Florida Case Number; JANE DOE Plaintiff v. JEFFREY EPSTEIN Defendant OF EMERGENCY i hereby certify that, as a member of the Bar of this Court, have carefuliy examined this matter and it is a true emergency. 3 further certify that the necessity for this emergency hearing has not been caused by a lack of due diligence on my part, but has been brought about onty by the circumstances of this case. The issues presented by this matter have not been submitted to the Judge assigned to this case or any other Judge or Magistrate Judge of the Southern District of Florida prior hereto. I further certify that have made a bona ?de effort to resolve this matter without the necessity of emergency action. - Dated this 2 day of JULY 2010 Signature as?) Printed Name: BRADLEY J. EDWARDS, ESQ Fiorida Bar Number: 543075 Teiephone Number: .. .. wwmw? ww?uwmmeMw?nmn FOR OFFICE USE ONLY hereby certify that the Judge assigned to this Case is unavailable for this emergency(a copy of notification to the Cterk is on file). In accmdance with Local Ruie 3.7, the Honorable as randomly drawn from the Emergency Wheel. i hereby certify that the Judge randomiy assigned to this emergency is unavailabie due to (A copy of noti?cation to the (Stark $5 on tiie). tr: accordance with Local Rule 3.7, the Honorabie was randomly drawn from the Emergency Wheel. Dated this day of 2O STEVEN M. LARIMORE Court Administrator - Clerk of Court By: . Deputy Clerk UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. IN RE PLAINTEFF JANE EMERGENCY MOTION FOR AN EXPANDED PROTECTIVE ORDER AFFIDAVIT 0F MICHAEL FISTEN l. I am an investigator licensed by the State of Florida to conduct investigations and i am employed by the law firm of Farmer Ja?e Weissiog Edwards Fistos and Lehrmau. One case on which I am working is Jane Doe v. Je?irey Epstein, No. 08~80893, currently pending in the U.S. District Court for the Southern District of Florida. Before being a private investigator, I spent thirty years in south Florida as a law enforcement of?cer with a majority of that time investigating homicides, robberies and organized crime. I retired with the rank of Lieutenant, with my last three years assigned to the Miami Field Division of the Federal Bureau of Investigation Joint Terrorist Task Force. 2. On Thursday the 1st Day of July 2010 your Affiant received a ?antic telephone call ?om Jane Doe that she was being followed by a black male driving a silver In?nity wagon. Jane Doe advised your Af?artt that the unknown black male followed her from a retail store. She stated that he made no attempt to hide his presence and clearly wanted her (Jane Doc) to have the knowledge that she was being followed. To confirm this, Jane Doe advised your Af?ant that she pulled off to the side of the road at which time she observed the unknown black male pull behind her and also stop. Jane Doe advised your Af?aut that she then drove to her residential address in unincorporated West Palm Beach County, observing that the unknown black male followed closely behind her the entire distance. Once at her residence Jane Doe advised your A?iant that the unlmown black male parked almost directly across form her residence. Jane Doe advised that she was in fear for her safety and the safety of her infant child and grandmother all of which were inside her residence. 3. Jane Doe provided your a?iaat with the Florida license tag number of the vehicle that was followiag her. The vehicle tag number T?Knolz (Exhibiti?) was registered to Thaddeus Knowles a resident of Palm Beach County. Your Af?artt conducted a records search with the Florida Department of Agriculture and discovered that Thaddeus Knowles is a licensed private investigator intern Florida License number CC2800614 (Exhibit?). 4. At approximately 8:00 your Af?ant contacted the Palm Beach County Sheriffs Of?ce and advised them of the situation. They advised that they were responding to the home of Jane Doe to access the situation. They also advised your Af?ant that a private investigator had called the center and advised that he would be on surveillance in the vicinity of Jane Doe?s residence. 5. At 8:05 p.rn., your Af?ant received a call from the Palm Beach Sheriff? 5 Of?ce and advised that they made contact with Thaddeus Knowles and veri?ed that he was a licensed private investigator. The deputy advised your Af?ant that Knowles admitted to him that he was watching Jane Doe, but he would not divulge to the deputy who hired him. The deputy cautioned Knowles not to go near Jane Doe or enter her property. The deputy cleared the scene and authored an incident report under Palm Beach case number ill-095370, although that report has not been obtained yet. 6. At 9:00 your Af?ant contacted Jane Doe who stated that she continued to be in fear for her safety. Jane Doe advised that the investigator is still outside her house and that he had moved closer to her front gate. 7. At 9:45 your Af?ant responded to the residence of Jane Doc to conduct an investigation. Your Af?ant arrived on the scene and observed Thaddeus Knowles parked in his silver In?nity wagon approximately 50 feet north of Jane Doe?s residence. Your af?ant observed Knowles position his vehicle in a manner where he faced the front of Jane Doe?s residence. He made no attempt to conceal his presence which would be the normal course of business for an investigator conducting surveillance. It was obvious to your Af?ant that the manner in which Knowles was positioned it was with the sole intent to convey to Jane Doe that she was being watched. 8. Your A?iant approached Knowles who re?ised to engage in conversation. Your A?iant then photographed Knowles and his vehicle to depict the proximity between his vehicle and the residence of Jane Doe (Exhibitt?i). Your Af?ant was able to clearly see that Knowles was video taping ane Doe?s residence (ExhibitM). 9. Your Af?ant then approached Jane Doe at her residence; she was clearly shaken and was convinced that this was being done at the behest of Jef?ey Epstein. While speaking with Jane Doe, the investigator, Knowles, repositioned his vehicle closer to Jane Doe?s front yard, activated his high beam headlights and preceded to video your Af?ant and Jane Doe (ExhibitiiS). 10. Your A?iant was advised by Jane Doe that the actions displayed by Knowles were so egregious she did not feel safe staying in her own home and was intimidated into abandoning her residence. Jane Doe decided to relocate to alternative living quarters and is in fear of returning to her home and in fear for her family. ILA: approximately .1 1:00 pm, yam Af?am drove Jam? {30% t0 the aitemative living quartera but prim t0 doing so, your af?am' con??onted Knowles. agai?. Yam Af?am idc?ti?ed mysalf? to Knowlm, adviseti him thai was; leaving with: Jane 13063,. that she is in; fear for her. safety and act it} follow us. As: your Af?am: draw away ?mn the msidenm with jam Due, Knowles immediately" started. his "vehicle, initiated a u~'tum and attempt?d' to follow A'lf?an't anti Jan-e Doe. Based on your Af?an?t?s "training and. experienw I was able {0 take evasive driving mneu'vers and {waded any further surveiilanw. I. daclare and?r penalty of parjury? that the faregaing 33 true am} aorrect. FURTHER. AFFIANT SAYETH NAUGHTM Dated this 2?d day of July, 2010.. f? . MiChael Liam]. investigator The: tbregeing- was ELEM day of July, mm- by MICHAEL FISTEN, who is. personally knawn*t??3 . r? )i Mm rpm: P1113915 . Commassmn Expires: KM My}; 3. commesmom it: {313895350 mamas June (32. 2013 {@973 395mm 4 '?x?f?ww .. . .mwwm. ?5 - ma?a IV. - m? MWWM a. a M?x?g?mwm ?.mmg?mmw W?wm . a? ?gs: ?imsa?mw Puma: Assess: System License Numbar I I Expires I I Status ("302300614 OSXBOXZM RENEWAL NOTICE SENT The ?ame and. Wigwam-ac number far this i-?n?ividml i5 restrict-mt} from pub-Iii: retard in. '2nec-nrdance: with Seetian 493.6122, tramwaaim Lam-m None New ?earch #3 .1 EX 'E?i as.? 4mm Ma weway Jane Doe . mm; . r'w 213.5? 8 i 11 V6 Howie EX - #4 #5 W3: DEFENDANT BRADLEY J. ED WARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, 62? al. Case No. 50 2009 CA 040800XWMBAG EXHIBIT THE CERCUIT COURT OF FIFTEENTH JUDICIAL IN AND FOR PALM BEACH COUNTY, CRIMINAL DIVISION STATE v3 CASE NO. 06 CF9454AMB os 9381CFAMB JEFFREY EPSTEIN "Urn" Defendant. @3553 .T if.? oe??.no 23: from IV g~ PLEA CONFERENCE ,Aom . ?Tajif . ?a {3 3* 1% 2:23;} to tho? HONORABLE DEBORAH DALE m. :3 rm APPEARANCES: ON BEHALF OF THE STATE: BARRY E. KRISCHER, ESQUERE State Attorney 401 North Dixia Highway West Palm Beach, Florida 33401 By: LANNA BELOHLAVEK, ESQUIRE Assistant State Attorney ON BEHALF OF THE DEFENDANT: ATTERBURY, GOLDBERGER 250 Australian Avonue South Suite 1400 West Palm Beach, Florida 33401 By: JACK GOLDBERGER, ESQUIRE June 30, 2008 Palm Beach County Courthouse West Palm Roach, Florida-33401 Beginning at 8:40 o'clock, a.m. A. DAMES, OFFICIAL COURT REPORTER REMEMBERED that the following proceedings were had in the aboVe?entitled cause before the HONORABLE DEBORAH BALE PUCILLO, one of the judges of the aforesaid court, at the Palm Beach County Courthouse, located in the City of Weet Palm Beach, State of Florida on June 20, 2008 beginning at 8:40 o?clock, a.m. with appearances as hereinbefore noted, to wit: THEREUPON: MR. GOLDBERGER: Good morning, Judge, Jack Goldberger on behalf of Jeffrey Epstein. THE COURT: Good morning. MR. GOLDBERGER: Your Honor, we are here for a plea conference._ THE Raise your right hand. TBEREUPON: JEFFREY EPSTEIN, after being called as a witnees by the Defense and after being first duly sworn by the Court, was examined and testified as follows: THE DEFENDANT: Yee, ma'am. THE COURT: Is this one case or two? MS. BELOHLAVEK: Two. THE COURTDAMES, OFFICIAL COURT REPORTER o: affidavit in both cases, please? 2 Ms. BELOHLAVEK: There are no PC 3 affidavits. There was originally an 4 Indictment, the second charge was filed 5 ,9 arising out of the booking. It was all 6 testimony presented to the grand jury. 7 THE COURT: Let me see the Indictment 8 then? I 9 I have one Indictment, one 10 Information? 11 MS. BELOHLAVEK: Correct. 12 I THE COURT: So one case is charged by 13 Indictment, one ie charged by Information? 14 MS. BELOHLAVEK: Correct. 15 THE COURT: In case 2006036744 you 16 are charged with procuring a persoo under 17 ;8 for prostitution, a second degree 18 felony, maximum penalty of fifteen years 19 Department of Corrections; minimum, some 20 period of probation. No mandatory minimum 21 apply, is that correct, State? 22 MS. BELOHLAVEK: Correct. 23 THE COURT: And in case number 06 24 9454CF, you are charged with felony 25 solicitation to prostitution, a third A. DAMES, OFFICIAL COURT REPORTER degree felony. punishable by a maximum penalty of five years in the Department of Corrections, and a minimum, probation. No mandatory minimums. correct? MS. BELOHLAVEK: Correct. ITHE COURT: The defendant has no prior criminal record? .MS. BELOHLAVEK: Correct. MR. GOLDBERGER: Yes. Your Honor. THE COURT: You checked the NCIC as well as State recorde? MS. BELOKLAVEK: Yes. THE COURT: And the guideline score sheet I have before me ehowe 21.5 months in the Department of Correctione ae the lowest permissible prison sentence i? months. Both sides agree to the preparetion of the guideline score sheet? MR. GOLDBERGER: We so agree, Your, Honor. MS. BELOHLAVEK: Yes. THE COURT: What is proposed ?m it goes on for pages. MR. GOLDBERGER: Your Honor, much of the documentation is acknowledgement by my A. DAMES, OFFKCIAL COURT REPORTER client to status. THE community control, sex offender COURT: I understand. Okay. What ie proposed w? those are the maximums and minimums, Mr. Epetein. What is proposed ie that you will be pleading guilty to felony solicitation to prostitution and procuring a person under 18 for prosecution. you would felonies, MS. THE defendant A PSI would be waived, be adjudicated guilty of both is that correct? BELOHLAVEK: Correct. COURT: And on 06 9454, the to be Sentenced to lZ?months in the Palm Beach County detention facility? jail? MS. THE served. sentenced He's going to do time in the BELOHLAVEK: YES. COURT: With credit for one day And on 08 9381, he is to be to six months in the Palm Beach County jail detention facility, with credit for one day served. And the Six month eentence is to be served consecutive to the 12 month sentence? A. memes, OFFICIAL COURT REPORTER f??all w' 1 I MS. BELOHLAVEK: Correct. 2 THE COURT: Following the six months 3 sentence, the defendant will be placed on 4 12-monthe of community control one. The 5 conditions of the community control are 6 attached hereto and incorporated herein. 7 As a special condition of 8 community control, he's to have no 9 unsupervised contact with minors and the 10 supervising adult must be approved and I 11 would say, pre~approved, approved ahead of 12 time, not after the fact by the Department 13 of Corrections. And you eould mean by that l4 I his community control officer? 15 MS. BELOHLAVEK: Correct. 16 THE COURT: The defendant is 17 designated as a sexual offender pursuant to 18 Florida Statute 943.0435 and must abide by 19 all the corresponding requirements of the 20 statute, a copy of which is attached hereto 21 and incorporated herein. The defendant 22 must provide a DNA sample in court at the 23 time of this plea. Is this the m? and the 24 attachments are the terms and conditions of 25 community control. There are some A. DAMES, OFFICIAL COURT REPORTER I, I a as 1 squigglee on the bottom of the page, what 2 would those squiggles be? 3 I MR. GOLDBERGER: Thank you, Your 4 Honor, thoee are my client?s signature 5 - acknowledging that we have gone over all 6 the oonditione. 7 THE COQRT: One page after the plea 8 sheet that really Spells out the terms and 9 conditions of community control, Florida 10 Statute 948.101, Mr. Epstein, is that 11 squiggle at the bottom your squiggle? 12 THE DEFENDANT: Yes, ma'am. 13 THE COURT: Would those be your 14 initials? 15 THE DEFENDANT: ma'am. 16 THE COURT: Did you read all of that 17 page? 18 THE DEFENDANT: Yes, ma'am. 19 THE COURT: Can you read? 20 THE DEFENDANT: Yes, ma?am. 21 THE COURTeohool? 23 THE DEFENDANT: High school. 24 THE COURT: That's your highest 25 degree? A. DAMES, OFFICIAL COURT REPORTER 1 THE DEFERDANT: Yes. 2 I THE COURT: And is this your 3 I Signature on the plea sheet that reoitee 4 the terms of the plea I juot read? 5 THE DEFENDANT: Yes, ma'am. 6 THE COURT: Did you read that 7 document as well? 8 THE DEFENDANT: Yea, ma'am. 9 THE COURT: You understand once you 10 do your 12 monthe followed by your oix 11 months all in the Palm Beach County jail 12 you will then be put on community control 13 which involvee having an electronic monitor 14 attached to you and 15 MR. GOLDBERGER: Actually Your Honor, 15 the agreement of the partiee is to, it's 17 community control one which is not monitor. 18 THE COURT: Oh, community contxol 19 one, is that Spelled out in here? 20 MS. BELOHLAVEK: Yes. 21 MR. GOLDBERGER: Yes, it ie, Your 22 Honor. 23 MS. BELOHLAVEK: He does not fall 24 under the Jessica Luneford Act which 25 requires the bracelet. A. QAMES, OFFICIAL COURT REPORTER 1 THE COURT: Community control two. 2 MS. BELOHLAVEK: Correct. 3 THE COURT: Community control one 4 that would be no electronic monitor? 5 MR. GOLDBERGER: That is correct. 6 THE COURT: Now which of the terme 7 and oonditione of community control one are 8 you incorporating? 9 MR. GOLDBERGER: I can go through 10 them with Your Honor. 11 THE COURT: None of the them appear 12 to be articulated in the plea sheet which 13 ie why I'm asking. 14 MR. GOLDBERGER: These are the 15 standard conditions of community control by 16 statute would apply to anyone that goes on 17 community control and out of an abundance 18 of caution, we simply memorialized those 19 standard conditions in the plea Sheet 20 agreement. 21 THE COURT: The Court shall require 22 intensive eupervision and surveillance for 23 an offender placed on community control 24 which may include but is not limited to 25 specified contact with the parole and A. DAMES, OFFICIAL COURT REPORTER ?1m? 10 probation officer, specified by who? 2 PROBATION OFFICER: Specified by you, 3 Your Honor. 4 THE COURT: I don't see that in the 5 plea sheet. That's why I'm asking the 6 questions. No one has specified how often, 7 how frequently he ie to have contact with 8 his parole and probation officer. 9 Confinement to an agfeed upon residence 10 during the houre away from employment and 11 public service activity, has that been 12 articulated? 13 MS. BELOHLAVEK: I believe 14 Judge McSorley hae a etandard order 15 somewhere on the bench up there regarding 16 this, I?m told by the prosecutor. 17 MS. LENHARDT: Judge, usually this is 18 the probation sheet she hands out to folks. .19 THE COURT: I have seen those 20 sheets I have seen them incorporated in 21 plea agreements which is why I'm asking. 22 MR. GOLDBERGER: I see. 23 THE COURT: Is there some reason you 24 didn't use this particular document in thie 25 case? A. DAMES, OFFICIAL COURT REPORTER a a u. 1 MS. BELOHLAVEK: didn't realize 2 until Me. Lenhardt just told me that Judge 3 McSorley has that. 4 MR. GOLDBERGER: We'd be happy to 5 execute that document, Your Honor. We were 6 we overreacted by just having him Sign 7 off on all conditiens of community control. 8 THE COURT: Well, thie is 9 MR. GOLDBERGER: Ferhape the better 10 practice would be ww ll THE COURT: This is, the reason 12 Judge MoSorley does this which makes 13 ultimate eenee is we're going to be here 14 half the morning if we're going to decide 15 among ourselves now what the 16 MR. GOLDBERGER: That makes sense. 17 THE COURT: I'm not going to leave 18 this just unspecified. 19 MS. BELOHLAVEK: We can take care of 20 that right now if you could give us a few 21 minutes. 22 THE COURT: All right. 23 These are the standard conditions 24 that Judge McSorley normally uses. If you 25 like them, you need to circle the ones that A. DAMES, OFFICIAL COURT REPORTER ?a iwg ?Wp 12 1 apply and everyone must initial them. We 2 will go over it. If you wish to change 3 you underetand there is quite a bit of 4 latitude given the court in putting 5 somebody on community control. If you 6 agree to some change, let me know, but 7 understand at the outset that I'm a big fan 8 of specificity. 1 want to know what he 9 will be doing for employment. I want to 10 know exactly where_he is going to be living 11 I and I want it on the record now. It can 12' change but it can only change with 13 preapproval by DOC. I want it 14 clear. I don't want the coomunity control 15 officer who gets this case the day he walks 16 out the Palm Beach County to have any doubt 17 or confusion as to exactly what this 18 defendant is supposed to do, where he is 19 supposed to be when, exactly what I am? 20 requesting that officer to supervise. 21 MS. BELOHLAVEK: Absolutely. 22' THE COURT: Okay. 23 MR. GOLEBERGER: We will work on it. 24 Thank you, Youx Honor. 25 -- THE COURT: We will recall that case. A. DAMES, OFFICIAL COURT REPORTER (Brief recess.) MR. GOLQBERGER: Your Honor, we are back on Jeffrey Epstein, actually it worked, we had an opportunity to go through Judge McSorley's conditions of community control and we asked the Department of Corrections representative to aeeist us to make sure we did everything prOperly. They were very helpful and we eXecuted the document. MS. BELOHLAVEK: Yee, and Your Honor, this defendant doesn?t fall under the sex offender probation but we have included special sex offender conditions as part of the community control and they are all circled there. THE COURT: The plea agreement Stated the defendant is designated as a sexual offender pursuant to Florida Statute 942.035. MS. BELOHLAVEK: Correct. But the sex offender probation, the statute is different and only applies to certain offenses and this one was not enumerated. THE COURT: Okay. I want to make A. DAMES, OFFICIAL COURT REPORTER sure both i and the defendant are clear. The sexual offender statute you are referring to in the plea Sheet is the one that requires registration? MS. BELOHLAVEK: Correct. MR. GOLDBERGER: Correot. THE COURT: And we will talk about that. MR. GOLDBERGER: Okay. THE COURT: But it is not the one that requires the special conditions of sex offender probation? MS. BELOHLAVEK: Correct. THE COURT: Now, rather than 948, do you want me to disregard 948? He's read it? MS. BELOHLAVEK: He?s read it. THE COURT: We will leave it in there. But these conditions we are going to go over right now are going to be viewed in my mind, yes, and they have been signed by the defendant and we will go over that in a second as a part of the whole plea. MS. BELOHLAVEK: Correct. THE COURT: So circled are A. OFFICIAL COURT REPORTER e9 15 1 conditions, A, you will remain confined to 2 your residence except one half hour before 3 and after your approved employment, 4 community service work or any other 5 activity approved by your probation 6 officer. 7 B, you will maintain an hourly '8 - accounting of all your activities on a 9 daily log which you will submit to your 10 supervising officer upon request. 11 My understanding about the daily 12 log, maybe I'm juet confused from other 13 cases I've heard, ie the daily log ie a 14 weekly log, I guees it is submitted ahead 15 of time, is that correct? l6 PROBATION OFFICER: That is correct, 17 Your Honor. 18 THE COURT: So part A, where he has 19 to stay in his residence except for one 20 hour before and after the approved 21 employment, community service work and 22 other activity. All thet'e information 23 that will be recorded in writing and the 24 defendant will have a copy and he will know 25 exactly where he is supposed to be when. A. DAMES, COURT REPORTER ,w gg 5 ?g 16 PROBATION OFFICER: That is correct, 2 Your Honor. 3 THE COURT: As will his supervising 4 probation officer. And then to document 5 that he?s eupposedly done all that he 6 himself will be keeping a daily log? 7 PROBATION OFFICER: That is correct, 8 Your Honor. 9 THE COURT: And the log form will be 10 provided by the department and he will be 11 turning that in every time he meets with 12 I the probation officer? .13 PROEATION OFFICER: That i3 correct, 14 Your Honor. 15 THE COURT: Okay. So that applies 16 and applies. ?Does apply? No. 17 MS. Did I circle 18 COURT: No. made one up, 19 the defendant will be residing at 358 El 20 Brillo Way, Palm Beach, Florida, 33480. He 21 knows now that that's where he will be 22 living when he is released after his 12 23 months and eix months. 24 MR. GOLDBERGER: That is correct, 25 Your Honor. A. DAMES, OFFICIAL COURT REPORTER w? .I i a 3., 1 THE COURT: That's a private 2 residence? 3 MR. GOLDBERGER: That is his home. 4 THE COURT: Does he own the residence? 6 MR. GOLDBERGER: He does, Your Honor. THE COURT: Is there any possibility 8 that he no longer owns the residence? 9 MR. GOLDBERGER: Not anticipated, 10 Your Honor. 11 THE COURT: Okay. Should he not be 12 for whatever reason lswmonthe ie a long 13 time, should he not be owning that 14 residence or able to reside there, he will 15 have the obligation of notifyihg his 16 probation officer prior, and I emphaeize 17 this, prior to his releaee from custody. I 18 assume that the department will be notified 19 prior to, to his release? 20 PROBATION OFFICER: That is correct, 21 Your Honor. 22 THE COURT: And then you would need 23 to send someone to meet with him before he 24 walks out of the Palm Beach County jail and 25 verify his address and employment A. DAMES, OFFICIAL COURT REPORTER information? PROBATEOR OFFICER: That is correct. THE COURT: All address ww I assume all of this to and from work and any other approved activities reetricte him to Palm Beach County, is that correct? PROBATION OFFICER: That is correct, Your Honor. THE COURT: So let's be clear, everything, from the day he welke out occurs in Palm Beach County, is that clear? MR. GOLDBERGER: We underetand, Your Honor. That?s correct. THE COURT: Then the additional condition of his probation, they are not sex offender standard conditions, they are just conditions that are being imposed especially in this case? MS. Correct. THE COURT: They are as follows, you shall submit to a mandatory curfew from 10 p.m. to 6:00 a.m. regardless of any other reetrictione regarding work or approved activity, there will be no exceptions to being at home in house from 10 p.m. to 6 A. DAMES, OFFICIAL COURT REPORTER 19 is that correct? 2 MS. BELOHLAVEK: Yes. 3 THE COURT: If the victim was under 4 age of 18 years which I gather is the case 5 because it's circled, you shall not live 6 within 1000 feet of a echool, day care 7 1 center, park, playground or other place 8 where children regularly congregate. 9 Has Someone verified tha? 358 El 10 Brillo is such a place? 11 MS. BELOHLAVEK: No, but that will be 12 done prior to his release. 13 THE COURT: SO 358 El Brillo will not 14 be approved if it should happen to be one ?15 thousand feet from a school, day care 16 center, park, playground or other place ?w 17 this is rather open. 18 MR. GOLDBERGER: Where children 19 gather. 20 THE COURT: Where children regularly 21 congregate. 22 MS. BELOHLAVEK: Right. 23 THE COURT: The Court knows 358 El 24 Brillo Way is a reeidential neighborhood, 25 are there areas there where children A. DAMES, OFFICIAL COURT REPORTER regularly congregate? MS. BELOHLAVEK: I personally do not know. THE COURT: ?either do I, which is why I'm aeking. Has that been investigated? MR. GOLDBERGER: We have done our due diligence, for what it?s worth, there is a residential street. There are not children oongregating on that street. We think the address appliee, if it doesn't, we fully recognize that he can?t live there. THE COURT: Okay. is, you shall not have any contact with the victim, are there more than one Victim? MS. BELOHLAVEK: There's several. THE COURT: Several, all of the victims. So this should be plural. I'm making that plural. You are not to have any coataot direct or indirect, and in this day and age I find it neceseary to go over exactly what we mean by indirect. By indirect, we mean no text no ewmail, no Face Book, no My Space, no telephone calls, no voice mails, no A. DAMES, OFFICIAL COURT REPORTER .ktmummessages through carrier pigeon, no messages through third parties, no hey would you tell so and so for me, no having a friend, acquaintance or stranger approach any of these victims with a message of any sort from you, is that clear? THE DEFENDANT: Yes, ma'am THE COURT: And then it states, unless approved by the victim, the therapist and the sentencing court. Okay. THE DEFENDANT: I understand. THE COURT: And the sentencing court. So, if there is a desire which, I would think would be a bit strange to have contact with any of the victims the court must approve it. MS. BELOHLAVEK: Correct. THE COURT: If the victim was under the age of 18, which was the case, you shall not until you have successfully attended and completed the sex offender program. So, is this sex offender program becoming a condition of probation? MS. BELOHLAVEK: That ie not. I don?t believe I circled that one. A. DAMES, OFFICIAL COURT REPORTER THE COURT: You did. MR. GOLDBERGER: That's a mistake on our part. Actually the statute that he is pleading guilty to doee not require the-~~ THE COURT: understand that, but you circled it. MS. BELOHLAVEK: I apologize, that one is not. He has already been in treatment with a private THE COURT: Which you find to be an adequate eubstitute for sex offender program? MS. I it is not required and based upon the evaluation and my contact with that doctor, I don't believe it's neceesary at this point. THE COURT: Has that been I assume you have a law degree and do not have a in a or MD in MS. BELOHLAVEK: That is correct, I don't. THE COURT: So it is just your I I judgement MS. BELOHLAVEK: Correct. THE COURT: me that his treatment A. DAMES, OFFICIAL COURT REPORTER MK 1.: I a 23 with some fancy private or 2 in his cage is okay? 3 MS. BELOHLAVEK: That is correct. 4 THE COURT: So you are not imposing 5 6 MS. Correct. 7 THE COURT: F, if the victim was 8 under the age of 18, you shall not work or 9 . play or as a volunteer in any school, day 10 care center, park, play ground or other 11 place where children regularly congregate, 12 is that understood? l3 THE DEFENDANT: Yos, ma?am. 14 THE COURT: Children will be defined 15 as anyone under the age of 18. There are a 15 lot of places where children regularly 17 congregate. What kind of work do you do? 18 THE DEFENDANT: Banking. 19 THE COURT: Here in Palm Beach 20 County? 21 THE DEFENDANT: Virgin Islands, 22 ma'am. 23 THE COURT: You understand you will 24 not travel from Palm Beach County for the 25? duration of this? A. DAMES, OFFICIAL COURT REPORTER -. a 24- 1 THE DEFENDANT: Yes, ma'am. 2 MR. GOLDBERGER: Your Honor, I?m 3 sorry to interrupt, we do cover the 4 employment later in the agreement as to 5 what he is going to be doing during the one 6 year that he is on community control. 7 THE COURT: Okay. And let me 8 condition G, which is circled, unless 9 otherwise indicated in the treatment plan 10 provided by sexual offender treatment 11 program. l2 MR. GOLDBERGER: That?s not in there. 13 I THE COURT: Is that what you want? 14 MS. BELOHLAVEK: 15 THE COURT: But you do want the, you 16 will not View, own or possess any obscene l7 pornographic 18 MS. BELOHLAVEK: Correct. 19 THE Okay. But are you saying 20 that this therapist can okay'him to own 21 cextain pornographic material? 22 MS. BELOHLAVEK: No, not at all. 23 MR. GOLDBERGER: No, Your Honor. 24 THE COURT: Would be really helpful 25 if people read these things before they A. DAMES, OFFICIAL COURT REPORTER signed them thoroughly. Unlees otherwise indicated in the treatment plan. I'm just going to strike out, provided by the sexual offender treatment program. Is that what you intend, that his therapist can MS. BELOHLAVEK: No. THE COURT: No? MS. BELOHLAVEK: NO. THE COURT: Unless otherwiee indicated. MR. GOLDBERGER: The parties have agreed that'during the period that he is cannot be THE COURT: Condition will now read, you ehall not View, own, any obscene, pornographic or sexually stimulating visual or auditory material including telephonic, electronic media, computer program or computer services that are relevant to your deviant behavior pattern. And who is going to enforce that? MS. BELOHLAVEK: The community control officer. THE COURT: A. DAMES, OFFECIAL COURT i 26 1 MS. BELOHLAVEK: They have the 2 obligation and included in there for 3 warrantiese eearch to check at any time his 4- home, hie computer, anything he has contact 5 with. 6 THE COURT: And do they regularly do 7 that? 8 PROBATIOR OFFICER: Yes, ma'am. 9 THE COURT: Since we have the 10 pleaeufe of having someone from the 11 Department of Corrections here. 12 Okay. H, you shall submit two 13 epecimens of blood to the Florida 14 Department of Law Enforcement to be 13 reoietered in the DNA data bank. 16 J, you shall submit to a 17 I I warrantlees search by your probation 18 officer or community control officer of 19 your person, residence or vehicle. 20 where is the 21 MS. BELOHLAVEK: That was under the 22 original part, not under the sex offender 23 one. 24 THE COURT: Okay. Defendant to have 25 contact with the community control officer A. DAMES, OFFICIAL COURT REPORTER minimum one time a week. Defendant to work at Florida Science Foundation, 250 Australian Avenue, West Palm Beach, Florida. Is that volunteer work or work for pay? MR. GOLDBERGER: It is a 501C corporation that he has formed, Your Honor, that will be doing charitable work. THE COURT: That he has formed? MR. GOLDBERGER: Yes. THE COSRT: What exactly is Florida Science ?oundation? MR. GOLDBERGER: Do you want to explain? THE DEFENDANT: It funds science programs around the state and the country. THE COURT: How long has it been in existence? THE DEFENDANT: Fifteen years. THE COURT: How many programs has it funded? THE DEFENDANT: Numerous, more than 50. THE COURT: What is your position with the organization? A. DAMES, OFFICIAL COURT REPORTER THE DEFENDANT: President. THE COURT: IS there a board of directors? THE DEFENDANT: Yes, ma'am. THE COURT: Who?s on the board of directore? THE DEFENDANT: Two attorneye. THE COURT: What exactly do you do? THE DEFENDANT: I'm an inveetment banker but my THE COURT: No, no, I mean with the science foundation. THE DEFENDAST: We fund science programs THE COURT: I don't want to know what we do, I want to know what you do. How often are you there? THE I'm there every day, I research, I take in people who want to make presentations about why they need money for funding medical research, advanced science My background is in physics. I go through all the programs in detail, review the Science work potentiale, I follow through on a daily A. DAMES, OFFICIAL COURT REPORTER besie with what they have been given money to do. THE COURT: Who are some recent grantees? THE DEFENDANT: Harvard University. There is a full program of Evolutionary Dynamics, Neuro Science Institute of California, the Physics Instioute, MIT. THE COURT: Do you ever have occasion to deal with anyone under the age of eighteen? THE DEFENDANT: Not very often. It is, if someone is in college sorry. THE Right, that's why I?m aeking the question. THE DEFENDANT: Most of the people I fund are all usually profeesors. THE COURT: Thank you. You understand that you can?t have contact with anyone if this organization, do they ever have any involvement with high schools? THE DEFENDANT: No, ma?am. THE COURT: Students or teachers? THE DEFENDANT: No, ma?am. A. DAMES, OFFICIAL COURT REPORTER .K?g 3o 1 THE COURT: Okay. 2 MS. BELOHLAVEK: Those are 3 duplicates, you will see those are the same 4 as the ones on the previous page, however, 5 it was reproduced. 6 THE COURT: The next condition, you 7 ehall maintain a driving log. You Shell 8 not drive a motor vehicle while alone 9 without prior approval of your supervising 10 officer. 11 If there was Sexual contact, you 12 shall submit to at probationer's or 13 community controllee'e expense an HIV test 14 with results to be released to the victims, 15 victim's parent or guardian will be 16 I victims, plural. Has that been done? 17 MR. GOLDBERGER: Not yet. 18 THE COURT: Do we have a time frame 19 . on that? I would think ASAP might be good 20 on something like that. 21 MS. BELOHLAVEK: I believe they can 22 actually do that at the jail. 23 THE COURT: At hie expense? 24 MS. BELOHLAVEK: Yee. 25 THE COURT: I would request that that A. DAMES, OFFICIAL COURT REFORTER DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISP TED FA TS Epstein v. Edwards, 6! :22. Case No. 50 2009 CA EXHIBIT QQ .SUBPOENA TO DAILY NEWS AND UNITED STATES DISTRICT - SOUTHERN DISTRICT. oi?- IN RE To QU-ASH CASE No. 10 Mass GEORGE RUSH AFFIDAVIT - I 1. I am ah htvlestigator empioyediby the lawl??rmio'f Farmer affe Iwe'iss'ihg? Edwards-i I Fistos and Lehman who has been assigned to work on the ease'broaght by Jane Doe, seeking compensation for damages in?icted-on her by .Ie'f?ey Epstein. The case is Jane Doe effr?ey Epstein,? No; 08480893, and 'is currently pending in the District Court for the-Southern District of Before being a private iavestigator, I spend'thirty years in south Florida as a lave- enforcement of?cer.' I 2. ?In'puirsuit of information related. to the litigation against Jeffrey Epstein I had a' - - Conversation with George RaSh, a reporter With the New York Daily News, on October 22?, 2009. I called Rush after I had become aWare of him 'becaose he was giving infomatioh' toaIi?author about Jeffrey Epstein." The author told me that. this was extremely valuable - infomation. fer the working One. The author said that Raslh?plla-yed-a' tape I -- for the author and-another person that 'was-?a- recording 'of Epstein. I had the-impression that Rush-had played-the entire tape ,forlthis aadler; The ant-ho: said Words? .to-the' effect; I ?My god..- you?ve get this't'ape. HetalkS about the girls.? The adthor?told "me thatither 'admissiohs'm'ade by Epsteinl'ihfthetape would be'very'helpful' to the girls pursuing eiVil suits against Epstein1e: thisp?eyx New etc-?get; I Epstein and himself." . - I ._'Ri1Sh previOuSIjr Brad Edwai'ds] (the attorney fie?reseh'ting'l' I I. Jane Doe) and me concerning" a story he (RuS'h) was writing 'oo'Jeffrey Epstein. Rash - Stated that he compiled 'Very negative inforfnation- on Epstein concerning his exploits 'with' . underage. girls and how he eluded the justice system. Rush stated that he presented the - story to his publisher, who killed the story. He stated that his. publisher, who knows . Jeffrey Epstein, received a call from EpStein which resulted in him killing the story. I 7. Rush agreed to paraphrase his recorded interview of ef?ey Epstein, providing me with the following highlights. He stated that Epstein spoke in a New York accent advising how he came from Brooklyn and became wealthy. He stated that people do not like it when people make good and that was one reason he was being targeted. He stated that he did nothing wrong and went to jail for no reason.? He stated that the time he Spent in jail "was too harsh of a sentence and if the same circumstances would-haw: happened in New York he would have only received 'a $200 ?ne. He continued by making very negative comments concerning Attorney Brad Edwards (the lead" attorney representing . Jane Doe), that he (Brad) was causing all his problems. He referred to Edwards as an. ambulance chaser and his clients such as IL.M..as'a person that came to him as a prostitute - and drug addict.- .He stated that all the girls, suing him are only to get-a meal ticket and the only thing he might have done wrong was to maybe to. cross?the line a little too closely. 'Rnsh advised that Epstein was very upset that Edwards subpoenaed Ghisline Maxwell, referring'to her as a good person that did nothing wrong. 8.- Rush advised that he was going to listen to the tape again and provide me with additional information. Rash had no other information to Ioffer. 9. At no point during this phone call wasl told that the discussion was ?off the record? or otherwise con?dential. I Was never told that there Was any agreement for secrecy. I had the clear impression that Rush knew I would be relay all of the information that he had provided to me to Brad Edwards and other attorneys and investigators working on Jane Doe?s case and other similar cases. - '10. After I interviewed'Rush, I asked for a copy of the tape of Epstein.- He said he had no problem with doing that. He just had to run by his legal people. But later that day, he called me backand said ?legal? would not let him givve me the tape. 11.01:. October. 26,, 2009, when my discussion with Rush was fresh in my mind, I wrote up a report membrializing what Rush had told me. Rush later sent the emails about the Epstein lease,- including forwarding to me an EpStein'h'ad 13.1 have reviewed the af?davit of George Rash, dated April 6, 2010, filed- in this contents of the Epstein interview to. anyOne other than the individuals I have described here Be, Brad Edwards. other individuals who met with Rush in New York], except for Anne Carroll, the attorney representing-me in this proceeding.? This statement is not accurate, as Rush gave me. a: detailed description of 'the Epstein tape recorded. - interView..- I - - - - 14.1 have been extensiver inVolyed 'in the investigation "attempting to- Support Jane I Dee?s Claims againSt Epstein, As. part .of my duties investigating the ease; I have attempted to lecete. all recorded- statements made by Epstein regarding his sexual abuse of Jane?Doe' and other 111111101? girls. haye not been able to. locate anysueh-recordings. Nor do. I currently poSsess?any inveStigative leads for {melting down such recordings, I I declare milder penalty of that the?Iforegoi?g is correct. . FURTHERAFFLANT - . Dated thi? 23?diday of?April, 2010'. - 161%.? lsten, Invesltl-gator? I The foregoing; instrument was .aelmowledg-ed before line this 23?; day of April, 2010 by MICHAEL FISTEN, Who is personally known to me. I I My EXpires: I . .. . gageDEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, er al. Case No. 50 2009 CA OAOSOOXWMBAG EXHIBIT THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. IN RE: JANE DOE, Plaintiff, vs. UNITED STATES OF AMERICA, Defendant. Federal Courthouse West Palm Beach, Florida July 11, 2008 10:15 a.m. The above entitled matter came on for Emergency Petitioner for Enforcement of Crime Victim Rights before the Honorable Kenneth A. Marra, pursuant to Notice, taken before Victoria Aiello, Court Reporter, pages 1~32. For the Plaintiff: Bradley Edwards, Esquire For the Defendant: Dexter Lee, AUSA Maria Villafana, AUSA whmvun-u-a.? w. . -, v, . OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page ?irts?235*?! . raise: viva-91 -n 41.3% wax: 393:?: y: Page 2 2 (Call to Order of the Court). THE COURT: Good morning. Please be seated. This is the case of In Re: Jane Doe, Case 3 Number 08~80736wCiv?Marra. May I have counsel state their appearances, please? MR. LEE: Good morning, Your Honor. May it please the Court, for the United States of America, we have Maria Villafana, Assistant United States Attorney and Dexter Lee, Assistant United States Attorney. And we have seated in the front row FBI 2 Special Agent Becker Kendall and Jason Richards. Thank you, Your Honor. MR. EDWARDS: Good morning, Your Honor. Brad Edwards on behalf of the petitioners. Petitioners are also in the courtroom today. This petition is styled on her behalf. THE COURT: Good morning. All right. We're here on the petitioner?s motion to enforce her rights as a victim under 18 USC 3771. I have received the petition, the government?s response and the victim?s reply, which was filed, I guess, this morning. So, You want to proceed, counsel?. MR. EDWARDS: Yes, Your Honor. You prefer me i at the podium? 2 THE COURT: It is easier for us to hear you. OFFICIAL REPORTING SERVICES, LLC (954) 467~8204 MR. EDWARDS: Your Honor, as a factual background, Mr. Epstein is a billionaire that sexually abused and molested dozens and dozens of girls between the ages of 13 and 17 years old. And through cooperating victims, that evidence can be proven. Because of his deviant appetite for young girls, combined with his extraordinary wealth and power, he may just be the most dangerous sexual predator in U.S. history. This petitioner is one of the victims and she is in attendance today. Another one of Mr. Epstein's victims is also in attendance today. She would be able to provide evidence that she provided~~ that Mr. Epstein paid her to provide him over 50 girls for the purposes of him to the undercurrents of the sexually abuse. Therefore, petition are clear. The plea bargain that was worked out for Mr. Epstein in light of the offenses that he committed is clearly unfair to the point that if anybody looks at the information, it is unconscionable. THE COURT: Well, I mean, is that for me? That?s not my role. That?s the prosecutor's role to apply, would it not? I can't force them to bring criminal charges. What do I have to do with that. MR. EDWARDS: OkayOFFICIAL REPORTING SERVICES, LLC (954) 467~8204 Page 3 4? THE COURT: That may be your opinion, that may be your client's opinion, but I presume that the government is aware that that?s your client's opinion. How does that change anything? MR. EDWARDS: That's my problem. I?m not sure that the government is aware that is petitioner's Opinion and that's why we're here today, just to enforce the victim?s rights under 18 USC 3771, Crime Victims Rights Act, and all we are asking is to order that the plea agreement that has been negotiated in this case~~ THE COURT: How do you know there is a plea agreement? The plea agreement is with the State of Florida, wasn't it? MR. EDWARDS: There was a state charge with one victim that I?m aware of. And the plea agreement as to that one victim was 18 months in the county jail. But along with that, the Palm Beach County Sheriff investigating this case was getting no action out of the local authorities and sent this to the FBI. THE COURT: It was actually the Palm Beach?~ Town of Palm Beach Police, not the Sheriff's Office. MR. EDWARDS: I'm sorry, Judge. And that's why the FBI got involved because Michael Feeter OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 4 an? wrote a scathing letter to the State Attorney about Mr. Epstein receiving preferencial treatment by local authorities. Before the FBI took the case, they went behind the victim's back, and this is our motion, without the victim's input and allowing her the right to meaningfully confer with the government, which is a right that she can assert at this time. They worked out a plea deal where if Mr. Epstein would plead to this other charge regarding another victim in the state court case, they would agree to not prosecute him for all of the federal charges of what they were aware of in federal court.. THE COURT: So that's already apparently taken place, correct? MR. EDWARDS: I don't know if it has taken place. I'm not sure exactly what stage it is in. I know it is supposed to be attached at some point in time to a state court plea. THE COURT: Hasn't he already plead guilty, though? MR. EDWARDS: If he did plead guilty, it is my understanding and belief that the agreement with the federal government and with the U.S. Attorney?s Office wasn't signed on that day. So it is still my Page 5 OFFICIRL REPORTING SERVICES, LLC {954) 467~8204 Anon.? ?fir belief, I could be wrong, but that that agreement hasn't been completed as of this time. THE COURT: So let's assume it hasn?t been completed. MR. EDWARDS: Okay. Then petitioner would like the right to confer with?? THE COURT: You can go in the conference room. We've got the FBI agents, you've got the assigned prosecuting attorney. You have got a conference room. You've got your client. Go and talk. Confer. And then it is up government to decide what to dor correct? MR. EDWARDS: In a way, Your Honor, that's very similar to what happened in In Re: Dean and PB case where there is a plea agreement negotiated and then the victim gets the right to confer. THE COURT: It?s already negotiated. What am I supposed to do? MR. EDWARDS: Order that the agreement that was negotiated is invalid and it is illegal as it did not pertain to the rights of the victim. THE COURT: I can order you into the conference room. Then the government can do what it chooses. It can agree to prosecute or it can agree to going forward with the agreement it had already mun?, "we wuqy-I 31OFFICIAL REPORTING SERVICES, LLC (954) 467~8204 Page 6 Page 7 reached and after consulting your client and in i taking into consideration your client's views, i decide to go forward anyway. I can't make them i prosecute him. I can?tbest, say confer with the victim, consider the victim's input before you make a decision or reconsider the decision you already made in View of the victim's input, if it is possible for you to do that. So if I invalidate the agreement, what's the best you can 3 get? The right to confer? MR. EDWARDS: Exactly. That is all we can. i THE COURT: So why can't you go into the conference room now, take as much time as you feel i you need and confer? MR. EDWARDS: Judge, at this time I'd like to move ore teous to add the victim that's in the courtroom to this conference with the U.S. Attorney's Office. THE COURT: So is that Jane Doe 2 for purposes of this? 5 MR. EDWARDS: Exactly, Your Honor. THE COURT: All right. Let me hear from the government then. i MR. Good morning, Your Honor. May it please the Court. OFFICIAL REPORTING SERVICES, LLC (954) 467m8204 Page 8 Let me update the Court on the status of various matters. The agreement to defer prosecution to the State of Florida was signed and completed by December of 2007. Mr. Epstein's attorneys saught a higher review within the Department of Justice and it took a number of months for that to come to fruition. When it came to fruition, he ended up pleading guilty on June 30, 2008 to two charges in state court, and he was sentenced to a term of incarceration of 18 months, with another 12 months of community control after the completion of his sentence, and he is currently incarcerated as we speak. We have two arguments, Your Honor. First, insofar as the right that they claim under 3771(a)(5), their right to confer in the case, we respectfully submit that there was no case in I federal court and, indeed, none was contemplated if the plea agreement was to be successfully completed, since it contemplated the State of Florida sentence on the criminal charges. So as long as certain conditions were met and certain federal interests were vindicated, the federal government was satisfied that this was an appropriate disposition. Insofar as the best effort, Your Honor, we 1, way ma m. OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 have cited the Attorney General's guidelines. The guidelines do say that you should normally advise victims of plea negotiations and the terms of the plea, but they recognize that there are times when they may not be appropriate or coald cause some harm or prejudice, and they set out six factors which are to be considered, non?exhaustive factors. We have advised, in the declaration of AUSA Villafana that when the subject of having Mr. Epstein concede that he would be convicted of an enumerated offense for purposes of a cause of action under 18 USC 2255, there was a rather strenuous objection from Mr. Epstein's counsel that the federal government was inducing some effort to either fabricate claims, enhance claims or embellish claims and if this agreement ultimately could not be consumated, then we'd have a federal prosecution on our hands, and we did not want to be in a positin of creating additional impeachment material. I can't say that the stand by Mr. Edwards that the arguments of inducement in a subsequent civil action can be made by any criminal victim, that is true. It is another thing for that inducement to have come before the prosecution arguing about the credibility and veracity of the I . - Nywni OFFICXAL REPORTING SERVICES, LLC (954) 467*8204 Page 9 5 "uy?c individual. That was a considerably strong point, in essence, in not discussing those terms with the victims as might ordinarily be done if those considerations did not exist. first, we believe that So, Your Honor, 3771(a)(5) does not apply. THE COURT: Well, what about the language in the statute that suggests that a victim can bring a claim or seek enforcement of his or her rights under the statute before a case is filed? What does that refer to? MR. LEE: Your Honor, we believe that's a venue provision essentially telling an individual if there is no exigent case, there is no case of United States versus So And So, then you seek to enforce your rights, then you can go in and do so in the did court where the offense occurred. This is not saying, necessarily, that rights exist, but if you believe they exist, here is the place where you're going to have to lodge it, and the Court will have to decide. Now, there are certain of the eight rights accorded in 3771(a) that could come up before any charge is filed. For instance, let's say somebody believes that the perpetrator of the crime is going I ?may "32.1w nun-q. am m-w- w. I Page 10 OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 3? 2?51?? Page 11 to try to harm them or threatened them or 2 intimidated them into not testifying or cooperating 3 with the government and, of course, no indictment 4 has been returned. If an individual went to the 5 government and believed that the individual had not 6 acted appropriately, they can go to the district 7 court and say I need to have my rights under 8 3771(a)(1) enforced because those people are 9 threatening me, and the government hasn't done 10 enough. That would be a situation. 11 But we're talking really here about 12 which is the right to consult in the case and we 13 respectfully submit that there is not case until a 14 charge has been filed. 15 THE COURT: Sog?what about the circuit case 16 that was actually pending case had to do with a plea l7 agreement in a pending case? 18 MR. LEE: Yes. The distinction between the 19 Dean case and the instant case, Your Honor, is 20 this. In Dean, they had negotiated with BP 21 Petroleum for a plea and it was always contemplated 22 that there was going to be a federal prosecution. 23 The distinction in this case was that there was 24 already a pending state prosecution and the objective for both sides was to keep it in state urn.? law-man.? rt,? w. 1 -- - OFFICIAL REPORTING SERVICES, LLC (954) 467-8204 Page 12 court and the federal government's objective was to ensure that there were sufficient safeguards in the state court proceedings and concessions made by Mr. Epstein so that federal interests, particularly a cause of action for damages for the victims of the sexual exploitation could be preserved. So that's the key distinction because there was no federal case, there was no federal criminal charge i contemplate so long as the agreement could be reached. THE COURT: All right. So they want me to invalidate your nonwprosecution agreement. MR. LEE: Your Honor, we respectfully submit that 3771 does not grant authority of this Court to do so. In the Dean case, for instance, Your Honor, there was a plea agreement that was entered into and district court, of course, entertained a plea agreement and exercised its judicial discretion in terms of whether to accept it or not. The victims were encouraged to go to district court and say, you know, we didn?t hear about this. We should have, and we object to it for the following reasons. The district court take that into account. There is no plea agreement before this Court. There will be no plea proceedings in this court. That was all done ?w - .u-u uvn'rr Hum-u - an v, 7--.- . he ?vv- OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page in state court several weeks ago. So that's another basis for distinguishing Dean. THE COURT: All right. So is there any point in conferring with these victims? MR. LEE: Your Honor, I will always confer, sit down with Jane Doe and 2, with the two agents and Ms. Villafana. We'll be happy to sit down with them. THE COURT: But it wouldn't make any difference in terms of the outcome. Would maybe give them.the benefit of your explanation of why you did what you did and why you came to the conclusion you did, but it is not going to change your decision in any way. MR. LEE: If it is going to change, it would have to be done at a level higher than mine, Your Honor. THE COURT: What wasww I didn't understand your statement earlier that Mr. Epstein wanted some kind of review of higher authority within the Department in terms of whether or not the federal government was going to insist on preserving any civil claims. MR. LEE: Your Honor, of the agreement was consumated by the parties in December of 2007"wk. ,3 .u . .. .. 13i OFFICIAL REPORTING SERVICES, LLC {954) ?67-8204 gamma: .74, fie-,1. rag-519s. Page 14 Epstein's attorneys wanted a further review of the agreement higher up within the Department of Justice and they exercised their ability to do that. THE COURT: Meaning? Again, I'm trying to understand. He wasn?t happy with the agreement that he had signed? MR. LEE: Basically, yes. And was trying to maintain that the agreement should be set aside or more favorable terms. THE COURT: Now, in terms of You don't dispute that Jane Doe and 2mm First of all, do you have an objection to Jane Doe 2 being added as a petitioner in this case? MR. LEE: No, I don't. THE COURT: I'll grant that request. You don't dispute that they're victims within the meaning of the Act. MR. LEE: It depends to which There is one Jane Doew? Well, there is one individual who is one of Mr. Edwards' clients who we do not believe to been a victim. If these are SN and CW, then we have no objection and I can discuss?~ If I may have a moment, Your Honor. I have been Your Honor, thank you. corrected. We have no objection. - e?w-v-?"rum-1. w?uOFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 15: 1 THE COURT: Okay. 2 MR. LEE: We agree they're victims. 3 THE COURT: Now, what is your position, 4 then, regarding the right of a victim of a crime 5 that is potentially subject to federal prosecution 6 to be, to have input with the prosecutor, your 7 office, before a resolution or decision not to 8 prosecute is made? Do you say that there is no 9 right to confer under those circumstances because 10 there is no "case pending" so any decision not to 11 prosecute, there is no right to confer but that 12 right to confer only is triggered once there is an 1" 13 indictment or an information filed? 14 MR. LEE: That is correct, Your Honor. The 15 Attorney General guidelines which were published in 16 May of 2005 provide that the rights in 377l(a)(l 17 through 8) accrue when a charge is filed in federal l8 court. Now, that my change after the Dean 19 decision. It is under consideration. But that's 20 the government's position. 21 THE COURT: All rightsaying all of the rights?? 23 MR. LEE: Your Honor, some of the rights 24 clearly will only pertain after a charge has been filed. The one that pertains to notice of public . uyum1? -. - OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 16 hearing, public proceedings, though, can't apply until there are public proceedings to be had. Of course, these guidelines are a floor and not a ceiling. They're to be applied with common sense. If somebody?w If charges of assault were being investigated and somebody would come in and say the perpetrator whom you?re investigating is getting ready to indict has been threatening me, following me, and I need help because he or she is going to do something bad to me and try to take care of me before I can testify in the grand jury, this person would not be turned away because a charge hasn't been filed yet. Those guidelines would be applied with common sense. But specifically insofar as a which is the right to consult with the attorney for the government in the case, that would not accrue until there is a days. And, in our View, a case doesn?t come into being until charges are filed. THE COURT: And are there any reported decisions that you are aware of where any court has found a right to confer before charges are filed? MR. LEE: I'm not aware of any, Your Honor. THE COURT: All right. Thank you. MR. LEE: Thank you, Your Honor. .H q, r, My.? n?l1uqh?l1 .. u? .-.-4 ~41. w- Jay. w, . umnr- -. .- .. OFFICIAL REPORTING SERVICES, LLC {954) 467*8204 LON Page 17 3 THE COURT: Counsel? MR. EDWARDS: I would just like to address a that Dean decision. They're asking you that you 3 just simply ignore it because the decision clearly was a decision made because as it is a direct result 3 of a plea deal being worked out prior to the victims i being able to speak. 3 THE COURT: But there was a pending case, though, correct? 3 MR. EDWARDS: As I understand the decisionwmi THE COURT: As I understand the plea deal, it was negotiated prior to charges being filed. Then 2 there was a filed case and then the court had the ability to accept the plea or not. And at that point, you would have the ability to entertain or assert an objection because you weren't consulted about the plea. So there was a proceeding or case in which you can assert a right to confer. How do you do i that before a case is filed? How do you enforce the government or force the government to consult about not filing a case? Every case they have to consult with the victim before they decide not to prosecute? MR. EDWARDS: No, there are limitations. I i think in my reply I refer to the case of U.S. V. OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 18 Rubin where they discussed that very scenario stating there at least has to be criminal charges contemplate by the government before these rights kick in. The rights under and the right to confer and the Dean case clearly states clearly rights under the CBRA apply before prosecution is under way. Logically, this includes the CBRA establishments of a victim's reasonable right to confer with the attorney for the government. And, that's read in the plain reading of the statutes as well. This first case in interpreting_it, I think it's pretty clear the distinction they're making i between and this case. Is it a distinction withoug a real difference in that the court is saying you have this right before the case is filed which is exactly what we are saying. And the result a in that case was they filed the case, later let him plea out to some sweet deal. And in this case, what 3 we have is they avoid that by deciding not to file. Either way, you deprive the victim of their right before making that decision. And the main problem that the court had in Deathr as it states, the victims do have rights when there is an impact and the eventual sent is I Arm-u . ms?, 1 I th-rwhe-yl. ,u'lr?k . ..- . - ".9134 9,muOFFICIAL REPORTING SERVICES, LLC (954) 467~8204 --. 3,51.VVanJyhu .. .- - .--. . .Page 19 substantially less. Whereas here, their input is received after the parties have reached a tentative deal. Well, the government just stated the deal was reached back in October of 2007. However, attached to their response is a letter to my client petitioner, dated January 10, 2008, after the time then counsel just put on the record that the deal was already finalized and it starts, the Opening paragraph talks about whether they wanted the victims to have the right to confer. It says, this case is currently under investigation. This is January 2008. This case has been a process and we request your continued patience while we conduct a thorough investigation. Sounds like the exact opposite of, we want you to come in and confer and let us know what you really feel about this. That is our biggest problem with what has happened here, is that she just wasn?t given a voice and if somebody would have heard her, we believe there would have been a different outcome. To go back into a room right now and talk, after there has already been a plea negotiated without Your Honor ordering that in this case the plea deal needs to be vacated, it is illegal and give her her rights. THE COURT: Well, would you agree or not OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 mm. . 7 +7 ~g menu-1?- haw-9: r3 that Mr. Epstein plead guilty to the state charges probably at least, in part, in reliance upon the fact that he had an agreement with the federal government they weren't going to prosecute? Would you concede that or would would present evidence to that effect? MR. EDWARDS: Of course we would. Yes, of course. Sure. THE COURT: So you agree that Mr. Epstein is now sitting in the Palm Beach County Jail a convicted felon serving 18 months of imprisonment, at least in material part, because he relied upon the government's nonwprosecution agreement? MR. EDWARDS: Yes. I agree that he is sitting there because he is guilty and maybe he took the plea rather than going to trial and being found guilty later in part because of this nonwprosecution agreement that was worked out behind the other backs. victims' I would agree with that. THE COURT: So he accepted the State's deal in part because he knew he had an agreement from the federal government that they weren't going to prosecute. MR. EDWARDS: I presume. I speculate that is true. n' 1 Mamas Ins. r- 1. I Nu" . ?re-wu- y- u, ?RunPage 20 OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 - tau-Va Page 21 1 THE COURT: So you want me now, then, to set 2 aside the government's agreement with him because 3 there was no conferring, yet he has already accepted 4 a plea agreement and is sitting in custody, in part, 5 in reliance on that agreement. I mean, I can undo 6 the agreement in your theory, but how do Mr. 7 Epstein, in a sense, would then be adversely 8 affected by my actions when he acted in reliance 9 upon the agreement. How does that work? i 10 MR. EDWARDS: Certainly, we're only asking 11 you to vacate the agreement. I understand and your 12 point is well taken. and I believe that at that 13 point in time his rights may kick in and say, wait, 14 I was relying on this other deal so I wouldn't be 15 prosecuted for these hundreds of other girls that I 16 molested; that I plead guilty over here to the one i 17 girl that I will admit to molesting. So maybe I can i 18 get to withdraw my plea. But the last thing he wants 19 to do because if he ends up going to trial, I'll be ?rm-1N- at: :03? -: In: 20 in prison for the rest of his life like any other 21 person who ever did this crime would be. He could 22 have that argument, I guess, but still wouldn't 23 really work well for him. 24 THE COURT: All right. So you still think I 25 should set aside the agreement, require the . . OFFICIAL REPORTING ssavicss, LLC (954) 467*8204 Page 22 government to confer? MR. EDWARDS: Work out a plea negotiation i commensorate with the crimes that he committed and that are favorable after they confer with the victims. And it is within their discretion. Of course, they can decide on their own that, hey. I think that the agreement was fair after they have talked with the victims. That could happen. I don't know if a reasonable person that would do that, but it could happen. THE COURT: Apparently. you are not suggesting that that these person are not reasonable. MR. EDWARDS: I'm suggesting they haven't conferred with the victims and that if they took into consideration what these two in the courtroom have to say, I don?t think that we'd be in this same position right now. i THE COURT: They have never spoken to your client about what happened to them? my. (cg, sag-31357}. MR. EDWARDS: They have spoken to them about what happened. Maybe not about what the girls wanted to happen as a result of this case, which is part of conferring to decide that these girls wanted money on their own, which is basically what thisww OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 23 qIb 1 this noneprosecution agreement entails that has 2 language that he'll agree to liability in a civil 3 case. That's not what these girls~w They want 4 justice. They want him in prison now more than 5 ever. The reason they stated they kept this 6 agreement from.the girls and they basically conceded 7 we didn't tell the girls about this agreement, well, 8 the reason is because they would have objected and 9 they wouldn't have been able to sign off on this and 10 the victims would have had a voice, and we?d still ll been going through litigation. The exact problem 12 they tried to prevent, at least in their terms which . 13 was the impeachment of these girls at a later trial, 14 is still available to anybody once the civil suits 15 are filed anyway. 16 They have three arguments. One, we didn't 17 have to talk to theml Two, we did talk to them sort 18 of. And if you don?t buy that, the reason we didn't l9 talk to them, we were trying to prevent them from i 20 being impeached later. None of them trump the 21 victims? rights to confer prior to plea 22 negotiations. That's why, Your Honor, we would ask 23 this Court to enter an order vacating that previous 24 plea agreement as illegal, ask them to confer with 25 the victims once again or for the first time and OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 24 work out a negotiated plea to that accord. THE COURT: Well, all you can ask them to do is confer. I can't ask them to do anything beyond that. I mean, it is up to them to negotiate. MR. EDWARDS: I wouldn't quarrel with that. THE COURT: Now, having learned today, I guess, that the agreement was signed when, in October? MR. EDWARDS: October 2007, I heard. THE COURT: About eight or nine months ago, is there any need to rush to a decision in this matter? The decision has already been made. You filed this, I think, on the presumption that the agreement was about to take place and you wanted to be able to confer beforehand and you weren?t sure what was going on. MR. EDWARDS: Precisely, Your Honor. And I'm holding the letters that are exhibits that they were writing to my client during the year of 2008 telling her how of a process this was going to be and be patient. So, right, I was completely in the dark about when this agreement was signed. THE COURT: In View of the fact that this agreement has already been consumated, and you want me to set it aside, as opposed to something that's .. .. . OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 25% about to occur, would you agree thatwm and I have done this very quickly because of the petition and your allegation that something was about to happen. I'm not blaming you. MR. EDWARDS: I was mistaken. THE COURT: I'm not blaming you for doing that. In View of what you know now, is there any need to treat this as an emergency that has to be decided by tomorrow? MR. EDWARDS: I can't think of any reason in light of what we just heard. THE COURT: Mr. Lee, do you have anything else you wanted to add? Does either side think I need to take evidence about anything? If I do, since this is not an emergency anymore, I can probably find a more convenient time to do that. I don't have the time today to take evidence. But if you do believe that I should take evidence on this issue. MR. EDWARDS: It may be best if I conferred with the U.S. Attorney's Office on that and we can make a decision whether it is necessary or whether Your Honor deemed it was necessary for you to make a decision. THE COURT: I want to know what your r. .. a. .. v. OFFICIAL REPORTING SERVICES, LLC {954) 467w8204 Page 26 respective positions are because it may be something in terms of having a complete record, and this is going to be an issue that's it going to go to the Eleventh Circuit, may be better to have a complete record as to what your position is and the government's is as to what actions were taken. And I don?t know if I have enough information, based on Ms. Villafana's affidavit or I need additional information. And because it is not an emergency, I don?t have to do something quickly, we can play it be ear and make this into a more complete record for the court of appeals. MR. EDWARDS: If there is a time where it is necessary to take evidence, Your Honor is correct in stating that it is not an emergency and it doesn't i need to happen today. And, I will confer with the government on this and if evidence needs to be taken, it be taken at a later date. It doesn't seem like there will be any prejudice to any party. THE COURT: Mr. Lee, do you have any thoughts? You want to consult with Mr. Edwards? 6 MR. LEE: There may be a couple of factual matters that I need to chat with petitioner's i counsel on. If we can reach agreement on those as to what was communicated to CW and what time, if . . you?. *4 ?newOFFICIAL REPORTING SERVICES, LLC (954} 467*8204 they don't dispute that, be necessary to have an evidentiary hearing. But if we can agree, fine or maybe we can't. We'll talk about it. THE COURT: All right. So why don't you let me know if you think an evidentiary hearing is necessary. If there are additional stipulations you want to enter into or supplement what has already been presented, you can do that. Now, the other issue I want to take up, though, is the government filed its response to the petition under seal. And so I want to know why. What is in there that at this point needs to be under seal? Is there anything in there that's confidential, privileged, anything that's different from what you hve said here in Open court that requires that to be sealed? MR. LEE: on our motion to Well, Your Honor, seal was based on two reasons. One that dealt with individuals or minors at the time that the offense occurred. So we were attempting to protect the privacy of those individuals. And also it dealt with negotiations with Mr. Epstein which were in the nature of plea negotiations, which we treat as confidential. Normally, they're not aired out in ww rand-n- {swan-u" lunar-um3.. OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 then we don't think it will- Page 27 5 Page 28 i open court. So those were our two reasons. But I guess the i THE COURT: All right. letters you attached only related to Mr. Edwards' client. MR. LEE: Three of them, yes, Your Honor. THE COURT: Are you prepared, Mr. Edwards, to waive any issues regarding the release of those documents that relate to your clients? MR. EDWARDS: Judge, I think it would be appropriate to redact the names of the clients as they have done. THE COURT: I don't think the names are in there. MR. EDWARDS: I think they're redacted. 2-: mm They're blacked out. I have no problem with i releasing those documents. I?m not sure that's part of the deal. But if it ism? MR. LEE: It is. MR. EDWARDS: Okay. I'll waive. THE COURT: You really don't have any objection to those letters that were sent to them being released to the public? MR. EDWARDS: Of course not, Judge. THE COURT: Then what is there about the i plea agreement or the negotiations that is in the OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 29 response that we really haven't already kind ofww MR. LEE: Your Honor, there was a confidentiality agreement in the deferral of prosecution to the State of Florida. So we were trying to maintain the confidentiality of the negotiations that occurred since we had discussions during those negotiations as one of the reasons why we decided not to tell all of the individuals what was going on. THE COURT: But is that still necessary, that confidentiality or is that kind of moot at this point? MR. LEE: Well, we would like it sealed. Admittedly, what happened today in open court has :11: probably weakened our argument. I don't dispute i that. THE COURT: In your opinion, anything in particular, any paragraph in the response or in Ms. Villafana's affidavit that you think is particularly troublesome that should remain under seal? MR. LEE: May I have a moment, Your Honor? 5 THE COURT: Yes. MR. LEE: Thank you. Your Honor, one aSpect of this in the notification letters that were dispatched to individuals which were attached to Ms. w? .- rm?: a nun 1- - ..-OFFICIAL REPORTING SERVICES, LLC [954) 467*8204 Villafana's declaration, there is a citation to a clause in the agreement that was reached regarding the damages remedy under 18 USC 2255 that was subject to the constitutionality agreement, we believe that should still remain confidential. THE COURT: But hasn't the fact that this provision was part of the agreement again been aired? Is there any secret to it anymore? MR. LEE: The actual text of it has not been aired. The existence of it has been heard but the actual text has not and we believe it should still remain confidential. THE COURT: Okay. Any other argument on that issue? MR. LEE: No, Your Honor. Thank you. THE COURT: Ms. Villafana wants to speak to you. MR. LEE: Your Honor, one item that I?d like to bring to the Court's attention. We had advised Mr. Epstein and his attorneys that if we were to dislose some of the agreement, we would give them advance notice and ability to lodge an objection. We would like an opportunity to do that. THE COURT: All right. But you're not disclosing. It would be by my order that it would - ., 1. . w; --.. w. H. . . Page 30 a: r? was! OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 wa- nvm- - - u. rm. ww mam-u . .- new . tumult-"bum; .f be disclosed. MR. LEE: Yes, Your Honor. And we just would like to register that we believe it should remain confidential. THE COURT: All right. MR. EDWARDS: Your Honor, I don't see any authority for keeping that under seal. THE COURT: I agree. The fact that there is this preserved right on behalf of the victims to pursue a civil action is already a matter of public record; the exact text of the clauseuw I don't see that disclosing the text of the clause when the fact that the clause exists is already a matter of public record. It is not harmful in any way to Mr. Epstein or the government and the letters to the victim that the victim can disclose those letters, they?re not under any confidentiality obligation or restriction and they're free to disclose it themselves if they choose to. So I don't see that there is any real public necessity to keep the response sealed in View of what we discussed already on the record and the victim's ability to disclose those provisions of their own choosing, if they wish. So, in View of the public policy that matters filed in court proceedings should be open to the public and sealing OFFICIAL REPORTING SERVICE 8, LLC (954) 467?8204 Page 31 Page 32 should only occur in circumstances that justife the need to restrict public access, I'm going to deny the motion to seal the response and allow that to be viewed. All right. So I'll let both of you confer about whether there is a need for any additional evidence to be presented. Let me know one way or the other. If there is, we?ll schedule a hearing. If there isn't and you want to submit some additional stipulated information, do that, and then I'll take care of this in due course. MR. EDWARDS: Thank you, Your Honor. THE COURT: All right. MR. LEE: Thank you, Your Honor. MS. VILLAFANA: Thank you, Your Honor. THE COURT: You?re welcome. (Proceedings concluded.) . ..- ??n?rm . p. map-m. . w- u; - OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 Page 33 1 I hereby certify that the foregoing is true a 2 and correct to the best of my ability. 6 8 Victoria Aiello, Court Reporter OFFICIAL REPORTING SERVICES, LLC (954) 467*8204 DEFENDANT BRADLEYJ. EDWARDS ?5 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, er 61!. Case No.: 50 2009 CA 040800XJOCXMBAG EXHIBIT PP Alanfllilershowitz '1525-?Massaehusetts Avenue Cambridge, Massachusetts ?02 1'38 - 617-939?600; - Joseph Reearey Detective I I Palm Beach Police Department I I . 345 S. County Road I . PalmBeach, Fl; 33480 Re: Epstein matter Bear Detective Recarey: - sending you? this lotteries response't'o the s?ribus eclice'm you- raised) at our meeting regarding 'an alleged claim that one of our investigators had . misrepresented himself as a?police of?cerand?in-fect 'ha?d Socially. 'attempteclrto helpersonate you. As I 1101? my client woo-Id eye?r'tolerate'erry such conduct on the pan-"017014: investigators; 'Witha?iat?in ijm?edietely- ofour staff, and'believe that the contemporanewsnotes taken?"by ominiIestigiitof; while attempting to interview i- will. ?provide-?the-necessary nexplahatitm "foe-your thoroughly osti?ed co?stemation. It will also, I believe, provide a more troublesome and telling-illustration ofher characteru' At our meeting, you may advised you that our investigation had discovered at least .one?of' her web sites and am enclosing some - examples. You will nOte-tha?tshe, herself, has the nick-name of ?pimp juice? and the 'site goes on teadetail, "including photos, her apparent fascination with marijuana. This will Come as no surprise to you as ,I?m sure you' are already aware of her recent Palm Beach arrest for bothpossession of marijuanaand drug paraphernalia. The following raw notes Were taken by investigators (one who suffers from a I quite distinct speech. impediment; making, therefore, a truly ifmocent claim of impersonation virtually impossible). Both of them have many years ekperience in conducting defense investigations and debrie?ng witnesses. They are'both well versed in the law and extremely sensitive to any potential allegations of wrongdoing especially from witnesses who may have their own agendas. In this instance, they were instructed 'tO take statement verbatim because we feared that she, an accomplished drama siudent,-might tryto mislead them as successfully as she had misled others. They were instructed to ask detailed questions to ?irther elucidate her previous pronouncements regarding the extreme she?would rich, no, i mean really, really rich?. But as you will read, they sever got a chance to ask even a single question, and could not for a moment he thought cf, as attempting to misrepresent themselves as police of?cers. In fact even though, they are both well prepared and seasoned investigators, they were quite shocked at the overwhelming, non-stop barrage of profanity being hurled at them at a pace and volume from what initially appeared . .o?ly?t'o be a- young woman of slight build and softvdemeahof. The'foll?owinggis an excerpt ?foz'n the {investigator?s report detailing her extremely, short but home the ilesspungent statements; ?1121,2005, my partner, Steve Kiraly, and traV-eled to Grange Park (Jacksonville), Florida, in order to attempt to interview The purpose of haying two .people present was to act as?wime'sses as to whatever might have been'said'by during?the course of our interview. If, wim?her 18 year old boy??iend, William, aad his mother and boyfriend at 2768 Kiowa Avenue, Orange Park, FL. At approximately 6:30pm Hall arrived-1 home. We waited about 1-0 minutes and approaChed the residence. I knocked on the door and a woman, who I now know as Mary Parker, answered" the door. Iltold her that we wouldlil-ce to sgeakzeita She-said mere was no ?there. there Jeep-barked out front. She then said, son-y, you'mean and-I Said yes} - doom. . Smiley]; 1.. my Harrie-is Bill Riley (as I handed her: my-bUSi'ness capo)- is my partnef Steve Kiraly. Weate investigators'from Miami working on behalflof Jeffrey 'lEp'steliri. . . a Idon?t talk to-fu'ckia'g cops and I?m-not talking to you; -[Riley] welre not cops. . You?need-toleave. 1 Get the fuck off my property, leave now. I there is no need'to-be. hostile? We are not cops. we: are just trying to learn. the truth: I I :Get the fuck off my prOperty. What, you?re still stand-log. here? _-[Rlley] were leaving but we don?t understand 3why you?re-so hostile. have no right to be here. I moved. All that shit is behind me in -an0ther world, so get the ?ock out of here. . goes back inside the house and Mary Parker came outside on the porch g-[Ri-ley] Ma?am we?re. not being hostile, We?re here just to learn the truth. [Parker] Look, . is a good girl and she left down there. We?re trying to sort things out now and hire he: anlattomey. [Riley] I understandbut we?re not the bad guys and we?re not ceps. .'[Parker] Okay, but she doesn?t want to talk with you and, you really have no right being here on my property this time of night. - [Riley] I?m sorry we?re here but your 3011, Will, told as weeoul'd come back. [Parker] He doesn?t own this property. I . came-backoutside I You?re still here, get the fuck out. I?m calling the cops if you do-not'leave. [Riley] we?re taI-kiag with Mary and yes, we?re leaving, but all we wwlted was to learn the truth from you about what knowledge you may or may not have.?, As you can gather from this, we believe her-to be the source of your concern. Our other, but we believe, less likely alternative source for the potential misunderstanding could be a close friend of Miss -3 named who goes by the more outlandish self chosen moniker and complete web name of "f Fucking .. . -.. whose web page I also enclose. In 'the event that the sOurce of the allegation =is' neither of the Mo women mentioned above, if you would providemc with the name of the person, or persons, making the claim I will check with the ralevzint investigators 'andfol?low Ithraugh until we aresa?s??d that. we have gotten to the Bottom of mismatch I-trust the information provided in this i?tter is helpful?toi?you as w? all to bring dif?cu? pgrio'd to a ci?se.? :5 - - Sincerely, . My Alan Dershowitz . . Enclosures cc: Barty Kris?her Lanna Belohlavek Daliah Weiss - DRAFT 1/11/07] January W, 2007 Professional Standards Unit Palm Beach Police Department 345 South County Road Palm Beach, Florida 33480 Florida Department of Law Enforcement PO. Box 1489 Tallahassee, Florida 32302~ 489 Detective Joseph .Recarey/ID No: 791 5 Dear We write to request an investigation of the actions of Palm Beach County Detective Joseph Recarey (?Recarey?) in the investigation of Jeffrey E. Epstein (?Epstein?). Detective Recarey?s conduct of the investigation; his presentation of the investigation to the State Attorney; and his conduct subsequent to the bringing of charges against Epstein warrant disciplinary action. As more fully set out below, the misconduct of which we are aware and for which Detective Recarey should be disciplined falls into the following categories: 0 Signi?cant and material omissions of facts known by Detective Recarey that were omitted from the Police Report and/or Probable Cause Af?davits, which facts if known would have had and ultimately did have a material impact on the decision whether and how to proceed. Professional Standards Unit Palm Beach Police Department January W, 200'? Page 2 0 Signi?cant and material misstatements of fact, which misstatements were consistently slanted to support a finding of probable cause. 0 The public release to the press of the Police Report and Probable Cause Affidavits, all of which contained material omissions of fact and material misstatements of fact, and which release was done to cause harm to Epstein and to in?uence state and federal prosecutorial authorities. Below we set out some of the most signi?cant of these actions. Provided herewith is an Appendix containing the underlying documents to which we refer. Tab numbers correspond to the section (I or II) and paragraph number. I. Inaccuracies and Material Omissions 1. The Video Surveillance Equipment Both the Police Report (at 43) and the Probable Cause Af?davits (at 18) make particular mention of the ?discovery? of video surveillance equipment(or ?covert (hidden) cameras? as they are called) in Epstein ?3 garage and library/of?ce. Inclusion of this information insinuates a link between the equipment and the events at issue: the Probable Cause Affidavits note that ?on the ?rst floor of the Epstein residence . . . [Recarey] found two covert cameras hidden in clocks. One was located in the garage and the other located in the library area behind Epstein?s computer. . . . the computer?s hard drive was reviewed which showed several images of Haley Robson and other witnesses interviewed. All of these images appeared to come from the camera positioned behind Epstein?s desk?. (Probable Cause Af?davits at 18). Professional Standards Unit Palm Beach Police Department January m, 2007 Page 4 events are described by ?Call. Detective Recarey cites ?l to support a claim that displayed in the house were photos of and Marcinkova having sex. That is contradicted by the recording Detective Recarey also reported that united that on one occasion she ?continued rubbing his legs, thigh, and feet. . . . [and then Epstein] turned over onto his back. She continued to rub his legs with oils. Epstein touched her breasts and began to masturbate?. (Police Report at 40). That ?episode? appears to be from reports of two separate incidents. However, concerning neither did . make mention of rubbing Epstein?s legs, thighs, and feet or of Epstein turning over onto his back. Nor did she allege that Epstein masturbated while touching her breasts. Detective Recarey also claims (Police Report at 40) that during the sworn statement said ?Epstein had purchased [Marcinkova] from her family in Yugoslavia . . . [and] bragged he brought her to the United States to be his Yugoslavian sex slave?. No such statement is made by- who refers to Marcinkova as Epstein?s ?girlfriend? and refers offhandedly to other women in the home as ?slaves?. Nor did Detective Recarey include -i admission that on one occasion she engaged in sexual conduct with Epstein?s girlfriend as a birthday ?gift? to Epstein. Neither is attention paid in the Probable Cause Af?davits of the fact that maintained a MySpace webpage in which she admitted to various criminal and dishonest acts, including creating false references for her work and her extensive drug use.1 Nor does Detective Recarey include that refused to discuss the disposition of the thousands of dollars she said she was given by Epstein. (Transcript at 3 1). Or that she falsely claimed not to use drugs (id) despite her MySpace entries that scream can ?t wait to buy some weed! Finally, Recarey knew that- was not to be believed when she claimed she had been given a car by Epstein because when preparing the Probablt Cause Affidavits 1 A fleeting reference can be found in the Poiice Report (at 67), however, her marijuana use is only generally noted and no mention is made of her other admitted or prover: dishonest conduct, inciuding the report of her thefts from her employer. Professional Standards Unit Palm Beach Police Department January m, 2007 Page 5 Recarey was in possession of the two month rental agreement, contradicting. statements. Yet -fancifnl claim that she was given a car appears in the Police Report, without reference to the fact that Recarey knew that to be untrue. Nor is the evidence that she engaged in multiple thefts from her retail employer included. 3. Sworn Statement of Juan Alessi. The Police Report and Probable Cause Af?davits detail information purportedly obtained by Detective Recarey from Juan Alessi, a former Epstein house manager. The statement was recorded by a stenographer. A comparison of the transcript and the Police Report and Probable Cause Af?davits reveal signi?cant ditterences. Detective Recarey reports that ?Alessi stated that towards the end of his employment, the masseuses were younger and younger?. (Police Report at 57). Alessi actually stated that for the most part the masseuses did not appear young. (Transcript at 9). Alessi further declared that only ?one? girl was young and in hisjudgrnent she looked ?16 or 17?. Detective Recarey also notes (Police Report at 57) that Alessi claimed ?the bed would almost always have to be made after the massage?. This statement is directly contradicted by other witness statements, which are devoid of any accusation by any woman that any activity ever occurred on the bed. Indeed, Alessi himself actually stated that on a ?few? occasions the bed was unmade after a massage, suggesting Epstein may have taken a nap. (Transcript at 11~12). Alessi ?n?ther explained that even in the absence of a massage he could be called upon to make Epstein?s bed three or four times a day, thus providing an innocent explanation for the frequent bed making. It was in fact Detective Recarey who suggested that ?something else occurred?, and even then, Alessi insisted he did not know of ?something else?: . . or something else, I cannot (Id. There is also no ofAlessi?s burglary of the Epstein residence; his theft of cash and possible theft of a gun, or ofAlessi?s suicidal ideations, all of which made him an unreliable witness. Professional Standards Unit Palm Beach Police Department January 2007 Page 6 4. Broken ?Sex Toys? in Epstein?s Trash. The Police Report details the police ?discovery? in Epstein?s trash of what is described as pieces of?sex toys? and makes the point that these materials corroborate witness statements. Omitted from both the Police Report and the Probable Cause Af?davits is the fact that during the course of executing the search warrant on Epstein?s home, the police realized that a key ?sex toy? was in fact the entirely innocent broken handle of a salad server. Though the ?sex toys? play a prominent role in the Police Report and Probable Cause Af?davits, the Police Report was never amended to re?ect the discovery of this new and highly relevant evidence. 5. Polygraph Examination and Report. The State Attorney was provided with a report of a polygraph examination of Epstein and the polygraph examiner was subsequently interviewed by the State Attorney. The polygraph exam focused on the allegations being made with respect to Ms.? The report con?rmed that no sexual conduct occurred; Epstein never threatened told Epstein she was 18 years old; and Epstein believed -was 18 years old. Though these results were provided to the Police Department and Detective Recarey was given an opportunity to meet with the polygraph examiner, after con?rming that he would attend he inexplicably failed to appear or to send a representative in his place. No information concerning the fact of the exam appeared in the Police Report or the Probable Cause Af?davits. 6. Meetings with the State Attorney. Attorneys for Epstein provided other information to the State Attorney, as well. Though clearly material, virtually none of it was included in the Police Report. For example, at the meeting at which the polygraph expert was made available for questioning, the who conducted a examine of Epstein (and who concluded he was healthy) was also made available to discuss his evaluation. Also provided at the meeting was information concerning MySpace website pro?le, including her false representations that she was 18 and nude and otherwise provocative photos that she chose to use to represent herself to the public- After Professional Standards Unit Palm Beach Police Department January m, 2007 Page 7 initially saying he would be present, Detective Recarey failed to attend or to send a substitute. II. Unreported Criminal Histories and Other Factors Bearing on Credibility of the Witnesses Virtually every witness relied on to support the Police Report and the Probable Cause Af?davits had a background that raised questions as to whether his or her testimony could support a ?nding of probable cause, let alone sustain what would be the State?s burden of proof at a trial. (Indeed, nearly all the witnesses, and certainly those deemed complainants, were friends, which undermines any argument that one witness corroborates another). Though this evidence was given to Detective Recarey, none of it was included in the Police Report, the Probable Cause Affidavits, or released to the public. Jean Ales, Si: former Epstein employee, terminated for cause; found stealing mpneyfrom Epstein; suspected of stealing a gun from Epstein?s home that was never recovered 1n order to commit suicide; repeatedly burglarized Epstein 3 home. 2. a - i father; he had a federal fraud conviction, which was uncovered and turned over to the Detective Recarey during the course of the investigation. served 21 months in federal prison for his offense. This raised questions about the motives in reporting the events. 3. -- stepmother; she had a state conviction for identity fraud w? criminal use of identification information. This information was uncovered and turned over to Detective Recarey during the course of the investigation and similarly raised questions about the motives in reporting the events. 4. a poteritialpvid?tiirn; she had pending charges for possession of marijuana and drug paraphernalia; she ?came forward? as a result of her arrest; she admitted on her MySpace webpage to multiple and frequent drug Professional Standards Unit Palm Beach Police Department January 2007 Page 9 investigating this matter. If you have any questions, please do not hesitate to call. Very truly yours, Professional Standards Unit Palm Beach Police Department January MW, 2007 Page 8 use, lying to get her job and lies about the reason for her termination; a written report detailing her multiple thefts from a former employer; parts of her story were inherently incredible; she made false statements about having been given a car by Epstein; and she refused to state the disposition of the money paid to her by Epstein. 5, g. -. a potential victim; she had multiple runaway complaints lodged by her parents and was assigned to a special high school for drug abusers; she published false representations that she was 18 on her MySpace webpage, along with nude photos of herself, boasts about having beaten someone, details of her drug use and a claim that she was earning in excess of $250,000/year. Nor is there reference to the fact that police had recently responded to a complaint at her home to find her ?under the in?uence of a narcotic?. The State Attorney relies on the professionalism, the integrity and the skill of members of the Palm Beach Police Department to conduct investigations and to report all material facts fairly and accurately. That is essential so that prosecutors can make charging decisions consistent with the facts, the law, the appropriate allocation of limited resources and fit'ibl-ic policy, If police officers hide facts, misstate evidence, or otherwise fail to provide prosecutors with all material information then justice cannot be served. It is our unfortunate but unmistakable conclusion that Detective Recarey failed to discharge his duty in this matter. Moreover, his decision torelegse toggle public the Police Report and Probable Cause Affidavits, particularlywiiv'hen they contained material omissions and misstatements of fact, was intended to harm Epstein, ill served the criminal justice system, and ultimately failed the people of Palm Beach County. an.? . We are prepared to proyidp any other information you may need in . DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et a1. Case No. 50 2009 CA OAOSOOMMBAG EXHIBIT 1of16 JEFFREY EPSTEIN (hereinafter "Defendant"). ELECTRONIC . JULY 7, 2008 STEVEN M. CLERK (LS. 0381'. CT. 8.0. OF UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA RE: JANE DOE, Petitioner. EM my can )1 PETITION FOR ENFORCEMENT OF CRIME RIGHTS ACT 18 U.S.C . SECTION 3771 COMES NOW the Petitioner, JANE DOE (hereinafter ?Petitioner"), by and through her undersigned attorneys, pursuant to the Crime Victim?s Rights Act, 18 U.S.C. Section 3771 and ?les this Petition for Enforcement in the above styled action as follows: 1. Petitioner, an adult, as a minor child was a victim of federal crimes committed by These crimes included sex traf?cking of children by fraud, in violation of 18 U.S.C. l591, use of a means of interstate commerce to entice a minor to commit prostitution, in violation of 18 U.S.C. 2422, as well as wire fraud, in violation of 18 U.S.C. 1343. The Defendant committed these crimes within thejurisdiction of the Southern District of Florida in Palm Beach County, Florida. 2. Upon information and belief, the Defendant is the subject of a federal criminal investigation conducted by the United States of America in the Southern District of Florida. The Defendant has recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit Court for Palm Beach County to various similar state offenses including solicitation of minors for prostitution. 3. Upon information and belief, the Defendant is engaged in plea negotiations with the Of?ce of the United States Attorney for the Southern District of Florida concerning federal crimes which he is alleged to have committed against minor children, including the Petitioner. Such negotiations may likely result in a disposition of the charges in the next several days. 4. Under the CVRA, before any charges are ?led against the Defendant, the I Petitioner has the rights (among others) to notice of her rights under the CVRA, to confer with the prosecutors, and to he treated with fairness. As soon as charges are filed, the Petitioner has the rights (among others) to timely notice of court proceedings, the right not to be excluded from such proceedings, the right to be heard at such public proceedings regarding conditions of release, any plea, and any sentence, the right to confer with the attorney for the government, the right to restitution, and the right to be treated with fairness and with respect for her dignity and privacy. 5. The Petitioner has been denied her rights in that she has received no consultation with the attorney for the government regarding the possible disposition of the charges, no notice of any public court proceedings, no information regarding her right to restitution, and no notice of rights under the CVRA, as required under law. 6. The Petitioner is in jeepardy of losing her rights, as described above, if the - government is able to negotiate a plea or agreement with the Defendant without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defendant and any attendant proceedings. I. THE CRIME RIGHTS ACT MAKES CRIME VICTIMS . . INDEPENDENT PARTICIPANTS THROUGHOUT THE CRIMINAL JUSTICE PROCESS. . In October 2004, Congress passed and the President signed into law the Crime Victims? Rights Act, Pub. L. No. 108-405, 118 Stat. 2251 (codi?ed at 18 U.S.C. 3771). Because this appears to be the ?rst case involving the Act to come before this Court, a bit of background may . be in order. A. The CVRA Gives Crime Victims Rights to Participate in the Criminal Justice Process. Congress passed the CVRA ?to give crime victims enforceable rights to participate in federal criminal proceedings.? Opinion at 14. Congress was concerned that inlthe federal system crime victims were ?treated as Inomparticipants in a critical event in their lives. They were kept in the dark by prosecutors too busy to care enough and by a court system that simply did not have a place for them.? 150 Com. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). - To remedy this problem, Congress gave victims ?the simple right to know whatis going on, to participate in the process where the information that victims and their families can provide may be material and relevant Id. The CVRA gives victims of federal crimes a series of rights, including the right to notice of court proceedings, to be heard at plea and sentencing hearings, and to reasonably ?confer with the attorney for the Government in the case.? 18 U.S.C. 3771(a). Victims also have a ?right of access to the terms of a plea agreement In re Interested Parrot}, 530 F.Supp. 2d 136, 2008 WL 134233 at *7 (D.D.C. 2008). The CVRA also assures victims broadly that they will ?be treated with fairness.? 18 U.S.C. 3771(a)(8). 3 Of course, these rights would be of little use to most crime victims unless they were told about them. To ensure that victims are noti?ed of their rights, the CVRA directs employees of the Justice Department ?and other departments and agencies of the United States engaged in the detection, investigation, or prosecution of crime? to use their ?best efforts to see that crime victims are noti?ed of the rights described [in the 18 U.S.C. 377l(c)(l) (emphasis added).1 B. The CVRA Gives Victims Rights During the Investigation of a Crime. The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit recently reached this conClusion, holding: The district court acknowledged that ?[t]here- are clearly rights under the CVRA that apply before any prosecution is underway.? BP Prods. 2008 WL 501321 at *11. 2008 U.S. Dist. LEXIS 12893. at *36. Legically, this includes the establishment of victims? ?reasonable right to confer with the attorney for the Government.? 18 U.S.C. 3771(al(5). At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea - bargain. - In re Dean, 527 F.3d 391, 394 (5th Cir. 2003). The position that CVRA rights apply before charges have been ?led is consistent with the Justice Department regulations under the CVRA, which explain that government of?cials ?must advise a victim [about their rights under the at the earliest opportunity at which it may be done without interfering with an investigation.? A.G. GUIDELINES FOR AND I 1 Further supporting this requirement is another statute, 42 U.S.C. 10607(c)(3), which directs government officials to provide victims with ?the earliest possible notice of,? among other things, ?the ?ling of charges against a suspected o?ender.? ASSISTANCE 23 (May 2005). And the plain language of the CVRA undergirds this conclusion, as it applies not simply to prosecutors but to government agencies ?engaged in the detection [and] investigation of crime 18 U.S.C. 3771(c)(1)l. Indeed, if there were any doubt, the plain language of the CVRA extends victirns? right to situations ?in which no prosecution is underway.? 18 U.S.C. 3771(d)(3). II. PETITIONER IS A PROTECTED BY THE CVRA. Under the CVRA the crime victim is de?ned as ?a person directly and proximately harmed as a result of the commission of a Federal offense 18 U.S.C. Section 3771(e). I In particular, Defendant called Petitioner when she was a minor over a telephone (a means of interstate communication) requesting that she perform a massage in exchange for payment. As Defendant well knew, that request was fraudulent, as he not only intended to receive a message, but also intended to have her perform sexual acts in exchange for a cash payment to Petitioner. Only when Petitioner arrived at a Defendant?s mansion as directed by Defendant, did Defendant reveal his true purpose of obtaining sexual favors in exchange for payment. This conduct violated 18 U.S.C. 2422, which forbids using a means of interstate commerce to knowingly ?induce? or ?entice? a minor ?to engage in prostitution.? In addition, this conduct was both a use of ?head? to obtain a commercial sex act, in violation of 18 U.S.C 1591, and use of wire communications to perpetrate a ?scheme and arti?ce to defraud,? in violatidn of 18 U.S.C. . 1343. it appears obvious that Petitioner was ?directly and proximately? harmed by these'crimes, thereby making her a victim under the CVRA. It should be emphasized that the CVRA ?was designed to be a ?broad and encompassing? statutory victims? bill of rights.? United States v. I Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah 2005) (quoting 150 Cong. Rec. S4261 (daily ed. Apr. 22, 2004) (statement of Sen. FeinsteinD. Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing'the CVRA generously, the Ninth Circuit observed: ?The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children seen but not heard. The Crime Victims? Rights Act sought to change this by making victims independent participants in the criminaljustice process.? Kenna v. US. Dist. Court for CD. Cal, 435 F.3d 1011, 1013 (9th?Cir. 2006). because the CVRA is remedial legislation, courts should interpret it ?liberally to facilitate and accomplish its purposes and intent.? Elliott. Industries Ltd. Partnership v. BP America Production (30., 407 F.3d 1091, 1118 (10th Cir. 2005) (noting remedial legislation should be ?interpreted liberally to facilitate and accomplish its purposes and inten The CVRA itself suggests this conclusion by requiring that courts must treat crime victims with ?fairness.? United States v. Patkar, 2008 WL 233062 at *3 (D. Haw. 2000) (citing United States v. Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). I Not only must the CVRA as a whole be interpreted liberally, but its de?nition of ?crime. victim? requires a generous construction. After reciting the direct-and-proximate-harm language at issue here, one of the Act?s two eo?sponsors w- Senator explained that ?[t]his is an intentionally broad de?nition because all victims of crime deserve to have their rights protected 150 Cong. Rec. $10912 (Oct. 9, 2004) (emphasis added). The description of the victim de?nition as ?intentionally broa was in the com?se of ?oor colloquy with the other primary sponsor of the CVRA and therefore deserves signi?th weight. See Kenna, 435 F.3d at 1015-16 (discussing signi?cance of CVRA sponsors: ?oor statements). 6 The de?nition of ?crime victims? must thus be construed broadly in favor of Petitioner. She obviously quali?es as a ?victim? under the CVRA. PETITIONER IS ENTITLED TO NOTICE OF HER RIGHTS, AN OPPORTUNITY TO CONFER WITH THE PROSECUTORS AND TO BE TREATED WITH FAIRNESS. Because Petitioner is a ?victim? under the CVRA, she has certain protected rights under the Act. Most important, the Act promises that she will have an opportunity to ?_?confer with the attorney for the Government in the case.? To date, Petitioner has not been given that right. This raises that very real possibility that the Government may negotiate and conclude a plea agreement with the Defendant Without giving Petitioner her protected rights.2 Petitioner is entitled to have this conference _with prosecutors before any ?nal plea agreement is reached. The Fi?h Circuit reached exactly this conclusion in a very recent case. In In re Dean, 52'? F.3d 391 (5th Cir. 2008), the Government negotiated a plea agreement with the well-heeled corporate defendant without conferring with the victirns. When the failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had indeed violated the CVRA. The Fifth Circuit observed: ?In passing the Congress made the policy decision?which we are bound to enforce-that the victims have a right to inform the plea negotiation process by conferring with prosecutors before a plea agreement is reached.? Id. at 394. This Court is obligated to protect the rights of Petitioner. The CVRA directs that any court proceeding involving an offense against a crime victim, the court shall ensure that the 2 021 information and belief, roughly the same crimes were committed against several other young females. These victims, too, are in danger of losing their right to confer under the CVRA. 7 crime victim is afforded the rights described in [the 18 U.S.C. 3771(b)(l). The CVRA also confers on crime victims the right to ?assert the rights described in [the 18 U.S.C. 3771(d)(1). Therefore, this Court has its own independent obligation to intereede and ensure that the Government respects the rights of Petitioner under the CVRA. CONCLUSION The Petitioner requests the intervention of this court to ensure that her rights are respected and accorded, as promised in the Crime Victims? Rights Act. DATED this It]; day of J_uly, 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD ASSOCIATES, LLC I . 1" Brad Edwards, Esquire Attorney for Petitioner Florida Bar #542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954?414-8033 Facsimile: 95 4-924?1 5 30 it CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by United States mail and via facsimile to: ANN MARIE C. VILLAFANA, AUSA, United States Attorney's Of?ce, 500 South Australian Avenue, Suite 400, West Palm Beach, Florida 33401, this 211; day of 11311, 2008. Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 HIS 4? [lien 2 It? ?ltc IS 44 civ cover sheer and the infomtatiott contained herein neither rc lace nor so by local rules ofcottrt. This form, approved by the Judicial Conference 0 the United CIVIL COVER SHEET tne civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OFTHE memo the ?ling and service of pleadings or other spots it tales in September 1914. is requtred for the use oft Cierk FILED by DJ 0.0. ELECTRONIC NOTICE: Attorneys MUST Indicate All lie-filed I. 1:7 ??53 tfount} of Residence of First Listed Plaictit?f ?uff/W? 504 . lN LLS. DEFENIJANTS (C) Attorney?s Name. Address. and Telephone Number} my all?!? a? 5m} ZOE 5? Fkr?'f?n gray-F ?S'Vr?f'i: 2?02- F6 (I) Check County Where Action Arose mot: 3 MONROE :1 onowcno ?rcw BEACH :1 Mum! :3 51.1.06 ll. BASIS OF JURISDICTION 33920 Wine on and? v" 14755- 51. all +65 in One Box Only) 04417139! County of Residence of First Listed Defendant mt v.5. PLAINTIFF cases our) EN CONDEMNATIUN CASES. USE THE OF TRACT LAND 7?65?. 59% JULY 7, 2008 STEVEN M. CLERK Dist: 61?. 5.0. OF Attorneys Knownl in? Man 59 xii"? (For Diversity Cases Only} -e c. M/br??e/ a?ys IE RIVER JOKEECHOBEE HIGHLANDS CITIZENSHIP OF PRINCIPAL art or in One Box rot 9lzintir?i' and One liox for Defendant} 1" (imarnmcot 3 zedernl Question NT DEF DEF Plaintiff ?is. Government Not t: Party) Citizen of This State 3 i 3 Incorporated or l?rincipttl Place 4 3 4 of Business in This 2f: (internment 2 4 Diversity Citizen of Another State 3 3 :3 lncorporatedrmd Principal Place .3 5 5 - r13 A til: I cm m? {indicate Cilicenship of Parties in item itCitizen or Subject ofc 3 3 3 Foreign Nation Foreign tv. NATURE or surr in.? at. Dec ?ex oth CONTRACT FDRFEITURHPENALTY OTHER STATUTES inctrame PERSONAL INJURY FERSONAL IN3U It." 3 6H) Agriculture ?3 422 Appeal 1R USC 153 2.1 dill] Sure Reapportionment no Marie: ate it rplarre ?3 361 Personal injury :l we food a: Drug :3 :1 mt Antitrust I lit: Miller Act 3 315 A Product Med. Malpractice 3 625 Drug Seizure 2i! l5? :1 #30 Barks and Banking 1' ram Negotiahic instrument Liability 3 365 Personal Injury of Property 2: USC mu :3 4350 Commence tilt 3 320 Assault. Libel at l?mducl Liability 3 (till Liquor Laws 11 ?60 Deportation Jr alludgmem Slander 3 368 Asbestos Personal :1 Mo FLR. 8; Trnca 821} Copyrights :3 no Racketeer In?uenced and Muliclre Act :1 330 Federal Employers? Injury Product 2! {:56 Attila: Regs. 3 "30 Farm: Corrupt Organicatlom :52 Reuters- oI?Oel'at Liability Liability 3 660 Occupational RM) Trademark 480 Consumer ("re?ll Srud-rnt Loans 13 3?10 Marine PERSONAL Sufetytliealtlt SI #90 Cattle Sat TV {Etc . Vt terms) 33 545 srit?tc Product 3 Either :l 690 (3th" 2' sro Selective Sonic: 2? $53 Liability Truth irt Lending LAEOR SOCIAL SECURITY 350 sec ?trics'commodnies Bene?ts '3 350 Motor Vehicle 3 389 Other Formats! :1 ll!) Fair Labor Standards 2! 8M HM tassm Exchange Mil Storkholden? Soils 33 3?55 Motor Vehicle Property Damage Act 3 862 Black 1.993823) 375 Customer :1 WEI Product Liability :l 385 Property Damage 21 3'20 Relations 3 863 {405ml} 12 1. SC 5410 it 195 Contrac? Product Liability 3 lot: trite: renew Product Liability 2) 130 LubodM gmt?cportitts 3 864 5520 Title 890 Other Statutory Actions 3* 196 Frat-chit: a Disclosure Act 3 365 3 it?ll REM. PIIGPERTY RIGHTS PMSONEZR PETITIONS 11 1'40 Railway Labor Act FEDERAL TAX SUITS :1 392 Eccrromic Stabilization Mr 2- Eli} 3 44! Voting 3 $19 Motions to Vacate 2 ?9ll()tl1cr Labor Litigation 33 8'30 3 393 Environmental II 21? Forrclowurc 3 I542 Employment Scoteocc :1 79} Empl. Rut. lac. Security or Defendant) :1 ii'M Etrr-rgy Allocation Act II :56 Rent Lens: Eiertment It #43 Housing: Room Corpus: Act 2} IRS Third Party :1 . :t are ?rom to Lam! Accommodation! :3 530 (icrterrtl as us: too-a "5 he?d? ?t 245 Tor Pmclurt Liability 3 can Welfare 3 535 Death 9cnally I :1 930 Anger}! offer.- Determination . . 445 Amer. 462 Naturalization nder qttal access to Justice ?3 .90 Mi 3 540 Mandamus 3t. Other 3 Appaiu?u? M6 Amer. \h Disabilities - .. . . 463 lichens 0m" 3 550 t. ml De?ain? . . 455 Other immigration 950 Constitutionality cfStatc X439 Orher (. it it Rights :l 555 Frtsora omlittort 3 Actions mm onr?n? {Fleet an in One Box Only) Transferred {mm ca? ?0 Dismm - 1 Original :1 2 Removed from ?3 3 Re-?ledv Reinstatcd or 5 d? - :3 6 Multidistrict Cl '1 3? . another . . . Prowcutrg State Court {see below) Reopened (specify) Jud VI. rrAserst. {See instructions recom} page): a) Re~ftied Case Cl YES Cl N0 JUDGE it) Related Cases YES 3 NO DOCKET NUMBER VII. CAUSE OF ACTION ?Wv?f?t by: 41 (Card at 5?61" and 8/ )3 05?: a4 watt-M 0.6 59K a?enses 72> so: 1% we LENGTH OF TRIAL win (lays estimated (for both sides to try entire case) 2? Ciro the Us Civil Statute under which yo}: are ?ling and Write a Brief Statement of Cause {Do not cite statutes unless diversity}. Cnme i: Jae/10.115 5'77) REQUESTED KN ?3 CHECK IF THIS IS A cuss narrow DEMAND 5 CHECK YES only ?demanded in complaint: COMPLAINT: UNDER REEF. 23 JURY ammo: :1 Yes :3 No groove INFORMATION ts ?mus: counsel" 70 mm 1 RE BEST OF MY KNOWLEDGE 180119 OF RECURB F011 OFFICE U98 ONLY RECEIPT it! 7mm? ?aw? i ?e?Gi a?l??fa'i" q. t? 21g 1' "If! .4 uu?i?: 7, i ?mwar ?s it} 1? I: DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, et a1. Case No. 50 2009 CA 040800WMBAG ?zw?i ?ts? dw??ui 3? 2 5123??! w: was . ?2 32w?, .. v. a? .. 9,5313%: 3/ 3:5 no {firz?se zdf?d? Y3. {So ?1 wu . awmm?wamwgw @men553:3? 83%? . A 3.3. 3 My: vuwNM?w?mi . Qua; 331hwy?? 2m? 2 is it; w. Law331.. {333% a? 52% K: . . its awaw?wvwai x. .N mm? cm, ?a$mewwm?mmw y? . $223 a . . i, i 3&3 3.933 .. . 3% . . - . 3? ?wmwiuw Mgan x3 . . 5223. NW3: .zs .3: . 4% . at}? Aha?? an x? 3 a {ma} . 3Y3. WW w. . ?@333?gamma18.69%; . . as.T?Q?ir y, 2; k? :12 Manhattan?s Upper East Side, home to some of the most expensive real estate on earth, exists the crown jewel of the city?s residential town houses. With its lS-foot-high oak door, huge arched windows, and nine floors, it sits onmor, rather, block of ?l?lst Street between Fifth and Madison Avenues. Almost ludicrously out of pro? portion with its four- and ?ve-story neigh~ bors, it seems more like an institution than a house. This is perhaps not surprising? until 1989 it was the Birch Wathen? private school. Now it is said to be Manhattan?s largest private residence. Inside, amid the flurry of menservants attired in sober black suits and pristine white gloves, you feel you have stumbled into someone?s private Xanadu. This is no mere rich person?s home, but a high? walled, eclectic, imperious fantasy that seems to have no boundaries. The entrance hall is decorated not with paintings but with row upon row of indi? vidually framed eyeballs; these, the owner tells people with relish, were imported from England, where they were made for in? jured soldiers. Next comes a marble foyer, which does have a painting, in the man- ner of Jean Dubulfet . . . but the host coyly refuses to tell visitors who painted it. In any case, guests are like pygmies next to the nearby twice?life~size sculpture of a naked African warrior. Despite its eccentricity the house is curi- ously impersonal, the statement of someone who wants to be known {or the scale of his possessions. Its occupant, ?nancier Jeffrey Epstein, 50, admits to friends that he likes it when people think of him this way. A good looking man, resembling Ralph Lauren, with thick gray?white hair and a weathered face, he usually dresses in jeans, knit shirts, and loafers. He tells people he bought the house because he knew he ?could never live anywhere bigger.? He thinks 51,000 square feet is an appropriately large space for some- one like himself, who deals mostly in large conceptsmespecially large sums of money. 302 VANITY Guests are invited to lunch or dinner at the town houseprstein usually refers to the former as ?tea,? since he likes to eat bite? size morsels and drink copious quantities of Earl Grey. (He does not touch alcohol or to- bacco.) Tea is served in the ?leather room,? so called because of the cordovan-colored fabric on the walls. The chairs are covered in a leopard print, and on the wall hangs a huge, Oriental fantasy of a woman holding an opium pipe and caressing a snarling li? onskin. Under her gaze, plates of ?nger sandwiches are delivered to Epstein and guests by the menservants in white gloves. Upstairs, to the right of a spiral stair? case, is the ?of?ce,? an enormous gallery spanning the Width of the house. Strangely, it holds no computer. Computers belong in the ?computer room? (a smaller room at the back of the house), Epstein has been known to say. The of?ce features a gilded desk (which Epstein tells people belonged to banker I. Morgan), 18th?century black lacquered Portuguese cabinets, and a nine? foot ebony Steinway grand. On the desk, a paperback copy of the Marquis de Sade?s The Mjortunes of Virtue was re- cently spotted. Covering the floor, Epstein has explained, ?is the largest Persian rug you?ll ever see in a private homemso big, it must have come from a mosque.? Amid such splendor, much of which re?ects the work of the French decorator Alberto Pin- to, who has worked for lacques Chirac and the royal families of Jordan and Saudi Ara? bia, there is one particularly startling oddi- ty: a stuffed black poodle, standing atop the grand piano. ?No decorator would ever tell you to do tha Epstein brags to visi- tors. ?But I want people to think what it means to stuff a dog.? People can?t help but feel it?s Epstein?s way of saying that he always has the last word. In addition to the town house, Epstein lives in what is reputed to be the largest private dwelling in New Mexico, on an $18 million, 7,500-acre ranch which he named ?Zorro.? ?It makes the town house look like a shack,? Epstein has said. He also owns Little St. James, a 70-acre island in the U.S. Virgin Islands, where the main house is currently being renovated by Edward Tue tie, a designer of the Amanresorts. There is also a. $6.8 million house in Palm Beach, Florida, and a ?eet of aircraft: a IV, a helicopter, and a Boeing 727, replete with trading room, on which Epstein re cently ?ew President Clinton, actors Chris Tucker and Kevin Spacey, supermarket magnate Ron Burkle, Lew Wasserrnan?s grandson, Casey Wasserrnan, and a few oth~ ers, on a mission to explore the problems of AIDS and economic development in Africa. Epstein is charming, but he doesn?t let the charm slip into his eyes. They are steely and calculating, giving some hint at the steady whit of machinery running behind them. ?Let?s play chess,? he said to me, af- ter refusing to give an interview for this arti? cle. ?You be white. You get the first move.? It was an appropriate metaphor for a man who seems to feel he can win no matter What the advantage of the other side. His advantage is that no one really seems to know him or his history completely or what his arsenal actually consists of. He has care? fully engineered it so that he remains one of the few truly baf?ing mysteries among New York?s moneyed world. People know snippets, but few know the whole. ?He?s very enigmatic,? says Rosa Menck- ton, the former (113.0. of Tiffany Co. in the UK. and a close friend since the early I980s. ?You think you know him and then you peel oil~ another ring of the onion skin and there?s something else extraordinary underneath. He never reveals his . He?s a classic iceberg. What you see is not what you get.? ven acquaintances sense a curious dichotomy: Yes, he lives like a ?modern ma~ haraja,? as Leah Kleman, one of his art dealers, puts it. Yet he is fastidiously, al? most obsessively privatemhe lists himself in the phone book under a pseudonym. He rarely attends society gath- erings or weddings or funerals; he considers eating in restaurants like ?eating on the sub? way?mi.e., something he?d never do. There are many women in his life, mostly young, but there is no one of them to whom he has been able to commit. He describes his most public companion of the last decade, Ghislaine Maxwell, 41, the daughter of the late, disgraced media baron Robert Max- well, as simply his ?best friend.? He says she is not on his payroll, but she seems to organize much of his lifewrecently she was making telephone inquiries to find a California-based yoga instructor for him. (Epstein is still close to his two other long? term girlfriends, Paula Heil Fisher, a for? mer associate of his at the brokerage firm Bear Stearns and now an opera producer, and Eva Andersson Dubin, a doctor and onetime model. He tells people that when a relationship is over the girlfriend ?moves up, not down,? to friendship status.) Some of the businessmen who dine with him at his homemthey include newspaper publisher Mort Zuckerrnan, banker Louis Ranieri, Revlon chairman Ronald Perelman, real-estate tycoon Leon Black, former Mi- crosoft executive Nathan Tom Pritzker (of Hyatt Hotels), and real-estate MARCH 2003 1?0 BOTTOM: BY USA HINGE. i. B. personality Donald Trumpmsometimes seem not all that clear as to what he ac~ tually does to earn his millions. Certainly, you won?t find Epstein?s transactions writ? ten about on Bloomberg or talked about in the trading rooms. ?The trading desks don?t seem to know him. It?s unusual for animals that big not to leave any footprints in the snow,? says a high-level investment manager. Unlike such fund managers as George Soros and Stanley Druckenmiller, whose client lists and stock maneuverings act as their calling cards, Epstein keeps all his deals and clients secret, bar one client: bil~ lionaire Leslie Wexner, the respected chair- man of Limited Brands. Epstein insists that ever since he left Bear Stearns in 1981 he has managed money only for billionaires? who depend on him for discretion. was the only person crazy enough, or arrogant enough, or misplaced enough, to make my limit a bil~ lion dollars or more,? he tells peo- ple freely. According to him, the flat fees he receives from his clients, combined with his skill at playing the currency markets ?with very large sums of money,? have afforded him the lifestyle he enjoys today. Why do billionaires choose him as their trustee? Because the prob~ lems of the mega~rich, he tells peo- ple, are different from yours and mine, and his unique philosophy 'is central to understanding those problems: ?Very few people need any more money when they have a billion dollars. The key is not to have it do harm more than any? thing else. . . . You don?t want to lose your money.? has likened his job to that of an architectmmore speci?cally, one who spe- cializes in remodeling: always describe [a billion- aire] as someone who started out in a small home and as he became wealthier had add- one. He added on another addition, he built a room over the garage . . . until you have a house that is usually a mess. . . . It?s a large house that has been put together over time where no one could foretell the ?nancial fu- ture and their accompanying needs.? He makes it sound as though his job combines the roles of real~estate agent, ac? countant, lawyer, money manager, trustee, and con?dant. But, as with Jay Gatsby, and rumor swirl around Epstein. Here are some of the hard facts about Epsteinmones that he doesn?t mind people knowing: He grew up middle?class in Brooklyn. His father worked for the city?s MARCH 2003 parks department. His parents viewed educa~ tion as ?the way out? for him and his young? er brother, Mark, now working in real estate. Jeffrey started to play the piano-mic: which he maintains a passionwat five, and he went to Brooklyn?s Lafayette High School. He was good at mathematics, and in his early 20s he got a job teaching physics and math at Dalton, the elite Manhattan pri- vate school. While there he began tutoring the son of Bear Stearns chairman Ace Greenberg and was friendly with a daugh- ter of Greenberg?s. Soon he went to Bear Stearns, where, under the mentorship of both Greenberg and current Bear Stearns 0.13.0. James Cayne, he did. well enough to become a limited partnerwa rung be? neath full partner. He abruptly departed in 1981 because, he has said, he wanted to run his own business. Thereafter the details recede into shad? ow. A few of the handful of current friends who have known him since the early 19803 recall that he used to tell them he was a UNREAL ESTATE E'om top: the ?leather room? in Epstein?s house, i where ?tea? is served to guests; Epstein at his Zorro ranch in 1992 with his ?best friend,? Ghislaine Mam/ell; Epstein in l9?9. ?bounty hunter,? recov- ering lost or stolen mon? ey for the government or for very rich people. He has a license to carry a ?rearm. For the last l5 years, he?s been running his business, 3. Epstein Co. Since Leslie Wexner appeared in his lifemEpstein has said this was in 1986; others say it was in l989, at the earliestm he has gradually, in a way that has not generally made headlines, come to be ac? cepted by the Establishment. He?s a mem- ber of various commissions and councils: he is on the Trilateral Commission, the Council on Foreign Relations, the New York Academy of Sciences, and the Insti? tute of International Education. His current fan club extends to Cayne, Henry Rosovsky, the former dean of Harm vard?s Faculty of Arts and Sciences, and 303 CEDA. Fashion Awards, SPOILS 0F SUCCESS From top: Epstein?s 70- acre island, Little St. James, in the US. Virgin now calls it Little St. Jeff; Epstein with President Clinton in Brunei, 2002; Leslie Werner with his future wife, Abigail, at the 1990 in New York, 1991. Larry Summers, Harvard?s current presi- dent. Harvard law professor Alan Dersho- witz says, ?I?m on my 20th book. . . . The only person outside of my immediate family that I send drafts to is Jeffrey.? Real-estate developer and philanthropist Marshall Rose, who has worked with Epstein on projects in New Albany, Ohio, for Wexner, says, ?He digests and decodes the information very rapidly, which is to me terri?c because we have shorter meetings.? Also on the list of admirers are former senator George Mitchell and a gaggle of distinguished scientists, most of whom Epstein has helped fund in recent years. They include Nobel Prize winners Gerald 3041VANITY FAIR Edelman and Murray Gell- Mann, and mathematical biologist Martin Nowak. When these men describe Epstein, they talk about ?energy? and ?curiosity,? as well as a love for theoreti- cal physics that they don?t ordinarily ?nd in laymen. Gelleann rather sweetly mentions that ?there are al- ways pretty ladies around? when he goes to dinner ch62 Epstein, and he?s under the impression that Epstein?s clients include the Queen of En- gland. Both Nowak and Dershowitz were thrilled to find themselves shaking the hand of a man named ?Andrew? in Epstein?s house. ?Andrew? turned out to be Prince Andrew, who subsequently arranged to sit in the back of Dershowitz?s law class. Epstein gets annoyed when anyone sug? gests that Wexner ?made him.? had real- ly rich clients before,? he has said. Yet he does not deny that he and Wexner have a special relationship. Epstein sees it as a partnership of equals. ?PeOpIe have said it?s like we have one brain between two of us: each has a side.? think we both possess the skill of seeing patterns,? says Wexner. ?But Jef~ frey sees patterns in politics and finan- cial markets, and I see patterns in lifestyle and fashion trends. My skills are not in in? vestment strategy, and, as everyone who knows Jeffrey knows, his are not in fash~ ion and design. We frequently discuss world trends as each of us sees them.? the time Epstein met Wexner, the latter was a retail legend who had' built a $3 billion em? piremone that now in~ eludes Victoria?s Secret, Express, and Bath Body $5,000 lent him by his aunt. ?Wexner saw in Jeffrey the type of person who had the potential to real~ ize his [Jeffrey?s] dreams,? says some? one who has worked closely with both men. ?He gave Jeffrey the ball, and Jeffrey hit it out of the park.? Wexner, through a trust, bought the town house in which Epstein now lives for a reported $13.2 million in 1989. In 1993, Wex~ ner married Abigail Koppel, a 31-year~old lawyer, and the newlyweds relocated to Ohio; in 1996, Epstein moved in~ to the town house. Public documents suggest that the house is still owned by the trust that bought it, but Epstein has said that he now owns the house. Wexner trusts Epstein so cornpletely that he has assigned him the power of ?du- ciary over all of his private trusts and foun- dations, says a source close to Wexner. In 1992, Epstein even persuaded Wexner to put him on the board of the Wexner Foun? dation in place of Wexner?s ailing mother. Bella Wexner recovered and demanded to be reinstated. Epstein has said they settled by splitting the foundation in two. Epstein does not care that he comes be- tween family members. In fact, he sees it as his job. He tells people, am there to represent my client, and if my client needs protectingwsometimes even from his own it?s often better that people hate me, not the clien ?You?ve probably heard I?rn vicious in my representation of my clients,? he tells people proudly; Leah Kleman describes his haggling over art prices as something like a scene out of the movie Mad Max: Be- yond Thunderclome. Even a former mentor says he?s seen ?the dark side? of Epstein, and a Bear Stearns source recalls a meet- ing in which Epstein chewed out a team making a presentation for Wexner as MARCH 2003 TO BOTTOM: BY USA SARAH KEHEN, SCUM being so brutal as to be ?irresponsible.? One reporter, in fact, received three threats from Epstein while preparing a piece. They were delivered in a jocular tone, but the message was clear: There will be trouble for your family if I don?t like the article. On the other hand, Epstein is clearly very generous with friends. Joe Pagano, an Aspen~based venture capitalist, who has known Epstein since before his Bear Steams days, can?t say enough nice things: have a boy who?s dyslexic, and Jeffrey?s gotten close to him over the years. . .. Jeffrey got him into music. He bought him his first piano. And then as he got to school he had dif?culty . . . in studying .. . so Jeffrey got him interested in taking ?ying lessons.? Rosa Monekton recalls Epstein telling her that her daughter, Domenica, who suf- fers from Down needed the sun, and that Rosa should feel free to bring her to his house in Palm Beach anytime. Some friends remember that in the late 80$ Epstein would offer to upgrade the air? line tickets of good friends by affixing ?rst? class stickers; the only problem was that the stickers turned out to be unofficial. Some- times the technique worked, but other times it didn?t, and the unwitting recipients found themselves exiled to coach. (Epstein has claimed that he paid for the upgrades, and had no knowledge of the stickers.) Many of those who bene?ted from Epstein?s largesse claim that his generosity comes with no strings attached. ?1 meter felt he wanted anything from me in return,? says one old friend, who received a ?rst-class upgrade. pstein is known about town as a man who loves wom- enwlots of them, mostly young. Model types have been heard saying they are full of gratitude to Epstein for ?ying them around, and he is a familiar face to many of the Victo? ria?s Secret girls. One young woman recalls being summoned by Ghislaine Maxwell to a concert at Epstein?s town house, where the women seemed to outnumber the men by far. ?These were not women you?d see at Upper East Side dinners,? the woman recalls. ?Many seemed foreign and dressed a little bizarrely.? This same guest also at- tended a cocktail party thrown by Maxwell that Prince Andrew attended, which was filled, she says, with young Russian mod- els. ?Some of the guests were horrified,? the woman says. ?I-Ie?s reckless,? says a former business associate, ?and he?s gotten more so. Mon? ey does that to you. He?s breaking the oath he made to he would never do anything that would expose him in the MARCH 2003 media. Right now, in the wake of the pub- licity following his trip with Clinton, he must be in a very dif?cult place.? ccording to SEC. and other legal documents un? earthed by Vanity Fair, Epstein may have good reason to keep his past cloaked in secrecy: his real mentor, it might seem, was not Leslie Wexner but Steven Jude Hellen- berg, 57, who, for a few months before the SEC. sued to freeze his assets in 1993, was trying to buy the New Post. He is cur? rently incarcerated in the Federal Medical Center in Devens, Massachusetts, serving a 20~year sentence for bilking investors out of more than $450 million in one of the largest Ponzi schemes in American history. When Epstein met Holfenberg in Lon- don in the 19808, the latter was the char- ismatic, audacious head of the Towers Financial Corporation, a collection agency that was supposed to buy debts that peo? ple owed to hospitals, banks, and phone companies. But Hoffenberg began using company funds to pay off earlier investors and service a lavish lifestyle that included a mansion on Long Island, homes on Man- hattan?s Sutton Place and in Florida, and a fleet of cars and planes. Hoffenberg and Epstein had much in common. Both were smart and obsessed with making money. Both were from Brook? lyn. According to lioil?enberg, the two men were introduced by Douglas Leese, a de- fense contractor. Epstein has said they were introduced by John Mitchell, the late attor? ney general. Epstein had been running International Assets Group Inc. (I.A.G.), a consulting company, out of his apartment in the Solo building on East 66th Street in New York. Though he has claimed that he managed money for billionaires only, in a 1989 dep- osition he testified that he spent 80 per~ cent of his time helpng people recover stolen money from fraudulent brokers and lawyers. He was also not above entering into risky, tax-sheltered oil and gas deals with much smaller investors. A lawsuit that Michael Stroll, the former head of Wil- liams Electronics Inc., filed against Epstein shows that in 1982 received an in- vestment from Stroll of $450,000, which Epstein put into oil. In 1984, Stroll asked for his money back; four years later he had received only $10,000. Stroll lost the suit, after Epstein claimed in court, among oth? er things, that the check for $10,000 was for a horse he?d bought from Stroll. ?My net worth never exceeded four and a half mil- lion dollars,? Stroll has said. Hoilenberg, says a close friend, ?really liked Jeffrey. . . . Jeffrey has a way of getting under your skin, and he was under Hof? fenberg?s.? Also appealing to Hoffenberg were Epstein?s social connections; they in~ eluded oil mogul Cece Wang (father of the designer Vera) and Mohan Murjani, whose clothing company grew into Gloria Van~ derbilt Jeans. Epstein lived large even then. One friend recalls that when he took Cana? dian heiress Wendy Belzberg on a date he hired a Rolls-Royce especially for the oc? casion. [Epstein has claimed he owned it.) In 1987, Holfenberg, according to sources, set Epstein up in the of?ces he still occu? pies in the Villard House, on Madison Av? enue, across a courtyard from the restaurant Le Cirque. Holfenberg hired his new pro? tege as a consultant at $25,000 a month, and the relationship flourished. ?They trav? eled everywhere togethermon Hoffenberg?s plane, all around the world, they were al- ways together,? says a source. Hoffenberg has claimed that Epstein con?ded in him, saying, for example, that he had left Bear Stearns in 198l after he was discovered ex? ecuting ?illegal operations.? Several of Epstein?s Bear Steams contem? poraries recall that Epstein left the compa? ny very suddenly. ?Within the company there were rumors also that he was involved in a technical infringement, and it was thought that the executive committee asked that he resign after his two supporters, Ace Green- berg and Jimmy Cayne, were outnumbered. Greenberg says he can?t recall this; Cayne denies it happened, and Epstein has de- nied it as well. ?Jeffrey Epstein left Bear Stearns of his own volition,? says Cayne. ?it was never suggested that he leave by any member of management, and manage ment never looked into any improprieties by him. Jeffrey said speci?cally, ?1 don?t want to work for anybody else. 1 want to work for Yet, this is not the story that Epstein told to the S.E.C. in 1981 and to lawyers in a I989 deposition involving a civil business case in Philadelphia. In 1981 the Jonathan Harris and Robert Blackburn took Epstein?s tostlmony and that of other Bear Stearns employees in part of what became a protracted case about insider trading around a tender offer placed on March ll, 198l, by the Seagram Company Ltd. for St. Joe Minerals Corp. Ultimately several Italian and Swiss in- vestors were found guilty, including Italian ?nancier Giuseppe Tome, who had used his relationship with Seagram owner Edgar Bronfman Sr. to obtain information about the tender offer. After the tender offer was announced, the S.E.C. began investigating trades in? volving St. Joe at courmuse on men 3::3 VANITY FAIR 305 contains a parody of Affleck and Matt Da? mon making Good Will Hunting II, Ai?eclc says to Damon, ?What do I keep telling you? You gotta do the safe picture, then you do the art picture. Then sometimes you gotta do the payback picture because your friend says you owe him. Then sometimes you got- ta go back to the well.? ?Sometimes you do Reindeer Games,? Damon says derisively. ?That?s just mean,? Al?eck whines. But it?s a pretty accurate description of his career to date. ?Ben takes these franchise properties so he can go and experimen says Harvey Weinstein. ?He believes in trying to stretch himself and not keep doing the same thing,? ob? serves Bruce Willis, who starred with Ai?eck in Armageddon. ?He?s an awesome actor, and I think he?s going to do great things.? Several years ago, in a televised interview on Inside the Actors Studio, Af?eck said that his goal was to make big commercial movies. He has since revised his ambitions. ?That?s an adolescent aspiration, in a way. I?d rather be in movies like Magnolia, which I think is a towering achievement. I?ll con? tinue to act, but I won?t act in a way that requires me to hang my name out there and do a lot of publicity. I?ll do character roles and focus on writing and directing. It doesn?t require the same kinds of sacri- lice, in terms of quality of life and person? al life, and it?s a more holistic approach to the process. It?s become increasingly frus- trating for me to have my role in the story? telling process limited to one character. You have to be respectful and judicious about your input when it?s somebody else?s proje Af?eclc has always impressed colleagues with his voracious appetite for information and skills. ?He has made it a point to learn everything he can about how the business works-?not just the craft of acting, but from the producing standpoint, from the studio standpoint,? says Jon Gordon, exec? utive vice president of production at Mira? max. ?He knows how deals work. It?s what sets him apart. If he wanted to run a studio at some point, he could. He?s about as sharp as they come.? ?leclc is already juggling his acting with screenwriting and such other commit? ments as Project Greenlight, the contest he and Damon started to help launch the ca- reers of young ?lmmakers. A?leck?s friends are certain he?ll be directing soon. ?There?s no question,? Weinstein says. ?Both he and Matt. I think they?re going to rewrite the rules. These guys can ?x anything. There?ll be home runs in both instances.? But there are other thoughts tickling the back of Ai?eclc?s mind as well. A passion? ate liberal, he campaigned for Al Gore, cares deeply about political issues, and is extremely well informed. He entertains him- self by writing imaginary political speeches in his head. He would rather discuss AIDS in Africa than his movie career. When Lopez goes to Al?eck?s mother?s house for dinner, Weinstein reports, .Lo told me that the coriveisation at the table is always about politics-?about government initiatives, educational initiatives, what?s go- ing on in the day.? So is planning to become the lib? erals? answer to Ronald Reagan? He admits that he entertains the thought of someday running for Congress, at least: think there?s a real nobility to public service. It would be fun to run en a platform I really believed in, without any of the kind of compromises people makemwithout being beholden to the win~at~all~costs mentality.? And the invasion of privacy would be nothing new. ?What are you going to say about me that hasn?t already been said? I don?t cheat, I don?t drink, I don?t do drugs, I live a clean life,? Af?ch says, his eyes twinkling. ?He?s only 30 years old,? says Jennifer Todd, who co-produced Boiler Room. ?He still has an enormous amount of time to do things.? Time, and drive. think he?s incredibly hungry,? says Sean Bailey, who founded the media and production company Live- Planet with Affleck, Damon, and Chris Moore. ?1 think the guy has very grand aspirations. 1 don?t think he?s going to be content with just being a movie star. He knows he has the potential to do very big things.? Such ambitions could be derailed by any number of miscalculations, including a pri- vate life that generates too many sensational headlines, but Al?eck has a clear idea of the ultimate goal. ?On my deathbed, I have to be one who looks back and feels I lived a good and substantial and meaningful life,? he says. In the meantime, however, there?s a wed? ding to plan. Jeffrey Epstein CONTINUED FROM PAGE 305 Bear Stearns and other ?rms. Epstein resigned from Bear Steams on March 12. The S.E.C. was tipped oil? that Epstein had information on insider trading at Bear Stearns, and it was therefore obliged to question him. In his SEC. testi? mony, given on April 1, 1981, Epstein claimed that he had found ?offensive? the way Bear Stearns management had handled a disci? plinary action following its discovery that he had committed a possible ?Reg viola~ tionmevidently he had lent money to his clos? est friend. (In the 1989 deposition he said that he?d lent approximately $20,000 to Wan ren Eisenstein, to buy stock.) Such an action could have been considered improper, al? though Epstein claimed he had not realized this until afterward. According to Epstein, Bear Stearns man- agement had questioned him about the loan around March 4. The duestioners, Epstein said, were Michael (Mickey) Tamopol and MARCH 2003 Alvin Einbender. In his l989 deposition Ep- stein recalled that the partner who had made an ?issue? of the matter was Marvin David? son. On March 9, Epstein said, he had met with Tarnopol and Einbender again, and the two partners told him that the executive com? mittee had weighed the offense, together with previous ?carelessness? over expenSes, and he would be ?ned $2,500. ?There was discussion whether, in fact, I had ever put in an airline ticket for some one else and not mySelf and I said that it was possible, since my secretary han? dles my expenses,? Epstein told the S.E.C. In his 1989 testimony he stated that the ?Reg incident had cost him a shot at partnership that year. What the S.E.C. seemed to be especially interested in was whether there was a con- nection between Epstein?s leaving and the alleged insider trading in St. Joe Minerals by other people at Bear Steams: Q: Sir, are you aware that certain rumors may have been circulating around your ?rm in con- nection with your reasons for leaving the ?rm? A: I?m aware that there were many rumors. Q: What were the rumors you heard? A: Nothing to do with St. Joe. Q: Can you relate what you heard? A: It was having to do with an illicit affair with a secretary. Q: Have you heard any other rumors suggest- ing that you had made a presentation or com munication to the Executive Committee con- cerning alleged improprieties by other mem- bers or employees of Bear Stearns'? A: I, in fact, have heard that rumor, but it?s been from Mr. Harris in our conversation last week. Q: Have you heard it from anyone else? A: No. A little later the interview focuses on James Cayne: Q: Did you ever hear while you were at Bear Stearns that Mr. Cayne may have trader or in? sider information in connection with St. Joe Minerals Corporation? A: No. Q: Did Mr. Cayne ever have any conversation with you about St. .loe Minerals? A: No. Q: Did you happen to overhear any conversa? FAIR 343 efirey Epstein tions between Mr. Cayne and anyone else re garding St. Joe Minerals? A: No. And still later in the questioning comes this exchange: Q: Have you had any type of business deal? ings with Mr. Cayne? A: There?s no relationship with Bear Stearns. Q: Pardon? A: Other than Bear Stearns, no. Q: Have you been a participant in any type of business venture with Mr. Cayne? A: No. Q: Do you have any expectation of participat- ing in any business venture with Mr. (Jayne? A: No. Q: Have you had any business participations with Mr. Theram? A: No; nor do I anticipate any. Q: Mr. Epstein, did anyone at Bear Stearns tell you in words or substance that you should not divulge anything about St. Joe Minerals to the stat? of the Securities and Exchange Com- mission? A: No. Q: Has anyone indicated to you in any way, either directly or indirectly, in words or sub- stance, that your compensation for this past year or any future monies coming to you from Bear Stearns will be contingent upon your not divulging information to the Securities and Exchange Commission? A: No. Despite the circumstances of Epstein?s leaving, Bear Steams agreed to pay him his annual bonuswwhich he anticipated as be- ing approximately 100,000. The S.E.C. never brought any charges against anyone at Bear Stearns for insider trading in St. Joe, but its questioning seems to indicate that it was skeptical of Epstein?s answers. Some sources have wondered why, if he was such a big producer at Bear Stearns, he would have given it up over a mere $2,500 ?ne. Certainly the years after Epstein left the firm were not obviously prosperous ones. His luck didn?t seem to change until he met Holfenberg. ne of Epstein?s first assignments for Hof- fenberg was to mastermind doomed bids to take over Pan American World Airways in 1987 and Emery Air Freight Corp. in 1988. Hoffenberg claimed in a 1993 hearing before a grand jury in Illinois that Epstein came up with the idea of ?nancing these bids through Towers?s acquisition of two ailing Illinois insurance companies, Associated Life and United Fire. ?He was hired by us to work on the securities side of the insurance companies and Towers Financial, supposedly to make a pro?t for us and for the companies,? Hoffen? berg reportedly told the grand jury. He also alleged that Epstein was the ?technician,? ex- 344 coating the schemes, although, having no broker?s license, he had to rely on others to make the trades. Much of Hollenberg?s sub- sequent testimony in his criminal case has proven to be false, and Epstein has claimed he was merely asked how the bids could be accomplished and has said he had nothing to do with the ?nancing of them. Yet Rich- ard Allen, the former treasurer of United Fire, recalls seeing Epstein two or three times at the company. He and another ex- ecutive say they had direct dealing with Ep- stein over the ?nances. And in his deposition of 1989, Epstein stated that he was the one who eXecuted ?all? Hoifenberg?s instructions to buy and sell the stock. He called it ?mak? ing the orders.? He could not recall whether he had chosen the brokers used. To win approval from the Illinois insur- ance regulators for Towers?s acquisition of the companies, Hoffenberg promised to in? ject $3 million of new capital into them. in fact, in his granddury testimony Hoffenberg claimed that he, his chief operating officer, Mitchell Brater, and Epstein came up with a scheme to steal $3 million of the insurance companies? bonds to buy Pan Am and Ern? ery stock. ?Jeffrey Epstein and Mitch Brater arranged the various brokerage accounts for the bonds to be placed with in New York, and I think one in Chicago, Rodman Ren- shaw,? Hoil?enberg reportedly said. Then, said Hollenberg, while making it appear as though they were investing the bonds in much safer ?nancial instruments, they used them as collateral to buy the stock. ?Ep- stein was the person in charge of the trans- actions, and Mitchell Brater was assisting him with it in coordination on behalf of the insurance companies? money,? Hoffenberg claimed at the time. At one point, according to Hoffenberg, a broker forged the documents necessary for a $1.8 million check to be mitten on insurance- company funds. The check was used to buy more stock in the takeover targets. Mean- while, in order to throw the insurance regula? tors off, the $1.8 million was reported as being safely invested in a money?market account. United Fire?s former chief ?nancial of?cer Daniel Payton con?rms part of Hoffenberg?s account. He says he recalls making one or two telephone calls to Epstein (at I?l'offen- berg?s direction) about the missing bonds. ?lie said, ?Oh, yeah, they still exist.? But we found out later that he had sold those assets . . . leveraged them . . . [and] used some man gin account to take some positions in Emery and Pan Am,? says Payton. Epstein?s extraordinary creativity was, ac? cording to Hoffenberg, responsible for the purchase by the insurance companies of a $500,000 bond, with no money down. ?Ep~ stein created a great scheme to purchase a $500,000 treasury bond that would not be shown [as] margined or collateralized,? he reportedly told the grand jury. ?It looked like it was free and clear but it actually wasn?t,? he said. Epstein has denied he ever had any deal? ings with anyone from the insurance com? panies. But Richard Allen says he recalls talking to Epstein at Holfenberg?s direction and telling him it was urgent they retrieve the missing bonds for a state examination. According to Allen, Epstein said, ?We?ll get them back.? He had ?kind of a ?ippant atti~ rude,? says Allen. ?They never came back.? Epstein, according to Holienberg, also came up with a scheme to manipulate the price of Emery Freight stock in an at- tempt to minimize the losses that occurred when Hoffenberg?s bid went wrong and the share price began to fall. This was alleged to have involved multiple clients? accounts con? trolled by Epstein. Eventually, in 1991, insurance regulators in Illinois sued Hoffenberg. He settled the case, and Epstein, who was only a paid cousul- taut, was never deposod or accused of any wrongdoing. Barry Gross, the attorney who was handling the suit for the regulators, says of Epstein, ?He was very elusive. . . . It was hard to really track him down. There were a substantial number of checks for signi?cant dollars that were paid to him, I remem? ber. . . . He was this character we never got a handle on. Again we presumed that he was involved with the Pan Am and Emery run that Holl?enberg made, but we never got a chance to depose him.? ?From the government?s discovery in the main sentencing against Hotlenberg it would seem the government was perhaps a bit lazy,? says David Lewis, who represented Mitchell Brater. ?They went for what they knew they could get . . . and that was the fraudulent promissory notes the much larger and unrelated part of Hoifenberg?s fraud, based in New York State}. . . . What they couldn?t get, they didn?t bother with.? Another lawyer involved in the criminal prosecution of Hoffenberg says, ?In a crim- inal investigation like that, when there is a guilty plea, to be quick and dirty about it, discovery is always . They don?t have to line up witnesses; they don?t have to learn every fact that might come out on cross?examination.? pstein was involved with Hoffenberg in other questionable transactions. Finan- cial records show that in 1988 Epstein in? vested 1.6 million in Riddell Sports Inc, a company that manufactures football helmets. Among his co?investors were the theater mogul Robert Nederlander and attorney Leonard Toboroff. A source close to this transaction claims that Epstein told Neder? lander and Toboroff that he had raiscd his share of the money from a Swiss banker, MARCH 2003 ALBERTO PINTO whose identity they could not be allowed to know. But Hoifenberg has claimed the men? ey came from him, and Towers?s ?nancial statements for that year show a loan to Ep- stein of $400,000. (Epstein has said he can?t remember the details and has dis- puted the accuracy of the Towers ?nancial reports.) Around the same time, Nederlander and Toboroff let Epstein come in with them on a scheme to make money out of Pennwalt, a chemical company. The plan was to group together with two other parties to take a substantial declared position in the stock. According to a source, Epstein was supposed to help Nederlander and Toboroff raise $15 million. He seemed to fail to ?nd other investors, say those familiar with the deal. (Epstein has said he was merely an in? vestor.) He invested $1 million, which he told his co?investors was his own money. But in his 1989 deposi- tion he said that he put in only $300,000 of his own money. Where did the rest come from? Hof- fenberg has said it came from him, in a loan that Nederlander and Toborol?i? didn?t know about. Two things happened that alarmed Nederlander and Toboroif. After the group signaled a possible takeover, the Pennwalt management threatened to sue the would?be raiders. Epstein was reluctant ini? tially to give a deposition about his share of the money, telling Toboro?? there were ?reasons? he didn?t want to. Then, after the opportunity for new investors was closed, co?investors recall Epstein announcing that he?d found one at last: Dick Snyder, then (3.13.0. of the publisher Simon Schuster, who want? ed to put up approximately $500,000. (Nei~ ther Epstein nor Snyder can now recall the investment. Yet in the i989 deposition Epstein said that he had recruited Sny? der, whom he had met socially, into the deal.) According to a source, Toboroil" and Ne- derlander told Epstein that Snyder was too late, but, without their realizing it, Hoffen- berg has claimed, Snyder wrote a check to Hoffenberg and bought out some of his in? vestment. But then Snyder wanted out. ?Nederlander started to get these irate calls from [Snydegl who wasn?t part of the deal, saying he was owed all this money,? says someone close to the deal. Toborofl" and Nederlander were baf?ed. Eventually, a source close to Hoffenberg says, Holfenberg paid Snyder off. MARCH 2003 ust as Nederlander and Toboroff were growing wary of Epstein, he became in? creasingly involved with Leslie Wexner, whom he had met through insurance executive Robert Meister and his late wife. Epstein has told people that he met Wexner in 1986 in Palm Beach, and that he won his con?dence by persuading him not to invest in the stock market, just as the l987 crash was approach? ing. His story has subsequently changed. When asked if Wexner knew about his con? nection to Hoffenberg, Epstein said that he began working for Wexner in 1989, and that ?it was certainly not the same time.? Wherever and whenever it was that Ep? stein and Wexner actually met, there was an immediate and strong personal chem- istry. Wexner says he thinks Epstein is ?very smart with a combination of excellent judg- ment and unusually high standards. Also, he is always a most loyal friend.? OFFICE SPACE The ?of?ce? in Epstein?s house. It has no computers, but it does have a desk that Epstein tells people once belonged to banker J. P. Morgan, and ?the largest l?ersian rug you?ll ever see in a private home.? Sources say Epstein proved that he could be useful to Wexner as well, with ?fresh? ideas about investments. ?Werner had a con- ple of bad investments, and Jeffrey cleaned those up right away,? says a former associ~ ate of Epstein?s. Before he signed on with Wexner, Epstein had several meetings with Harold Levin, then head of Wexner Investments, in which he enunciated ideas about currencies that Levin found incomprehensible. ?In fact,? says some one who used to work very 0103er with Wes- ner, ?almost everyone at the Limited won- dered who Epstein was; he literally came out of nowhere.? ?Everyone was mysti?ed as to what his appeal was,? says Robert Morosky, a fonner vice?chairman of the Limited. Much of Epstein?s work is related to clean- ing up, tightening budgets, and ef?cien? cies. One person who worked for Wemer and who saw a contract drawn up between the two men says Epstein is involved in ?every- thing, not just a little here, a little there. Everything!? In addition, he says, ?Wexner likes having a hatchet man. . .. Whenever there is dirty work to be done he?d stick Jef? frey reputation for being ruthless but he gets the job done.? Epstein has evidently been asked to fire personal?staff members when needed. ?He was that mysterious person that everyone was scared to death 0 says a former employee. Meanwhile, he is also less than popular with some people outside Wexner?s company with whom he now deals. ?He ?inserted? himself into the construction process of Lesw lie Wexner?s . That resulted in liti- gation down the road between Mr. Wexner and the shipyard that eventually built the ves? sel,? says Lars Forsberg, a lawyer whose ?rm at the time, Dickerson and Reily, was hired to deal with litigation stemming from the construction of Wexner?s Limitlessw at 315 feet, one of the largest private yachts in the world. Evidently, Ep? stein stalled on paying Dickerson and Reily for its work. ?It?s probably once or twice in my le? gal career that I?ve had to sue a client for payment of services that he?d re? quested and we?d per- formed . . . without issue on the performance,? says Forsberg. In the end the matter was settled, but Ep- stein claims he now has no recollection of it. The incident is one of a number of disputes Epstein has become embroiled in. Some are for sums so tiny as to be battling; for instance, Epstein sued investment adviser Herbert Glass, who sold him the Palm Beach house in 1990, for $13,444?mEpstein claimed this was owed him for furnishings removed by Glass. In 1998 the US. Attorney?s Of?ce sued Epstein for illegally subletting the former home of the deputy consul general of Iran to attorney Ivan Fisher and others. Epstein paid $15,000 a month in rent to the State Department, but he charged Fisher and his colleagues $20,000. Though the exact terms of the agreement are sealed, the court ruled against Epstein. Wexner otters some insight into his friend?s combative style. ?Many times people confuse winning and losing,? Wexner says. ?Jeffrey has the unusual quality of knowing when VANITY Jeffrey Epstein he is winning. Whether in conversations or negotiations, he always stands back and lets the other person determine the style and manner of the conversation or negotiation. And then he responds in their style. Jeffrey sees it in chivalrous terms. He does not pick a ?ght, but if there is a fight, he will let you choose your weapon.? One case is rather more Serious. Currently, Citibank is suing Epstein for defaulting on loans from its private-banking arm for $20 million. Epstein claims that Citibank ?fraud- ulently induced? him into borrowing the money for investments. Citibank disputes this charge. The legal papers for another case offer a rare window into Epstein?s ?nances. In l995, Epstein stopped paying rent to his landlord, the nonpro?t Municipal Arts Society, for his office in the Villard House. He claimed that they were breaking the terms of the lease by not letting his staff in at night. The case was eventually settled. However, one of the papers filed in this dispute is Epstein?s financial state- ment for 1988, in which he claimed to be worth $20 million. He listed that he owned $7 million in securities, $1 million in cash, zero in residential property (although he told sources that he had already bought the home in Palm Beach), and $11 million in other assets, including his investment in Riddell. A co?investor in Riddell says: ?The company had been bought with a huge amount of debt, and it wasn?t public, so it was meaningless to attach a figure like that to it .. . the price it cost was about $1.2 mil? lion.? The co~investors bought out Epstein?s share in Riddell in 1995 for approximately $3 million. At that time, when Epstein was asked, as a routine matter, to sign a paper guaranteeing he had access to a few million dollars in case of any subsequent disputes over the sale price, Wexner signed for him. Epstein has explained that this was because the co?investors wanted an indemnity against being sued by Wexner. One of the investors calls this ?bullshit.? pstein?s appointment to the board of New York?s Rockefeller University in 2000 brought him into greater social promi? nence. Boasting such social names as Nancy Kissinger, Brooke Astor, and Robert Bass, the board also includes such pro-eminent scientists as Nobel laureate JOSeph Gold? stein. ?Epstein was thrilled to be elected,? says someone who knows him. After one term Epstein resigned. Accord- ing to New Kirk magazine, this was because he didn?t like to wear a suit to meetings. A spokesperson for the Rockefeller board says Epstein left because he had insufficient time to commit; a board member recalls that be 346 FAIR was ?arrogant? and ?not a good fit.? The spokesperson admits that it is ?infrequen for board members not to be renominated after only one term. Still, the recent spate of publicity Ep? stein has inspired does not seem to have fazed him. In November he was spotted in the front row of the Victoria?s Secret fashion show at New York?s Lexington Avenue Ar- mory; around the same time the usual co- terie of friends and beautiful women were whisked olf to Little St. James (which he tells people has been renamed Little St. Jefl?) for a long weekend. Thanks to Epstein?s introductions, says Martin Nowak, the biologist ?nds himself moving from Princeton to Harvard, where he is assuming the joint position of profes- sor of mathematics and professor of biolo- gy. Epstein has pledged at least $25 million to Harvard to create the Epstein Program for Mathematical Biology and Evolutionary Dynamics, and Epstein will have an of?ce at the university. The program will be dedi- cated to searching for nature?s algorithms, a pursuit that is a specialty of Nowak?s. For Epstein this must be the summit of every- thing he has worked toward: he has been seen proudly displaying Harvard president Larry Summers?s letter of commitment as if he can?t quite believe it is real. He says he was reluctant to have his name attached to the program, but Summers persuaded him. He rang his mentor Wexner about it, and Wexner told him it was all right. An insatiable, restless soul, always on the move, Epstein builds a tremendous amount of downtime into his hectic work schedule. Yet there is something almost programmed about his relaxation: it?s as if even plea? sure has to be measured in terms of self- improvement. Nowak says that, when he goes to stay with Epstein in the Caribbean, they?ll get up at six and, as the sun rises, have three~hour conversations about theoret? ical physics. ?Then he?ll go off and do some work, reappear, and we?ll talk some more.? Another person who went to the island with Epstein, Maxwell, and several beautiful women remembers that the women ?sat around one night teasing him about the kinds of grasping wornen who might want to date him. He was amused by the idea. . . . He?s like a king in his own world.? Many people comment there is some? thing innocent, almost childlike about Jef- frey Epstein. They see this as refreshing, given the sophistication of his surroundings. Alan Dershowitz says that, as he was getting to know Epstein, his wife asked him if he would still be close to him if Epstein suddenly ?led for bankruptcy. Dershowitz says he replied, ?Absolutely. I Would be as interested in him as a friend if we had hamburgers on the boardwalk in Coney Island and talked about his ideas.? t] 1 . - Affleck?s Double RI. T-shirt from Double '{fileonsfcoll Deborah Woknin for-Art -: {Mir-{the Aegean." 3. 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NHL, or coll 212-327?oror; for RovrBan sunglosses, cell 888- I: - Page 23f: locket from . from Double RL, NYC. (and LA, long ~sleeved shirt I Tommy Hilfiger Tommy Hilfiger stores .: . . worldwide. or call 800- I I Double RL Tvshirt - or go to for Levi?s icons. coll MARCH 2003 idli- DEFENDANT BRADLEY J. EDWARDS ?8 STA TEMENT OF UNDISPUTED FACTS Epstein v. Edwards, 61 al. Case No. 50 2009 CA EXHIBIT 0 RECEIPT papmmse - PROPERTY Cl FOUND {Probated} PERSONAL I DESTROY EMDENCE E3 TRIAL E3 LABORATORY I OTHER INCIDENTICITATION NUMBER PROPERTY (Leave Stank} BEN NUMBER (Leave Blankso; ADDRESS WHERE eeo'eemwmeouwoeo("Iva .KW.) we" w/ ewoo??ew A am: City 2:13 PHONE NUMBER (r 4 . {kiwi . o'rwefo??i'e?. an? 2 It gwnen?s NAME 1 ?10.13. ADDRESS Streef City Zip PHONE NUMBER SUSPECTS NAMEIDDB. ADDRESS Street org: mp NUMBER or mi" ,5 . va ?rhm? . ?.33 Mite?? 2;:ij 2 3% s?uspecwooe. ADDRESS Street City 259 PHONE NUMBER INSTRUCWONS FOUND PROPERTY CLAIM .90 DAYS NOT CLAIM Ci QUANTITY VALUE DESCRIPTION 'ii? 1.111?; *5 ?9 fifgjeg?: w? N15. i. 6-1- La?m?on . .I Eh I .- TOTAL PACKAGE WEIGHT i hereby acknowledge that the above list represents alt property taken I hereby acknowledge that the above ?st represents a1! property impounded from me and that i have received a copy of this receipt. by me Eh the of?cial performance of my duty as a police officer?Mvn?hui'v?qu; (M if"? xiv-m? a 4 ml; en} 338359? ?we? (We; nib?? meme-r? of?" - -. he? SIGNATURE DATE UNET Jm a. - I RECENED BY REASON a DATEJTJME RECEIVED ifrial} h: L?s? I why-Hm? ,4 g: 1M1. 1: 1 2.1. 1 . .. 2 . DETEQWE BUREAU. 2' I soaring, Eloecggseo?mr?baied) C3 CONFESCATEG macaw/913nm mum-sen. Traoivaamgwsea (L'gave BEN-NUMBER .. Z-Q-QE ADDRESSWHEREPHOPEHTYIMPOUNDE . I . MI, I ?If? I . - ADDREISSI .srree!I_ .Cffy- I- . .I NUMBER II II Aobne?s "Street" 'Cr'ny- "259$ - 3.990% suspects 0.0.8. P?Abnaess Cir? I . 3509533 I- Street?; .PEONEINUMBER - ?cream-[3f - ..Esmwnow . - I QUANTITY II-VALUE .. . . ?aw2?fins; ?ag r?Xr?wgg-53x13 .255 . a #32. awayscatIIJ, - ?1%va . I hereby ack?bwiedge that'ih?abbxie'lisz r?pres?nt?lall i herebyiacknawlledge mat the' abidve list repr?sentsiai! propezty iIrInpoqInded froImme. and that I hayeI'reQQEVed r?ceipzthe offing performance qu'y duty as a'poii'ce o?iderDATE - my .UIINIT . RECEIVEDRe?-a?f??y A afficer? warrant was: ??cacut- r30 ?fl?it-L the; above fi?vx?im?fiqryf?ght??ig} 4e, "53f ladleiqithe greperty taken by mgtI- LGderS'me ma .I I/this-'2; day Its-fr .32 . - A PROPERTY . - i -- :8 PERSONAL -. ?Cl . a?i?mLEm?egoi/?ERED. Bowen} -. 7? j: -. yum?aga 1 C: DATEITIME RECOVERED . - PROPERTY (Lgaye Bz?nk} - BIN ADDRESS VQHERE .. ?74; 5 91299an $130ng5 - - I .- .. .. Disqovenep'M1 Anoa??a Street ?City NUMBER ., z? Mm; 31093;. I. - - -, _Aqna?ss.- - . Street - ?1 City 2m -. PHONENUMBER sus' ADDRESS - . Street! Zip PHONE-NUMBER . w? - Street Zip" '1 -3 --. I (firnggo BHOPERTY DAYS .. g?3/311" . I 1? (V ??t?if "J?wfhfir?rl'l?i'?? (I ?f?rawIii! if I .I?w Wily.- vii.3523? -. I I. I - '65} {?fkaj?./ :12 . 34?3" 1c! -.- 3. af?x-Q I 5" 51'0"{rammeand?that i ?av?ggecei?e'qia Copyp?his? reCeipt. - h?febji-g?knowiedge? that he ?bdve lisuepresems ?11! hr?operty?impourideld - ?ne in?rm official performance of my'd?uty as a police officer._ Pa ?th35 Isa?m?w?a? "1 DATE . it . . . "v Wm .- .1 Cir-bum}, - "Cl QONFISCATEE ?Lgsomfdm - .- Cl DESTROY - - i - . PROPERTY NUMBFR (gem-Bram .- .. 5 {3w 13w NUMBER (Lea?e wankHr? plscovgnm ADDRESS Street . City 32?; - NUMBER . ADDRESS. . Street City . Zip". PHONENUMBEH ADDRESS 5% I 8.989891?? New: 9.98- 4.9/3- ?a . Tame: Zip NUMBER -- Aoo??g -. ADDRESS .srgea: . - 2:10 PHONE NUMBER I. . ??oeam' - CLAIM VA-LU a. I. 396 DAYS inXi? g2; 125:; 5-K: fzfm'mavwa?e. {a {mrwucm :5 . I. I II I .f-?-Argu: it: a. Wii?'?if?f? ,5 2; ANN 39.2 Mirage; gnaw 5.5M 2-1/sum-KM? Q35 ?ligr?[3374? - 1 I, mn?f (333%; We 5.122. I fa?d?bgfz?ng? ,?ifmi5.10 ..I . m-n'fgm" .f'fv ffi-aT-fiK-?g? mm .?if -- i . 1?5. 151993" fiiman?i . I . TOTAL I?qr?bygacknow?dgeMatine- abov? Iistr?pr??ehts at! prepeny'tak?n I ifr'cm? me and th?gt have received a cppy pf this receiptthe above Ilist represents an property/impotmded by {me in the o?ipga! peifo'rmance of my duty as a' police-d?icer. - "Fir; haw SIGNATQRE: w- -. .- DATE. a; Em; BY. REASON $53 2? k2.? . - am" .- .. ?sp'o Liam #52 1. I II is "1 DETECTNE '5 . 1:13 ??epaaw . - .DDECEA SEO {Prdb??t?ciGil?wq?wpDESTROY - I .. ww?ga RECOVERED NUMBER {Le'age mange) NUMBER (Leave Stank! ?fi-Abpn DEE) a 851' 7 Discovmeo sums. ADDRESS Street City .pr I PHONE. NUMBER I . ADDRESS. - Street lofty 7 P??yuamumaan NW5 I {feet - PHONENUMBER I. - a Aoi?mL .. Strep! ?C?Ify I. .: . Kl 1' PHQNENUMBEB. I . . a ?dijirilif'?o?snw: . I. .. NOT CLAW r, RQESGRIPWON . (griffin; '45? THEM QUANTWY - . . . TOTAL - - -- he?byackno?ledge ihat?the'abo?e {Est represents aifpb??rtyt?ken fromm? and may have r'ec?ived a com; ofthis receipt I I hemby aclghOWiedge that'lthg above ,list' f?piese?'tsi?ti by me in the: official perfonnanoe of my duty as. gp?iice Officer. x? .1. a. property impounded I .- I DATE . L?i??ii??isxk .. REASON DATEJTIME RECEIEVED v5! - ?y - 13"? 637% .. . I. . 5:?pr fibrin?#52 - -- ?bLIbE-??m??n?m ark-35 wm-Ma?s?gg qua.? EJFOUND - - - GCONFISCATED DESTROY . . .- maonAtonv a OTHER ?Wag? . . f? . PROPERTY NUMBER (Le:an Blank). . SignADDRESS. w' I [Discovamsaawuga I ADDRESS - a, Street cay- - qu?ewmaa cry-Ia II-pr- 2 Shires! - . Street- Gity? _lzip NpMasa - ?22mm -. rig?): - c327? -- . ..--.. war; 'Lli'filf? 5? . . TOTAL PACKAGE WEIGHT . . ,3 hereby that the. above. list resil?rg?ents ail property taken . I hereby acknowiedge that the above ?st Irepr?s?r'i'ts? propa?y impounded I from-me and that 1 have received a copy of this?receipi. . - ?in- me in theof?ciaf performance 9f my duty- as}: potiqu b?icea - midst '1 I UNITM SIGNATURE I DATE IBECEWED-"Tim. MM .3 - ?3?;sesame; . 8 El . . firimile?e??efsv ff FOUNEJ .. 0.955730?" m'mao?mex - Dome: e-i?e NUMBER emimma Recoveefg'I - (Leave BIank)? . em NIQMBEH a -- -- v- :?ie/e II :eyecqvgage I. - Amazes - '_Is,rreer? I qWNER'sI-mrgemeet -- street] le- I I PHQNENQMBER - g9 . . - Sfreet'. . Zip I mime ?ween - megs . i. .. .. - 3 NOTCHW I . . a New"; - e. . v?th VIKW .IIW . ?1}me5 "i - ?33? e: i; TOTAL PACKAGE WEIGRT I hereby acknowiedge that the above list repr'?sedls all property taken. I I hereby acknowiedge that the above he! represents at! property impounded - frgm'rrie land that have received 3; copy'of this receipto?iciai performance 9! my duty gas a? police o?ieersiem'me?g II II II RECEIVED BY 1. .. eeoeweo . I -I I . . . gym?. 005%. I- SIGNATURE - i I. 1 . I I Qi-gnbpe?fv? Fou?n Doowsc?mm p?si'aov- I '?{Lem Bl?mk} "i BIN NUMBER {ma?e?aizi?m?i-v 29$} L?l' ADDRESSWHEREPRQPEHWIMPOUNDE .t 1' . i. QIR. lg; . I -. $052593" 3-3399: . ncr'ry, 2:10 I ADDRESS - 3 StreetIPHOINENUMBIER 7?srrgig'r" I 'susPaqr-?s Emm I 'ry .. I PHONE {unQmoms? II .. my; zile -. mania .wsmugmws . 4.6 f5?Tami?i QUANTITY VALUE "3'55 ?Tf If?.143 . .. 1. mm . - . .Iwr?a .5- . ..- . ,w (Irmay.124 . . -: "??31 lit-.5131WEIGHT . 'l hereby ?ckanfedge. Iab?ov'e "?st 're'present's at! property It?ken I . hereby acknowledge that the above ?st repr?s?nts'ali progeny impounded ty as?a police o?ider. I - by ImeIinthe o?idiaipemrmance ofmy du -I gamma; I .I - UNIT .. RECEIVED BY. - -- 1' . REASON I - BECEWED Rag-78343337, I 14319; 7::th warrant: was. ?g?C?tx CEO swaar the La "Ema 'ng QB the ?sroperty "taken-I337 me, under I- I. I w? - A: ch9m ?to $?3?353Q?ib?dIbefore'Itfuis'if {day at"; .. .. . - .. . ?orm 3:52" .--DETEICTNIE BUREAU ?E?i?awen?g; ID FOUND v, 5 CONRSCATED . syoingcovE?ghg-e - tantrum: RECOVERED . - PROPERTY Human-[Leave Bi'?qk) aim NUMBER (Le'ave?alank3??- a f, -- 3:13:32 Cl . ADDRESS WHERE -- 22 -. z; a . ADDRESS v' Street - "'Ciry' 12?: ., hi. - IAQDRESS. I .- Street - 'cny -- I. Zip-I I ADDRESS isneer 260 I . PHONE-NUMBER. -I -a034m..I-Aoqr?m; ADDRESS. -. - I .S{r?er City - II . .- - . {fix I . I El Mfg-?; fs-zfnaiz- -. I I lair?=45? 7? 2m 3 .. a ?fasmriv a . - I. I. II 'ifvw??'?i?m Juaw??,Ir' I {'ii". erfei?f- e} 31% ?1 - - WEEK ??vf??if I I 3?31.3 i f; - Q4- - ?313;- a; 1/2. 4* ?wig gl??-a?kvwci?1.5TOTAL WEIGHT - . - 3? {$35.71 "i regresentsIalII property-taken h?IrIeby' QCRnowledgeIthat {he ?bdve iiSt-represents ail prope?yjmpoqnded I . and-that I a copy q?ghis receipt. - . . -by._me inI.the o?iciai performance .of mdey as a bolice of?cer; - Elwwi0,57; . RufREASON a; Mmmw?ax? .DATENME . "u I was": . my . CI DECE?EDii'Pr?b?ted) I besmcw' - gram; Lga'omf'cija'fi" A clap ?zz; . y. . BEN MUM BER {Leave Biarik)" PROPERTY - 1? IE DISCOVERED ADDRESS - I Street -. City "Zip. - . NUMBER . 'Sgre?: SIX Zip. .- we. 30013688" . I Hz; 2'19 NUMBER - .. ApgnEss .. mow 3:107 - FSHONE NUMBER . I Pomp Pnppenfw 9 1' I ??53052:an .- 5_ .- I ?2 Ewi'?'ff?' "74} 4 ?f'mk??m (I k2 (9 g: IE-amwg 235,: 57?? . hiss-fart;- {c m- Tw bam- a. . I I 3.73. r27: '0-1-{3iir9 . ZS?-m?r 5.4713), J4 wry-a; . Hum-M ??imgx; (an N. . I IQUHI $96 Pryorn. Kr. ?#7'14'5 . 56333-wa {51.4.75 egg-z; 5115:2332; J?-ngw-s; :21: ?z'gramy- rm . z'txim em}? 64:1?) $556-$116 1 ?73544 5: ax a; F- V: 63:: gap-am 31? $3.242 (x mm- ?air-?5262 353.II @mw%w%wma ".rgm? .. I .- . {gill??8}? Eff-.5? {a C, - .?hkj' - TOTAL PACKAGE WEIGHT -- - 5w a? . . . 33mm: I i! hereby-acknowledge-I'thaz the aboxie ?st 'fr'om me and that have received a copy 'p'r?operty r?pr?serits at: of this receipt; {ak?n "gaemwms thereby ackn?wjedge'thatihe above list represents-alt propertyimpouaded by me'i'n the officia? perfozmance of my duty as a po?ce officer. a; <24. . 75:1,; Ra?-REASON 5 . I ?mi-bin; i? .r - $51390 Fofhi #52- . . ?rm 1 ID maoa?frbhU'D?E'smov- omen - Emil - I??mmwc?mow NUMEER .. pA?rImgh-JE .I -- .. In NUMBER (Leave Bfan'k; BIN NUMBER (wave Blankfv - - .I mscoven?ep 752;? I ?smeet- Cigr' .pr - - I . ADDRESS. . 2:12. . moms. WMBER - I I - 2:10: - I I. .. Am??rm. .I . apoaass -. I .szl? -. I Pmbi?auma?a. I . 35f? *f?inurqomoemw :93? @3562". 5-, I .. li?_ . r3 ?rst: My: 12TOTAL PACKAGEWEGHT 'l'hergby acknoWInge thatthe ?bove fist repreSents from m?and mag I have received a copy of this receipt. prop??ny taken i hereby acgnowfedge that! by me in the official performance of my duty as of?ce be" above. fist' represe?ts'. all propeny impounded . r. - -. DATE I . REASON I if RECEIVED ngTEcrsz b? - . (Team ?ow #52" - . .zi - 'U-?P?bps?w Chomp . . urn-deb - 3v: EVIDENCE. - DECEASED (Prob?i?df a LABORATORYDATEJTIMERECOVEBED (Leav? Biarik) awnsumm (ngv?.Blankwages :beuuo? DISCOVERED - Street I. .my ADDRESS- City PEENE NUMBER 1 owwEars-?AMEjAfDan - ADDRESS ya Stre at zip- A SUSPECTS NAME (016,3; f? gpa?? 8.: #9 .srr. et- -1 City - .i PHONE high-{BER f3; . Aao?ass . FHONENUMQER - -me?1~ . I ms. -- Joe-gammy - ma. wed?? .- I El?v?se? 4? i .a?f?iw 23% f? 5 . see? an.19} Ham-w Brag?, I, - Hgf'ikrTOTAL PACKAGE WEIGHT from-me and that I have received a copy of thp?- receipt. SIGNATURE hereby acknowledge tha: the above Eist rep? sents a2! propeny taken hefeby acknowiedge that the above. list represerits 5H '?rqper?y impounded 3 in thgo?icial perfonhance of my dilly-518.3 poiiqe Officer. 1w Bacewep BY "a Kara-N, - . a? - Wigwam-32+ PE -- i -- ma?a:ng mg; :5 BUREAU E3 "Drown. . ~C1Faj?a?cimcf Cl CONFISCATEED 053mm El LA?o?Afda? - omeg- - DATEJTIME RECOVERED - {Leave Blank} NUMBER (Leave . wank} =3 33500318350. swuos. Street .th PHONE NUMBER 3' mme?ko?pla; - - ADDRESS Street City . 23p PHONE NUMBER ADDR E38 Street' fg? - 2:13 (Jamie NUMBER . mom; 33325911903: Appaass Sires! PHONE mutt-35:2 scum PROPERTY GLAND NOT CHEM . - DAYS ITEM. - a ??33 - . - - 3 "(1"?:43 . TOTAL PACKAGE WEIGH - me and that I have received a I hereby ackridwiedg?' {halt the ?bb?a list E?pfgs??ts. ail?prbp?-rty?tak?n comic! this receipt. '1 56:95? that the above list represents ail propedy impounded by me it} $119 of?cial pedomance my' duty as a police of?cer. SIGNATURE DATE -. . - RECEIVED BY DATETFEME RECEIVED 313:? REASON . . /5?ba Arr Q-w 03*? . u. ?33; . :5 mm?! wee-Hun wumwc :33 92?" {312" . eBQDFomgz' - - DETECTIVE BUREAU I Cl Ci FOUND Ci DECEASED (Probated) Ci PERSONAL Cl CONFISCATED . DESTROY . e. LABORATORY STOLENIRECOVERED OTHER I NUMBER DATEITIME RECOVERED PROPERTY NUMBER (Leave Biank] BW NUMBER (Leave Biank} I . 5:13 I n. - i if?: 51:1", ?inufwi p} .. KAI W5 i- I 57". ,5 ?we/J Rr? 2. k/ mug} NJ - WHERE PROPERTY IMPOLIJNDED Discoveai?s?o aw Doe. ABOHESS Street any 'zip PHONE NUMBER OWNER NAME I 0.0.8. ADDRESS Street City Zip PHONE NUMBER Aopaess I Sire-e! Qty PHONE NUMBER - w? r" ?2 i354. . i? i {mi 2* ADDRESS Street" Ciry Zip PHONE NUMBER ENSTRUCTIONS FOUND PROPERTY CLAIM C3 90 DAYS NOT CLAIM E3 QUANTITY VALUE DESCRIPTION . - 3. .483 ?rm 3-5! I. 11?- ,vIIp - a 5; -5- . I In-IrWe(1(if'12. i 9.?Jv"vsIf"vsif?uid?, 3 3 I ?1that?re?t. i hereby acknowledge that the above list represents propeny taken from me and that i have received a cepy of this receipt. i hereby acknowledge that the above ?st represents at! properzy impounded by me in the official performance of my duty as a poiice officer. I i i SIGNATORE I lei} UNIT I SIGNATURE DATE RECEIVED BY REASON nh'u? wunw: r" Whining Wit-"41V I Ree a; or RECEIPT eereo'rwe PBPD Fiona 4?52 . - i Rennie-3 E3 PROPERTY FOUND DECEASED {Probated} PERSONAL CI CONFISCATED DESTROY EVIDENCE ICE LABORATORY STOLENIRECOVERED OTHER I Darensz RECOVERED PROPERTY NUMBER {Leave Biank) BIN NUMBER {Leave Biankmm} (xiRROPERTY IMPOUNDED . - - . rj: '53: . .- 3 r" 32f DISCOVERED ew Doe. ADDRESS Street City Zip PHONE NUMBER NAME DOB. ADDRESS Street City Zip PHONE NUMBER suseecrs was? :3 genera?: are zip PHONE NUMBER 1 fr? 1?7 732k0.0.8. ADDRESS Sim: City zip PHONE NUMBER I SPECIAL INSTRUCTIONS E3 . . 90 DAYS NOT CLAIM 13 QUANTITY VALUE 2 DESCRIPTION - '35? 3115:3342; r" r" ii. Orr-?m dew-$95K? if? 5123??" {ire-A ?re59.131": ?31? .-: a -. :L'i r? . film i3 Viv-?1 f" KO e12?- r~ ..-. if{Eff r' 4' 4? 5.3" I . x; p? i. 5-431.vru'u' - w. .. - -- eff/'r27 me?rm; . :?TOTAL PACKAGE wearer-a7 i hereby acknowiedge that the above list represents at! property taken from me and that i have received a copy Of {his receipt. I hereby acknowledge that the above iist represents at! preperty impounded by me in thelofficiai performance of my duty as a poiice officer. . .. 1" rmEtna} ?1.7 f-Y I M- "t-g )r a 3? ri- by. New!" ?an gar" SIGNATURE DATE SingATUE-?iE?e?e-x UNIT RECEIVED. BY DATEITIME RECEIVED REASON .PBPD Form #52 I I PROPERTY RECEIPT . r'vr'hm mr?w?i A?.ng web-mew? Vime Trek-?f ?1 .9 .r an" I, {155; .er? 4' 6:5} DETECTWE BUREMJ C3 FOUND 13 DECEASED (Probaled) M. 1 2w [3 PERSONAL comesm?o {3 oesmov ewoewce x? TRIAL - a LABORATORY CI OTHER DATEITIME RECOVERED PROPERTY NUMBER (Leave Biank) NUMBER {Leave Biankes: 1.OUND - i3teas-.4 at :e DISCOVERED BY I 0.0.8. ADDRESS Street City 596% NUMBER NAME ADDRESS Sires! City PHONE NUMBER SUSPECTS NAME 1? 13.0.3. . xv 3&75?335 3' ug?poness Street City 2:50 PHONE NUMBER . - me?? gem e. if" Sc? ?13* ?73k" seen. if . . . Apoeess Street City zip PHONENUMBER SPECIAL memory!?sz FOUND PROPERTY CLAIM I 90 DAYS NOT CLAIM ITEM QUANTITY VALUE. I i ?a who}! . ?1 :1 Leg"; - sea: 35:5'agile-E?; {15: m- r. 45 If?sax ?Jwerc?r? in ?1 3,53? 57;? s? ?233I115. TOYAL PACKAGE WEIQHT I hereby acknowledge that the above ?st represents ail property taken from me and that have received a copy of this receipt. Voyage in the official? performance of my duty as a police officer. I hereby acknowledge that the above ?st represents all property impounded we I 4, v-n-n Nana-J; Ev" 1i? ?(fl-W SIGNATURE DATE iD# UNZT RECEIVED BY RECEIVED "tum-J PALM BEACH A r1?; - A Pref a 2 . Cl PROPERTY C3 some DECEASED {Probated} C3. PERSCNAL UCCNFISCATED Cl DESTROY - 5 STOLENIRECOVERED Ci OTHER g5"; moro?g?iwg?mow NUMBER RECOVERED PROPERTY NUMBER {Leave Blank) em NUMBER (Leave Biank} in?" .- ?If {my A. ax {vi-xi gm ymeoowogo. A. g? s? .5 4"?6?1 ?:33 :13 Exit-?hwy {Ed} DISCOVERED ew Doe. ADDRESS Smear City Zip PHONE NUMBER NAME 1 ADDRESS Street crry Zip PHONE NUMBER SUSPECTS NAMEJ0.0..B. ADDRESS A Zip PHONE NUMBER i' .iqf?irvi. he? :3Eri- MJ 5: 3' in". SUSPECT Doe. ADDRESS Sires! Zip PHONE NUMBER FOUND PROPERTY 90 DAYS NOT CLAIM [3 HEM a: UANTITY VALUE 13?s? tritig??wm-c?? gag?" car} ?345 A x17.) ii-?z- a I xi?ik kmEli;- .E I. TOTAL PACKAGE i hereby acknowledge that the above list represents ail propedy taken I hereby acknowiedge that the above list represents ail property impounded from me and that i have received a copy of this receipt. by me in the o?iciai performance of my duty as a officer. . ?at I he? I. (J: ii; ml"? SIGNATURE DATE SIGNATURE iD# RECEIVED BY REASON RECEIVED ?fig: I. . . 3 :VMth murmur?: a ?In? 1 - . PT {salamms'z' . . t. ii- BUREAU . PROPERTY FOUND Cl DECEASED (Probated) Cl PERSONAL CI CONFISCATED C3 DESTROY EVIDENCE LABORATORY STOLENIRECOVERED OTHER r' z. - - ENCIDENTICITATION NUMBE DATEITIME RECOVERED Blank; am Blank) ("2:151 - . ADDRESSWHERSPROPERTYEMPOUNDED t. I I J: it?? I 1: I: DISCOVERED BYI ADDRESS Street City 2:33 PHONE NUMBER I VICTIMS NAME 1? ADDRESS Street City zip "r 22* ADDRESS Street mp PHONE NUMBER i I. . 33 . Jrnuxa: 5? ,a?w ?1 t5" Street (3in 2:39 PHONE NUMBER FOUND PROPERTY CLAIM a . 90 DAYS NOT CLAEM . QUANTITY VALUEennui?4w?uff r'TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents alt property taken I hereby aoknowtedge that the above fist represents all from me and that i havghreceived a copy Di this receipt. _Dy me in the O?iciat performance 0! my duty as a police of?cerSEGNATURE DATE SIGNATURE rm": t}th RECEWED BY REASON RECEIVED . - Tb WEOJQD ran-Mu I 8 lie?remuDETECTIVE BUREAU .PBPD Form #52FOUND Cl DECEASED {Probated} [3 PERSONAL i3 DESTROY EWDENCE, L3 LABORATORY STOLENIRECOVEREQ OTHER women RECOVERED PROPERTY NUMBER (Leave Bleak) BIN NUMBER 11:11ADDRESS WHERE .: 1 1 . if(1'5 5w" I 3 Doe ADDRESS Street City Zr}: PHONE NUMBER OWNER I NAME I 0.0.8. ADDRESS Street City . Zip PHONE NUMBER NAME 0.0.8. {?lm it?? ADDRESS sneer City 3?10 PHONE NUMBER fr? i ME: I If: gram. ii; ?he't Fm iv" c: ?Mr? r? 050.8. I ADDRESS Street City Zr}? PHONE NUMBER n?r-I' ow": SPECW FOUND PROPERTY CLAIM - I 90 DAYS . NOT t3 QUANTITY VALUE ?fiFri-I?. If I Hi 4" ft.? 3' - '43. 11' - 4.32:: 5.7 a. xizz .. r? 25,3?at? I 51"! TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents atl property taken I hereby acknowledge that the above list represents alt property impounded from me and that have received a copy of this receipt. by me in the official performance of my duty as a police officer. I . t9" r" i Jim-?8? . DATE lD# UNIT RECEWED BY REASON DATEITIME RECEIVED a: . n. .-.. .-.- PALM BEACH POLICE DEPARTMENT I PROPERTY RECEIPT DETEORVE BUREAU P9530 Form #?52 . . PROPERTY FOUND DECEASED (Probatec? [3 PERSONAL CONFISCATED C3 DESTROY EVIDENCE TRIAL Ci LABORATORY [3 OTHER 55;: ENCIDENTICETATEON NUMBER RECOVERED PROPERTY NUMBER (Leave Blank) BIN NUMBER {Leave BlankAOORESS WHERE PROPERTY IMPOUNDED t? I BY AOORESS Street City Zip PHONE NUMBER Jigs? I I If?! .- IJI NAME 0.0.3. Street City PHONE NUMBER SUSPECTS NAME I 3.0.3. :3 ADDRESS Street crry Zr}: PHONE NUMRER ADDRESS srree: City 2:10 PHONE NUMBER FOUND PROPERTY CLAIM . a it; i 90 DAYS NOT CLAIM ITEM QUANTITY VALUE DESCRIPTION faggitII 2 y" i If, I i xii-?" .r I r? TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents alt property taken 1 hereby acknowtedge that the above list represents alt property impounded from me and that I have received a copy of this receipt. by me in the otficiat performance 0: my dutyes a police officer. SEGNATURE DATE SIGNATURE UNIT RECEIVED BY REASON DATEITIME RECEEVED .5 5 Bee. seem:Ngip?evq I -- . 6909533 .?rresr. - my zip PHONE sweat"233.; - Phoes?frf?u 'EB'gLeaw? Beak) Gauge "ffFame NUMBER . '-Streer fig-gm; .- mm 55? PHONE NUMBER 'eegogngeeffeecx?totge_ - FOUND peopeew - - CLAIMCJ .. -. 90 em; . bescmp?QUANTITY VALUE 8? We TOTAL PACKAGE WEIGHT I hereby acknowledge the: the above fist represents alt-properiy taken from me and that i have received a copy of this receipt. hereby acknowledge that the above ?st represents ail prope??y impounded by me in the o?iciai performance of my duty as a police officer. "If; f. a, mo? 1 SIGNATURE DATE SIGNATURE Fm uN?tT RECEIVED BY . REASON DATENEME RECEIVED ((" rmem -. . . -. - - - . - . DETECTIVE BUREAU .- - ie?ee??w?wmega{gage erankfy; BIN NQMBER/Legyey?gh?? .. - email): Accesses v? :1 Sega? . - . I o. .Aep?ses l_ - 25:2 . . - . ?53- .. street .259 ELQzip PHONENUMEER I . .. ?9'303? -. .- . .: .Streer. - . Specie;:Nsrelucncus;, I ?ouNo PROPERTY eoemrs .. . DESCRIPTION . -. - .I-e'gmjkil I QUANTITY --IVALUE .- mm?rem. PACKAGE WEIGHT I'hereby ecknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. I hereby acknowledge the: the above ?st represents ail property impounded by me in the official performance of my duty as a police officer91H. 5 Mia-re} ,n - SIGNATURE I DATE Sl??muee toe GMT RECEIVED BY REASON omen:er eecezvee -. I I. {3mm - -: :i?iizc'e?m 1 I. Ebowmmn . ?ma?@3 awwmr; U'Mab?m?? 2:5. .. .- 3- Grimm- . . - - .bes?faov: - NUMBER - ATmmr-z RECOVERED QROPEBW-NUMBER (Leave Blank) . . am NUMBER (Leave Bank}. - - - misc'oiv'?nmw . ?11- . Laud. i ADDRESS Street" City? PHONENUMBEH NAMI (9.0.39 . --. @3683.- Sires; pr' mow: NUMBER 1 59stch 3932+ r- a's?i -- I .- -- Street. my 260 - PHONE NUMBER 409mg? 9.0.5. 'Aoo?e?? Street - 'City 2:15 PHGNE NUMBER - '7 - .. mi. 57w gym- FOUND PROPERTY CLAIM L3 90 DAYS . 1mm VALUE. I I . liq-:3 '2 6?1 fi x: DESCRIPTION I wasem from me and that I have received a copy of i hereby acknowiedge mail th? above 1is? represe?t? at! prope?y taken this receipt. 5 hereby acknowledge {hat the above list represents an property impounded by me in the officia! performance of my duty as a police of?cer. SIGNATURE DATE SEGNATURE UNIT: - REASON RECEIVED BY 5 I . v: g" DATEWIME I I.. I. I/f?w? 1 1 'i parsersz .. - . RECOVERED .- - em NUMBER {Leave et?nk} "7 1? I . CI CONFISCATED. -. . Deemov? . w- - 1/ "can315? a . .. I .3999! 2:2: PHONE NUMBER -: :?tr_eer cw. . PHONENUMBER ADDRESS Street . cry 2:1: PHONE swearADDRESS Street Cr'ty' . 2:30 . .- useeol?uuemoo?riowe . FOUND Peopeew - GLAND - .. _.gg-mysf I QUANTITY VALUE - - DESCRIPTION -- - . 61?? L- I 5g? feiIn?; {Liz's.42"in; 3 5 I TOTAL PACKAGE WEIGHT i hereby acknowledge that the above list a? property taken hereby aoknowiedge that the above Iist represents a1! property impounded from me and that I have received a copy of this receipt. by me in the official! performance of my duty as a police of?cer. . I NW. . - Hi;- lL I I SIGNATURE DATE 3' rm: UNIT RECEEVED ey REASON . DATEITIME RECEIVE ?uwm'm. Papb?brm use .. - ,Eia?jenw ?ElegTu?-I BUREAU xapmaw. CI .gff co'quiScATE'b' - . 'mm? '17 6:551:40? a'w' - yum-BER. -. .. .. . -- (team Stank} "am 1. 319: NUMBER (Le-m BlankA90 8533 WHERE PROPERTY .. (pair: .- - is?! A Igcovgae? 3w 0.0. . 434+"- . a . Srk?et "Marry-W .zrp PHONE NUMBER owns-53's NAME 0.0.3.. Strata; -- forty 2 . gm. - NUMBER . 0.0.8,r?F *1 .5 j?f? . App?ess._ .. I . _8!r_eet -- Zw' PHONE NUMBER SUSPECTIDQB. "Slresr- 3&0 PHONE NUMBER (tau-:2 za?lm -- . Special. iwsrsiu.CTgo~s . .- some PROPERTY '90 I CLAIM NOT OWN: QUANTITY VALU .n #1 musTGTAL PACKAGE WEIGHT I hereby acknowledge that the above ?st represents at! prbperty taken from me and that I have received a copy of this'receipt. i. I hereby acknowiadge that the above Eist represents ail property impounded by me in the official performance of my duty as a police officer. i {1'2 I UNIT DATE SIGNATURE RECEIVED 5/ RECENED BY (r .L. If.) 1' REASON PBPD Form #52 PROPERTY RECEIPT LM BEACH POLICE DEPARTMEL DETECTIVE BUREAU Cl PROPERTY Cl FOUND Cl DECEASED (Probated) Ci PERSONAL C3 cowesscmeo Cl DESTROY EV.an EWDENCE Cl TRIAL Ci LABORATORY NUMBER DATEITSME RECOVERED PROPERTY NUMBER (Leave Bian BIN NUMBER {Leave Blank21"; 2? -- row- ADDRESS WHERE PROPERTY IMPOUN BY I {3.0.8 ADDRESS. Sires: City Zr}? PHONE NUMBER - NAME 3' [3.043. ADDRESS Street City .er PHONE NUMBER I SUSPECTS NAMEID.O.B. ADDRESS Street City 2:10 PHONE NUMBER SUSPECT I ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND CLAIM E3 90 (DAYS NOT CLAIM ITEM QUANTITY VALUE .mix 52? a 'xm TOTAL PACKAGE WEIGHT i hereby acknowledge that the above list represents ail propeny taken from me and the: I have received a copy of this receipt. I hereby acknowledge that the above fist represents ail property impounded by me in the of?cial performance of my duty as a police officer. DATE SIGNATURE iD# um RECEEVED BY REASON RECENED .. 1: Forast sou?o'" comasc'gteb a 1; . Nono-f?, agoovssao. . 3 {Leave StankAPDBESSWHERE If . I: ADDRESS - . Street pity-- - mom ADDRESS Street Ciry' zip - moss NUMBER-- ADDRESS . Street -thy- 2:1: NUMBER . 'Aoorm..suopeo?Dingo; .- Aoohess .. Street . cw .259 PHONE NUMBER. . PROPERTY I CLAIM Ci - I . I. QUANTITY VALUE - . - oescmp'rtowli? aim-173?3. Hi r, I a . 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I \j Mast: w: 1.9-3 . . . 5w;- if? ?si .u-r ?g ?ll(gim- PACKAGE WEIGHT I hereby a?knowted from me and that i 96 that ihe above list represents an properly taken have received a copy of {his receipt. by me in the officiai -. . . - 'l a? 1 I hereby acknowtedge that the above list represents at! property impounded performance of my duty as a police officer. . Em" DATE lD# UNIT RECEIVED BY EASON RECEIVED . . - .- {i 2? 3r r' DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, 62? a2. Case No. 50 2009 CA 040800WMBAG EXHIBIT NN Print Page Page 1 of 7 Jeffrey Epstein: International Moneyman of Mystery He's pals with a passe] of Nobel Prize-winning scientists, CEOS like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. But it wasn?t until he flew Bill Clinton, Kevin Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder who he is. 8y Landon Thomas Jr. {Email} He comes with cash to burn, a ?eet of airplanes, and a keen for the ladies to say nothing of a relentless brain that challenges Nobel Prize?winning scientists across the country and for ?nancial markets around the world. Ever since the Post?s ?Page Six" ran an item about the president's late- September visit to Africa with Kevin Spacey and Chris Tucker on his new benefactor's customized Boeing 727 the question of the day has been: Who in the world is Jeffrey Epstein? .-. - inim- Cash Casual: Epstein dresses Emit: Courtesy of Jeffrey Epstein) It's a life full of question marks. Epstein is said to run $15 billion for wealthy clients, yet aside from Limited founder Lesiie Wexner, his client list is a closely held secret. A former Dalton math teacher, he maintains a peripatetic salon of brilliant scientists yet possesses no bachelor's degree. For more than ten years, he's been linked to Manhattan-London society figure Ghislaine Maxwell, daughter of the mysteriously deceased media titan Robert Maxwell, yet he lives the life of a bachelor, logging 600 hours a year in his various planes as he scours the world for investment opportunities. He owns what is said to be Manhattan's largest private house yet runs his business from a too?acre private island in St. Thomas. Power on Wall Street has generally accrued to those who have made their open bids for it. Soros. Wasserstein. Kravis. Weill. The Sturm and Drang of their successes and failures has been played out in public. Epstein breaks the mold. Most everyone on the Street has heard of him, but nobody seems to know what the hell he is up to. Which is just the way he likes it. "My belief is that Jeff maintains some sort of money~management ?rm, though you won't get a straight answer from him," says one well?known investor. ?He once told me he had 300 people working for him, and I've also heard that he manages Rockefeller money. But one never knows. It's like looking at the Wizard of Oz -- there may be less there than meets the eye." Says another prominent Wall Streeter: "He is this mysterious, Gatsbyesqne ?gure. He likes people to think that he is very rich, and he cultivates this air of aloofness. The whole thing is weird." The wizard that meets the is spare and with a long jaw and a carefully coiffed head of silver hair, he looks like a taller, younger Ralph Lauren. A raspy Brooklyn accent betrays his Coney Island origins. He spends an hour and ?fteen minutes every day doing advanced yoga with his personal instructor, who travels 12/ 9/1 5/2010 Print Page Page 2 of 7 with him wherever he goes. He is an enthusiastic member of the Trilateral Commission and the Council on Foreign Relations. He dresses casually jeans, open-necked shirts, and sneakers and is rarely seen in a tie. indeed, those close to him say the reason he quit his board seat at the Rockefeller Institute was that he hated wearing a suit. "It feels like a dress," he told one friend. Epstein likes to tell people that he's a loner, a man who's never touched alcohol or drugs, and one whose nightlife is far from energetic. And yet if you talk to Donald Trump, a different Epstein emerges. ?I've known Jeff for ?fteen years. Terri?c guy," Trump booms from a speakerphone. "Hewith. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about i -- Jeffrey enjoys his social life." But beautiful women are only a part of it. Because here's the thing about Epstein: As some collect butter?ies, he collects beautiful minds. invest in people m- be it politics or science. It's what I do," he has said to friends. And his latest prize addition is the former president. In his eyes, Clinton as a species represents the highest evolutionary form of the political animal. To be up close to him, as he was during the African journey, is akin to seeing the rarest of beasts on a safarifriend upon his return from Africa, "If you were a boxer at the downtown gymnasium at 14th Street and Mike Tyson walked in, your face would have the same look as these foreign leaders had when Clinton entered the room. He is the world's greatest politician." "Jeffrey is both a highly successful ?nancier and a committed philanthropist with a keen sense of global markets and an in~depth knowledge of twenty~?rst~century science," Clinton says through a spokesman. especially appreciated his insights and generosity during the recent trip to Africa to work on democratization, empowering the poor, citizen service, and combating Before Clinton, Epstein's rare appearances in the gossip columns tended to be speculation as to the true nature of his relationship with Ghislaine Maxwell. While they are still friends, the English tabloids have postulated that Maxwell has longed for a more permanent pairing and that for undetermined reasons Epstein has not reciprocated in kind. "it's a mysterious relationship that they have," says society journalist David Patrick Columbia. "In one way, they are soul mates, yet they are hardly companions anymore. It's a nice conventional relationship, where they serve each other's purposes." Friends of the two say that Maxwell, whose social life has always been higher-octane than Epstein's, lent a little pizzazz to the lower-pro?le Epstein. Indeed, at a party at Maxwell's house, her friends say, one is just as apt to see Russian ladies of the night as one is to see Prince Andrew. The Oxford-educated Maxwell, described by many as a man~eater (she flies her own helicopter and was recently seen dining with Clinton at Nello's on Madison Avenue), lives in her own townhouse a few blocks away. Epstein is frequently seen around town with a bevy of comely young women but there has been no boldfaced name to replace Maxwell. "You may read about Jeffrey in the social columns, but there is much more to him than that," says Jeffrey T. Leeds of the private equity ?rm Leeds Weld Co. "He's a talented money manager and an extremely hardworking person with broad interests. Most unusual, though, is that in this media~obsessed age he is not in any sense a self?promoter." 9/ 15/2010 Print Page Page 3 of 7 Born in 1953 and raised in Coney Island, Epstein went to Lafayette High School. According to his bio, he took some classes in physics at Cooper Union from 1969 to 1971. He left Cooper Union in 1971 and attended Courant Institute, where he took courses in mathematical physiology of the heart, leaving that school, too, without a degree. Between 1973 and 1975, Epstein taught calculus and physics at the Dalton School. By most accounts, he was something of a Robin Williams~in-~Dead Poets Society type of ?gure, wowing his high~school classes with passionate mathematical riffs. So impressed was one Wall Street father of a student that he said to Epstein point~blankz "What are you doing teaching math at Dalton? You should be working on Wall Street why don't you give my friend Ace Greenberg a call." Epstein was in many respects the perfect candidate for Greenberg's consideration. Greenberg, a senior partner at Bear Steams at the time and a legendary trader in his own right, has long made it clear that it's the hungry, brilliant guys lacking the fancy degrees that he favors at Bear. They even have an acronym: PSDs -- poor, smart, and a deep desire to be rich. It was a description that fit Epstein to a He was a Brooklyn guy with a motor for a brain, and while he did love teaching, this close?up view of the rare?ed Upper East Side life of his students' gave him a taste for the big time. So in 1976, he dropped everything and reported to work at Bear Stearns, where he started off as a junior assistant to a ?oor trader at the American Stock Exchange. His ascent was rapid. At the time, options trading was an arcane and dimly understood ?eld, just beginning to take off. To trade options, one had to value them, and to value them, one needed to be able to master such abstruse mathematical confections as the Black-Scholes option-pricing model. For Epstein, breaking down such models was pure sport, and within just a few years he had his own stable of clients. "He was not your conventional broker saying 'Buy or 'Sell Xerox,? says Bear Stearns CEO Jimmy Cayne. "Given his mathematical background, we put him in our speciahproducts division, where he would advise our wealthier clients on the tax implications of their portfolios. He would recommend certain tax-advantageous transactions. He is a very smart guy and has become a very important client for the firm as well." In 1980, Epstein made partner, but he had left the ?rm by 1981. Working in a bureaucracy was not for him; what?s more, in rubbing up against ever greater sums of money during his time at Bear, he began to feel the need to grab his own piece of the action. In 1982, according to those who know Epstein, he set up his own shop, J. Epstein and Co., which remains his core business today. The premise behind it was simple: Epstein would manage the individual and family fortunes of clients with $1 billion or more. Which is where the mystery deepens. Because according to the lore, Epstein, in 1982, immediately began collecting clients. There were no road shows, no whiz-bang marketing demos -- just this: Jeff Epstein was open for business for those with $1 billion?plus. His ?rm would be different, too. He was not here just to offer investment advice; he saw himself as the ?nancial architect of every aspect of his client's wealth from investments to philanthropy to tax planning to security to assuaging the guilt and burdens that large sums of inherited wealth can bring on. want people to understand the power, the responsibility, and the burden of their money," he said to a colleague at the time. 12/ 9/1 5/2010 Print Page Page 4 of 7 As a teacher at Dalton, he had witnessed ?rsthand the troubled attitudes of some of the poor little rich kids under his charge; at Bear, he had come to the realization that, counterintuitively, the more money you had, the more anxious you became. For a middle-class kid from Brooklyn, it just didn't make sense. From the get-go, his business was successful. But the conditions for investing with Epstein were steep: He would take total control of the billion dollars, charge a ?at fee, and assume power of attorney to do whatever he thought was necessary to advance his client's ?nancial cause. And he remained true to the $1 billion entry fee. According to people who know him, if you were worth $700 million and felt the need for the services of Epstein and 00., you would receive a not?so?polite no-thank~yon from Epstein. It's nice work if you can get it. Epstein runs a lean operation, and those close to him say that his actual staff based here in Manhattan at the Villard House (home to Le Cirque); New Albany, Ohio; and St. Thomas, where he reincorporated his company seven years ago (now called Financial Trust Co.) numbers around 150 and is purely administrative. When it comes to putting these billions to work in the markets, it is Epstein himself making all the investment calls there are no or portfolio managers, just twenty accountants to keep the wheels greased and a bevy of assistants many of them conspicuously attractive young women to organize his hectic life. So assuming, conservatively, a fee of .5 percent (he takes no commissions or percentages) on $15 billion, that makes for a management fee of $75 million a year straight into Jeff Epstein?s pocket. Nice work indeed. It has been rumored that Linda Wachner and David Rockefeller have been clients, too, but both parties deny any such relationship. What's more, who ever heard of a ?nancial adviser turning down $500 million accounts? All the speculation and mystery has proved fertile ground for some alternative Jeffrey Epstein stories the most bizarre of which has him playing the piano (he is classically trained) for high rollers in a Manhattan piano bar in the mid~eighties. Another focus of curiosity is the relationship that Epstein has with his patron and mentor Leslie Wexner, founder and chairman of the Columbus, Ohio~based Limited chain of women's?clothing stores. Wexner, who is said to be worth more than $2.5 billion by Forbes, became an Epstein client in 1987. "It's a weird relationship," says another Wall Streeter who knows Epstein. "It's just not typical for someone of such enormous wealth to all of a sudden give his money to some guy most people have never heard of." The Wexner~Epstein relationship is indeed a multifaceted one. Given the secrecy that envelops Epstein?s client list, some have speculated that Wexner is the primary source of Epstein?s lavish life but friends leap to his defense. "Let me tell you: Jeffrey Epstein has other clients besides Wexner. I know because some of them are my clients," says noted m&a lawyer Dennis Block of Cadwalader, Wickersham Taft. sent him a $500 million client a few years ago and he wouldn't take him. Said the account was too small. Both the client and I were amazed. But that's effrey." Epstein' current residence in Manhattan a 45,000usquare-foot mansion on East 71st Street - was originally bought by Werner for $13 million in 1989. Wexner poured many millions into a full gut renovation, then turned it over to Epstein in 1995 after he got married. One story has Epstein paying only a dollar for it, though others say he paid full market price, which would have been in the neighborhood of $20 million. Epstein then undertook his own $10 million gut renovation (special features: closed-circuit TV 12/ 9/15/2010 Print Page Page 5 of 7 and a heated sidewalk in front of the house for melting snow), saying to friends: don't want to live in another person's house." There are other houses as well, including a sweeping villa in Palm Beach and a custom-built 51,000-square- foot castle in Santa Fe. Said to be the largest house in the state, the latter sits atop a hill on a 45,000?acre ranch. He had it built because of the month or so he found himself spending there, talking elementary particle physics with his friend Murray Gall-Man, a Nobel Prize?winning physicist and co?chair of the science board at the Santa Fe Institute. Epstein also owned a grand house (he has since sold it) near Wexner's opulent manse at the center of the Limited magnate's high-end housing development in New Albany, Ohio. New Albany was a lush sprawl of farmland on the outskirts of Columbus that Wexner, starting in 1988, turned into a rich village of multimillion~dollar Georgian homes surrounding a Jack Nicklausmdesigned golf course. It was a massive development project, ?nanced largely by Werner himself. Epstein was a general partner in the real~estate holding company, called New Albany Property, despite putting only a few million dollars of capital into the project. "Before Epstein came along in 1988, the ?nancial preparations and groundwork for the New Albany development were a total mess," says Bob Fitrakis, a Columbus~based investigative journalist who has written extensively on Wexner and his ?nances. "Epstein cleaned everything up, as well as serving Wexner in other capacities -- such as facilitating visits to Wexner's home of the crew from Cats and organizing a Tony Randall song~and~dance show put on in Columbus." Wexner declines to talk about his relationship with Epstein, but it is clearly one that continues to this day. Not that it helped Epstein in any way to land Clinton. Wexner is a staunch Republican donor, and Epstein, aside from a small contribution to the president's legal-defense fund, has given more to the likes of former senator A1 D'Amato. What attracted Clinton to Epstein was quite simple: He had a plane (he has a couple, in fact the Boeing 727, in which he took Clinton to Africa, and, for shorter jaunts, a black a Cessna 421, and a helicopter to ferry him from his island to St. Thomas). Clinton had organized a weeklong tour of SOuth Africa, Nigeria, Ghana, Rwanda, and Mozambique to do what Clinton does. So when the president's advance man Doug Band pitched the idea to Epstein, he said sure. As an added bonus, Kevin Spacey, a close friend of Clinton's, and actor Chris Tucker came along for the ride. While Epstein got an intellectual kick out of engaging African ?nance ministers in theoretical chitchat about economic development, the real payoff for him was observing Clinton in his m?tier: talking aids policy with African leaders and soaking up the love from Cape Town to Lagos. Epstein brings a trophy-hunter's zeal to his collection of scientists and politicians. But the real charge for him is in seeing these guys work it. Like former Democratic Senate leader George Mitchell, for example. In Epstein's mind, Mitchell is the world's greatest negotiator, based on his work in Ireland and the Middle East. So he wrote the senator a bunch of checks. Says Mitchell: "He has supported some philanthropic projects of mine and organized a fund-raiser for me once. I would certainly call him a friend and a supporter." 12/ 9/15/2010 Print Page Page 6 of 7 But it is his covey of scientists that inspires Epstein's true rapture. Epstein spends $20 million a year on them encouraging them to engage in whatever kind of cutting-edge research might attract their fancy. They are, of course, quite lavish in their praise in return. Gerald Edelman won the Nobel Prize for physiology and medicine in 1972 and now presides over the Neurosciences Institute in La olla. eff is extraordinary in his ability to pick up on quantitative relations," says Edelrnan. "He came to see us recently. He is concerned with this basic question: Is it true that the brain is not a computer? He is very quic Then there is Stephen a at Harvard. Epstein ?ew up to laboratory in Cambridge this year to witness an experiment that was conducting and Epstein was funding. Namely: Is it true that certain Tibetan monks are capable of holding a distinct mental image in their minds for twenty minutes straight? "We disproved the thesis," says "Jeff was on his cell phone most of the time -- he actually wanted to short the Tibetan market, because he thought the monk was so stupid. He is amazing. Like a honeybee -- he talks to all these different people and cross~pollinates. Just two months ago, I was talking to him about a new alternative to evolutionary He got excited and sent me a check." Epstein has a particularly close relationship with Martin Nowak, an Austrian biology and mathematics professor who heads the theoretical-biology program at the Institute for Advanced Study at Princeton. Nowak is examining how game theory can be used to answer some of the basic evolutionary questions why, in our Darwinian society, does altruistic behavior exist? Epstein talks to Nowak about once a week and ?ies him around the country to his various homes to deliver impromptu lectures. Over the past three years, he has written $500,000 worth of checks to fund Nowak's research. This past February, Epstein had Nowak over for dinner at the 71st Street townhouse. It was iust the two of them (not including the wait staff), and Nowak, making use of a blackboard in the formal dining room, delivered a two~hour highly mathematical description of how language works. After dinner, Epstein asked if Nowak wanted to meet up with his new friend President Clinton, and off they went to a nearby deli, where Clinton regaled the starstruck former Oxford professor with tales from his own Oxford days. "Jeffrey has the mind of a physicist. It's like talking to a colleague in your ?eld," says Nowak. "Sometimes he applies what we talk about to his investments. Sometimes it's for his own curiosity. He has changed my life. Because of his support, I feel I can do anything I want." Danny Hillis, an MIT?educated computer scientist whose company, Thinking Machines, was at the forefront of the supercomputing world in the eighties, and who used to run R821) at Walt Disney Imagineering, thinks Epstein is actually using scientific knowledge to beat the markets. "We talk about currency trading -- the euro, the real, the yen," he says. "He has something a physicist would call physical intuition. He knows when to use the math and when to throw it away. If}: had acted upon all the investment advice he has been giving me over the years, l?d be calling you from my right now." On the 727 these days, he has been reading a book by E. O. Wilson, the eminent scientist and originator of the ?eld of sociobiology, called Consilience, which makes the case that the boundaries between scienti?c disciplines are in the process of breaking down. It's a view Epstein himself holds. He wrote recently to a scientist friend of his: "The behavior of termites, together with ants and bees, is a precursor to trust because they have an extraordinary ability to form relationships and sophisticated social structures based on mutual altruism even though individually they are fundamentally dumb. Money itself is a derivative of trust. If we 9/15/2010 Print Page Page 7 of 7 can ?gure out how termites come together, then we may be able to better understand the underlying principles of market behavior and make big money." So how do termite grouping patterns fare as an investment strategy? Again, facts are hard to come by. A working day for Epstein starts at 5 when-he gets up and scours the world markets on his Bloomberg screen each of his houses, in New York, St. Thomas, Palm Beach, and New Mexico, as well as the 727, is equipped with the necessary hardware for him to wake up, roll out of bed, and start trading. He will put some calls in to his private banker at PMorgan to get a reading as to how wealthy investors the best gauge of market sentiment, he believes are reacting to the market's movements. Then he will call currency traders in Europe. On a given day, he will spend ten hours or so on the phone after all, he is running $15 billion essentially by himself. Strangely enough, given his scienti?c obsessions, he is a computenphobe and does not use e-mail. like to hear voices and see faces when interact," he has said. Given the huge sums he has to invest, he focuses on assets with extremely high liquidity, like currencies though he dabbles in commodities and real estate as well. Those who know him say he is an impulsive, trader, still governed by Ace Greenberg's trader's maxim: If the stock is down to percent, sell it. He has been on the short side of the Brazilian real, and those close to him say bets there have paid off in spades. He recently took along position on the euro before its rebound on the basis that Europeans were too proud to see their currency sink any lower against the dollar. His next targets: an across-the?board short of the German stock exchange and a possible attack on the Hong Kong dollar peg in light of the recent disclosure of North Korea's nuclear? weapons program. None of this is investment rocket science, but getting the direction and the timing right, no matter how conventional the investment idea, can spin large money for an investor. Before taking a big position, Epstein will usually fly to the country in question. He recently spent a week in Germany meeting with various government of?cials and ?nancial types, and he has a trip to Brazil coming up in the next few weeks. On all of these trips, he flies alone in his commercial-jet-size 727. Friends of Epstein say he is horri?ed at the recent swell of media attention around him (Vanity Fair is preparing a megapro?le, and the Villard House of?ce has had a barrage of calls from other media outlets). He has never granted a formal interview, and did not offer one to this magazine, nor has his picture appeared in any publication. Yet for one so obsessive about his privacy, one wonders didn't he realize that ?ying Clinton and Spacey around Africa was going to blow his cover? As he said to a friend: "If my ultimate goal was to stay private, traveling with Clinton was a bad move on the chessboard. I recognize that now. But you know what? Even Kasparov makes them. You move on." 2/ 9/15/2010 DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, er al. Case No. 50 2009 CA 040800WMBAG EXHIBIT 6. 7. AFFIDAVIT 0F BRADLEY JAMES EDWARDS I am an attorney in good standing with the Florida Bar and admitted to practice in the Southern District of Florida. I am currently a partner in the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos Lehrrnan, PL. In 2008, I was a sole practitioner running a personal injury law ?rm in Hollywood, FL. While a sole practitioner I was retained by three clients, L.M., E.W., and Jane Doe to pursue civil litigation against Jeffrey Epstein for sexually abusing them while they were minor girls. I agreed to represent these girls, along with attorney Jay Howell (an attorney in Jacksonville, Florida with Jay Howell Associates) and Professor Paul Cassell (a law professor at the University of Utah College Of Law). I filed state court actions on behalf of L.M. and E.W. and a federal court action on behalf of Jane Doe. All of the cases were ?led in the summer of 2008. My clients received correspondence from the U.S. Department of Justice regarding their rights as victims of Epstein?s federal sex offenses. (True and accurate copies of the letters are attached to Statement of Undisputed Facts as Exhibit In mid June 2008, I contacted Assistant United States Attorney Marie Villafaiia to inform her that I represented Jane Doe and, later, Jane Doe I asked to meet to provide information regarding Epstein. AUSA Villafaiia did not advise me that a plea agreement had already been negotiated with Epstein?s attorneys that would block federal prosecution. AUSA Villafa?a did indicate that federal investigators had concrete evidence and information that Epstein had sexually molested at least 40 underage minor females, including E.W., Jane Doe and L.M. I also requested from the U.S. Attorney?s Office the information and evidence that they had collected regarding Epstein?s sexual abuse of his clients. However, the U.S. Attorney?s Office declined to provide any such information to me. The U.S. Attorney?s Office also declined to provide any such information to the other attorneys who represented victims of Epstein?s sexual assaults. I was informed that on Friday, June 27, 2008, at approximately 4:15 p.rn., AUSA Villafa?a received a copy of Epstein?s proposed state plea agreement and learned that the plea was scheduled for 8:30 am, Monday, June 30, 2008. She called me to provide notice to my clients regarding the hearing. She did not tell me that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. My clients did not learn and understand this fact until July 11, 2008, when the agreement was described during a hearing held before Judge Marra on the Crime Victims? Rights Act action that I had ?led. In the summer of 20081 ?led complaints against Jeffrey Epstein on behalf of L.M., E.W., and Jane Doe. 10. 11. In the Spring of 2009 (approximately April), I joined the law ?rm of Rothstein, Rosenfeldt and Adler, PA. I brought my existing clients with me when I joined RRA, including L.M., E.W., and Jane Doe. When I joined the ?rm, I was not aware that Scott Rothstein was running a Ponzi scheme at RRA. Had I known such a Ponzi scheme was in place, I would never have joined RRA. I am now aware that it has been alleged that Scott Rothstein made fraudulent presentations to investors about the lawsuits that I had ?led on behalf of my clients against Epstein and that it has been alleged that these lawsuits were used to fraudulently lure investors into Rothstein?s Ponzi scheme. I never met a single investor, had no part in any such presentations and had no knowledge any such fraud was occurring. If these allegations are true, I had no knowledge that any such fraudulent presentations were occurring and no knowledge of any such improper use of the case files. Epstein?s Complaint against me alleges that Rothstein made false statements about cases filed against Epstein, that RRA had 50 anonymous females who had ?led suit against Epstein; that Rothstein sold an interest in personal injury lawsuits, reached agreements to share attorneys fees with non-lawyers, paid clients ?up front? money; and that he used the judicial process to further his Ponzi scheme. If Rothstein did any of these things, I had no knowledge of his actions. Because I maintained close contact with my clients, EW, LM and Jane Doe, and Scott Rothstein never met any of them, I know for certain that none of my clients were paid ?up front? money by anyone. Epstein alleges that I attempted to take the depositions of his ?high pro?le friends and acquaintances? for no legitimate litigation purpose. This is untrue, as all of my actions in representing L.M., E.W., and Jane Doe were aimed at providing them effective representation in their civil suits. With regard to Epstein?s friends, through documents and information obtained in discovery and other means of investigation, I learned that Epstein was sexually molesting minor girls on a daily basis and had been for many years. I also learned the unsurprising fact that he was molesting the girls in the privacy of his mansion in West Palm Beach, meaning that locating witnesses to corroborate their testimony would be dif?cult to ?nd. I also learned, from the coarse of the litigation, that Epstein and his lawyers were constantly attacking the credibility of the girls, that Epstein?s employees were all represented by lawyers who apparently were paid for (directly or indirectly) by Epstein, that co?conspirators whose representation was also apparently paid for by Epstein were all taking the Fifth (like Epstein) rather than provide information in discovery. For example, I was given reason to believe that Sarah Kellen, Larry Visoski, Larry Harrison, David Rogers, Lonella Rabuyo, Nadia Marcinkova, Ghislaine Maxwell, Mark Epstein, and Janusz Banasiak all had lawyers paid for by Epstein. Because Epstein and the co-conspirators in his child molestation criminal enterprise blocked normal discovery avenues, I needed to search for other ordinary approaches to strengthen the cases of my clients. Consistent with my training and experience, these other ordinary approaches included ?nding other witnesses who could corroborate allegations of sexual abuse of my clients or other girls. Some of these witnesses were friends of Epstein. Given his social status, it also turned out that some of his friends were high-pro?le individuals. 12. In light of information I received suggesting that British socialite Ghislaine Maxwell, 13. former girlfriend and long-time friend of Epstein?s, was involved in managing Epstein?s affairs and companies I had her served for deposition for August 17, 2009. (Deposition Notice attached to Statement of Undisputed Facts as Exhibit BB). Maxwell was represented by Brett Jaffe of the New York firm of Cohen and Gresser, and I understood that her attorney was paid for (directly or indirectly) by Epstein. She was reluctant to give her deposition, and I tried to work with her attorney to take her deposition on terms that would be acceptable to both sides. Her attorney and I negotiated a con?dentiality agreement, under which Maxwell agreed to drop any objections to the deposition. Maxwell, however, still avoided the deposition. On June 29, 2010, one day before take Maxwell?s deposition, her attorney informed me that Maxwell?s mother was deathly ill and Maxwell was consequently ?ying to England with no intention of returning and certainly would not return to the United States before the conclusion of Jane Doe?s trial period (August 6, 2010). Despite that assertion, I later learned that Ghislaine Maxwell was in fact in the country on approximately July 31, 2010, as she attended the wedding of Chelsea Clinton (former President Clinton?s daughter) and was captured in a photograph taken for US Weekly magazine. Epstein alleges that there was something improper in the fact that I noti?ed him that I intended to take Donald Tramp?s deposition in the civil suits against him. Trump was properly noticed because: after review of the message pads confiscated from Epstein?s home, the legal and investigative team assisting my clients learned that Trump called Epstein?s West Palm Beach mansion on several occasions during the time period most relevant to my clients? complaints; (13) Trump was quoted in a Vanity Fair article about Epstein as saying "I?ve known Jeff for ?fteen years. Terri?c guy." "Hewith. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it -- Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passe] of Nobel Prizewwinning scientists, CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he ?ew Bill Clinton, Kevin Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder who he is. By Landon Thomas Jr.; I learned through a source that Tramp banned Epstein from his Maralago Club in West Palm Beach because Epstein sexually assaulted an underage girl at the club; Jane Doe No. 102?s complaint alleged that Jane Doe 102 was initially approached at Trump?s Maralago by Ghislaine Maxwell and recruited to be Maxwell and Epstein?s underage sex slave; Mark Epstein (Jeffrey Epstein?s brother) testi?ed that Tramp ?ew on Jeffrey Epstein?s plane with him (the same plane that Jane Doe 102 alleged was used to have sex with underage girls) deposition of Mark Epstein, September 21, 2009 at 48-60; Trump visited Epstein at his home in Palm Beach the same home where Epstein abused rninor girls daily; Epstein?s phone directory from his computer contains 14 phone numbers for Donald Trump, including emergency numbers, car numbers, and numbers to Trump?s security guard and honsernan. Based on this information, I believed that 14. 15. Trump might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. Epstein alleges that there was something improper in the fact that I noti?ed him that I intended to take Alan Dershowitz?s deposition in the civil suits against him. Dershowitz was properly noticed because: Dershowitz has been friends with Epstein for many years; in one news article Dershowitz comments that, ?I?m on my 20th The only person outside of my immediate family that I send drafts to is Jeffrey? The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair; Epstein?s housekeeper Alfredo Rodriguez testified that Dershowitz stayed at Epstein?s house during the years most relevant to my clients; Rodriguez testi?ed that Dershowitz was at Epstein?s house at times when underage females where there being molested by Epstein (see Alfredo Rodriguez deposition at 278-280, 385, 426- 427); Dershowitz was reportedly involved in persuading the Palm Beach State Attorney?s of?ce not to ?le felony criminal charges against Epstein because the underage females lacked credibility and thus could not be believed that they were at Epstein?s house, despite him being an eyewitness that the underage girls were actually there; Jane Doe No. 102 stated generally that Epstein forced her to be sexually exploited by not only Epstein but also Epstein?s ?adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional and personal acquaintances? -- categories that Dershowitz and acquaintances of Dershowitz fall into; during the years 2002-2005 Alan Dershowitz was on Epstein?s plane on several occasions according to the ?ight logs produced by Epstein?s pilot and information (described above) suggested that sexual assaults may have taken place on the plane; Epstein donated Harvard $30 Million dollars one year, and Harvard was one of the only institutions that did not return Epstein?s donation after he was charged with sex offenses against children. Based on this information, I believed that Dershowitz might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. Epstein alleges that there was something improper in the fact that I noti?ed him that I intended to take Bill Clinton?s deposition. Clinton was properly noticed because: it was well known that Clinton was friends with Ghislaine Maxwell, and several witnesses had provided information that Maxwell helped to run Epstein?s companies, kept images of naked underage children on her computer, helped to recruit underage children for Epstein, engaged in lesbian sex with underage females that she procured for Epstein, and photographed underage females in sexually explicit poses and kept child pornography on her computer; newpaper articles stated that Clinton had an affair with Ghislaine Maxwell, who was thought to be second in charge of Epstein?s child molestation ring. The Cleveland Leader newspaper, April 10, 2009; it was national news when Clinton traveled with Epstein (and Maxwell) aboard Epstein?s private plane to Africa and the news articles classified Clinton as Epstein?s friend; the ?ight logs for the relevant years 2002 - 2005 showed Clinton traveling on Epstein?s plane on more than 10 occasions and his assistant, Doug Band, traveled on many more occasions; Jane Doe No. 102 stated generally that she was required by Epstein to be sexually 16. 17. 18. 19. exploited by not only Epstein bat also Epstein?s ?adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional and personal acquaintances? - categories Clinton and acquaintances of Clinton fall into; ?ight logs showed that Clinton took many ?ights with Epstein, Ghislaine Maxwell, Sarah Kellen, and Adriana Mucinska, -- all employees and/or co~conspirators of Epstein?s that were closely connected to Epstein?s child exploitation and sexual abuse; Clinton frequently ?ew with Epstein aboard his plane, then suddenly stopped raising the suspicion that the friendship abruptly ended, perhaps because of events related? to Epstein?s sexual abuse of children; Epstein?s personal phone directory from his computer contains email addresses for Clinton along with 21 phone numbers for him, including those for his assistant (Dong Band), his schedulers, and what appear to be Clinton?s personal numbers. Based on this information, I believed that Clinton might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. Epstein alleges that Tommy Mottola was improperly noticed with a deposition. I did not notice Mattola for deposition. He was noticed for deposition by a law firm representing another one of Epstein?s victims not by me. Epstein alleges that there was something improper in the fact that I noti?ed him that I intended to take the illusionist David Copper?eld?s deposition. Copper?eld was properly noticed because: Epstein?s housekeeper Alfredo Rodriguez testi?ed that David Copper?eld was a guest on several occasions at Epstein?s house; according to the message pads con?scated from Epstein?s house, Copper?eld called Epstein quite frequently and left messages that indicated they socialized together; Copper?eld himself has had similar allegations made against him by women claiming he sexually abused them; one of Epstein?s sexual assault victims also alleged that Copper?eld had touched her in an improper sexual way while she was at Epstein?s house. Based on this information, I believed that Copper?eld might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. Epstein alleges that there was something improper in the fact that I identi?ed Bill Richardson as a possible witness against him in the civil cases. Richardson was properly identi?ed as a possible witness because Epstein?s personal pilot testified to Richardson joining Epstein at Epstein?s New Mexico Ranch. See deposition of Larry Morrison, October 6, 2009, at 167?469. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable inference he was sexually abusing these girls since he had regularly and frequently abused girls in West Palm Beach and elsewhere. Richardson had also returned campaign donations that were given to him by Epstein, indicating that he believed that there was something about Epstein that he did not want to be associated with. Richardson was not called to testify nor was he ever subpoenaed to testify. Epstein alleges that discovery of plane and pilot logs was improper during discovery in the civil cases against him. Discovery of these subjects was clearly proper and 20. 21. 22. necessary because: Jane Doe filed a federal RICO claim against Epstein that was an active claim through much of the litigation. The RICO claim alleged that Epstein ran an expansive criminal enterprise that involved and depended upon his plane travel. Although ndge Marra dismissed the RICO claim at some point in the federal litigation, the legal team representing my clients intended to pursue an appeal of that dismissal. Moreover, all of the subjects mentioned in the RICO claim remained relevant to other aspects of Jane Doe?s claims against Epstein, including in particular her claim for punitive damages; Jane Doe also ?led and was proceeding to trial on a federal claim under 18 U.S.C. 2255. Section 2255 is a federal statute which (unlike other state statutes) guaranteed a minimum level of recovery for Jane Doe. Proceeding under the statute, however, required a ?federal nexus? to the sexual assaults. Jane Doe had two grounds on which to argue that such a nexus existed to her abuse by Epstein: ?rst, his use of the telephone to arrange for girls to be abused; and, second, his travel on planes in interstate commerce. During the course of the litigation, I anticipated that Epstein would argue that Jane Doe?s proof of the federal nexus was inadequate. These fears were realized when Epstein ?led a summary judgment motion raising this argument. In respo?nse, the other attorneys and I representing Jane Doe used the ?ight log evidence to respond to Epstein?s summary judgment motion, explaining that the flight logs demonstrated that Epstein had traveled in interstate commerce for the purpose of facilitating his sexual assaults. Because Epstein chose to settle the case before trial, Judge Marra did not rule on the summary judgment motion. Jane Doe No. 102?s complaint outlined Epstein?s daily sexual exploitation and abuse of underage minors as young as 12 years old and alleged that he used his plane to transport underage females to be sexually abused by him and his friends. The ?ight logs accordingly might have information about either additional girls who were victims of Epstein?s abuse or friends of Epstein who may have witnessed or even participated in the abuse. Based on this information, I believed that the flight logs and related information was relevant information to prove the cases against Jeffrey Epstein and accordingly I pursued them in discovery. In approximately November 2009, the existence of Scott Rothstein?s Ponzi scheme became public knowledge. It was at that time that I, along with many other reputable attorneys at RRA, ?rst became aware of Rothstein criminal scheme. At that time, I left RRA with several other RRA attorneys to form the law ?rm of Farmer Jaffe Weissing Edwards Fistos and Lehrrnan (?Farmer Jaffe?). I was thus with RRA for less than one year. in July 2010, along with other attorneys at Farmer Jaffe and Professor Cassell, I reached favorable settlement terms for my three clients L.M., E.W., and Jane Doe in their lawsuits against Epstein. On July 20, 2010, I received a letter from the US. Attorney?s Of?ce for the Southern District of Florida the office responsible for prosecuting Rothstein?s Ponzi scheme. The letter indicated that law enforcement agencies had determined that I was ?a victim (or potential victim)? of Scott Rothstein?s federal crimes. The letter informed me of my rights as a victim of Rothstein?s federal crimes and promised to keep me informed about 23. 24. 25. Dated: subsequent developments in his prosecution. A copy of this letter is attached to this Af?davit. (A copy of the letter is attached to Statement of Undisputed Facts as Exhibit UU) Jeffrey Epstein also ?led a complaint with the Florida Bar against me. His complaint alleged that I had been involved in Rothstein?s scheme and had thereby violated various rules of professional responsibility. The Florida Bar investigated and dismissed the complaint. I have reviewed the Statement of UndiSputed Facts ?led contemporaneously with this Af?davit. Each of the assertions concerning what I learned, what I did, and the good faith beliefs formed by me in the course of my prosecutions of claims against Jeffrey Epstein as contained in the Statement of Undisputed Facts is true, and the foundations set out as support for my beliefs are true and correct to the best of my knowledge. All actions taken by me in the course of my prosecution of claims against Jeffrey Epstein were based upon a good faith belief that they were reasonable, necessary, and ethically proper to ful?ll my obligation to zealously represent the interests of my clients. I declare under penalty of perjury that the foregoing is true and correct. 2010 Bradley J. Edwards, Esq. DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISP UTED FACTS Epstein v. Edwards, er Case No. 50 2009 CA EXHIBIT MM EC . .973}? Gilt Aircraft Make Aircraft Points of Departure Ari-Surat Mifes Flight Remarks, Procedures, Nur?ber Aircraft i and Model identi?ca?on Mark Fiown No: Haneu?vers, Endorsements of Landings mm; From To I Gum-5mTi?a?T (:va LN artfo?f?rmw - Lu 1" - pg LS 311,, (gig ??lms; Mew\567 363:0? 1 ?i WW ?38? mm ?396?? 1 "2 (5 ?10:1 M4 09556 (9certify that the statements made by me on thi? form are true. page 7033: ?6 (RI Amoun: Forward ?5ng . . I 0 . 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I K0 ?5 GLI. 3 a: WAT gig-i1 ?x?v-l Kali-ya" 2" (7 (:fa?) ?mfg-e) as?? {3 1:31? am. 3c car?? that the statements made by me on this form are true. - i Page Total Amoumizomard 3 99? ?gqb Pziot's Signature ?otal to Date {9 2? i 93:5 kg :1 Aircraft Make and Model Aircraft ?dersti?cation Mark . ?g is I n1 wwv??t To ?a .- - 3?5- Pain - - - - is of Departure 8. Ara-Na! Wes Flight Remarks, Procedures, Number Aircraft mam Flown No. Maneuvers, Endorsements of Landings . . I . - p.11 K. ?a?lr?i?mh? V: X??im .M ?w-Nm asan 43?? Tu?3'v'3?x?u 1 ii 246?? E3 $91 :3 gr, a may? Via-K} ?131362/311. 134; Lu: Wat-(gum) 1K: mm 51.1 \13 A {3-29 a: ?21112: um.? VNEI I MU VV ULLT 35:. HQ 713.gal/?M 3 3 v} {:5ij 3 g: *1 nag-a A 1? *4 (.1: v- - - ?31; i 1 we Mug?m - MM, Jr If; Qua}; {,wa LIV- ?L?Larm .) *4 .M unmask-?AW. 3, 1 r? h? ?Vii-1M W??i"Lila'n'n 3 Law?. 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NM 33:.w3wiirb (fr"5?3 D. 7323 kiwi: 3x: 9% is a) 3H airmanr3.? .. - '7 EC: ?94-99% E3 3 \3 ?r )Alm?h A: 5Q 3?3? m-cz?iw?wt Lie??mnrw} 5* ul .. {7?0 ?u :63 {4112. Lacs a *1 a? 1 3.39% :37" "7 . few-m .r'mhsw; ?g?amw M?lyi?f(~51 Ck a \vl mm 312x: DI: an? five?:1., {z?cz?fb?f? ?3 43am;va Iff??ligwarfg 5?5 v? - 7 I 3? VPWC WA {Ibis-?w rim335W (33 g} m: Tm 115;?. x: .5: 316:3: i?G?icenify that the statements made by me on this form are true. Page Tomi 3? I 4. xv? Lia?6' gal-9 Jr J3 ,rJ f? . [in Amount Forward 5,2510 .1 fit-PadsSignatm ?a qua Totaito Date yg q) i] Date Am?) Aircraft Make and Mode} Aircraft identification Mark Points of Departure Arriva! Miles Flight Remarks, Frocedures, Flown No. Maneuvers, Endorsements Number of Landings Aircraft From :35} To 53*?72?7? IQ 1 ?i 0836?; a TI \i 5:33- LC: 1. iv . - mg, ?41? 3&33)? 1'33 "2?le 'bifi?v I Bi ?5 AFT hip?; 55.) I, . Ier?\ M. If} a? . ?waging/?12; in'U LL. -- - (amia'as'v?? c: R39 '6 i certify that the skatements made by me on this form are true. LE Cr. ?314?: .0qu 3" ygduz. I 55-5! ??363? N?ww 19:53:: u. C. Cb fa ?JLgd?em 7 (it mam" Luau CH I I {?51 I if) L58) 8 04;: L. . '34 mama L2: - L9 ?a?tm?movc 7. ?pb?fi o? 4f?) Page Total 5 (@151:ch Amount Forward Pifot?s Signature Total to Date Date Aircraft Make Aircreft Points of Departure Arrival Miies Ffighi Remarks, Procedures, Number Aircraft and Model Identification Mark Ffown N0. Maneuvers, Endorsements of Landings ?ip . lee") From To ?333,qu p?i4gyvoz?r 32-: await -, - . a? m, ?3 . w- ?32; (gm augngN raspupe-z?mwracxr - {:15 1.53193 *3 I (?IU?ris?f 9? J. \93 axe-m3?? amaz?ievc I ?3 2.. (7y 01 {5 Maggi: a 9, ?gig ?3,23 1 1 F) (1 We {'?b?bLm -I2M. 1153? GM ?553333;; . 1? 7 I: $11; 313: ?gfevz'fgw Ll 2\ W3 '53f-r i-?Fbgw? 1H 1? sax; a 2?0 - .. . Lye {ea awe-ww?m?; we.? was mark: JM 38% XWM lb *t we? 24% ?re? Ti," ?43 3. f) {at} 5-5} 200316;}? in m: nixei-fe?a?/ <53P?man Tully; Qu?m(at: a! Liqu i I I . . 3? ?wih?i?h?: {3?31 g} QT 1 3123??) 1.13 xx \i No . mm? ?uwa EL f?uklsf rich-g ss mu Auto skew-41??) 32. EST TEST L?r??w x} Slips-1:: 32. N?b?mk T157 ZSQK 7.36?. mm pk, T?s?czamz? La?eh?ii?fww . 3' 7 certify that the statements made by me on this form are true. Page Tote; I w: 3 - 2 .4. Amount Forward I L1 i 3 21 f? ink? Pilot's Signature?avj all? 144*? Total to Date 1066! '7 ?1(92. 2 VJ LI.) Date Airc?aft Make Aircraft Points of Departure 8; Arrival Miles F?igh1 ?ne-marks, Procedures, Number Aircraft and Modei identification Mark From To Flown No. Maneuvers, Endorsements of Landings Awfn?m? L): m? yam/141 x? (acme LEKQ C161 IKE, min?! ?xewm, urgi?ifawix11': I 359% E5 0106156 \9 T66 qi?a Mam33? Tar-3:. 194.. f? ?5 a (5 pry. L361 ?53? 13in; max; VizwysogQ-m g; 1 emm? Nqoctgye ?$2231 33 1): mm 7. 5* 53: tam-3"" 1 1 CY 1:543 ?3 z. a CVUL W5): ni??x" mamaflux Jim; 9 ?33Fi?gi?f?gc?yjj 21 T1:er m- a :3 at 33>: @352?? t/ 1+ *1 545% N?oq 3e 1945 i; 4'1 WW 1 (-3 I 1129: let?147139: 0/0 mtg-136553; K7313 Hi 1? 21 Ml?x/ I 1 I sanity that the statemenzs made by me on {his form are true. Page Tote! c! mm Forward ?01 g- 3 13 Piiot?s Signature?;i?wi?x i" Total *0 Date Ch 3 ?45, ms ?mm $23? Sf??iims 1:35? From To Lg; Gum? 35 ?7 2:113 p; 0m (5333? 3? 6m: we, 3: 1?5 ?ggi'm .Wf Li: . iffy 1 5- @6537 ?33257 cm, ?4 Epwqm um? am L55 may21.3% I 1 certify that the statements made by me On this form are true. Pilot?s' Signature (bu-5?36 9) \3 emsw ?oqje T63 1M1 ?1 P.) 13?; WM 9?36? i/ '3 9 lo ?1 956: 3:15: 20 v~ ?rst? Tm?? ma?a 334: ?25 25 ?12. <39 1? 155.3 3t/ 1' 7) 73M 1 NW6?"5x (345% ma; 7% 1w 5- '33? i655L639 TM Ami: L696 L015 Li 1-1 Li 0 1?1. as {bf 17/37 harm" gamma? "3 ??~th> Sy-?o Lam M199 Miler I f+ .s Page T0256 8 1? (- Amcuni Forward ,3 (1 3 Total to Date a" 3 Aircraft Make and Model Aircraft identification Mark Points of ?eparture 8. Arrivai From To No, Flight Remarks, Procedures, Maneuvers, Endorsements Number of Landings Aircraft Gum-.4. {5:1 ?2:1 ?ab pm 32% Imp; I 2_ 0 4-111 3511ma?ge?z 5 . .. mam-.My) am" $315"; ammuv certify that the szatemems made by me on this form are true. . - qk a? . Pilot?s Signature ?43- Vii-9" 3' rs} away alwwr? my 8 C?xs?i 9 at 061.3 Ll ?4 T6353 j: Qr?j $31119: M, Wm} 1.53s ?f?fs-gm: ,w at 321*.an Ml??igivv-g99h; .1 ?~14 4?61 mm 6'1: k; mew Warm mg; Gm {we mom 09c, it 17:3,; 1:331. 6&9 Hg 44?: rv'r'i?rar?z ?m A Beg{git} 7 ?I?fa??f?r (9 2am Tam my: 1mm 3:13iv?? 33.43ng I- i I ?5'3 .35 g/ 7 km} 73? ?93% Wait? 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M. l_ if ?xx Amount Fomard f3 Piiot?s Signatut?ij Cuff: 36144;, Total to Date Ci 7 Date Aircraft Make AirCraft Points of nepa?ure Arrivai Mites Flight Remarks, Procedures, Number Aircraft .493: and Mode: ideniification Mark Fiown No. maneuvers, Endorsements of Landings . From To QLEQIHL A . d. 1? Ni.? {51"723r7?17- :53? T. 23bi?z??ra?2e2? eig??t?km I 1 15 3 F1 2."Z's 5? (.3 E3273: 5?1 ?o?je 17V 3? 1513 Tibf \bg{huas? 13:51 :1 3 is?? we amaziep19, 1 Ma, 3e ,59, 5 Mm e?m- LV 7 z; \c lg?q 3&3 31.3; 51!, u. if) 155%. 75(5:17:14ny g? (3'cediiy that the statements made by me on this form are true. page Total (3/29 A Amoum Forward '5 3 . - (33:44- . Piiofs Signature 1 (Gui/3f j/ i Var" t? Bate ?3315; :5 I 1?3 My"- Aircraft Make and Model Identi?cation Mark Points of Departure 8: Arrival Flight Na. Remarks, frocedures, Maneuvers, Endorsements I certify mat the statements made by me on this form are irue. Page Amount Forward ~1 Piiot?s Signature% From To I Az? qum. zqyj?r'371Nmr5KJTD '98: 2am MVSQES PB: Tag mi 5?:110 T636 Ma?a) ?57 F3620 lam 1 ?ap T?-gc} iBzLP?S?awvm?zm pg: M63565 RESK {5 :2 2: ram meme my: 9K lugm??i} 3'94 L995 1% M?a?f??qkm Wt?gg? o- Lgf'ja 9! ("kw H: a 3% 25? $5731: Nani?19:! aw 3 Lf 15? JE. (?312.95? ?a?wiis?i a \Uf- 8 'n W561 1533M NW);le pm (7 mm :39; 2511? 3a, (gm, a. 3 g7 {3 255% TD vhm?asd Cork 5 5 8 Total to Date Aircraft an? kk?xgg. 5 I certify that the statements made by me on this form true. my Pilot?s Signature Page Toiai Amount Femard 70:81 to Date Data Aircraft Make Aircraft Points of Departure 3! Arrival Miles Ffighz Qemarks, Procedures, Number Aircraft and Mode! Identificat?on Mark Fiown N0. Maneuvers, Endorsements of Landings oar-i From To i. .9 @3qu at? w} a; {10% 39597.. ?63? "2.23 m? 7?7 3 a gateway: 353damp LiEsq Egg?); 7 3 1" .m ?x v? (3: 53% ?la31! ?gt-N M: may {Cilia ?1 "7 {25" 1? I $453.0 1L8 I 3&16 NM: TD .14; 1% 37(10?45Lib-~17: 1 1?57 .3 $1 \4 Mr; ?aw Wei Wakig?w Rama 99:9st 5 1 :l f) Mg? laggijxi mum7,15; m? (Sif?mal; $119630?; H?omum Af?l A - . - .. n59fit-u?ngwr {k ?Ya 3K 318an?? 'f-Smh?i?cu MM 2mm? "Cf?"Liga??fg??u 1. - .. :3 law-?wit? ?K?nm -. 3a m. x; ?sx .21- a: .x L, .13: aix? "28:1 If(37> CVWET A) Tag 1?3 43" 3:11 3 q- I v? Date AirCra? Make Aircraft Points of Departure 8. Arrival Miies Flight :nemarks, Procedures, Number Aircraft and Mode! ident??caiion Mark Fiown N0. Maneuver's, Endorsements of Landings 1 From To ?8 Te 8 6&9 ?3?18 34*; 33$;me 01 3&0 um M219 g?iwa/ I T85 '50 6:1: :5 2.6 3?5 {39> 2: TEST Vi? 335%,; 2* 3 6 2w 9)::mU L??m [was a??luowix. C) ?4 MED mm! ?mmjA/\ [mfg ?9m? C315: ?32) -, .3 was) 74? . "1 "l mr Q'chg 22:06m: 7 5:52;? 11923-353": ?DNi-v 6 63) 49:1 -3 angry 3? QC. 125:, Baumv?sxm; gig} 1/1 ?5 Rig? it M): T1967 3 f? ., . a .. Pr!- p? IL . )1q?5? E) J: 24:35 t? 2-. 6" \k (3 251x ?Eefgi?fibm?l?f Smw?f? 1m 3616? 36:, ?511, Sigrid Lea 353, 3: 345;," ngl?f?gmg? ?apmpw?lm tm 2 5 i certify that the statements made by me or; this form are me. I I Page Total 3 .. Amoulni Forward (E '3 Pilot?s Total to 9am i :irgra? make Aircraft 2.0351 MOdel identification Mark Points of Devanure 8: Arrival We I a? 0 7'2. From To Fiowsn Eight gamma! pmcedures (-- I amen" 753' "Tl Ci (3 j: Endo meats Aircraft Catego 1 I ij?? I Li A I . ?afwiv?: ?0 gri?p??'wvm mw2.65": e? - SVK L956 L6 1% LO a Line EGGW 2?40 49%! [\?mizg?omgtv 1?2, \2 2?93 ??W?Wmm ??mgm?w 55? I, - . I 230? I ?*1?in Law (3 "\qu ?3 Wocx?re FBI: 2 1? 3&1?ng Sis/L \ll Li mm 2? Pf?: T66 Hose; :35; {he 1 2% Tm PB35:; WNW T659 HVN 1,was?) ?.?3ifwi?m5?VMJW Ly - ?Ta? . . "2m ?1 ma?a ms lCeriifythatme 3? i 1' State em 3 made by me on this form are true PziotsSIgnature . otai . Mi Amount Forward I . Total to Date ( R?marks, Procedures, Date Aircraft Make Aircraft Points of Departure Arriua! Flight Number Aircraft and Model identi?cation Mark N0. maneuvers, Endorsements ofLandings a mg From 3'0 . 311" 1?3 9:406: :11: T6133 mmv' rm 395(542:: ?33 Hr Ncloce?? e? PL 1?713?rv?5i??r'3 3% 5? :57 2:73 'S?rmamiw?? ?a?ix 5 "71:67 1' 34,5,? 1? 2L. 7A cw H311 '5 0%:52: ml: Tar?) naq?FI??w? ?u NM LV ?33ffy?g/ mysag Max:311 GR pg, 1 12% my}, 1 mr 7 ?i Teri? P?f rm? 44' :33 ?L?gia??m?r?r *5 \q $121143? 510%:38 559: ff 5t)" 23% ?gg?r?235%, 33 fv? 15K, 5 S'Tc?xst: 19/ (7535;; 123-1 '3 I t/i {Lot ?Leif?7K5 L?'f?Pr 2,15; ?5 L699 LPBL 1801433M'3iwm 333K111) ?th certify that he matements made by me on this farm are true. . I fxExg/?TA I Pilot?s Signatureg ?i141?! $313.? Page Totaf Amount Forward (5?1 '1 '1 Tot I to Date a by} G. c5?) 0" Date Aircraft Make and Model Aircnaft :dentification Mark Poiats of Departure 8: Arrival Pram To Remarks, Procedures, Maneuvers, Endorse-meats Number of Landings Aircraft era baggie: i Ni?t?riit i396 a: 36: awf-?SJA. .12? . L369: 9919:1th Lin; 352? A?vil?iltiaif?) i: 36; 2.9 a: A ?35; 2.0 ?5 a: as; {3 ?Mai: giltLave, 3? gig ?Te331% ,1 m. {iv-135% :95 mot-m s5:? T1343 i Ms lei Tag}; Ly; 4? ?Tia 1. 9,144 as"? (EM If)? LV 3 a: Li?s? ?it! ?332127?3 3-43 8 11am Tags xix, ~33 {f3 if; lSK?bgwa Vv'i a mm 3'5, Ni?; L?v? 1g, 1 a 75:3 $519 :32- A M0 mu?? WW w! 3L: 6 i cenify that the Statements made by me on this form are true. 0 $11] A Piiot's Signatur?h Page Totai A mourn! orward 3.4 ?total to Date i .cf: -F a I ces?fy that the statements made by me on form are true. Page Total 7/2: Date Aircraft Make Aircraft Points of heparture 3: Aniva: mes Flight n?marks, Procedures, Number Aircraft 1 4.9.: and Mode; identification Matk Fiown No. Maneuvers, Endorsements of Landings - 2% From To ?a?m?r?wxm Ham}; ?592? (I: ?33:74 is N61613: We 1'3? 20 2:19; Mama 3% A >1 15m3i: 3'33?" 1 ?35 1733'? as? {Lad t?fm 2.3 2.142: 051.313; @823: ma GM, Mg? V?j LI 218 6?12: am N?b?fg? Trix" 6K Cimri'l? 1/ (-4 0 36% 596?)? 3% 3.235 a; 2.. as 9332:) Qua Lmogmm {:95 33)- W-a was: {out-raw 9; 3 5 3 ll 3 ~L~5muwwi ?1 it i I i E?i?W'zwb?i?th??L m) 35?5 33E: 57?? :21. MW 3 T3137 WaysT31be hm $152, NM, 3K LV '7 as, 914%?) 'Lv 123:) L5): 1233* Lv ?315746 {0033:2033 (1-: Ga W4 Vii-$1 331% 3?me ?p??f'g?inwm?a??wx??Vi W1 1 geagg j: LV 1/1 3; L?s/i (0 \i fir-3? I DHN 2_ Piiot's Signagure wee??1 arde Amount Fozwaz-d (Jakarj 3 Total to base (?033 D?o? 3? I - Da?e Aircraft Make Aircrafz Points of Departure a Ara-5m! Mites Flight Remarks, Procedures, Nvmber Aircfaft .0493; and Model identi?cation Mark From Me. Maneuvers, Endorsements of Landings I - 1:15; From To Baggy?? ba?hri . f. i . 535 325$? 5512?: $163 I ?13:3 B, 0? ?37; IV 3 ?3 K. Luv/5 11-1 W3 1; '3 3?>13" 3? 15 acf?r MW .n 09/1}, 3K, mm ?JFL-b?tg1c: ?137%;be 3V3 Cf 3.1313: I gxicr. L, ($1119.351C1 175:3.1- 375?: J: M525??:23 ?am '52.:1 ?3 Wm mamucnraamr Lg.) - 934;: 1? . if i rust-v5; ma?a I 3m?th 5 33?? NM 324:} MIT. 5&0, saw; mmwm? my. 1L v, x, are, Sm?? want; 319%, lee, Jew: :ww Cmcma?: ?f?gm?oir}, {cvt?mawrmm 1 )0 8 (43?46% SUE ma: i?r? GM ?ux, 10?0"; c; .Euwa4mg?? p?ctm?ym mam 5 1'7) 35.9%} 110 if) Vt) WM 7 cenify that the statemenis made by me on this form are we. page C1 {f1 g, Amount Forward "5 '1 863 Pilot?s Signature aha-1"- tk'kg? i 3-: Total to Date 0% 71'? 1 i 1' Date Aircraft Make Aircraft avg-9:39 and Mode? identification Mark Points of Departure 8: Arrival Remarks, Frucedures, Number From To Maneuvers, Endorsements of Landings ?23? 8 "1214153 Cloi??r (5-K r9552 ts?fa 21% fer ??/Wasww? 33.1% Mg ?11 1:3? Cit/?Cult. ?$1555; .. {355i 99K LN g/ 1 sg?gK T4353 Q, gm LV {77> Nam-3e- F?fl 3?3 ??3?93?8 Mme- ?611 1* ?r151 Tm rm?mswiv12. :25 man-w owe ?rm? @3?1 ?a 36?; E13) :61 G?u?-m ml: 36?2", :m 321.: 3:53 AM, Lv . gags-3: Tag Ea, QM) NM LV .73 35:33") ~10? 6mm mam-z, LP, Q. m; jMa??M? waned.qu i\ it Ra? $69-74? w; v' $52 Total to Date - . . I wab?b ?109511 3K i certify that me statements made by me on Ms form are true. Page Tom! 1 I La Amount Forward Pilot?s Signaiure 6?4? ECU (A ?rm-aft Date 'Aircrai: Make Aircraft Points of Departure Arrival Miles High! Remarks, Procedures, Number Aircraft and Model Menti?caiion Mark Flown N0. Maneuvers, ?ndersemenzs ofLandings 1&5; From To (Salk-{1. saga/arr 43"; rs ?916}: ?mgr; rm (3:94.33: 2. 5 so 3? T68 mgr-Tamra,in NM 5H ?h m: - mug-q 99? 5K 13? 45 26> 34Lmm?) 1 2- <23. 3 EVE 1:35;. EIQD {321,9 TIP, mu 9, tamer; 81?} 3 (3 TLST NM EH 1/ $1 1 ?T?zf? rm? 3K NM - r\ f3?) Wruj??g?x L/?l ?23 {0 Tail-3 ?9 5'51? 13-95% 3> 22,. my; Tar?) 3? NM 2.35? wad?? PM. 1 3-H WK Tara ?13.33an m7 '1 ea- 16 1* - 'T?fr W1 3mmT337 199:: 73> ?5 53:7 I 3 $7.57 m3; 333: i I kl/ CL 1* 73'! Tag sea-arr 3H 31.. 1-3 3 Egg-a) p9 fr? j; i491: 1;th rug?f?TQ 05mg). 1 Icenifythatzhe statemems made by me onthisform areirue. page Total 1 LI I Amoum Forward Pifot's Signature Total to Date 618;; (5 Daie Aircraft Make Aircraft Points of Departure Arrival Miles Flight Remarks, procedures, Number Aircraft and Modei identification Mark Fiown N0. ?aneuvers, Endorsements of Landings 4 mi)! From To . Ammww 7 WU: 9? 1/ szit??g?. fit?C? (mm Ma?a 593%: 333:, 32:: PM: NM 16 in) 1: T?jff 381'"? 3 NM Tag 183%? A ,5 ($14 Isa-m amg?kpamumgg :29 3? 491537?: '15??53? 1am 3c: .08T633 cm Sizixmm. mm 1 Cf 375'? mm was; 3e. gig LV v; ?i 9.: ?5:0 I 35;. AM .NM 25-, 18:4; LV 1 in {was ram N?iisb??aj?? LC 6: LC Ci? ?5?43 ?am? 62:21.43" I 1 7 i2. Tifv'?? 7.33% 3% :34, AM NM ?223; 0/0 7 ?ng 6,455,315 A951 bckS-?: Tag 133% Egg; (5m;ng LV 8 35:39 06:20 i855 (TM LV 05w $36.9 g; $56213 Te: 343,37 ?4 '33? 934-24141? Mom-e; TEST SK Elia 9:5 Th? MK rag-2. 3th . C: icenifythatthe stgzemenzs made by me on this form are true. ?mwi?*??mm 533.5%18: a in I. Amount Fomard (19,31. (-33 ?lers Signature Total to Date ?19353? Aircraft Make Aircrait i certify that the statements made by me On this form are irue. Page Tote: Points of Departure 8. Arrival Mites Flight Remarks, Procedures, Number Aircraft 149::- and Model idenzi?ca?on Mark Ffown N0. Maneuvers, Endorsements of Landings . From To I at M'sa 76313 This? 2% 1; Whey,? a H: 3313*; ?ii?f? 3 r} 3* 5? MatCYUL. 181:2, mam ?13. 523C219 Tag mm 342., (251mm; 17-: 5,1: ?NMr-y DJ 01 616%?2?2172 m; 27% E132 3 31 T35 7 T5913 7542.; mum 59%} . 29 T??x E?i ?516*? Ez?f-?g??alg?? 1% '3 35:5 {Es mus-?5?? E) "@353 $52 E3 35 3% ?1 6&3) ?Fw? 15' 'n 2212.. a? M64 cs?'?gjg 51$25336sz me +Lp~$w gamma-sari) LV 33a} 1:14;? LES stage av ?3 us i i *9 ?at-D NM 3} g: 153;: Ian; ?gliadj?x?k 1 1? Pilot?s SignaturQCR Gil RCA if) vww0@w Amount Femard (EEK-KL) - v. Totalto Ekate 48891 :5 13131 PNG From To ram amp?? Guam i'f?aicoj 2i Nci?c?x? 5?99? x3164?! 55mm? x/l '7 ?v N7 1736 65? 3'51) 3* Tc? 12? H31 T68 \3?82 3/1 2 Tess Per 1383 v?iwr??: 1L 3 g) I Egg :i'?sj (EM, 29 f} C?cz?i Kft?p? (?363, F399 3 21 1331: 30?? 1 15,. 1? i: T5531 Knew-Y 1' 9 it.) .TE 6 13% G??amz?} 13%! T5) fema 1 V1 3 '30 Tis-j" I P63: man 311:; P6324: MAWWO12@594? (=16.st ?1 it may: 16:13 pm 33/0?: (31? 1/ I T58 RePanm? (46:38 P9935 5 Aim; LGQ \3?13?36?Beam?" Mamas 1 3 r: i @363 136;?: TE, 5 Hem Lewis 1/ (g zcertiry that the stat ems made by me onthisform aretme. Page Tomi EBA I Sq 7 I. Amount Forward 7375; 0! Hip L, Pilot?s Signature Tatai to Date '75! 3?3: {91 ?5 h? I Date Aircraft Make Aircraft Points of. Departure Arrival Mi?es Fl?ght "Remarks, procedures, Number Aircraft and Modei identi?ca?on Mark Fiown No. Maneuver's, Endorsements of Landings 10:0 From To ?mpi?B?e i sit :5 M01 03336 G- 9? L69 ms; Lewis 3 Kala-LL? ?lmr'im {mar}; 2x 1* mm . . ?i?g?a??t?i?fsw 2 3 C7 Eds-Gm1un 3515??: mama?? was :33 ?ch E56 T5065 Nos? 3' ?a 33;, T625: we Tai?mrmow Sac/mew 1 MEV Mag :63! Levis; 36.66315 2? 171-63 1ch La?? 5?55(1MB 2. x22. 918icemfymatthe statements made by me on this form are true. page Total H/c? 3 ?76135 4: 3 3 UL Pilot?s Signature (6427/61 ?Wag/Q, ?rota: to Date .7 5? OI .--. Date Aircraft Make - Aircra? Points of Departure an arrival Miles High: hemarks, ifrocedures, Number Aircraft and Model Mentificaiion Mark Flown No. Maneuvers; Endorsements of Landings am From To 032?ng (7mm: Hanna? 3?31" (3 48501 5&083'? ESQ-D ?Tail? 1mg '33; Bel-Li"? .11 xx T55 We] 3&1a9} swamev Lewxs /1 1 11 0 Ca M345 195 Wm 33%? i? ?50 5?61 11122-353may {c1234 T53 ?iw?b ?3 :1 ?r-t ASQ 39c 11125 Rayo?cmu 5 1 59? T628 m??i?m 5 5: it ?Tag . lama-3316??! at ?1 gm?) i433 1?42, Racy 6mm 7 ?esw E6 ?l?M um 7 ?i EC: (ECGmm? Sf?mm u. w?j it ?u (933): . T528 H33 ?ew/1w 1 Tag 11st HSH 116:, (arm, I 3 5. ,4 M35 $011 MS 1 1 9 am 99; 913 \ngfz?S icertify that the statemems made by me on this form are we. Page Total 6, Ab qs Amount Forward {(213372- 76161 1 ?1 3 3 m: Pilot's Signature Total t? Date 803-} 3 1 LL i: I Eage-i Aircraft Make Aircraft Points of Departure 8: Mrival Miies F?i?ht Remarks, Procedures, Number Aircraft 39"} and Model - Identi?cation Mark Flown No. Maneuvers, Endorsements of Landings in; 3.3 3,1; From To . FEQRBNE (32.10% ?cme f?v' ?(0&3ij 1C ?3 k" 11539H ?"53:? 7! a. Eu?. 1? EAL, 1 ?$3.alga!? (V $3,352.51Ngim?g 3: Elev M?s-o ?vm?oi?a?Vim shot?aimfl, {ale 23' Gug?? Ncio??m T645 azz?ije?w? TWMW Vi (5116ser TEMGLE 1 ?so?wce Cam-'1 Pm .- . .- In? wail?? c. I UWHS 99)? Viz?Liu'i?i?fw?lmzw?M? um: .. .-.. - v- .3 av?; may}! fail ?9&9 .r 30.31386. $93: 2 1:11 at mg ?27 a .3 ?30 "ff?5T I 35 3? h' 11 99-3: iaqgj?fam, Er 1/1 '7 330' i? i beM, (?571. w: Wamvr 6253 '99" ?9 1/ i; 1 wag; 3413,65?? {Rik-159W?! GQ?w?rb-C} 5K ?29 ?995 1'2. ?56-:ij ?awM243 12m ?i?q??iaW i2. ?5 it icenify that the statements made by me on this form are true. I Page Yozai Cf ?5 1 . Amount Forward C1 3) 'x i 4- Pilot?s Signature W) 16/1 in}, Total to gate i. . I: - .-- .. "t - - a. an? :23: 5 an; i cenify {hat the Statements made by me on this form are true. Dege Aircraft Make Aircraf? Points of Departure Bx Arrivai Miles Flight .Remarks, Procedures, Number Aircraft 19:13 and Modei identi?caiion Mark Flown No. Maneuvers; Endorsements of Landings I.- KUN From 7? - ?maave 0mm: {@me 14? 1mm :9 2.75m mirrwa r? ?z?itia??jtiz?: (9m 1 3 01 Gus-?g Ncio??f?? 13% PB9,82. . . we: SG, (153?. . . z; act {3&0 1260 31? '13 us? 3?6 i T613 (061. EQEW, ?Rm? 3 {?rme New on: PPR a: PR. E/s? 3 3 ??533 @043ng Wm Mia-'1? 1753 ?rm-?r Wm? i a I 1 ?15? E??i?b?f?br 2.22 3 7 is Bil-?5? Mqu m9%u?% ?ibf?l?g?ifww 2, ?3 5?10 g?1??W 2 3 13 MQNH SW 2. 3 it; Did} W11 we? 2 a ie 9.01 it: 3.56429, ("513' ?(kw 5?56?: 3/3 7:3 ?1 15' T633 {?13 as; g, j" \z 39,9 ma, ,3 15 59? 135') mama's", Lisa ':13 OPAL xxasca '3 game?: 1 1* (a Piioi?s Page Total .1 ?Amount Forward Gq?zat:l q) Total to Date {3 1'1 . . $9 gmg?T?ig'HQWU?f?j 6 Way I certify that the s2atements made by me on this form are true. Piiot?s Signature Page Total Amount Forward 781% "Tl I bis-3% Total to {Late x] (?Egg/k ?1?qu 16%; 0393 Date Aircraft Make Ai aft - - - 19m and Model idgif?gca?on Mark Points of Departure 1; Arnval Mlies Flight Remarks, Procedures, Number Aircraft categorym Fiown No. maneuvers, Endorsements Tub To 0 a - a . [Rf 1.02% x- ?ch a" v/ G?le 3 N51 @6375; 053 . #2 .2- . 1,6 \jj-sv Jr Kit i 3' (giggling 3L. - (war-m} mama; 3; ?3332mix?, . it H. "?0133. ?1mm a1?: m? 3?33 9 qsi?m a?wkww ?TUB m9. ?12i?h??mmp'm? \?E??iam 3 . - ?us?gnu.39??r $97.91if}; Earw?y 5'63153?: "g 115?. I521: i. C. 9* {Ali-r Q) q' \51 If? "1 "1?0 18? (41L ma $07232 I ?an- 1' . ,Iq Iii? 3 2:5 qucxgxPuttsfo r) .7 255 1? ?333mice} as? 1/ 7 'T?ft? 12:13 S?ZGN-izm??r?w} {was We 2:2; i ?t it '4 *Vi'H-l" ?63 3: Ti13 5 a ?r me: Ez?I'dr nape Aircraft Make Aircraft Points of Departure Arrival Miles Flight Remarks, Procedures, Number ?ircraft Category-u 195151 and Modei identi?cation Mark Flown N0. Maneuvers; Endorsements of Landings From To 5? Nqoc?xd: 3w 5% rm 36/ We?? . V1 ?6 5 g; Ta?) :33 [ammafv?fema 903m ?33 5 ?g .2: 3? 16?6:6 mo eat-mm . 1-5" . I . U213 r2?, mama? 13 W5 I ?75??97 11%! Mad, 2g +?1.43 1% I 12592 . 1 L1 \q C. ?.117, C5731Ncrom 53.871: T613 m3 mm at? '1 2 5 "@335 mm '1 ?5 ?471 anz 4339 w: ?ervwm ?25" 45% N?i egg-r: P632121 aims WW 1/ I 9. s" 3.2 Uta-1* TE :3 1 ?3 C5 0?2? ?8-1 ?36" I L-CWLS 13 a Bat?41:3?6, 509*?: 319?? ?5 5 Tea ac? 36,614! a9, Game's? Ram?auuge'r g/l 1 I certify that the staiements made by me on this form are true. Page Total . . ml . Amount Forward ?3 '7 Pilot's Signatur; 3 T?m? 166? 3 3 3 Date Aircraft Make We. Piiot?s Signature . Total to Date T107 Wm vow w? and Model Mark ?Mm? 85 3:33; ?ight 3233;32:32233222m $323193 aircraft mam? -. m. From To mm (2mm Mt,me 645% N?io?al?e (3&0 I raw, m1, mane? ram WW 9. ?t up 95: T151- moms? 2, 5 Ks TI-s?r T66 ma I?lcvm?w?e-?w?Tee. Per 21 PB 1' - TEB 1935 35-351} wa?ou?gfg?gbg?ggw 1/ 2. 25? Tag '93 m} 34.15pm, E1-l CLhm?lmeL 1 3? pen: Tee tom ewe-i; amaze lama-t. 9. ?3 Tee 3&0 mm Lewis 3 5 gee Ban I?gsgemup awe LGWIIS 13%94/l 2L .u 1&3 set: no: $62,919, New an m?m - 5m: {303 5'6. 3 s? \3 u? ?1 SEN Resigns? ?1 ?3 SQN %\355' Se: H. 599 nee re, memo mm mm" '5 AL, is 11 Tag \367 3?6: 33ng?Se. U1 2 Tag 95 353 323:: manor eu?ovgsew Maggi CL 12 't 961: TIST mo 32., amen; mm? GPM 2 2. {certify zhatzhe szatemems made by me on this form are true. page Total 3 Amount Fomrard 3 2. '7 ?f 3 ii ,2 3 v? -- wean??53 ram?nur? emu-Aircra? Make Aircraft Pomts of Departure 8: Ara-Iva: Miles Flight: Remarks, Procedures, Number Aircraft 19m andMOdel Fdemi?ca?on mark . Fiown N0. Maneuvers, Endorse-manta of Landings .iia' . New From To 9mm Gm Hamel (:Msae N?osse PM 3?6; awe-1? w: T68 nann?mraga-Mfr 1:51 BIL :6 ?ts-r 1; an (QC-mat?. Gut. W05 . 931: Tee 166 963: ml mm mom-e, 1 stern/aw W51: RSV 1322 376? V1 mm W3 1: ms mil Seisomemet- macaw 1? . Tet} war ms 1% 55mm, Mug *4 . gddlo?gg J: r?wxm?gx ,5 was? T653, (31; 1/1 L?x 2mm NTl?-ir em 37wa Mr1?5; {3,an5 ?13 356 A La usw? Ni?wxxa T355 W): 1-323 71. 39?? i325; 41453? 0 I certify that the szatements made by me on ihis form are true. ,4 Page Totat ff C, I Amount Forward ?a I. Piiot?s Signature . a. .. Total to Date ' Data! Aircraft Make Aircraiz Points of- Departure dArriual Miies Fiighi "Remarks, Procedures, Number Aircraft Category?- ;3529 and Mode: identi?cation Mark - Flewn No. Maneuver-?, snaorsements of Landings . 3, I From To 9,3331%? (Qt?phi: C-Ci?jj v. 6- ?xsz {10333: 5% $34.1: Ga(am, agaw?e 'ify??wi? *3 "3?2 . . mm m. {gmym 5: . log1437'. 1 ?1 2662.3 WNW 69m?gwigjilj:fr fig?va/z? 1x 1&3 NW ?9va ?up "325? a 2.6671,} mm?? PM - a? ?fg??ESwi?m?i?? 1 L3 7.24?! PM #57 z? 72PM H57 2.061,} ,m 1 (J: (2 w? LL. at: gait 10L:ij FLL, 6 09 ?15 ?1 159? W9 6 NE a, u; mega may?) 1-: 15 2952.3 H410 . 1 11? 2% L3 PM?wLei - larva)? ?2&7 "1 "g wad"? in NM i 9.. '23, log} ?ww WW was. - gm? 1 amme - NM Hg 1 ?cuoIcertiiythatlhe statemenis made by me on this form are true. Page ?rota; a} 3 *m Pilot?s Signature t? 93*? mi!) (7'3 3 {1?0 . . . .?Amrh-J - .. . - - W.m.?w '3 KW ,5 Data Aircraft Make Aircraft Points of Departure Arrivai Miles Flith Remarks, Procedures, Number Aie-crait 33:51:? and Mode: identificazion Marl: Fiown N0. Maneuvers, Endorsements of Landings gag From To {Mum Gaga: 97-292; 2.3 106 L3 NW 11,? Y5 . . .Qrinrw_ gig/3;; 23a let?3&3 1303* W?lgz?k?- a: r? 2. gr, an. wig?? 7? 1 gem?3 M??me Mi7,191 1 pm? {lip?w Jim? #4 23M um f: if?? ,4 1?41 0 5? @1wa I I 9 31% 5% Was@117. Wm?? Gatpuvg??m? Large 7 LLI g; 77., 9} 15> 5,5925/1;);adwaf; (Q: r, 10M ind/9 geld? 5-5 I. 5e JLK/n?fifa Ky. x?iz?-j?[Jivi )6 foli?/Q lg? 57 fc? A ?vita 17.; Rubim?mml mum?- . A C. ?3331663'3? {7:3 W5 1: - 77112:: a; Be: 3:49;; am): ER 351;? 1 -2.. {?rff?g?ivgawa?, 9.541 impiygfv'?155'"? Vwa A Muwmw mm.? *r 195 1: ran; War-M. I ?Tmm'? . a. . ?3 (bra -- ., ??53" J?w -. av wr Abb-quh.? I I k? L. ?5 ?Lie 53:4 a Isaak?? a Q5 celiify that me made by me on this form are true. page TomAmount Forward a ?uxPiioi {Date Aircraft Make Aircraft Points of Departure ?rrival Miles Flight ?emarks, Pyocedures, Number Aircraft 138;) and Mode} Beati?cation Mark Flown N0. Maneuvers, Endorsements of Landings Am, From To mewt?ie Ohmictjz. ?5 mt?? 6 amt: 3-3137 3&5225322?3 I ?5 H, 161:6 t?ta?ts 2 it 69 "$653 .w \33?13?33?0; 3/ t' Lt. 1? ?1 T66 713$ get,er t/ 3 3d it ?ng Tats :re, min/:7 Lt it T?tb MOW 13642. tzammt} 01 ?31 tt H. mm) T626 13% ?Stat . . @353: 75:15 em 1/ ?1 CC 1{ T625 3 8% Gmt'i Wm?? 0\ t7. sac tam-ch 7 x; 51:0 tzq?? 1. 5% L95 it? 2. was (PM 1360 3?9 0 i1 t< MW (37% (551 '3 6t tt at @553: ?226 IG- 22.1? :25 - *1 T66 39?) f?t?af?t?m? Sew? 7% '7 35 t. ?mw?r tat) tast v1- 3 7? 25 tt 'T?b (98 655 R@b?ifm? I at 1 Li 2 certify that the statements made by me on th?s form are true. Page Totai Fit/r}, 0] 01 Amount Forward "n 5'35 ?6 j) 3 We? Signature Total to Date :13 - -wn- r. rem To ?30 641.5% 676:? Tiff 1555 @6675511333 A) Qum"3'13? 65") Ting; Sap?jtg 2 ?3 6965;: ma? 13:55 ?gg 5- 5 WW ?29" (a 3? Fm LL60 138:, 111mm 1/ I) ?1 *i was (mmx Be; i?j?m ,7 vamAX Law 13g}, 0] 3? L666 3/5ng TQGM .7 3? EGGW EEGM 13?: Gm ?l 3? ??PrPr @393 m3, Sajem T635 min 1 Te?) 96 i rm 3&6 ?re-Ate? 1/1 1 t? It \Bgcf 32315 32? 5 I x3103fg?ng?mid: I 3: 6:919 W??a?mas I, manic: Manon?:20?; 1 1?s (36; 59,; mg 3:5, 1/ 3 i cenify that he statements made by me on this form are true. Page Tota: 5 7 2' PMS SignaturQ Amount Forward 7 3 3) . Totalto Date (9065? ?l Date Aircraft Make- Aircraft Points of heparture arrival Was Right Remarks; Procedures, Number Aircraft Category-u and Mode; identification Mark Flown No. Maneuvers, Endorsements of Landings - From To 9mm? {Aim/c l'f?bfl?w r} it, ?i ?v T?z? 25350 "5?5 7? 3* ?$66 - -- 15%? 33?? 1 2H 56;" EB): T69 83231? V1 2 T68 B): 1383 .1 3 ED Bl", Km% I ?1 ?335? F399: 3 Of 1? x: T55 59;, 6% fr; em, as; 30? mar-am, 1 31mm LP 1' 175 S9 :3 Lam Tg? 395Mam?G ?a $9 13% 3 ?30 ms: was 73%? WW: 1 (g 12?? 314;} {rm} {gr} 1 5 Tag (7 63>: m; ??i?Levj?s \b $61: We, 333 35:; Err if? \3 - 1?6/3} 13%- {40% 99% \3 L603 LCPQ) 33%? 361'] VOW: 7 35* n. 1?9536 ?9 3 53 \395 I 3 @6153 c? gm Tax, 5 Raw Gr Lam/:3 1/ {u lcertifyzhatthe stat ems made by me enmistorm are true. Page ?feta! ?3 SCI 7 a: 737M 3 3 nu, pm Signature LV 430161 mm to Date 323;;- 765 as: a ?3 ?3 hi, I: Date Aircraft Make Aircraft . Points of neparture Arrival Miles Fiight "Remarks, Procedures, Number Aircraft 49.: and Modei Identi?cation Mark Flown No. Maneuver?, Endorsements of Landings --, 21900 From To ?z?pc??e (Tum/e, Magma; of"? 6-4 1 sci 5 M61 ogre (3 Lei} 13cm EQISBELW Lawwife; GM, c;ij Kiwi)? 633mm (may 2 mm TEST fl 3 .23 1? ya .1 :51. EUUK- Nolsa?yrwm 3 c7 ?25. 31 GGW No} 323/ (rm; (D 25;; Geow {6 err-9; 1cm 3" NWwa Tasmev 2. 7 3 Tic)? {315 5: we? Swag? 1 ?1 Q3385: Hog 3&7 Levis] 36-56% 1A 1 .1 T157 ?Wag ja?aacauw sessw 1/ Ta?) 98 I No 35?} Er 3 a} Pier}: 114x335; 1/1 2. 2. w; (MW 933399 VAN mn??(36; Eat? 2L certify that the statements made by me on this form are true. Page Total n/C? 3 I Amount Forward a] 35 L3 ?5 1 (3 Pilot?s Signature (WM: t" Date of 3 1 Li Date Aircraft Make - Aircraft ?.491; and Mode? identification Mark 94%: From 435515 3? 0836cenify that the siatements made by me on this form are ?ve. 5 . Pilot?s Signaturech ?1 Points of bepadure Arrival 5 Dcer 51 ?36 ?233 ?18 Miles Flith Remarks, Procedures, Flown No. Maneuvers; Endorsements Number of Landings Aircraft LEW Hat; at? 0C8 5963; 13:53" 0 mg <53, Lei/v.15 we; 3'63; 5 chvuis HeLutt-g MBA EGJGM Cam (3M 1:42: Tit} Gum} Rag-7063.? I GM GM, (?4:35 Mm - m, ems-5?, Kai?L7 (6116M K43W5W E3 I?d 1 95%; refComm. Yuw?s'il swam-372mg ?f 8 ?3 I Tg?g?gfg?y . r1 pr?mgm?i?b) Ream? 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"3/55: - .. r' 2' Dent;ngt Aircraft Make Points of {Departure Arrival Mites Fii?m Remarks, Procedures, Number aircraft 191? and ?039' Mark Flown N0. Maneuvers, Endorsements of Landings A, {mmxt From To Rem,ch an . . I agcz - - . i 43123 $951.} 2.2.0059; 19mup?; . Wm "Mi?L?s 30?)2101;, 1:5 300:3 p; 91%?.pr? 1-. - xx?? ?9 ng'rv? (~5h3?1? Ncib?sy? 1235 $19? gmu?2?r>JgQr L, wa'ilr 9'15 I: i 31112; his?) $131373 {3sz ~sz @xpm9 Sb LC: 'G?p L5 @6579? 9 '6 K. (g?usmvs my: PG. me, 1'3 31% h: TEST ?51 2m {332?ng 2, a *x?j CL ?1 yaw at fgzj: ~f?i?5 \f?l 3L {5 "3 bk T133 3134 mama, "3 3m I ?wiifi?gz?i?? mes-m.? PB 1: xterm Lira" mu?) @063 rim SOL-U Lou? 3?ch3 9m? - m?Prma 9:61 ?"83 i rm; Tablet-5 - Pratt?s: 51%. '1 avg?) WW7 {Ev ?i We: Gu?g Move T66 :08} :23 ?rm-f 2.. 5 5'2? <9r?$1mwzr 2? raw; Mrm?rw if icertify that the statements made by me on :his form are true. Pilot?s Signature ?r?J 14% M. Page Tozai lb as Amount Forward 31' 1?0tal to Date ?1 Li (.7ng DEFENDANT BRADLEY J. EDWARDS ?8 STA TEMEN 0F UNDISP UTED FACTS Epstein v. Edwards, et a2. Case No. 50 2009 CA EXHIBIT urxuwzuues Lazy; FAA b618059846 USAO CONFRM 026 (?J-Jill DPJL f" . Department of Jus?ce Federal Bureau of lnvesligatlcn West Pain: Beech Suite 500 505 South Flagler Drive West Palm Beach. FL 33401 Phone: (581} 833451? Fax: (561} 833-7970 January 10-. 2003 Re: (3359 Number:- Dear This case ts currently under lnvasttgatlon. This can be a process and we request year continUed patience while we conduct a thorough investigative. As a crime victim. you have the following rights under 18 Unlted States Code 3771:- (1) The ?ght to be reasonably protected tram the accused: (2) The right to reasonable. accurate, and timely notice of any publla mun?pmceeding. or any parole proceedlng, Involving the crime a! of any release or escape of the accused: The right not to be excluded from any such publlc couzt unless the. court. after receiving dear and? convincing evidence. determines that testimony by the Victim Nettie be materially altered It the victim been! ether testimony at that pmceeding; (4) The ?ght ta be reassembly heard at any pubttc proceeding in the district court Involving release, plea, sentencing, at any parents proceeding; The remmbte tight the cenfer the attorney for the Government ln title case; (8) The right to tutt and timely reafftU?an as pml?de? In 18W: The ?ght to free frem unmme-bte delay: The right to he treated with faimese and respect for the victim?s dignity and privacyt We will make our best efforts ta ensure you am awarded the rights Most of these rights pattern to events occurring after the arrest or indict-nan! of an meivldua'l far the crime. and It will become the reseanetb'iltt?y of the pmecutlng United States Attorney's Of?ce to enema yet: are awarded those rights. You may 3350 seek the adch of a private attorney wllh; meme to these rights. The Victim Natt?aatien System (VHS) is designed to pmvide you with direct infeana?on {ageth the case as It brasserie mmugh the Justice system. You may obtain current Manhattan about this matter on the lntemet at or tram the VNS Gaitcanteret (14366465- 4968) WOW: 1~866~22846 19) (international: 1 in addition. you may use the Call Center or tntamet to update yew contact infemellen endler change your deeislen about {Jar?cipa?on in the nati?ceticn: p?m?gram, it yet: update you: Information to include a. curt-?enigma? addrees, send infomatinn tn thetaddress. Y'au will need the tettowln?g Victim ldan??cattan- Number (VIN) ?1941737' ehtl Personal leentl?-eatfen Number (PIN) '5502' anytime yea cantata! the Gen-Center and the ?re: time you. leg on to an the lntemeh In addition. the ?rst time yet: amass the VHS inteth site. you wilt be prompted to enter your last name (or business name) as currently contained in Wis; The name you should enter ls Vl? 07/09/2008 15:14 FAX 5618059846 USAO WPB @1027 WA. U-JU lf- you?have addi?onat questions which Involve this matter, ptease cantact the. 0mm listed above_ When you call. [steam pmvidu the ?le number iocazed atthe tap at this #31131: Please remember. your participation in the no??cg?o?n part of this program is voiuntary. In card-er 10? continue to receive nol??cations. it is your to keep your contact information current Sincerely, 4-23me Twlier Smith Victim Specialist 07/99/2098 15:15 FAX 5618059846 USAO WPB CONFRM 028 JEN. 0331. LLS. Department of Justlce Federal. Bureau of Invas?gation FBI - West Palm Beach Suite 500 505 Sooth Flagler Drlvo WW Palm Beach. FL. 33401 Phone: (561) 833-7517 Fax: (531) 333.7970 January us. 2003 James Elsenborg Ono Clo edeke Center Ste 704 Airetratlan South West Palm Beach. FL 33401 Re: Deer James Elsonborg: You have requested to receive noti?cations for This case is woently under lovostlgatioo. This can be a process and we request your continued patience while We conduct a thorough investigation. As a c?rne?viotlm. you have the lollowirzg rights under to United States Code?? 3771: The right to be reasonably promoted from the. accused: (2) The right to reasonable. accurate. and timely notice or any or any parole {evolving the wit-ire or of any release or escape of'the accused; ?rho right not to be axoludoo from any such publio court proceeding. unless the court. after - receiving- olear anti eonvlnolng avldenoe. determines that testimony by the victim would be materially altered if the victim heard other testimony at that (6) The right to be reasoneon heard at any public prowedlng In the dlot?rlct mun involving release, plea. sentencing. many parole proceeding; (5) The - reasonable right to confer with the attorney for the Government in the case; (B) The right to full and timely restitutan as provided in law; The right to proceedings free from unreasonable delay: The right to be treated fairness and with respect for the victim?s and privacy. We metro our treat efforts to ensure you are accorded the rights described. Most of these rights pertain to alter the arrest or Indictment of an for the crime. and it become the responsibility of the Uolted States Attorney?s Of?ce to ensure you are accorded those rights. You may arise seek the oovloe ol 3 private attorney with respect to those rights. Tho-Victim Noti?cation System (VNS) is designed to pmvido you with direct Information regerdlog the case as pmmagmrough the justice system. You may obtain current htonoatlon about matter on lhe Internet tat-.GGV or from the W8 Call Center at (1-366-365- 4953} lY: rose-228461) (international: In addition. you may use the Call Center or Internet to update your content information aodlor change your doolslor'r about participation in the noti?cation progmn.- ll you update your ?rnforroatlon to Include a current email a?ddroos. VNS will send information to that You will need the following Victim Identi?cation Number (WM) 19417451? and Personal identi?cation Number (PIN) anytime you contact the Call Center and the ?rst time you log on to VNS on the Internet. In addition. the ?rst llrne you access the VNS loternet site. you be prompted to enter your last name Eor business name) as currently contained in VNS. The name you should enter ls Eiseoberg. ulzuaz LUUO 4.0.1.0 FAA 0010003060 WEB UUNFRM DBL ?3273]. If you have additionai ques?uns whim Invalua this mailer, please mutant the o??ce 1?de show. When mu can. piease provide the ?le numha?: heated atthe top of this letter. Please remember. yaw participation in the noti?cation. pan of this pragra'm is voluntary. In order to continue to receive noti?cations. it is your responsibility to keep your contact I?formauon current. 3 Incemly. ?Milo: Smith Victim Specialist wlumwuo mm anwuauaqu usao WPB 030 3.3. Department of Justice Federal Bureau of Investigation FBI West Palm Beach Suite 500 505 South Fiagi'er Drive West Palm Beach. FL 33401 Phone: (561) 833-751? Fax: (561) 8334970 May 30. 2003' Ro: Deer Your name was referred totho F?i?s Victim Assistance Program as being a possible victim of a federal crime. We appreciate your assistance and cooperation while we are investigating this case. We would like to make you aware of the victim services that may be available to you and to answer any questions you may have regarding the criminal justice process throughout the investigation. Our program is part of the FBi's effort to ensure the victims are treated with respect and are provided information about their rights under federal law. These rights include noti?cation of the status oi the case. The enclosed. brochures provide information about the FBi's Victim Assistartoo Program. resouroes and instructions for accessing the Victim Noti?cation System WW 5). VNS is designed to provide you with information regarding the status of your case. This case is currently under investigation. This can be a process and we your optimized patience while we conduct a thorough investigation. As a crime victim. you have the following rights under 18 United States Code 3771: The right to be reasonably protected from the accused; (2) The right to reasonable. accurate. and timely notice of any public court proceeding. or any parole proceeding, involving the crime or of any release or escape of the accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence. dolor-mines that toetimony by the victim would be materially altered it the victim hoard other testimony at that proceeding: The right to be reasonably heard at any public proceeding in the districr court involving role ase, plea. sonton olng, or any parole proceeding; (5) The reasonable right to confer with the attorney for the Government in the soon; The right to full and timely restitution as provided in law; (7) The right to proceedings free from unreasonable delay: The right to be treated with fairness and with respect for the victim?s dignity and privacy. We will make our best efforts to ensure you are the rights described. Most of these rights pertain to events after the arrest or indictment of an individual for the crime, and it will become the responsibility of the prosecuting United States Aitorney's Cities to ensure you are accorded those rights- You may also seek the advice of a private attorney with respect to those rights. The Victim Noti?cation System (VNS) is designed to provide you with direct information regarding the -- more as it proceeds through the Criminal justice system. You may obtain current information about this matter on the internal at or from the VNS Call Center at {$585-$65- 4968) 1-666~223~4619) (international: in addition. you may use the Call Center or internal to update your contact information anoror change your decision about participation in the noti?cationprogram. if you update your information to include. a current email address. VNS will send information to that address. You will need the lollowing Victim identification Number (VIN) ?2074381'ond Personal identi?cation Number (PIN) '1816' anytime you contact the Cali Center and the first time you log on to VNS on the internal. In addition. the ?rst time you access the VNS Internet site, you will be prompted to ante your last name (or business name) as currently contained in VNS. The name you should orator is R. 07/09/2008 15:15 FAX 5618059848 USAO WPB CONFRM I 031 1-. I u-n nun-pn? - nu 9 JUA cam?. r'u?fit?i' if you ?ve additional questions which Invarve this matter, piease contact the of?ce listed above. When you (231%. piease provide the ?ie number located at the top of this fetter. Please remember. your participation in the noti?cation part of zhis program 13 vaiuntary. In order to continue to receive noti?cations. i113 your responsibility to keep your contact infon?nation current. Sincerely, (fig); bu, ,Ebm 11R) Twiiar Smith Victim Speciaiist TOTRL. . DEFENDANT BRADLEY J. EDWARDS STATEMENT OF UNDISP TED FACTS Epst'em v. Edwards, er al. Case No. 50 2009 CA OAOSOOWMBAG EXHIBIT LL Victims seeking sex offender's millions see painful pasts used against them Page i of 3 Print this page Ciose Victims seeking sex offender?s millions see painful pasts used against them By JANE MUSGRAVE Palm Beach Post Staff Writer Updated: 11:40 pm. Saturday, Jan. 23, 2010 Posted: tt:30 pm. Saturday, Jan. 23, 2010 One was in a Hobe Sound trailer when her father beat his girifriend's 8-year-oid son to death. Another watched her boyfriend kill himself. another was molested at 12 by her best friend's brother and was raped again three years later. Now their violent, traumatic and just plain sad lives are being used against them. Attorneys for multimillionaire Jeffrey Epstein are dredging up the most intimate details of the lives of more than a dozen women who are seeking millions from the sex offender. The women claim he lured them to his Palm Beach mansion for sexually charged massages when some were as young as 14. in court papers, Epstein's attorneys scoff at the women?s claims that they were traumatized after being paid $200 to give Epstein, now 57, massages that, for most, ted to sex. if they were so traumatized, his attorneys ask, why did they return to, 20, 50 or as many as times? if they were so traumatized, why did they take advantage of Epstein's offer to double their money by getting dozens and dozens of other girls to participate? Nothing is off limits, attorney Robert Critton has argued in court papers. To keep the women's hands off his client's money, he is seeking to prove that they had deep problems before they claim they were introduced to Epstein . "Because Epstein purportedly has ?lots of money,? they claim his actions caused their horrific damages," Critton wrote, asking a judge to force the women to answer his questions. "Yet performing in the 'Champagne Room,? dancing at strip clubs and prostituting themselves has no relevance to their claimed damages in this case? Are (they) and their attorneys seriously making this argument?" When given a chance to question the women, his tactics have been bare-knuckte. "i want you to tell the ladies and gentlemen of the jury whether or not aborting three fetuses is more traumatic than giving a man a massage in the nude," attorney Mark Luttier, Critton's partner, asked one of the women in a recent deposition. Reluctantly, the woman, who, like most of the others filed a civil suit using a pseudonym, admitted the abortions were worse. A controversial honwproseoution agreement Epstein signed to avoid federal charges was to protect the women from such intrusive questioning. "You have a number of girls who were very hesitant about even speaking to authorities about this because of the trauma that they have suffered and about the embarrassment," Assistant US. Attorney Ann Marie Villafana, who crafted the deai, told a federal judge. "So we did through the non?prosecution agreement tried to protect their rights while also protecting their privacy." 'Hyper-sexualized? women .. 9/15/2010 Victims seeking sex offender's millions see painful pasts used against them Page 2 of 3 After the feds promised to stop their investigation, Epstein agreed to plead guilty to two state charges: procuring a minor for prostitution and soliciting prostitution. He was released from the Palm Beach County Jail in July after serving 13 months of an 18?month sentence. As part of the deal, he agreed not to contest the accusations in the civil lawsuits. But, he can argue that the women don't deserve the millions they are seeking. That gave Critton the opening to question the women about the beatings some suffered at the hands of their fathers, stepfathers and boyfriends, their drug use, arrests, academic failures and their sex lives. For some, the questions were too much. Four of the 17 women who filed lawsuits have settled for undisclosed amounts. Adair: Horowitz, who represents six of the women, said it's not surprising that some would become strippers or prostitutes after their experiences with Epstein. "These women were hyper?sexualized at very young ages," he said. That they came from troubled, or even violent, homes only made them more vulnerable, he said. in a deposition, a woman identified as said she began working as a call girl and stripper after her experience with Epstein, whom she met at age 15. She said she left the "bunny ranch" business in June when she was 21. "i've been seeing and kind of realized that this life isn't for me," she said. if she was so traumatized by Epstein, Critton questions why she went to his house more than 100 times and solicited more than 50 other girls for him. Also, in a statement to police, she described Epstein as "an awesome man" who sent gifts to her baby shower. However, not all of the women have sordid pasts, according to court records. in her lawsuit, one ?Jane Doe" said she was working a $9-an~houriob at Mar-a-Lago when she was recruited at age 15. For four years, Epstein used her as his sex slave, taking her around the world on his private jet before she fled to Australia where she now lives, says the lawsuit filed by Miarni attorney Robert Josefsberg. Before she escaped, she, along with young girls from various foreign countries, were forced to service Epstein. She was also sexually exploited by his friends, including "royalty, politicians, scientists and businessmen," says the suit. it was settled last month. Epstein pleads the Fifth During depositions, Epstein has refused to answer questions about such allegations, claiming his Fifth Amendment right against sell~incrimination. He has refused to talk about his holdings a 51,000-square -foot mansion in Manhattan, a 7,500?acre ranch in New Mexico and a 70-acre island in the Virgin islands. He is mum about his background as a high school math teacher who worked for Bear Stearns before starting his own financial management company. He is equally taciturn about trips he took with former President Clinton, Britain's Prince Andrew and actors Kevin Spacey and Chris Tucker. Deposition exchanges have been nasty. "Would you agree with the description that you are a pervert?" asked attorney Spencer Kuvin. Epstein took the Fifth. "Do you believe you're a sexual deviant?" Kuvin asked. Epstein said no. in most cases, Critton has instructed Epstein not to answer. At the same time, attorneys representing the victims have instructed their clients not to speak about some matters. Although a magistrate who is overseeing the federal cases warned Critton not to be abusive, she said Epstein has a right to probe the women?s backgrounds. Critton said such questioning is only fair. 9/15/2010 Victims seeking sex offender?s millions see painful pasts used against them Page 3 of 3 (Their) damages will be substantiaiiy reduced due to several preexisting and diagnosed conditions for which they now attempt to pawn off on Epstein in an effort to increase their damages." Find this articie at: 92988.htm? Print this page Close .. 9/15/2010 DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISP UT ED FACTS Epstein v. Edwards, 62? 02. Case No. 50 2009 CA EXHIBIT 12/19/07". wag {$03 FAXWQOS 530 3440 amazes @1092 (LS. Department of Justice Uni?ed States Attorney Southern District afFlorida R. ME. 6 Sims? UNFFED YES Miami. FL 33132 {395} 96f~9f011~ Telephone (305} 530-64? wFuasimikl Dawmber 19, 200'? QELIVEREX BX @033;ng Ann Sanchez Fowicr White Burnett. PA. 3395 Brisket: Ave}, 14?? From Miami, FL 33 331 Re: Eagstein Dem Ms. Sanchez: 1 wite to follnw up on the December 14?h meeting between defense comma! and the: Epstein prosecutors, as win as our First Assistant, the: Miami FBI Special Agent in and myself} I write, to yam because 1 am not certain who among the: dafcnse team is the appropriate s'acipient of this iettar. address issues raised by several members of the defame team, and would thu 5 ask that you please provide a copy 0f this letter to all appropriate defense team mcmbars. - First, I wouid like to address the Section 2255 iswe.?a As} stated in my Dacembm' 4?h letter, my understanding i5 that the Mommas caution Agreement entered inns, bchcem this Of?ce and Mr, Epstein responds to Mn desire: to teach a giobal rcsulution ofhis state and fcdaml criminal liability. Under this Agreemeut, this District has agreecito defer prosecution for enumemwd sections Over the past two weeks, wc have received sewerai hundred pages of arguments and 2x1) ihiLs from defame counsel. This is not the forum to respond to the several items raised? and our :?icnce should not be as agreement; woutd, like to ad dress one issue. Your December 11?? letter states that its a result 01? 6e fense amuse! objections to the process, the USAC) proposed an sddendu to the Agreement to provide for {he use or an independent third party selector. As; mail this matter, beforc 1 had any knowiedge of deft-.th counsel objections, ma spams proposed the Addendum to Mr. Lefkowitz at an October meeting, in Palm Beach. 1 did is in an attempt to avoid what I wouid likciy be: a litigious selection macaw. It was an iy after 3 propo?ed this change that Mr. chkowitz raised with me his enumerated concerns. 3 Scction 2255 prnvides that: ?{a?lny person who. while a minor, was a victim of a violatian of {enumerated sactiom of'l?ilie is] and When an personal injury as a result of such vioiation . . .may sun in any appropriate United Slams; District Court and shim recover tin: actua! damages such person snataim; and the cost of the suit, inciudiug a reasonabic attorney's fee.? WED 17:03 FAX 305 530 64:10 EXECUTIVE OFFICE 003 of Title 18 in favor of by the Stairs of Florida, provided that the Mr. Epstein satisfies throo goneral federal interosts: ?oat Mr. Epstein plead guilty to a ?rogimombh? state o?fome; that this state plea include a binding recommendation for a suf?cient term of imprisonment; and (3) that the Agreement not harm tho intercom of his victims. With this in?mind, I have considered defense counsel oxgumonts regarding the Soction 2155 portions oftho Agreement. As I previously observed, our intent 23515 boon to place the victims in tho samo positioo as they would have; been had Mr. Epstein boon convicted at trial. No more; no loss. From our meeting, it appears that the defense agrees tho: this was the intonlt. During tho couxse of negotiations that intent was roduood to M?iting in Paragraphs 7 and 8, which as? wrote: previously, appear for ?ow simple to understand. I would thus propose that we solve our disagreements ovor interpretations by saying precisely What we mean, in a simple fashion. I would replace 9mth 7 and 8 with the following language: ?Any person, who while a minor, was a victim of a. violation of an come enumerated in Title 38, United Sfotos Code, Section 2255, will have the same rights to under Section 2255 as she would have had, if Mr, Epstein boon triod fodomlly and convicted of an em moroxod offense. For pumosos of implementing th is paragraph, the United States shall provide Mr. Epsioio? attomoys with a list of individuals whom it was proporod to mono in an indictment as victims of an onomoratod offense by MI. Epstein. Any judicial authority interpreting this provision, including any authority determining which ovidontiazy burdens if any a plaintiff must moot, shall consider that it is the intent of the parties to place those idontifi ed victims: in tho some pooition as they would have boon had Mr. Bpszoin boon convicted at trial. No mom; no loses.? Secoml, I would like to address tho issue of victim?s rights pursuant to Section 3771. I mideostand that the c?lofonso objoots to the victims being givon notice of time and place of Mr. Epstein?s stato court sentencing hearing. I have reviewed the proposed victim noti?cation letter and the stoloto. I would note 11m the United States provided the draft?iottor to defense as a ooimeoy. In addition, First Assistam United States Attorney 810mm already incorporated in tho letter several edits that had been requested by dol?onso counsel. 1 agree that Section 3771 applies to notice of proceedings and results of invosti gations of fedora] crimes as In the state crime. Weintorid to pmvide victims with notice of the federal resolution, as required by law. We will (info: to the discretion of the State Attorney regarding whether he wishes to provide victims with notice. of the state procoodings. although we will provide him with the information to do so ifho wishes. Third, 1 would like to address the issue: raised regarding lilo?doStatuto Section 796.03. At our meeting, Professor Dorshowitz took tho position that Mr. Epstein boliovos that his oomduot does not satisfy tho elements of {his offon so. His assertion :aisos for me subsmo? al ooncems. This O?ico will not, and cannot, be apart}! to on agxoomont in which Mr. Epstein pleads guilty to so o??enso that he believes he did not commit. We are considering how boot to proceed. ?ma:qu . .. mus/07 mo 17:04 FAX 305 3:149 EXECUTIVE OFFICE @304 Finally, I would like to address a more goneral point. Our Agreement was ?rst signed on September 2007. Pursuant to paragraph 1 I, Mr. Epstein was to use his best efforts to enter his guilty pioa and be sentenced no Iota: than October 26, 2007. A5 ouilioed in oowospondonce botwoon our prosecutors and dofonso counsel, this deadline came and wow. Our prosecutors roitemtcd to defense counsel sm?eral times moi: concerns regarding delays, and in fact, asked mo several woeks ago to declare the Agreemont in breach became of those delays. 1' rosiszod mat imitation. 1 share this fact because it is backgrourxd to my frustration with what appears to be an 11?? hour appeal. weeks before the now ochoduled January 4th plea date. This said, the issues raised are important and must be foil}; vo?od irrespective of timeliness conwms. We hope to preserve the Jazmary date. I understand that defense ammo] shares our desire not to move that appearance and will work with our office to oXpodlto this process over tho next several days. With this in mind, and in tho ovont that defame; couosoi may wish to seek review of our determinations in Washington 9.0., I spoke ?xis past Monday with the Assistant Attornoy Genera} Fisher, to infoxm he: of a possibio appeal, to aok her to grant the potential request for review, and to in faotrovi ow this case in an expedited manner to attempt to proservo the Jaouury 43? p1oa dato. 1mm to again reiterate that it is not the intention of this Offico over to force the hand ofa doibndant to enter into an agreement against his wishes. Your client has the right to pmccod to tri a1. and he should do so ifho belioVos that he did not commit tho elements of the charged offoriso. I wil! respond to the pending issues shortly. In tho inte?m, 1 would ask that you communicate your position w} 111 respect to the sections 2255 and 3371 issnos as quickly o5 possible. Sincerely, 7% R. ALEXANDER ACQSTA UNITED ATTORNEY co: Fisher, Asoistant Attorney General Jof??ey Slomao, First Assistant US. Attomoy AUSA A. Mario Vinafafia "Ann Made To "Jay Lemowitz" boo Og161200711:41 sumac; Ra: J5 A . . shes.- Hi Jay -- I looked up some 11th Circuit cases on simple assault and found some good language. I also learned that, every moment that one is aboard an enclosed civil airplane, they are in the ?special aircraft jurisdiction of the United States," so the assault charge is really a violation of 49 USC 46506, which doesn?t change the penalties. I have drafted up a factual pm??er that I would use at the change of plea based upon our brief conversation and the agents? interaction with Ms. Groff at her home. The agents and I would need to speak with Ms. Marcinkova and Ms. Groff brie?y to confirm that these facts are true. Feel free to make suggestions. 01: an "avoid the press" note, I believe that Mr. Epstein's airplane f" I was in Miami on the day of the Ms. Gro?? telephone call. If he was in Masai-Dada County at the thee, then I can ?le the charge in the District Couzt in Miami, which will cut the press coverage signi?cantly. Do you want to check that out? I will talk to you later. Thanks. ?d Amchmant 'Egsteig Plea Prc?gmoc' has been airchived bv uggi; on ?11126/2007 01:08:17?. DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, 9! a1. Case No.: 50 .2009 CA 040800WMBAG EXHIBIT KK Case Document 483 Entered on FLSD Docket 03/10/20t0 Page i of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. Plaintiff, Vs. JEFFREY et al. Defendant. Related Cases: 0880119, 0880232, 0880380, 08-80381, 0880994, 08-80811, 08?80893, 09-80469, 0980591, 09-80858, 09-80802, 0981092 PLAINTIFF JANE MOTION FOR AN ORDER TO SHOW CAUSE AND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe, respectfully fiies this motion for entry of an order directed to Jean Luc Brunel and his counsel ordering thern to show cause why they should not be held in contempt, for sanctions, and for an order compelling Jean Luc Brunel to appear for a deposition within 20 days. After plaintiff Jane Doe served Brunel with a subpoena for a deposition in this case, his attorney, on his behalf, represented that Brunel would appear for a deposition if Jane Doe would postpone the scheduted deposition date. As an accommodation to him, Jane Doe did postpone the scheduled deposition date, but then Brunei has not appeared as agreed for a deposition. After much communication in an attempt to coordinate Brunei?s deposition, Brunel?s counsel represented that Brunei was outside of the country, and thus unavailabie, when in fact he was inside the country Case Document 483 Entered on FLSD Docket 03/10/2010 Page 2 of 20 CASE NO: and easily available for a deposition. Because of these false representations, this Court should direct Brunei and his counsel to show cause why they should not be held in contempt. This Court should also compel Brunei to appear for the deposition that was previously scheduled and that he has avoided only through these false representations. Finally, the Court should sanction the appropriate person(s) for causing the undersigned to spend unnecessary time filing this motion. BACKGROUND Jane Doe personally served Jean Luc Brunei in New York City to appear for deposition in this case. The subpoena indicated a deposition date of September 22, 2009 at 10:00 AM. in New York City, New York. Brunei is an important witness in this case, as he is a good friend of Epstein?s and has information regarding Epstein?s pattern and practice of obtaining young girls for sexual purposes, relevant issues not yet admitted by Defendant Epstein. Shortly after Brunei was served, counsel for Jane Doe was contacted by Tama Beth Kudman, Esq., a licensed attorney in Florida. Kudrnan stated that she represented Brunei with regard to the subpoena and that she would produce Brunei for deposition in West Palm Beach if Jane Doe would agree not to go forward with the deposition date in New York. Counsel for Jane Doe honored that request, and with Kudman jointly arranged a deposition date for Brunei in West Palm Beach for October. Shortly before his deposition was to take place, Ms. Kudman contacted counsel for Jane Doe to move that deposition date because of a personal conflict. Once again, counsel for Jane Doe agreed. After several conversations regarding the deposition of Case Document 483 Entered on FLSD Docket 03M 0/20t 0 Page 3 of 20 CASE NO: Brunel, Kudrnan asked that counsel for Jane Doe set Brunei for deposition in January of 2010, as that was a time when she could assure his availability. In January, counsel for Jane Doe again contacted Ms. Kudman to arrange a mutually convenient deposition time. Ms. Kudrnan stated that Brunel would be in Florida the first week of February and she would work to coordinate his deposition for that time. The undersigned?s office contacted Ms. Kudrnan?s office on several occasions in January to coordinate a February deposition date of Brunei. On January 29, 2010, Ms. Kudman returned the call and left a voicemail apologizing for not returning the call sooner and indicating that she had Only been waiting to hear from Mr. Brunel as to his availability, and she invited the undersigned to contact her the following week to set it up. On February 5, 2010, counsel for Jane Doe contacted Ms. Kudrnan to coordinate Brunel's deposition. During that teiephone conversation, Ms. Kudrnan represented that her client, Mr. Brunet, had previously left the country to go to his home country of France before the New Year. Ms. Kudman further represented that while she betieved he was going to return, it turned out that he had no pians to return. Ms. Kudman also stated that if Brunel was in the country, she would make good on her representation that she would produce him. However, she had just spoken to him via a telephone call from him in France. Brunel told Kudrnan that he was staying there indefinitely with no plans to return. In subsequent telephone conversations, Ms. Kudrnan continued to represent that Mr. Brunet had been out of the country since sometime prior to the New Year and was not planning to return. Case Document 483 Entered on FLSD Docket 03/? 0/201 0 Page 4 of 20 CASE NO: Counsel for Jane Doe responded that this representation seemed quite strange, since Brunei has a significant business in the United States. Kudrnan replied that it was simply too expensive for him to return and that because of the expense he had no intentions of returning. Counsel for Jane Doe then pointed out that when Brunel was served, Kudrnan had promised he would be produced for deposition. Kudman replied that because he is in France with no plans to return there was simply nothing she could do. Kudman further advised counsel for Jane Doe that if he wanted to take B'runel?s deposition in France, then-it would be necessary to obtain a Letters Rogatory and go through the French Consulate. After these procedures, Kudman then indicated it would be necessary to take a trip to France for his deposition. Counsel for Jane Doe indicated that he might be willing to go through that process, but that he would like for Kudrnan to tell him if Brunei happened to return to the United States. Kudman promised that she would. Remarkably, after all of these representations had been made by Kudman, it turns out that Brunei was actually in the United States during the time when Jane Doe was trying to take his depositon. In fact, on February 16, 2010, counsel for Jane Doe took the deposition of Jeffrey Epstein?s house manager, Janusz Banaziak. Mr. Banaziak was asked if he knew Mr. Brunei. in summary, he responded that he knew him as Mr. Epstein?s friend. He elaborated that Mr. Brunei had stayed with Epstein at Epstein?s Palm Beach home on at least two occasions in 2010. The first 2010 visit was in January, when Mr. Brunei stayed for approximateiy 3 days. Then Mr. Brunei stayed at Mr. Epstein?s home from approximately February 10th or 113? through February Case Document 483 Entered on FLSD Docket 03/10/2010 Page 5 of 20 CASE NO: 2010. it was known by Epstein that Brunei was coming to stay at the house in February 2010, as he was picked up at the airport and driven to Epstein?s home by Epstein?s bodyguard, lgor Zinoview, and after his stay with Epstein, Bruce] was driven from Epstein's house to the airport by Sarah Kellen. See deposition of Janusz Banaziak at page 154461 and 1684 6 attached hereto as Exhibit MEMORANDUM OF LAW As is readily apparent from the foregoing facts, Ms. Kudman has either made false representations about Mr. Brunel?s whereabouts or Mr. Brunel has made false representations about his whereabouts that she passed on. In either case, they should be required to show cause why her and/or she shouid not be held in contempt of court for making false representations. See, Acton v. Target Corp, 2009 WL 5214419 at *5 (W.D. Wash. 2009) (entering order to show cause why counsel should not be held in contempt for making false representations). in particular, Mr. Brunel and Ms. Kodman should explain how it came to pass that Mr. Brunel was in Florida at the very time that Jane Doe was attempting to take his deposition while Ms. Kudman was confidently reporting that he was unavailable in France. Given the known facts, Ms. Kudman was either an unwitting messenger who passed along false representations delivered to her by her client Mr. Brunel, or she was a knowing participant in Brunel and/or Epstein?s attempt to obstruct discovery; either way a show cause order should be entered and the appropriate person(s) sanctioned and held in contempt. Mr. Brunel and Ms. Kudrnan should also be required to provide a fuii explanation of who precisely is paying the attorney fees for Ms. Kudman's services. Most, if not all, Case Document 483 Entered on FLSD Docket 03/10/2010 Page 6 of 20 CASE NO: os-cvem 19-MARRAIJOHNSON of the witnesses that have been deposed in this and related cases against Epstein have appeared with counsel retained and paid for by Defendant Jeffrey Epstein. In this instance, we know that Mr. Epstein was together with his house guest, Mr. Brunei, at a time when Brunel's counsel was representing that Brunei was out of the country and could thus not attend a deposition. Mr. Epstein also knew at that time that the undersigned had been trying to coordinate Brunel?s deposition for months. Therefore, there is no doubt that Mr. Epstein was assisting Mr. Brunei and/or Ms. Kudman in obstructing discovery. At the very least, Mr. Epstein was an accompiice, but was he the person paying the attorney to make false representations and tamper with important witnesses? While Mr. Epstein may be able to invoke his 5th amendment rights on such questions, Mr. Brunel and Ms. Kudrnan do not have that luxury, and at this point they should be required to provide these answers. Again, as the facts make ciear, Ms. Kudrnan has not delivered on promises made (as an officer of the court) to counsel for Jane Doe, and Mr. Brunel has not appeared for a deposition. As such, Jane Doe moves this Court to enter an order directing Mr. Brunei to appear for a deposition in West Palm Beach within 14 days. He was properly served with a subpoena by Jane Doe, and only through deceitful maneuvers he has been able to avoid his deposition. This Court should not permit subpoenas to be avoided in this fashion. WHEREFORE, Jane Doe respectfuliy requests the Court to direct Mr. Brunel and Ms. Kudrnan to show cause why they should not be held in contempt for making false representations in an effort to avoid a deposition. if the Court finds that they are in Case Document 483 Entered on FLSD Docket 03/1012010 Page 7 of 20 CASE NO: contempt, the Court should aiso impose appropriate sanctions, including attorney?s fees for Jane Doe in connection with filing this motion. The Court should also compel Mr. Brunel to appear for a deposition within 14 days of the Court?s order and grant any additional relief the Court deems just and proper. PRE-FILING CONFERENCE Counsel for Jane Doe has attempted to confer with Ms. Kudman about this motion, but she declined to make Brunei available for deposition, and in fact has again stated as recently as March 5, 2010 that Brunei has been out of the country since prior to the New Year with no plans to return. DATED: March 10, 2010 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, EDWARDS, FISTOS LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 5242820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801?585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu Case 9:08?cvu801i9?KAM Document 483 Entered on FLSD Docket 03/10/2010 Page 8 of 20 CASE NO: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 10, 2010, eiectronically filed the foregoing document with the Clerk of the Court using I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing. 3/ Bradley J. Edwards Bradley J. Edwards SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Fiorida Jack Alan Goldberger, Esq. Jdoldbercer@adwoa.corn Robert D. Critton, Esq. rcritton@bclciaw.com isidro Manual Garcia isidreearciatf?bellseuthnet Jack Patrick Hill inh?searcylawcom Katherine Warthen Ezeil KEzell?icodhursticom Michael James Pike Paul G. Cassell cassellb@iaw.utah.edu Richard Horace Willits lawyerswillite?aotcom Robert C. Josefsberg Case Document 483 Entered on FLSD Docket 03/10/2010 Page 9 of 20 CASE NO: riosefsberq?mdhurst.oam Adam D. Horowitz ahorowitz?isexabuseattomev.com Stuart 8. Mermelstein ssm?jmxabwea?omev?cm Case Document 483 Entered on FLSD Docket 03/10/2010 Page 10 of 20 CASE NO: EXHIBIT A Case Document 483 Entered on FLSD Docket 03/10/2010 Page 11 of 20 Page 154 A. ND. 2 MR. GOLDBERGER: Form. 3 BY MR. EDWARDS: 4 Q. And have you known, just based on your observations, Nadia to have girlfriends? And by 6 girlfriends I mean girlfriends that she would be '7 intimate with in addition to being the girlfriend of 8 Jeffrey Epsteinyou know some:on by the name of Jean 11 L110 Brunei? 12 A. Yes. 13 Q. How do you know himthe house like, I guess, a few 15 times. 16 Q. When? 17 A. When? 18 Q. When was the last time you saw him there? Hi? 19 A. A week ago. 20 Q. Today is, what, February 16th, and this is 21 a Tuesday. So, when we are saying a week ago, are 22 you saying it was last Tuesday, Wednesday, Thursday, 23 Friday, do you remember? 24 A. I don't remember tl?e date but he stay maybe 25 three days, I think, in the house. NW3 3?51: (561) 832-7500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 Etectroaicatiy signed by napkins Eiectronicaiiy signed by napkins Eiectronicaliy signed by hopkins (601415? ~976-2934) Case Document 483 Entered on FLSD Docket 0310/2010 Page 12 01?20 Page 155 1 Q. So, if he arrived on Tuesday, he stayed 2 through Thursday or Friday and -e 3 A. Yes. 4 Q. Do you know what the occasion was for him to come in town? 6 A. No. 7 Q. Where did he stay in the house last week? 8 A. One of the bedrooms upstairs. 9 Q. And was Mr. Epstein also staying in the 10 house? 2 11 A. Yes. 2 12 Q. All right. Did Mr.Brunel bring any i 13 company with himwas him alone? 2 16 A. Yes. 17 Q. How did he get tO'me house? 18 A. I think he has beeng?oked up by Igor at this 19 point. 20 Q. And where did he w? I assume he flew in 21 from somewhere? 22 A. Yes. 23 Q. Picked up from theairport, safe 24 assumption? He didn?t just dive to the airport. 25 (A.disoussion was had.off the record.) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by hopkins (601-651-976~2934) Electronicaziy signed by {napkins (601?051-9?6-2934) Eiectronicatiy signed by napkins (601-051-976?2934) 211752191 d-3eaa~42b3-ae22~b5d3c71 82d1e Case Document 483 Entered on FLSD Docket 03/10/2010 Page 13 of 20 Page 156% 1 BY MR . EDWARDS: i 2 Q. So, do you know where it was that 3 Mr. Brunei flew in from? 4 A. NO. 5 Q. imjyou know where Mr. Brunei generally 6 lives? I mean is it New York, is it ?w 7 A. IiobW'that he spends some time in Florida, in 8 Miami, but exactly where he is, I don't know. 9 Q. But obviously he wouldn?t fly here to Palm 10 Beach from Miami, right, so kahad to be coming from 11 somewhere else you would assume? 12 A. Yes, I assume. 13 Q. Were you told endlar to the way that 14 you have been describing the deposition, 15 you're told who is coming intown. Were you told he 16 was going to be at the house? 17 A. Yeah. Usually hezequires to be picked up, so 18 I know that he is coming. 19 Q. Okay. We'll go some other i 20 instances where you had to pick him up or 21 break plans, but talking spedfioally about last 22 week: When were you first Uid.that Mr. Brunei was 23 going to be coming into town? 24 A. I think Igor toldie that he has to go and 25 pick him up. PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by napkins (601-051-976~2934) Electronically signed by napkins {601-051~976-2934) Electronicaiiy signed by napkins (301-051-976-2934) 2d75391d-3eaa-42b3eeZZ-b?d3c71 82d1e Case Document 483 Entered on FLSD Docket 03/10/2010 Page 14 of 20 Page 157 day off, I guess, because usually I 3 am the one who pick up people. So, I guess it was my 4 days off and Igor was working, so he went to pick him 6 Q. Okay. It wouldn?t be Story Cowles picking ?the best of your recollection Igor 10 picked up Jean Luo Brunel soretime last week from 11 the airport and took him to the house? 3.2 A. Right. 13 Q. Do you know what ca: he took to pick him 14 up? 15 A. I think Cadillac Emalade. 16 Q. The black Esoalade? 17 A. Yes. 18 Q. And what did Mr. anel and Mr. Epstein do 19 for the three day stay when M. Brunel was staying 20 at Mr. Epstein's house last week? 21 MR. GOLDBERGER: FQWL 22 THE WITNESS: I 6.021%: know. 23 BY MR. EDWARDS: I 24 Q. Did you interact, eommunioate with 25 Mr. Brunel? Tm"? (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronicain signed by hopkins (601~051~976-2934} Eiectronicaily signed by hopkins (601-051-976~2934) Eiectronically signed by hopkins (601?051u976-2934) Case 9:08~ove80119~KAM Document 483 Entered on FLSD Docket Page 15 of 20 Page 158 1 A. Yes. 2 Q. And what did he say as to why he was here? 3 MR. GOLDBERGER: Form. 4 THE WITNESS: Good morning. How are you? 5 Exchange handshakekitchen and he was cooking something and that's 8 BY MR. EDWARDS: 9 Q. When you say he was cooking something, he 10 was personally cooking? 11 A. Yes. 12 Q. All right. So, this is a house that he is 13 familiar enough with and he is a regular enough 14 guest that he makes himself at home? 15 A. Yes. 16 Q. Okay. And last week do you remember anything in the three?day pended that Mr. Brunei was 18 staying at the house that Mr. Brunel did from the 3.9 time he woke up to the time that he went to sleep? 20 MR. GOLDBERGER: Form. 21 BY MR. EDWARDS: 22 Q. I mean did go to tie movies? Did he go to 23 the beach? Did they just haxg out around the house 24 and walk? 25 A. Yeah. I think he valked outside to the beach. . .. .. Electronically signed by hopkins Electronically signed by hopkins (601?051-976-2934) Eiectronically signed by hopkins (601-051?976-2934) Case Document 483 Entered an FLSD Docket 03/1012010 Page 18 of 20 Page 159 1 He was swimming in the pool, talking on the phone just a 2 what 1 remember. 3 Q. Okay. During the threewday stay last 4 week, how often were 1 mean, I assuming that he 5 came in town.to see Mr. Epstein; is that true? 6 A. Yes. 7 Q. And so the majority of his time during 8 that three days was spent hanging around with 9 Mr. Epstein? 10 A. Yes. 11 Q. All right. Did yousee them talking with 12 one another? 13 A. Yes. 14 Q. Where were they taking with one another? 15 A. In the cabana, outade sitting next to the 16 pool. 17 Q. All right. And when you said that 18 Mr. Brunei walked to the beadn did Mr. Epstein walk 19 to the beach with him? 20 A. No. 21 Q. Mr. Brunel walkedlione? 22 A. Yes. 23 Q. Who else was in thehouse last week while 24 Mr. Brunei was in the house? 2 25 A. Nadia, Sarah, and army; I think(561) 832*?500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by napkins (801?051-976-2934) Electronically signed by napkins (601?051~976?2934) Electronically signed by hopkins (601-051-97a2934) Case Document 483 Entered on FLSE) Docket 03/10/2010 Page 17 of 20 Page 160 1 Q. Sarah Kellen? 2 A. Yes. i 3 Q. And Story Cowles? 4 A. Yes. 5 Q. Okay. 'Who else, Igor? 6 A. Igor. I guess that?s it. 7 Q. Did you overhear any of the sabstance of 8 the conversations that Mr. Brunei was having with 9 Mr. Epstein? 10 A. NO. 11 Q. All right. What isyour understanding as 12 to the relationship between Mn Brnnel and i 13 Mr. Epstein? l4 I guess they are ?dends. 15 Q. Okay. In additionto being friends 16 well, let me ask this questbm first: Do you know 17 when they became friendsYou don't know howlong they have known 2 20 each otherYou don?t know whointroduoed themThey could have metsinoe they were five 25 years old or they could havesmt five years ago for (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Eiectronically signed by hopkms (601-053-976~2934) Eiectronically signed by napkins (601 4151 4376-2934) E?ectronically signed by hopidns (601 4151 ~976~2934} Case Document 483 Entered on FLSD Dockei 03/10/2010 Page 18 of 20 Page 161 1 all you know? 2 A. Yes. 3 Q. In addition to being friends, do you know 4 them to be have a business relationship with one 5 another? 6 A. I don?t know. i 7 Q. Do you know what Mr. Brunel does for a 8 living? 9 I think he has some modeling agency, owner of 10 some modeling agency. I dont know exactly where, which i 11 one. 12 Q. Why do you think {mt? Why do you think 13 he is involved with a modelbg agency? 14 A. I think somebody mid me. 15 Q. Okay. That's fairenough. Who? 16 A. I don't remember 17 Q. Would it be Sarah Epstein? 18 A. It could be. 19 Q. And whether it wasSarah or whoever . 20 told you about this was onecf the people that you i 21 have previously described asbeing within the 22 Jeffrey Epstein organization? 23 A. Yes. 24 Q. And as you sit heretoday, you can't say 25 definitely it was one pereonm?thin the organization Electronicaiiy signed by hopkins (601?051-976-2934) Electronica?y signed by hopkins (601-051-976?2934) Electronicaiiy signed by hopkins (601-051~976-2934) 2675a!? 82d1e Case Document 483 Entered on FLSD Docket 03/10/2010 Page 19 of 20 Page 3.68E 1 A. No. She was a guest, I assume. 2 Q. Any reason why there would be an overlap I 3 between her staying at the house and Jean Lac 4 staying at the house, or it was just coincidence as 5 far as you could tell? 6 A. I don't know. 7 Q. Okay: And is there anywhere where you've 8 written down or documented what Sue's last name isDid you take her ba?c to the airport? 11 A. Yes. 12 Q. And what day did ydttake her to the 13 airport? 14 A. Yesterday. 15 Q. Yesterday. So, enemas here four days. 16 She got here last Thursday orEwiday? l7 A. I think Fridaythe?mouse for a period of 19 time when Jean Lue Brunel wasat the house? 3 20 A. Yeah. I mean, lastweek, yes. 3 21 Q. Okay. So, she gotthere Friday. When did a 22 Jean Luc Brunel finally leaveNMn Epstein?s house? 23 A. I think Monday, yeah Monday. He ieft Monday. i 24 Q. That?s yesterday? I 25 A. Or Sunday. EZectronically signed by hopkins {601-051-976~2934) Eiectronically signed by hopkins {601-051-976-2934) Eiectronically signed by hopkins (601?051u976-2934) Case Document 483 Entered on FLSD Docket 03/10/2010 Page 20 of 20 Page 169 1 Q. Today is Tuesday. 2 A. Todw is Tuesday. Yes. I think Sunday. 3 Q. Okay. So, on Sunday Jean Luo Brunei left a and on Monday Sue left? 5 A. Yes. 6 Q. All right. Did you take Jean Luc Brunei '7 to the airport? 8 A. No. 9 Q. All right. Did Igor? 10 A. Sarah. 11 Q. Sarah Kellen. And do you know where he 12 was flying to? 13 A. No. 14 Q. You don?t know wheze he came from or where 15 he was flying to? 16 A. Right. Q. Right. And as of right now you have no 3.8 I knowledge as to where he primrily resides, whether 19 that I know you said that he spends some time in 20 Miami. but whether he primarily resides in Miami or 21 New York or Antartioa, you have no idea? 22 A. No. 23 Q. Okay. Other than last week, when was the 24 last time that you saw this @ntleman Jean Luo 25 Brunei at Jeffrey Epstein's house? (561) 832*7500 PROSE COURT REPORTING AGENCY, ENC. (563.) 832-7506 Electronically signed by hopkins (601-051~978-2934) Electronically signed by hopkins (601-051-976-2934) Electronically signed by hopkins (661-051~976-2934) Case Document 54? Entered on FLSD Docket 05/17f2010 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-80119, 0880232, 0880380, 0880381, 08-80994, 0880811, 08-80893, 09-80469, 09-80591, 09-80656, 09?80802, 09~81092 NOTICE OF SUPPLEMENTAL AUTHORITY ON PLAINTIFF JANE MOTION FOR AN ORDER TO SHOW CAUSE AND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW 4831 Plaintiff, Jane Doe, hereby gives notice of filing portions of the probation file of Defendant, Jeffrey Epstein, in connection with the above referenced Motion for Order to Show Cause and to Compel the Deposition of Jean Luc Brunei 483]. I On March 10, 2010 Plaintiff filed her Motion for an Order to Show Cause and for an Order to Compel 483] requesting entry of an Order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an Order compelling Jean Luc Brunei to appear for deposition. Plaintiff?s counsel recently obtained Epstein?s probation file that contains documents that further corroborate Plaintiff?s position that Brunel has not remained out Case 9:08ucv~80119~KAM Document 547 Entered on FLSD Docket 05l17/2010 Page 2 of 4 CASE NO: NSON of the country as Brunel?s counsel suggested, but has in fact been staying with Epstein much of 2010, if we are to believe the records Epstein provided to probation. The portions of the probation file, specifically the Written Reports from December 2009 through February 2010 are attached hereto as Exhibit A section of the Written Report requires Defendant to ?List full names, ages, and your relationship to at! persons who resided at your residence this month? in the middle section of the form. Defendant identifies Jean Luc Brunel in his probation papers as residing with him within the period of December 2009 to February 2010, when Ms. Kudrnan represented him to be out of Florida. As indicated in our previous pleading, Mr. Brunel was served for deposition, and his counsel Ms. Kudman represented that she would produce him for deposition in Florida. She ultimately reneged, saying that her client told her that he was in France indefinitely and would not be returning to the United States, a representation known to be false. In an email dated January 25, 2010, Ms. Kudrnan responds to a request for dates for her client?s deposition by writing, have just been informed that my client will be out of the country until the end of March.? (Ernail attached here to as Exhibit Again, while it is not beiieved that Ms. Kudman made the faise representation intentionaliy, and it is more likely that Mr. Brunei simply made that false representation Case Document 547 Entered on FLSD Docket 05/1 "712010 Page 3 of CASE NO: 1 Q-MARRAIJOHNSON to his attorney, it is impossible for the undersigned to know with any degree of certainty exactly who participated in this plan to obstruct Jane Doe?s discovery. As such, Plaintiff tiles her supplemental authority and requests the relief previously sought. DATED: Mav17, 2010 Respectfully Submitted, 8/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, LEHRMAN, PL. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 Email: brad@pathtojustice.com and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801685-5202 Facsimile: 801?585-6833 E-Mail: cassellp@iaw.utah.edu CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 17, 2010 electronically filed the foregoing document with the Clerk of the Court using I also certify that the foregoing document is being served this day on ali parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing. 3/ Bradley J. Edwards Bradley J. Edwards Case 9:08ucv~80119~KAM Beaumont 547 Entered on FLSD Docket {3511732010 Page 4 of 4 CASE NO: 9-MARRAIJOHNSON SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Jgoldberger@agwpa.com Robert D. Critton, Esq. rcritton@bolclaw.com Isidro Manual Garcia isidrogarcia@ballsouth.net Jack Patrick HEII iph@searcylaw.com Katherine Warthen Ezell KEzeN@podhurst.com Michael James Pike Paul G. Cassell cassellp@law.utah.edu Richard Horace Willits lawyerswillits@aol.com Robert C. Josefsberg rjosefsberg@podhurst.com Adam D. Horowitz ahorowitz@sexabuseattomeycom Stuart 8. Mermelstein ssm@sexabuseattorney.oom Case Dooument54Y~1 Entered on FLSD Docket Page ?1 of 4 CASE NO: 08?0 V?80?l 1 Q-MA Notice of Supplemental Authority on Plaintiff Jane Doe?s Motion for an Order to Show Cause and for an Order to Compel and Incorporated Memorandum of Law 738] EXHIBIT A Case Documem 54-74 Entered on [Emmi 05/1 Page 2 of .51:ng M?nth .. DEPARTMENT OF CORRECTIONS Datemm sub?! 9 - WRITTEN 1:13:90ng in YOU @5744? . EMPLOYER: '1 139* . . .. NAME: YOUR RESIDENCE (include Name of EMPLOYEES Subdivision. Apartment Complex and. Number, Mob?ie Hams Park and Lo: Number, afapplicablewau} TELEPHONE CELLULAR - - (Pravide physica! {Creation N01 Post. Q??ice Box) I a - - PAGER 0? .. TELEPHONE Hm?ni 5 5 EMPLOYER EMAILYOUR TOTAL MONEY EARNED I CEL-LBLAR TELEPHONEN - 0 i; - {a (Gross Amazing) I PAGER No. I Vehicie MakeJModeUYea n?Tag Full time.? Part~?ime Hourg Worked Additional emp'loyme?f infurnwtion: full names, ages, and your relationship to all persons wha misled ?3 your gag-denim timing thismonth: .H Himg? In ?Cu-43"; MW?Cu?icv-mw m4 wit; arm . ?0 2? 1 ave you consumed alcoholic beverages? Have?you used or bought illegal drugs 01? contro?ed substances? Have you attended educational, vocationa! classes or mental health, drug, alcohol, therapy, or selfwimprovement programs? (If yes, circle. which one) 3 - - - Have you been arrested or had any contact with law enfordement- during the last. month? If yes,- explain what happenet! on s?parate sheet {31' paper, attached to report. If you went into debt for any reason, explainrking, give: reason and source of income: If you have any questions or pmblem to discuss with your Office-r, explain: If monetary obligation owed, amount paid this month: 53 Receipts are available through your probation officer. DO NOT SUBMIT CASH OR PERSONAL Make money order payable t0 the Department of- Comedians, If monetary obiigation owed and no payment made, give reason and date when payment will be made: certify the above to be true_ and campleie; - Si nature-of Off" -. -. . . wet Your-SignatureMailing Address: a - Date WMR ReceivedDate Due: I I . . _C0mments: Hw?:wmwwiwm - State; Zip: i . EeMaii zaddra?{yappzicabiej Caee Document 547a Entered on FLSD Docket05l1?l2010 Wage 1 of 2 CASE NO: Notice of Supplemental Authority on Plaintiff Jane Doe?s Motion for an Order to Show Cause and for an Order to Compel and Incorporated Memorandum of Law 138] EXHIBIT Caoo 9:08novn80119~KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2 Beth Williamson From: Toma Beth Kudman {tama@tkudmanlaw.com] Sent: Monday. January 25, 2010 4:10 PM To: Beth Williamson Subject: Re: Regarding: Epstein - Dopo of Jean Luc Bruno: I have just been informed that my client will be out of the country until the end of March. Please ask Mr Edwards to call me to discuss this. Thank you Sent from my iPhone: Toma Both Kudman On Jan 25, 2010, at 3:22 PM, Both Williamson wrote: Dear Ms. Kudman: My name is Both. I am assisting Brad Edwards in the Epstein matters. I just wanted to followup on the voicemail I left you. I understand your client Jean Luc Brunel will be available the ?rst two weeks of February for deposition. Please provide me dates of availability as soon as possible, as calendars are ?lling. Thank you, Beth Williamson, FRP Florida Registered Paralegal Farmer, Jaffe, Weissing, Edwards, Fistos E: Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 954-524~2820 954-524-2822 fax beth?gathtojustice.mm Case Document 483 Entered on FLSD Docket 03i10f2010 Page ?i of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. Plaintiff, Vs. JEFFREY et al. Defendant. Related Cases: 08?80119, 08-80232, 08-80380, 0880381, 0880994, 08-80811, 08-80893, 0980469, 09-80591, 09-80656, 0980802, 09-81092 PLAINTIFF JANE MOTION FOR AN ORDER TO SHOW CAUSE AND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe, respectfully files this motion for entry of an order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an order compelling Jean Luc Brunel to appear for a deposition within 20 days. After plaintiff Jane Doe served Brunei with a subpoena for a deposition in this case, his attorney, on his behalf, represented that Brunei would appear for a deposition if Jane Doe would postpone the scheduled deposition date. As an accommodation to him, Jane Doe did postpone the scheduled deposition date, but then Brunei has not appeared as agreed for a deposition. After much communication in an attempt to coordinate Brunel?s deposition, Brunel?s counsel represented that Brunei was outside of the country, and thus unavailable, when in fact he was inside the country Case Document 483 Entered on FLSB Docket 03/10/2010 Page 2 of 20 CASE NO: and easily available for a deposition. Because of these false representations, this Court should direct Brunei and his counsel to show cause why they should not be held in contempt. This Court should also compel Brunei to appear for the deposition that was previously scheduled and that he has avoided only through these false representations. Finally, the Court should sanction the appropriate person(s) for causing the undersigned to spend unnecessary time ?ling this motion. Jane Doe personally served Jean Luc Brunei in New York City to appear for deposition in this case. The subpoena indicated a deposition date of September 22, 2009 at 10:00 AM. in New York City, New York. Brunei is an important witness in this case, as he is a good friend of Epstein?s and has information regarding Epstein?s pattern and practice of obtaining young girls for sexual purposes, relevant issues not yet admitted by Defendant Epstein. Shortly after Brunei was served, counsel for Jane Doe was contacted by Tama Beth Kudman, Esq., a licensed attorney in Florida. Kudman stated that she represented Brunei with regard to the subpoena and that she would produce Brunei for deposition in West Palm Beach if Jane Doe would agree not to go forward with the deposition date in New York. Counsel for Jane Doe honored that request, and with Kudman jointly arranged a deposition date for Brunei in West Palm Beach for October. Shortly before his deposition was to take place, Ms. Kudman contacted counsel for Jane Doe to move that deposition date because of a personal conflict. Once again, counsel for Jane Doe agreed. After several conversations regarding the deposition of Case Document 483 Entered on FLSD Docket 03/10/20?i0 Page 3 of 20 CASE NO: Brunel, Kudman asked that counsel for Jane Doe set Brunel for deposition in January of 2010, as that was a time when she could assure his availability. In January, counsel for Jane Doe again contacted Ms. Kudman to arrange a mutually convenient deposition time. Ms. Kudman stated that Brunel would be in Florida the ?rst week of February and she would work to coordinate his deposition for that time. The undersigned's office contacted Ms. Kudman?s office on several occasions in January to coordinate a February deposition date of Brunei. On January 29, 2010, Ms. Kudman returned the call and left a voicernail apologizing for not returning the call sooner and indicating that she had only been waiting to hear from Mr. Brunei as to his availability, and she invited the undersigned to contact her the following week to set it up. On February 5, 2010, counsel for Jane Doe contacted Ms. Kudman to coordinate Brunel?s deposition. During that telephone conversation, Ms. Kudman represented that her client, Mr. Brunei, had previously left the country to go to his home country of France before the New Year. Ms. Kudman further represented that while she believed he was going to return, it turned out that he had no plans to return. Ms. Kudman also stated that if Brunei was in the country, she would make good on her representation that she would produce him. However, she had just spoken to hirn via a telephone call from him in France. Brunel told Kudman that he was staying there indefinitely with no plans to return. In subsequent telephone conversations, Ms. Kudman continued to represent that Mr. Brunei had been out of the country since sometime prior to the New Year and was not planning to return. Case Bocurnent 483 Entered on FLSE) Docket 03/10/2010 Page 4 of 20 CASE NO: 08-0V-80119-MARRNJOHNSON Counsel for Jane Doe responded that this representation seemed quite strange, since Brunel has a signi?cant business in the United States. Kudman replied that it was simply too expensive for him to return and that because of the expense he had no intentions of returning. Counsel for Jane Doe then pointed out that when Brunel was served, Kudrnan had promised he would be produced for deposition. Kudrnan replied that because he is in France with no plans to return there was simply nothing she could do. Kudrnan further advised counsel for Jane Doe that if he wanted to take Brunel?s deposition in France, then it would be necessary to obtain a Letters Rogatory and go through the French Consulate. After these procedures, Kudman then indicated it would be necessary to take a trip to France for his deposition. Counsel for Jane Doe indicated that he might be willing to go through that process, but that he would like for Kudman to tell him if Brunel happened to return to the United States. Kudrnan promised that she would. Remarkably, after all or these representations had been made by Kudrnan, it turns out that Brunel was actually in the United States during the time when Jane Doe was trying to take his depositon. In fact, on February 16, 2010, counsel for Jane Doe took the deposition of Jeffrey Epstein?s house manager, Janusz Banaziak. Mr. Banaziak was asked if he knew Mr. Brunel. In summary, he responded that he knew him as Mr. Epstein?s friend. He elaborated that Mr. Brunel had stayed with Epstein at Epstein's Palm Beach home on at least two occasions in 2010. The first 2010 visit was in January, when Mr. Brunel stayed for approximately 3 days. Then Mr. Brunel stayed at Mr. Epstein?s home from approximately February 10?h or 111?} through February Case Document ?833 Entered on FLSD Docket 03/10/2010 Page 5 of 20 CASE NO: 1 2010. it was known by Epstein that Brunei was coming to stay at the house in February 2010, as he was picked up at the airport and driven to Epstein?s home by Epstein?s bodyguard, lgor Zinoview, and after his stay with Epstein, Brunei was driven from Epstein's house to the airport by Sarah Kellen. See deposition of Janusz Banaziak at page 154/161 and 1684 6 attached hereto as Exhibit MEMORANDUM OF LAW As is readily apparent from the foregoing facts, Ms. Kudman has either made false representations about Mr. Brunel?s whereabouts or Mr. Brunei has made false representations about his whereabouts that she passed on. In either case, they should be required to show cause why her and/or she should not be held in contempt of court for making false representations. See, Acton v. Target Corp, 2009 WL 5214419 at *5 (WD. Wash. 2009) (entering order to show cause why counsel should not be held in contempt for making false representations). in particular, Mr. Brunei and Ms. Kudrnan should explain how it came to pass that Mr. Brunei was in Florida at the very time that Jane Doe was attempting to take his deposition white Ms. Kudman was con?dently reporting that he was unavailable in France. Given the known facts, Ms. Kudman was either an unwitting messenger who passed along false representations delivered to her by her client Mr. Brunei, or she was a knowing participant in Brunei and/or Epstein?s attempt to obstruct discovery; either way a show cause order should be entered and the appropriate person(s) sanctioned and held in contempt. Mr. Brunel and Ms. Kudman should also be required to provide a full explanation of who precisely is paying the attorney fees for Ms. Kudman?s services. Most, if not all, Case 9:08acvm801 483 Entered on ELSE) Docket 03/i0i2010 Page 6 of 20 CASE NO: of the witnesses that have been deposed in this and related cases against Epstein have appeared with counsel retained and paid for by Defendant Jeffrey Epstein. In this instance, we know that Mr. Epstein was together with his house guest, Mr. Brunei, at a time when Brunel?s counsel was representing that Brunei was out of the country and could thus not attend a deposition. Mr. Epstein also knew at that time that the undersigned had been trying to coordinate Brunel?s deposition for months. Therefore, there is no doubt that Mr. Epstein was assisting Mr. Brunei and/or Ms. Kudman in obstructing discovery. At the very least, Mr. Epstein was an accomplice, but was he the person paying the attorney to make false representations and tamper with important witnesses? While Mr. Epstein may be able to invoke his 5th amendment rights on such questions, Mr. Brunei and Ms. Kudman do not have that luxury, and at this point they should be required to provide these answers. Again, as the facts make clear, Ms. Kudrnan has not delivered on promises made (as an officer of the court) to counsel for Jane Doe, and Mr. Brunei has not appeared for a deposition. As such, Jane Doe moves this Court to enter an order directing Mr. Brunei to appear for a deposition in West Palm Beach within 14 days. He was properly served with a subpoena by Jane Doe, and only through deceitful maneuvers he has been able to avoid his deposition. This Court should not permit subpoenas to be avoided in this fashion. WHEREFORE, Jane Doe respectfully requests the Court to direct Mr. Brunei and Ms. Kudman to show cause why they should not be held in contempt for making false representations in an effort to avoid a deposition. if the Court finds that they are in Case Document 483 Entered on FLSD Docket 03i10/2010 Page 7 of 20 CASE NO: 08-CV-80119-MARRAIJOHNSON contempt, the Court should also impose appropriate sanctions, including attorney?s fees for Jane Doe in connection with filing this motion. The Court should also compel Mr. Brunel to appear for a deposition within 14 days of the Court?s order and grant any additional relief the Court deems just and proper. CONFERENCE Counsel for Jane Doe has attempted to confer with Ms. Kudman about this motion, but she declined to make Brunei available for deposition, and in fact has again stated as recently as March 5, 2010 that Brunei has been out of the country since prior to the New Year with no plans to return. DATED: March 10, @010 Respectfully Submitted, 3! Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, EDWARDS, FISTOS LEHRMAN, PL. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 5242820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustioe.corn and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585?5202 Facsimile: 801-585-6833 E~Mail1 cassellp@law.utah.edu Case Document 483 Entered on ELSE) Docket 0311012010 Rage 8 of 20 CASE NO: CERTIFICATE or SERVICE I HEREBY CERTIFY that on March 10, 2010, I electronicaIly filed the foregoing document with the Clerk of the Court using I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner speci?ed, either via transmission of Notices of Electronic Filing generated by or in some other authorized manner for those parties who are not authorized to receive electronicatly filed Notices of Electronic Filing. s/ Bradlev J. Edwards Bradley J. Edwards SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Jdoldberder?ladweacom Robert D. Critton, Esq. rcritton?lbciclawcom Isidro Manual Garcia ieidrodarcia@beilscuth.net Jack Patrick Hill Katherine Warthen Ezell KEzell@eodhurst.com Michael James Pike Paul G. Cassell casselle@iaw.utah.edu Richard Horace WiIIits iawverswillits?aotcem Robert C. Josefsberg Case Ducument 483 Entered on FLSD Docket 03/10/2010 Page 9 of 20 CASE NO: riosefsberq?ipodhuramom Adam D. Horowitz ahorowitz@sexabu3eattornav.com Stuart 8. Mermelstein 88m@38xabuseattomev.com Case Document 4-83 Entered 0n FLSD Docket 0311012010 Page 10 of 20 CASE NO: EXHIBIT A Case Easement 483 Entered on FLSD Socket 03/10/2910 Page 11 of 20 Page 154 1 A. No. 2 MR. GOLDBERGER: Form. 3 BY MR. EDWARDS: 4 Q. And have you known, just based on your 5 observations, Nadia to have girlfriends? And by 6 girlfriends I mean girlfriends that she would be 7 intimate with in addition to being the girlfriend of 8 Jeffrey Epsteinyou know somebody by the name of Jean 11 Leo Brunei? i 12 A. Yes. i 13 Q. How do you know himthe house like, I guess, a few 15 times. 16 Q. When? 17 A. When? i 18 Q. When was the last time you saw him there? 19 A. A week ago. 20 Q. Today is, what, February 16th, and this is 21 a Tuesday. So, when we are saying a week ago, are 22 you saying it was last Tuesday, Wednesday, Thursday, 23 Friday, do you remember? 24 A. I don't remember the date but he stay maybe i 25 three days, I think, in the house. i (561) 832*7500 PROSE COURT AGENCY, INC. (561) 832-7506 Eiectronically signed by hopkins (661-051676?2934) - Eiectronically signed by hopkins {8914151376-2934) E?ectronicat?y signed by hopkins (601-051 676-2934) Case Easement 483 Entered on FLSD Docket 03/10/2010 Page 12 of 20 Page 155 1 Q. So, if he arrived on Tuesday, he stayed 2 through Thursday or Friday and "w a 3 A. Yes. 4 Q. Do you know what the occasion was for him 5 to come in town? 6 A. No. 7 Q. Where did he stay in the house last week? 8 A. One of the bedrooms upstairs. 9 Q. And was Mr. Epstein also staying in the i 10 house? 11 A. Yes. i 12 Q. All right. Did Mr. Brunei bring any 2 13 company with himwas him alone? 16 A. Yesthe house? 18 A. I think he has been picked up by Igor at this 2 19 point. i 20 Q. And where did he w? I assume he flew in 21 from somewhere? 22 A. Yes. i 23 Q. Picked up from the airport, safe 24 assumption? He didn't just drive to the airport. 25 (A discussion was held off the record.) Ezectronicaily signed by hopkins (6014351-976-2934) Ezectronicaily signed by [napkins {601-051~976~2934) Electromcally signed by hopkins (601-051-9m-2934) 2d75a91 Case Document 483 Entered on FLSEI) Docket 03/10/2010 Page 13 of 20 Page 156 i 1 BY MR . EDWARDS 2 Q. So, do you know where it was that 3 Mr. Brunei flew in fromyou know where Mr. Brunei generally 5 6 lives? I mean is it New York, is it 7 A. I know that he spends some time in Florida, in 8 Miami, but exactly where he is, I don't know. i 9 Q. But obviously he wouldn?t fly here to Palm 10 Beach from Miami, right, so he had to be coming from 11 somewhere else you would assume? 3 12 A. Yes, I assume. 13 Q. Were you told w? similar to the way that 14 you have been describing throughout the deposition, 15 you're told who is coming in town. Were you told he 16 was going to be at the house? 17 A. Yeah. Usually he requires to be picked up, so 18 I know that he is coming. 19 Q. Okay. We?ll go through some other 20 instances where you had occasion to pick him up or 21 break plans, but talking specifically about last 22 week: When were you first told that Mr. Brunei was i 23 going to be coming into town? 5 24 A. I think Igor told me that he has to go and 25 pick him up. 5 (561) 832~7500 PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by [napkins Electronically signed by hopkins {601651 ?5376-2934) Electronically signed by cynihia hopkins (601-051-976-2934) Case {Document 483 Entered on FLSD Docket Page 14 of 20 Page 157 day off, I guess, because usually I 3 am the one who pick up people. So, I guess it was my 2 4 days off and Igor was working, so he went to pick him 2 5 up. 2 6 Q. Okay. It wouldn't be Story Cowles picking the best of your recollection Igor 10 picked up Jean Luo Brunei sometime last week from 11 the airport and took him to the house? 2 12 A. Right. 13 Q. Do you know what car he took to pick him 5 14 up? 15 A. I think Cadillac Esoalade. 16 Q. The black Esoaiade? 17 A. Yes. 18 Q. And what did Mr. Brunei and Mr. Epstein do 3 19 for the three day stay when Mr. Brunei was staying 20 at Mr. Epstein's house last week? 21 MR. GOLDBERGER: Form. 22 THE WITNESS: I don't know. 23 BY MR. EDWARDS: 24 Q. Did you interact, communicate with 25 Mr. Brunei? i 1551', 83.2.4550 PROSE com as""siege"." Eiectronically signed by hopkins (601-051?976-2934) Eiectronically s?gned by hopkins {601~051~9??6~2934) Eiectronically signed by hopkins 82d1e Case 8:08?cvn88119wKAM Document 483 Entered on FLSD Docket 08/102?2010 Page 15 of 20 Page 158 A. Yes. 2 Q. And what did he say as to why he was here? 2 3 MR. GOLDBERGER: Form. 3 4 THE WITNESS: Good morning. How are you? 5 Exchange handshakekitchen and he was cooking something and that's 8 BY MR. EDWARDS: 9 Q. When you say he was cooking something, he 10 was personally cooking? i 11 A. Yes. 12 o. All right. So, this is a house that he is 13 familiar enough with and he is a regular enough 14 guest that he makes himself at home? 3 15 A. Yes. 16 Q. Okay. And last week do you remember l7 anything in the three?day period that Mr. Brunel was i 18 staying at the house that Mr. Brunel did from the 2 19 time he woke up to the time that he went to sleep? 5 20 MR. GOLDBERGER: Form. 2 21 BY MR. EDWARDS: 22 Q. I mean did go to the movies? Did he go to 23 the beach? Did they just hang out around the house 24 and walk? 25 A. Yeah. I think he walked outside to the beach. Ezectronicatiy signed by hopkins (601-051?9?6-2934) Etectronicaiiy signed by hopkins (601?051v-976u2934) Eiectronica?y signed by hopkins (601 4351 4176-2934) Case Sesamth 483 Entered on FLSD Docket 03H 0/2010 Page 16 of 20 Page 159 1 He was swimming in the pool, talking on the phone just 2 what I temember. 3 Q. Okay. During the threewday stay last 4 week, how often were I mean, I assuming that he 5 came in town to see Mr. Epstein; is that true? 6 A. Yes. 7 Q. And so the majority of his time during 8 that three days was spent hanging around with 9 Mr. Epstein? 10 A. Yes. 11 Q. All right. Did you see them talking with 12 one another? 13 A. Yes. i 14 Q. Where were they talking with one another? 15 A. In the cabana, outside sitting next to the 16 pool. 17 Q. All right. And when you said that 18 Mr. Brunel walked to the beach, did Mr. Epstein walk 19 to the beach with himMr. Bruhel walked alone? 22 A. Yes. 23 Q. Who else was in the house last week while 24 Mr. Brunel was in the house? 25 A. Nadia, Sarah, and Story, I think. i . Electronically signed by cynihia hopkins (601-4151 676-2934) Electronicain signed by hopkins Electronically signed by hopkins {601~051~976-2934) 82cm Case Document 483 Entered on FLSB Docket 03/10/2010 Page of 20 Page 160 i Q. Sarah Kellen? 2 A. Yes. 3 Q. And Story Cowles? 4 A. Yes. 5 Q. Okay. Who else, Igor? i 6 A. Igor. I guess that's it. 3 7 Q. Did you overhear any of the substance of 8 the conversations that Mr. Brunei was having with 9 Mr. EpsteinAll right. What is your understanding as 12 to the relationship between Mr. Brunei and i 13 Mr. Epstein? 14 A. I gueSs they are friends. 15 Q. Okay. In addition to being friends 16 well, let me ask this question first: Do you know 17 when they became friendsYou don't know how long they have known 2 20 each other? 21 A. No. 22 You don't know who introduced themThey could have met since they were five 25 years old or they could have met five years ago for Eiectronicaily signed by cynihia hopkins (691-051-976-2934) Eiectronica?y signed by cynihia hopkins (601-051~976-2934) Eiectronica?y signed by cynihia hopkins (601 4151 4376-2934) 2d75a91 d~3eaa~42b3-a822-b5d3071 82d'1 Case 9:08esw80?i19wKAM Document 483 Entered on FLSE) Docket 03/10/2010 Page 18 of 20 Page 161 1 all you know? 2 A. Yes. 3 Q. In addition to being friends, do you know 4 them to be we have a business relationship with one 5 another? 6 A. 1 don?t know. 2 7 Q. Do you know what Mr. Brunel does for a 8 living? 9 A. 1 think he has some modeling agency, owner of i 10 some modeling agency. I don't know exactly where, which i 11 one. i 12 Q. Why do you think that? Why do you think 13 he is involved with a modeling agency? 2 14 A. I think somebody told me. 5 15 Q. Okay. That's fair enough. Who? 16 A. I don't remember who. 2 17 Q. Would it be Sarah or Mr. Epstein? 18 A. It could be. i 19 Q. And whether it was Sarah or w" whoever 20 told you about this was one of the people that you 21 have previously described as being within the i 22 Jeffrey Epstein organization? 23 A. Yes. 24 Q. And as you sit here today, you can't say 25 definitely it was one person within the organization a (561) 832*??500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Eiectronicaiiy signed by hopkins (681-0513764934) Eiectronicaiiy signed by cynihia napkins (601-051-976~2934) Electronicaiiy signed by hopkins (601-051-93?64934) Case Document was Entered on FLSD Docket 03/ 10/2010 Page 18 of 20 Page 168 1 A. No. She was a guest, I assume. 2 Q. Any reason why there would be an overlap 3 between her staying at the house and Jean Luc 4 staying at the house, or it was just coincidence as 5 far as you could tell? 6 A. I don't know. 7 Q. Okay. And is there anywhere where you've 8 written down or documented what Sue's last name is? 9 A. No. 10 Q. Did you take her back to the airport? 11 A. Yes. 12 Q. And what day did you take her to the 13 airport? 2 14 A. Yesterday. 15 Q. Yesterday. So, she was here four days. 16 She got here last Thursday or Friday? 17 A. I think Fridaythe house for a period of 19 time when Jean Luc Brunel was at the house? i 20 A. Yeah. I mean, last week, yes. 21 Q. Okay. So, she got there Friday. When did i 22 Jean Luc Brune1 finally leave Mr. Epstein's house? 3 23 A. I think Monday, yeah, Monday. He left Monday. 24 Q. That?s yesterday? 25 A. Or Sunday. 2 (561) 832*?500 PROBE COURT AGENCY, INC. (561) 832~7506 Electronically signed by hopkins (601 4151 4376-2934) Electronically signed by cynihia hopkins (601-051-976-2934) Electronically signed by hopkins {801 ~051-976-2934) Case 9:08~cv~801i9~KAM Document 483 Entered on FLSO Docket 03/1012010 Page 20 of 20 Page 169 1 Q. Today is Tuesday. 2 A. Today is Tuesday. Yes, I think Sunday. 3 Q. Okay. So, on Sunday Jean Loo Brunei left 4 and on Monday Sue left? 5 A. Yes. a 6 Q. All right. Did you take Jean Loo Brunei 7 to the airport? 8 A. No. 9 Q. All right. Did Igor? 10 A. Sarah. 11 Q. Sarah Kellen. And do you know where he 12 was flying to? l3 A. No. 14 Q. You don't know where he came from or where i 15 he was flying to? 16 A. Right. 17 Q. Right. And as of right now you have no 18 knowledge as to where he primarily resides, whether 19 that I know you said that he spends some time in 20 Miami, but whether he primarily resides in Miami or 2 21 New York or Antartica, you have no idea? 22 A. No. 23 Q. Okay. Other than last week, when was the 24 last time that you saw this gentleman Jean Lao 25 Brunei at Jeffrey Epstein's house? g3;19566_i riggbs? Egg. Electronically signed by napkins (601-0518764934) Electronically signed by hopkins (601-051-976?2934} Electronically signed by hopkins {601 4151 ?9763-2934) DEFENDANT BRADLEY J. ED WARDS ?8 STA TEMENT 0F UNDISP TED FACTS Epstein v. Edwards, er a1. Case No. 50 .2009 CA 040800WMBAG EXHIBIT IN RE: INVESTIGATION OF JEFFREY EPSTEIN I 1 IT APPEARING that the City of Palm Beach Police Department and the State Attomey?s Of?ce for the 15th udioiol Circuit in and for Palm Beach County moreinafior, the ?State Attorney?s Of?ce") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter ?Epstoin"); IT APPEARING that the State Attorney?s Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the United States Attomey's Office and the Federal Bureau of Investigation have conducted thcir own investigation into Epstein?s background and any offenses that may havo been committed. by Epstein against the United States from in or around 2001 through in or around September 2007, including: (1) knowingly and willfully conspiring with .. others known and unknown to commit an o?mo against the United States, that is, to use a facility or means of interstate or foreign coroznoroo to knowingly persuade, induce, or entice minor females to engage in prostitution. in violation of Title 18, Unitod States Code, Section 24220)); all in violation ofTitle 18, United States Code, Section 371; . (2) knowingly and willfully compiring with others known and unknown to travel . in interstate commerce for the purpose of engaging in illicit sexual conduct, as' defined in 18 11.8.0 24236), With minor females, in violation of Title United States Code, Section 24230)); all in violation of Title 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commerce to knowingly persuades, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(1)) and 2; (4) oavoling in interstate commerce for the purpose of engaging in illicit sexual conduct, as de?ned in is 1.1.8.0. 2423(0, with minor females; in'violation Pageof Title 18, United States Code, Section 2423(b); and (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18. years and would be caused to engage in a commercial sex act as de?ned in 18 U.S.C. 1591 (ex in violation of Title 18. United States Code, Sections 159K330) end 2; and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the bene?ts provided by this agreement, he agrees to comply with its tonne, including undertaking certain actions with the State Attorney's Office; IT APPEARDJG, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Of?ce, that the interests of the United States, the State of Florida, and the Defendant will be served by. the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the . following conditions and the requirements of this Agreement set forth below. - If the United States Attorney should determine, based on reliable evidence, that, during the?period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home con?nement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days? of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis fer a determination of a breach of the Agreement. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney?s Of?ce, nor any offenses that arose from the Federal Grand Jury I investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed. Page 2 of 7 Terms of the Agreement: I. Epstein shell plead guilty (not nolo oontendere) to the Indictment as currently pending against him in the 15111 Judicial Circuit in and for Palm Beach County (Case No. charging one (I) count of solicitation of prostitution, in violation ofFl. Stat. 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney?s Of?ce charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostimtion, in violation of Florida Statutes Section 796.03; Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: Epstein shall be sentenced to consecutive tonne of twelve (12) months and six (6) months in countyjail for all charges. without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisomnent; and Epstein shall be sentenced to a tem of twelve (12) months of community control consecutive to his two tonne in' county jail as described in Term supra. This agreement is contingentupoo a Judge of the 15th Judicial Circuit accepting and executing the sentence agzeed open between the State Attomey?s Of?ce and Epstein, the details of which are set forth in this agreement. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney?s Of?ce from agreeing to recommend any additional charge-(s) or any additional term(s) of probation andfor incarceration. Epstein shall waive all challenges to the Infomation ?led by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. Epstein shall provide to the US. Attorney?s Of?ce copies of all Page 3 of 10. 11. proposed agreements with the State Attorney's Office prior to entering into those agreements. The United States shall provide attorneys with a list of individuals whom it has identi?ed as victims, as de?ned in 18 U.S.C. 2255, after Epstein has signed this agreement and been sentenced. Upon the execution of this agreement. the United States, in consultation with and subject to the good faith approval of Epstein?s cotmsel, shall select an attorney representative for these persons, who shall be paid for by Epstein. Epstein?s counsel my contact the identi?ed individuals through that representative. if any of the individuals referred to in paragraph (7), supra, elects to ?le suit pursuant to 18 11.8.0. 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person andlor the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identi?ed individual and Epstein, so long as the identi?ed individual elects to proceed exclusively under 18 U.S.C. 2255, and agrees to waive any other claim for damages, whomer pursuant to state, federal, or common law. Notwithstanding this waiver, as to these individuals whose names appear on the list provided by the United States, Epstein?s signature on this agreement, his waivers and failm'es to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability, Epstein?s signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States. Except as to those individUals who elect to proceed exciseively under 18 U.S.C. 2255, as set forth in paragraph (8), supra, neither Epstein?s signature on this agreement, nor its tones, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. - Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 sentenced not later than October 26, 2007. The United States has no objection to Epstein self~reporting to begin serving his sentence not later than January 4, 2008. 12. Epstein agrees that he will not be afforded any bene?ts with respect to gain time, other than the rights, oppommities, and bene?ts as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States? request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. l3. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that. the United States Attorney has no authority to require the State Attorney?s Of?ce to abide by any teens of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attomey?s Of?ce and to use his best efforts to ensure compliance with these procedures, which'coznpliance will be necessary to satisfy the United States? interest. Epstein also understands that it is his obligation to use his best efforts to convince the edge ofthe 15th Judicial Circuit to accept Epstein?s binding recommendation regarding the sentence to be imposed, and understands that the failure to . dose will be a breach of the agreement. In consideration of Epstein?s agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully ful?lls all of the toms and conditions of this agreement, the Uriited States also. agrees that it will not institute any criminal charges against any potential co-consoiratots of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groft', or Nadia upon execution of this agreement and a plea agreement with the State Attorney?s Of?ce, the federal Grand Jury investigation will be suspended, and all pending federal (hand Jury subpoenas will be held in abeyance unless and until the defendant violates any tom: of this agreement. The defendant likewise agrees to widtdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, Speci?cally evidence requested by or directly related to the gland jury subpoenas that have been issoed, and including cenain computer equipment, inviolate until all of the terms of this agreement have been satis?ed. Upon the successful completion of the toms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn. Page 5 of 7 By signing this agreement, Epstein asserts and certi?es that each of these toms is material to this agreement and is supported by independent consideration arid that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. By signing this agreement, Epstein asserts and certi?es that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to and public trial. Epstein further is aware that Rule 48(1)) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, inf?onnation, or complaint for unnecessary delay in presenting a charge to the Grand Jury, ?ling an information. or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer soch prosecution Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 4807) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the naming of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury?s investigation. Epstein asserts and certifies that he understands that the Fifth Arnendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury?s investigation, it may be by way ofan Infometiort signed and filed by the United States Attorney. and hereby waives his right to be indicted by a grand jury as to any such offense. I 1 Page 6 of 7 By signing this agreement, Epstein asserts and certi?es that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosccution Agreement and ewes to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Datud: By: - m" A. MARIE VIILAFANA ASSISTANT us. ATTORNEY Dated: a JEFFREYV Dated: GERALD LEFCOURT, ESQ. COUNSEL T0 JEFFREY EPSTEIN Dated: LILLY ANN SANCHEZ. ESQ. ATTORNEY FOR JEFFREY BPSTEIN Page 7 of 7 By signing this agreement, Epstein asserts and certi?es that the abovc has been read and explained to him. Epstein hereby states that he: understands the conditions of this Non? Prosecution and agrecs to comply with thcm. R. ALEXANDER ACOSTA UNITED STATES Dated: - By: A. MARIE VILLAFANA ASSISTANT US. ATTORNEY Dated: JEFFREY EPSTEIN Dated: - O7 Dated LILLY ANN SA ESQ. FOR JEFFREY EPSTEIN Page 7 of 7 By signing this ageement, Epstein asserts and certi?es the: the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non? Prosecution Agreement and agrees to compiy with ?rem. Dated:- Dated: Dated: R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A, MARIE - ASSISTANT us. ATTORNEY mm GERALD LEFCOURT, ESQ. COUNSEL T0 JEFFREY BPSTEIN ESQ. ATTORNEY FOR JEFFREY 395mm Page Of '7 IN RE: 0F JEFFREY I ADDENDW TO THE AGEEMEET APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 of the Non~Proseeutioa Agreement (hereinafter ?paragraph that agreement is modi?ed as ibtiows: 7A. 7B. 7C. The United States has the right to assign to an independent third-party for consulting with and, subjeet to the good faith approval of Bpsteta?s counsel, selecting the attorney representative for the individuals identi?ed under the Agreement. Ifthe United States elects to assign this reapoosibility to an independent mire-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the ?ne} designation of the attorney representative. - The parties will jointly prepare a short written submission to the independent third-party regarding the rote of the attorney representative and regarding Epstetn?s Agreement to pay such attorney representative his or her regular customary hourly rate for representing snob victims subject to the provisions of paragraph C. infra. I Pursuant to additiona! paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This previsioa, however, shat! not obligate Bp?stoin to pay thefees and costs of contested litigation ?led against him. Thus, if after consideration of potential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 115.0. 2255 or elects to pursue any other contested remedy, the paragraph 7 obtlgation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in 2255 to beat the costs or" the attorney - representative, shall cease. - . .a -A By signing this Addendum, Epstein asserts and certi?es that the above has been read and exp?iained to ?im. Epsmin hereby, stems that he underswids the cia??ca?ons to the Now Prosecution?wcanmt and agrees to comply with than. R. ALEXANDER ACOSTA UNITED sures ATTORNEY Dated: .. A. MARIE VILLAFANA ASSISTANT US. Dated: . SIETN Dated: . - . GERALD LEFCOURT, BS Q. COUNSEL T0 JEFFREY EPSTEW Dated: I I ANN ESQ. ATFORNEY FOR JEFFREY BPSTEYN By signing this Addendum, Epstein asserts and ccrti?es that the above has been read and explained to him. Epstein hereby states that he understands clari?cations to the Non- Prosocution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: - By: A. MARIE VILMFANA ASSISTANT (LS. AWORNEY Dated: JEFFREY EPSTEIN Dated: a 0 Dame}: LILLY ANN SANCHEZ. ESQ. ATTORNEY FOR JEFFREY EPSTEIN By signing this Addendum, Epstein mm and certi?es that the above has been read and explalnad to him. Epstein hereby stains that he understands the clari?cations to the Non. Prosecutioh Agreement and ta comply with them. Dated: Dated: mm: W. R. ALEXANDER ACOSTA UNITED STATES arrows? A. MARIE WLLAFANA ASSISTANT us. JEFFREY GERALD LEFCOURT, ESQ. COUNSEL T0 JEFFREY BPSTEIN arrows! FOR JEFFREY Wu-mm? "Mu?n DEFENDANT BRADLE .1 EDWARDS ?8 STA TEMENT 0F UNDISPUTED FA TS Epstein v. Edwards, 81? Case No. 50 2009 CA 040800MMBAG EXHIBIT YOUR ADDREssegocguee Name of Subdivision, Apartment Complex Numben Mobiie- Homework .cmd. I. Yong $5545! demon}. ?96: STATE omomA I I WRITTEN REPORT rein ., i2)er Wag Yam ?oodxr'FarW i (Provide physical locatioo Post. Of?ce Box) No.56 . a I ?15:9 CELLULAR TELEPHONE omen No. I I 1.: 3 EMPLOYEREMAIL: I YOUR TOTAL MONEY money - (Gross timeout) I Meme-Ia Vehicle MakeMgadeUYear/I?a? I Additional em?loy?lenilix?ormg?on?: ?111} no mes, ages; and your gela?onship to persons who resided of your {eeidence (1 ring this :?oot?e .I-. I Ha?g?s 7W: ?e mi '5 ?Won nave you consumed alcoholic beverages? I. I Have-you used orbought mega! drugs or controlled substances? It 6 Have you attended educational, vocational classes or mental I I II health, drug, alcohol, therapy, or Self-improvement programs? El (If yes, circle which one) Have you been arrested or had any contact with law enforcement during t?e?lasemoh?z? I - I 3 Eyes, explain what happened on separate sheet of paper, attached toreportHyou went" into debt for any ceaeon, explainnot working, give reason and source of income: If you have?any questions or problems to discuss with your Officer, explain: in!? I, ewe? ea? If monetary obligation owed, amount paid this month: I, . Receipts are available through your probation officer. DO NOT SUBMIT CASH 0R PERSONALL Make money order payable to the Departinent of Corrections. . x: - . If monetary obligation (Med and no payment made, give reason and date whee payment will be inside: certify the above to be tree and complete" Yoef'S'ig'natore: Date WMR Received: Date WMR Due: Comments: Mailing Address} u. .f . . E-Mail Address: (Efopplicabte) .2. I I .- "'Officef?s Name:. I For Month Ending: . . -. papaya/{om Datem?le submitth WRITTEN REPORT YOUR-NAME: 4 . In Emma; YOUR Name EMPLOYER SADDRESS: Apanmenr Complex {zodNumben I Mobig?ome Parkondio .551(Provide physical location Q??ice Box) CELL II TELEPHONE No? 1 PAGER No. TELEPHONE No. 6? f. f" ?173 - we! EMPLOYER EMAIL: CELLULAR TELEPHONE No. ?1 1 or 2 ?3?53 MONEY EARNED . .- . (Gross Amount) PAGER NoFull time?m Part-time Hours Workedm Vehicle Make/MPfieWearfl?ag I I Additional employment information: Mg. . . List full names, agesaand y?oonl?eela?onship to all persons who resided?at Stout resioence during this month: I Tom 4* - Angora ?uff?? 5 CF, 5' 9.1. ?g -- 1 6.7lave yoiz consumed alcoholic beverages? Havevyou used or, [weight iHegal dings or controlled substances? Have you attended edooa?on?al, vocational classes or mental health,Idrug, alcohol, ti; "fapy, of self-improvement programs? (If yes; circle which oneHave you been arrested?or had aziy contact with law enforcement during the last month? If yes, expiain whet happened on separate sheet of paper, attached. to report. I Ifyoni went into debt for?aoy reason, explain: I i If not working, give reason and soot-co of income: . Cl [113% mam if yozi have a'ny questions or problems to discuss with your Officer. explain: .K1 I If monetat-y'oblig'ation owed, a-mbunt peidimiris mooth: Receipts are available through your proba?oo'officer, DO NOT SUBMIT, CASH 0R PERSONAL Make money order payabie to the Department of Corrections. if monetary obligation owed and tie-payment made, give reason and date when payment will be made: I OffiCial Use Only: (I certify the above to 1) true . Signature of Officer Receiving Report: I Your SignIa?lreI. I a Mailin ddreos: 1'0, COW or ow -- . Bit: WMR OD Cm at? m" Comments: I State: V?w Zip: 35ft? . E-Mail Address: Dam/1 h?cabie? 5" I PP . .Ln - J??icer?s Name: If -- I, .H DEPARTMENT OF CORRECTIONS Datefrnme submtted:" I WRITTEN REPORT . . if], oce- . . . NAME: . YOUR RESIDENCE ADDRESS. (mam Name of wuss: . SubdivisMia? gm mew? Z?oce. .I- - a? I . Blend" EFL 3? a: EMPLOYEM TELEPHONE Neadom??y 't I (Provide physical {acorioa NOT Post O??ice Box) CELLULAR TELEPEONE No' PAGER o. TELEPHONE No. 55 EMPLOYER mam . YOUR TOTAL MONEY EARNED CELLULAR TELEPHONE '9?qu ,3 ?3 (Gross Amount) PAGER No. . . . Full?me Part~time Hours Worked a Vehide Makemiodewear?ag #3 WW Addition! employment information: List full names, ages, and your relationship to all persons who resided at your resideneetdurinng this meaty; . - .1 Mamet?; - ?3 .- Fraj?, 1 cu ?w an; .3- eat? ?op. Laura 6% .iave you consumed alcoholic beverages? Have-you used or bought illegal drugs or controlled substances? Have you attended educational, vocational classes or meats! heoiun, drug, alcohol, therapy, or self-improvement programs? {If yes, circle which one) I - m. He ve you been arrested or had any contact with law enforcement do ring the last month? if yes, explain what happened on separate sheet of paper, attached to report. . If you went into debt for any reason, explain: . CU: men If not working, give reason and source of income: If you have any questions or problems to discuss with your Officer. explain: if monetary obiigation owed, amount paid this month: Receipts are avaiiabie through your probation officer. 130 NOT SUBMIT CASH 0R PERSONAL Make money order payable to the Department of Corrections. If monetary obiigation owed and no payment made, give reason and date when payment will be made: Official Use Only: I I certify the above to be true and complete: Slgnature of Officer Report: Your Signature: Mailing Address: \cl'f/G'V/K ate WMR Received City: ?7 7) Date WMR Due: State: FL, ?Zip: I . Comments: 5 I 0 Retail Address: . (if applicable) DEFENDANT BRADLEY EDWARDS ?8 STA TEMENT 0F UNDISP TED FACTS Epstein v. Edwards, er at. Case No. 50 2009 CA 040800WMBAG EXHIBIT II UNITED- STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. [38-le WMARRNJOHNSON JANE DOE, Plaintiff, vs. JEFFREY Defendant. NGTIC-E 0F NGTIEE- that the Plaintiff. JANE DOE, wifl take the deposition of Jean Lu'c Bruhel cm 2009,, at 10:00 am, at: E?squire Stanza Rapo?em G?ae Pam} Plaza 813% 45-715 New York, NY 19119 The depoaition shall be c-Qnducted pursuant to the Flarida Rules of Civil Procedure and shali continue day to day, weekends and holidays- exaepted, completed. HEREBY CERTIFY that a true and correct copy of the foregoing has baen {served by US. Mail and emaif transmission this cf August, 2009 to all those on tha attached Service List CC: ESq'u%re Court-Reporters RQS-ENFESLDT ABLER Attorneys fer Plaintiff 401 East. Lass Olag Blvd, Suite 1650 Part Lauderd'ale, Florida. 33381 Tel: (954) 52293456" Fax: (954)527n3-663 Email: BRAD EDWARDS, ESQ. Flarid?a 542375 A0 83A (Rm. ?31,509) 1o Ratify oi. as Depositing or Fromm Bummer-1.23 a CEVEI Anion UNITED DISTRICT COURT for the Southern District of Florida JRNEE BEBE Piazimn?? I v. 3 Civil Action No, JEFFREY Emmi-N ("If the action is pending in another district, state where: 06:72:31de SHE-PGE-NA TE) MSTIFY AT A 01R TO IN A CIVIL ACTEQN To: Joan Loo Bram-i, 30?? E. 66th Street. New York, NY Q, Testimony: YOU ARE COMMANDEI) to appear at the time, date, and place sot forth below to testify ?11121 doposition to be. taken in this oivii action. If you are an" organizat?on that is no; a party in this case,- you must dooignato one or more officers, directors, or managing agents, or designate billet!? persons who consent-to testify on your behalf about the following matters, or those". set: fort-h in an attachmoot: Place: EsQuiro Court Reporters, Ono Pom Pia-m Date and Time: Suite 4715. New NY 09122/2009 19:00 The ?ep-osition will ho recorded by this mothod: ?1 You, or: your roprosontativos, must also bring with you to the deposition the following doouznonm, electronically stored infonnaiion, or objects, and. permit their iraSpoot?ion, copying, testing, or sampling. of the material: The provisions of Fed. R. Civ. P. Mating to your protection as a person subject to a. subpoena? and Rule 45 and (3), relating to your duty to respond to this subpoena and the poto'ntiai consequences of not doing so, are: attaohod. CLERK OF COURT Signamm QfCI?rk or 13?qu {Hark A fiamqr ?5 xig?amre Hm? The name, address, telephone number of-tho attorney rep'rosonjting (:rrmm-ofparw who issoos {Jr-requests thio subpoena, are: Brad Edwards, Esq, Rothstoin Rosonf'ozot Aoier. 401' E. Loo 01313- Bivd.? Suite 165.0; Fort Laudordalo, Florida 3330-1 (9'54) 522' 2346 A0 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2) Civil Action No. PROOF OF SERVICE (This section should not be?led with the court unless required by Fed. R. Civ. P. 45.) This subpoena for Mame ofindm'dua! and title, grany) was received by me on (date) ?21 I personally served the subpoena on the individual at @Iace) on (date) or E3 I left the subpoena at the individuals residence or usual piece of abode with (name) a person of suitable age and discretion who resides there, on (daze) and mailed a copy to the individual?s last imown address; or I served the subpoena on {name offedividual) I who is designated by law to accept service of process on behalf of (name oforganfza?'on) on (date) ;or I returned the subpoena unexecuted because ;or Other (specr?j: Unless the subpoena was issued on behalf of the United States, or one of its of?cers or agents, 3 have also tendered to the witness fees for one day?s attendance, and the mileage attowed by iaw, in the amount of My fees are for travel and for services, for a total of 0.00 I declare under penatty of perjury that this information is true. Date: Server is signal are Printed name and title Server ?5 address A Additional mfonnation regarding attempted service, etc: A0 88A (Rev. 02109) Subpoena to Testify at a Imposition or to Produce Documents in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 and (Effective 12/1/07) a Person Subject to a Subpoena. (1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The issuing court must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney?s fees on a party or attorney who falls to cemply. (2) Command to Produce Materials or Permit Inspection. (A) Appearance Not Required. A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of? premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial. (B) Objections. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises m? or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply; At any time, on notice to the commanded person, the serving party may move the issuing court for an order compelling production or inspection. (ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party not a party's of?cer from signi?cant expense resulting from compliance. or Modifying a Subpoena. (A) When Required. On timely motion, the issuing court must quash or modify a subpoena that: (5) fails to allow a reasonable time to comply; (ll) requires a person who is neither a party not a party?s of?cer to travel more than 100 miles ?rm where that person resides, is employed, or regularly transects business in person except that, subject to Rule the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held; requires disclosure of privileged or other protected matter, if no exception or waiver applies; or (iv) subjects a person to undue burden. (B) When Permitted. To protect a person subject to or affected by a subpoena, the issuing court may, on motion, quash or modify the subpoena if it requires: disclosing a trade secret or other con?dential research, development, or commercial information; (ii) disclosing an unretained expert?s opinion or information that does not describe speci?c occurrences in dispute and results born the expert?s study that was not requested by a party; or a person who is neither a party nor a party?s officer to incur substantial cXpense to travel more than IOO miles to attend trial. (C) Speci?u?ng Corrdr?tr?ons as on Alternative. In the circumstances described in Rule B), the court may, instead of quashing or modifying a subpoena, order appearance or production under speci?ed conditions if the serving party: (1) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and (ii) ensures that the subpoenaed person will be reasonably compensated. Duties in Responding to a Subpoena. (I) Producing Documents or Electronically Stored Information. These procedures apply to producing documents or electronically stored information: (A) Documents. A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand. (B) Formfor Producing Electronicalfy Stored ful?l-motion Not Speci?ed. If a subpoena does not specify a form for producing electronically stored information, the person reaponding must produce lt in a form or forms in which it is ordinarily maintained or in a reasonably usable form or fonns. (C) Electronically Stored Information Produced in Only One Form. The person responding need not produce the same electronically stored information in more than one than. (D) Inaccessible Electronically Stored Information. The person responding need not provide discovery of electronically stored information from sources that the person identi?es as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule The court may specify conditions for the discovery. (2) Claiming Privilege or Protection. (A) Withheld. A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: 'a expressly make the claim; and (ii) describe the nature of the withheld documents, . communications, or tangible things in a manner that, without revealing in formation itself privileged or protected,-will enable the parties to assess the claim. (B) Information Produced If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial- preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. A?er beirr noti?ed, a party must return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being noti?ed; and may present the information to the court under seal for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved. Contempt. The issuing court may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena. A company?s failure to obey must be excused if the subpoena purports to require the nonparty to attend or producc at a place outside the limits of Rule DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISP UT ED FACTS Epstein v. Edwards, et Case No. .- 50 EXHIBIT I ?A?xazonx-?Om . ISSGMercer Rd: Lexington, KY 40511 }ef{rey EpsItfziR 355 El Brine Way . Palm Bea ch, Fioricia 33480 USA $1131 - - i Jeffrey Epstein "preferences, and much more 24 hours I I .1 '358 Emmi? Way - "358 EI'Bzing Paim BeacfgingigaBMS .i?aim Beachfiodda 3342-10 . -- - ., -.- agar?? .. ,1 .gRetums Are?EasyIunopened - @?md (other restrictiom Your or?eno'?LS?pIember 4, 2005 (Order - IN THIS 1 SM 101: A?ealisgictigtrodgciidn_ . . - 53:1de -, . . . . .rapego . - again1=4 . 43143 - .. . ama?z?o?'and ypu'rq (IigInei' .-II Box-or L'lgmm I. II 11mm II I DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et Case No. 50 2 009 CA EXHIBIT HH UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. OBWCIV-80893 JANE DOE, Plaintiff, VS. JEFFREY EPSTEIN, Defendant. 1263 S.W. let Terrace Miami, Florida 33145 Tuesday, June 15, 2010 4:06 p.m. SWORN STATEMENT OF MARITZA VASQUEZ Taken before ELAINE CRANDALL, Registered Professional Reporter and Notary Public in and for the State of Florida at Large, pursuant to Notice of Taking Unsworn Statement in the above cause. U.S. Legal Support (305) 373~8404 2 4 1 APPEARANCES A. in his of?ce. 2 2 Q. Related to what; modeling? 3 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS 3 At workg?g, yeah. Modding. 4 gi?ii??gllm EDWARDS ES 4 Q. What, at that point in time, did you 425.1%lo Andrews Avenue, Shite? 2 know abomi Jean?Luc Emmi). 5 Fort Lauderdale, Fiorida 33301-3268 7, angin:othmg? At that ?me I did? know 6 7 MICHAEL FISTBN 8 Q. So how did you meet with Jean-Lac Brunei 8 9 in his office in 1998? 10 A. Because there was a gentleman from 1 0 1 Switzeriand who wanted to make business with them. 1 3. 3.2 And I was hired by that gentleman to look through 12 1 3 ah the accounts to make sure that you know, 13 3. 4 they were kind of in bankruptcy. But he wanted to 1 4 5 know that his money, his investment, would be 31?: 1 6 good. So that?s why i went. Like, an external 1 7 17 audit to do -- to see what was the income, the 8 i 8 expenses and something iike thatthe guy from Switzeriand? 2 0 2 A. i?m not going to tel} you his namethat somebody who is still in touch 2 2 2 2 with Jean-Lac Bruneiall. 2 4 2 4 Q. What's the reason for not wanting to 25 2 diseiose his name? Does he have anything to do 3 5 Thereuponn 1 with this case? 2 MARZTZA VASQUEZ 2 A. No. But i don't have permission. 1 3 was called as a witness by the Plaintiff and, 3 have to ask him. 4 after having been ?rst duly sworn, was examined 4 Q. Okay. And after your meeting with 5 and testi?ed as foliows: 5 Jean~Luc Brunei in 1998 ?u welt, what company was 6 DIRECT 6 Jean?Lac Brunei with then? 7 BY MR. EDWARDS: A. Karin?s Models, it was, at that time. 8 Q. Teli us your name. 8 Q. 9 A. Maritza Vasquez. 9 A. Yes. 1 0 Q. And just to the get to the point, you 10 Q. And is that the only other modeling 1 1 know who Jeffrey Epstein is? 11 agency that you have known Jean-Loo Brunei to be 3.2 A. Yes. 12 associated with, besides MC Squared? 1 3 Q. And you've met him before? 1 3 A. Yes. 1 4 A. Yes. 1 4 Q. And how long was Jean-Lac with Karin, 1 5 Q. And you know who Jean-Lac Brunei is? 15 from 1998 through -- 6 A. Yes. 1 6 A. No, Jean-Lac was the owner of Karin?s. 17 Q. And you have met him before? 17 Before that. {think since 1986, in Paris. 18 A. Yes. 18 Q. right. And why was he no longer 19 Q. Which one did you meet ?rst? 19 af?iiated with Karin at some point in time? 2 0 A. Jean?Luc Brunei. 2 {3 A. He closed And where did you meet him? 2 1 made a dissolution. He dissolved the company. 22 A. In Miami Beach. 22 Q. Were you ever hired to work with Karin? 2 3 Q. When? 2 3 A. I was hired to work with Karin's, yeah. 24 A. in 1998. 24 Q. When was that? 25 Q. And how? 25 A. In 1993. 2 (Pages 2 to 5) U.S. Legal Support (305) 373-8404 6 8 1 Q. What was your position? 1 Epstein owns or controls numerous apartments in 2 A. At that time, bookkeeper. 2 that at that same address; is that right? 3 Q. In Miami? 3 A. Yes. Yes. 4 A. Yes. 4 Q. And have you ever been to that address? 5 Q. And how long did you stay as the 5 A. No. 6 bookkeeper in Miami for Karin? 6 Q. And how do you know that he owns or 7 A. Until 2003, when they changed the 7 controls numerous apartments at that address? 8 company to MC Squared. 8 A. Because at that time Evelyn Valenzeula 9 Q. So when did the officiai change come 9 was the of?ce manager from Karin to MC Squared? 10 dealing personally with the assistant of Je??rey 3. A. In 2003. 3. Epstein. And she had to do the payments for the 3.2 Q. And when is the ?rst time you met 12 cable and, I believe, electricity. 1 3 Jeffrey Epstein? 13 Q. And Evelyn who was the assistant of 14 A. I met Jeffrey Epstein only once in my 14 Jeffrey Epstein that Evelyn was dealing with? 15 life. And I believe it was in 2003. Two 15 A. I don't know. 1 6 thousand yeah, by the end of 2003, 2004. 1 6 Q. Cecilia Stein? 1 7 Q. Where? 1 7 A. I believe so. 1 8 A. In New York. 1 8 Q. Do you remember that name? 1 9 Q. What was the occasion? 3L 9 A. Yes. - 2 0 A. It was the open pasty for MC Squared. 2 0 Q. That?s somebody who no longer iives 2 1 Q. Where was that held? 2 1 here. right? 2 2 A. In a discotheque in Manhattan. 2 2 A. i i beiieve i heard that, yeah. 2 3 Q. What diseotheque? 2 3 Q. Who did you hear that from? 2 4 A. I don?t know. I don't remember. 2 4 A. Fron'i Evelyn, from Conetta (phonetic), 2 5 Q. And did you meet Elaine Maxwell? 25 from 7 9 1 A. {don?t know her name. But he was 1 Q. Okay. And at sooie point in time you 2 with -- with a woman. I don?t know. 2 came to know that the models were also staying in 3 Q. And what is yodr understanding or what 3 these apartments at 301 East 66th Street, right? 4 was your understanding that Jeffrey in terms of 4 A. i don?t know speci?cally they stay at 5 Jeffrey Epstein's involvement with MC Squared? 5 Jean?Luo?s apartment. Butl know that the models 6 A. Jean?Loo always said that Jeffrey was 6 were staying in different apartments that belong 7 his friend, that he is a millionaire. And that 7 to Jeffrey Epstein. 8 Jeffrey was giving him the money to -- you know, 8 Q. And what are the names of the models 9 loans or whatever and the apartments for the 9 that were staying there, that you remember? 1 0 girls and things like that. A. Most of them. You know, at that time, 1 1 Q. All right. Let?s break that down. 1 1 when I was there who -- all the little girls. 12 Giving money for what purpose? For furthering MC 1 2 Mohini 13 Squared? 1 3 Q. How do you spell that? 4 A. For for yeah, the money came to MC 14 A. you know, that was in 15 Squared, not to -- i don't know. i?rior to 2003, i 5 NOD-something. I don?t recall all the names. 1 6 don?t know if Je?iey Epstein ever gave him money. 1 6 But there is a list that you can get it from the 1 ?i I know that item the longest Iean~Lue was living 1 7 of?ce in New York. 1 8 in an apartment that belongs to Jeffrey EpsteinWhat apartment is that? 9 A. They have a list of models that they 2 0 A. It's in New York. I don?t know the 2 0 were staying in those apartments. 2 1 address. 2 1 Q. If I were to request it from the of?ce 22 Q. Is that at 301 East 66th Street? 2 2 in New York, what would I ask for? 23 A. Yeah, something like that. I think it's 23 A. For the models? apartment list. 2 4 that one. 2 4 Chargebaek for models apartments. 25 Q. And it?s my understanding that Jeffrey 25 Q. Chargeback? 3 (Pages 6 to 9) U.S. Legal Support (305) 373*8404 10 12 3. A. Yeah, because le?rey Epstein never 1 A. No, I don't know. 2 2 3 charging rent to the giris. And in her statements 3 guarantor on the Line of Credit of a million 4 it shows 30l, 66 Apartment A, or Apartment B. And 4 dollars, what other involvement are you aware of 5 he was charging them, like, a thousand dollars a 5 that Jeffrey Epstein had with MC Squared and/or 6 month. 6 the apartments at 301 East 66th Street where the 7 7 8 A. Because I was doing the statements. 8 A. They were planning on buying or 9 Q. You were actually the one doing the 9 associating with a girl in -- in France for a -- 1 0 statements? 1 for a company. They were planning to do a 1 1 A. Not all the time. was in New York 1 3. company. And, actually, i gave the paper to -- to 12 starting 2003. 2 Mr. Shawn Connolly, which is an actual paper that 13 Q. Through what date? You were in New York 13 came from the office from Jeffrey Epstein, that he 14 from 2003 ?m 4 was giving instructions to Jean-Lac saying that he 1 5 A. 2006. 15 wanted to have the same contracts as -- uh, what's 1 6 Q. And while you were in New York you were 1 6 his name, of Donald Trump, and that he wanted to 7 working for MC Squared? 7 have the same kind of benefits for the scooters. 1 8 A. Yes. 1 8 So he was giving instructions to 19 Q. And what is the proof that you have seen 1 9 Jean-Lac on what to do, what to there is a 2 0 that Jeffrey Epstein was a partner or ?nancial 2 0 woman in Paris, 1 don?t recall her name, Freiit 2 supporter of MC Squared? 2 It (phonetic), i believe it was, and they were -- 22 A. I was the one who took the papers to 22 they were, the three of them, trying to do a new 2 3 Mellon Bank. 2 3 cornpany. But then everything was, like, on zero. 2 4 Q. That's in Miami? 2 4 They never they never did it together. 2 5 A. Yes. And Swetpaul (phoneticyon know why? 11 13 talking at the time to Rich I believe his name 1 A. No. 2 2 3 assistants of Jeffrey EpsteinGarry, 4 A. lfyou give it to me, yeah. ifyou give 5 A. Yeah. 5 me the name, i can recall. 5 Q. Do they call him Eric Gany? 6 Q. Okay. While I'm looking for that, how 7 A. That is him name, yeah, Eric Garry. 7 many girls that were models were living in the 8 That?s his name. I recall some things, not all 8 apartments at any given time at 381 East 66th 9 the time. I recall that Mr. Epstein didn?t want 9 Street? 1 0 to Sign the papers, but Mellon Bank didn?t want to l. 0 A. That?s that?s not only One apartment. 1 3. accept the Line of Credit if he didn?t Sign. So i. 1 There are a lot of apartments there. There is not 12 we had to return the papers to New York so he 1 2 only one girl. There is not only one apartment. 3. 3 actually signed the documents. 1 3 I believe there were, like, two or three 1 4 Q. And what was he aetaaily signing, that 1 4 apartments. And they were put in between four 1 5 you remember? Signing over as a Line of Credit 15 girls per apartment, I believe. 1 6 or 6 Q. How many apartments? 1 7 A. As a line as the grantor of the Line 17 A. believe there were, like, two or 1 8 of Credit. Because the Line of Credit came from 1 8 three. 1 9 J. P. Morgan directly, but he was the grantor. He 3. 9 Q. And there is four girls per apartment? 2 was the one who actually was responsible. 2 A. Yeah. 2 1 Q. And how much was the Line of Credit? 2 1 Q. And you know that because you saw the 22 A. A million dollars, it was, at that time. 2 2 documentation at MC Squared that showed where 2 3 Q. And did you ever keep track of whether 2 3 these girls were living? 2 4 or not that line was extended or any additional 24 A. Yes. 2 5 monies were given to MC Squared? 25 Q. Did you also have something to do with 4 (Pages 10 to 13) U.S. Legal Support (305) 373*8404 14 16 1 the visas that were prepared for the girls that 3. A. No. 2 were working? 2 Q. Have you ever met her? 3 3 Aim 4 attorney. His name is Luis Font. He was doing 4 Q. Have you ever met Sarah Kellen 5 the visas here in Miami. There was another 5 (phonetic)? 6 Vaienzneia was handling directly the visas in New 6 A. No. 7 York. And only when she had problems, she hired 7? Q. You have only met Jeffrey Epstein once 8 another attorney. i don't know the name of the 8 in person. How many times have you talked to him 9 attorney in New York. But Lois Font is the -- 9 on the phone? 1 was, at that time, the attorney handling the visas 3. 0 A. Maybe once. 1 1 for Miami. 3. 1 Q. At some point in time you drove several 12 Q. Do you remember doing the visa for Nadia 12 girls or a number of girls over to Jeffrey 1 3 Marcinkova? 1 3 Epstein?s house; correct? 3. 4 A. No, that was done in New York by Eve 1 4 A. Not me. Jean-Loo directiy took them. I 15 Valenzuela. 1 5 was making the arrangements to get a limousine or 1 6 Q. And Nadia's visa, that you speci?cally l. 6 a car. And Jean~Luc himself was driving the girls 3. 7 remember being done. right? 1 7 to his house because he was having a party and 1 8 A. Yeah, i remember that. Because at one 3. 8 there were supposed to be girls. 1 9 point, i believe, one of the renovations of her 1 9 Q. Which git-is did he drive over there? 2 0 visa, something happened. And Mr. Epstein coiled 2 0 A. One time I know he went with Mohini, 2 the of?ce while i was there and was really upset. 2 1 with uh, what?s her name? Four girls from 2 2 And he spoke with .Fean-Luc and they they were 22 Brazil, from the same agency. Mohini is one of 2 3 reaily nasty with Eve and, you know, it wasn't 2 3 them because i remember her name. The other 2 4 if it wasn?t Eve?s fault. it was their fault 2 4 Ones maybe if you 2 5 because they gave the wrong information. But, you 25 Q. Elena Weber? 15 17 1 know, she was only an employee and thatHow did Nadia Marcinkova come into the - 2 Q. Juliana Barbosa? 3 countrymodel?s visa, 1 beiieve. 4 Q. Do yon know those two girls? 5 Q. And was she brought in speci?cally by 5 A. Yes. 6 Jeffrey Epstein or Jean?Lac or do you remember? 6 Q. And were these girls somehow involved 7 A. Mr. Epstein was paying for the visas. 7 with Jean-Lac or the modeling agency? 8 But, you know, all the visas were done through -- 8 A. Yes. 9 through Karin's or MC Squared. I heiieve she came 9 Q. They were both MC Squared models? 1 0 with Karin's visa ?rst, then everything 1 A. Yes. 1 3. transferred to MC Square. And i believe those 1 1 Q, And at the time, when they began, how 1. 2 visas were paid directiy by Mr. Epstein. 2 old were they; do you remember? 1 3 Q. How oid was Nadia Mareinkova when she 1 3 A. i beiieve Molina was, like, 14, 15. And 1 4 first came? 1 43. Juiiana was 13, 14, when she came. 1 5 A. i don't know. i wasn?t in New York at 3. 5 Q. Okay. And do you know where they are 6 that time. Because i know she came prior to me 1 6 now, either one of them? 1 7 getting invoived in New York. 1 7* A. I know Juliana is in New York. 18 Q. And you were involved in New York in 1 8 Q. When is the last time you talked to her? 1 9 2803? 1 9 A. in 2006. 20 A. Yes. 20 Q. How do you know she is in New York? 2 1 Q. So she came in some time before that? 2 l. A. Because i saw her pictares whenever. i 22 A. I believe so. 2 2 believe she?s in New York. I don't know if she 2 3 Q. But even back in 2083, she still i 2 3 reaily is in New York but I believe. 24 den?t know how old she is now. She's probahiy 24 2 4 Q. Elena Weber? 2 5 or 25, right; do you know? 2 5 A. Elena, the 1331: time i saw her was in 5 (Pages 14 to 17) U.S. Legal Support (305) 373~8404 18 28 1 2006, too. And, speci?cally, i don?t know where 3. A. I heard that. i heard that. don't 2 she is. But if she?s in the United States, I 2 know, because I never met I never I was 3 believe She's in New York. If not, she is in 3 never, lilce, around him or nothing like that. l?rn 4 4 5 Q. All right. Do you know this person in 5 Jean~Luc, I know -- I know he has that kind of 6 Brazil, Cacha or Cache? or 5 problemlong as you knew Jean-Lac, he 8 Q. Here is a document that we obtained 8 always had a cocaine problem? 9 related to information from Jeffrey Epstein?s 9 A. Yes. 1 8 computer system. It says Massage Paris. It?s in 1 0 Q. What about Jeff Fuller? 3. 1 a square there and it continues to the next page. 1 1 A. I know he had a cocaine problem, too. 3.2 Tell me if you recognize any of those names. 1 2 He was one time on the interact, you know, like, a 13 A. No. Lakita -- Lila is one of the girls 3. 3 report on that. 3. 4 that went with Mohini, now that l'in seeing kind of i. 4 Q. And is Jeff Fuller somebody else who you 1 5 names. Lila is one ofthe other ones. ifthis is i. 5 also knew to have been associated sexually with 1 6 Lolita or Lakita, something like that, it?s a 1 6 underage girls? 17 black girl that believe she was she was not 3. '7 A. Eeff, I you know, i don't think Eeff. 8 underage but she was going outwith one of 3. 8 I always thought eff was gay. For me, he's gay. 1 9 Jeffrey's best friends. 1 9 You know, that?s the impression that I have. But 2 Q. Who is that? 2 i don't think so. 23. A. believe 21 Q. Did you ?nd out that Jeffrey Epstein 2 2 Q. Who is Jeffrey's best friend that she 2 2 and/or Jean?Lac Brunei were involved in these 2 3 was going out with? 2 3 underage girls that were staying in these 2 4 A. {don?t know. Idon't know. Lakita, 2 4 apartments at 301 East 66th Street? 2 5 something like that, is her name. 2 5 A. I really don?t know that. You know, i 19 21 1 Q. All right. What information do you have 3. cannot tell you. i know there were girls stayng 2 about canlezc being involved with underage girls 2 there. I never knew if they were going there or 3 at any point in time? And by that I mean being 3 not. 4 involved sexually with underage girls. 4 Q. You mean, you knew that the girls were 5 A. One day he told me that he wishes he can 5 staying there; 13, 3.4, 15? 6 sieep with one of those girls that was underage. 6 A. Some of the girls were underage, yeah. 7 And I told him that's a minor, whatever. And 7 Q. As well as 13, 14 or so? 8 then hoid on, that?s my son. 8 A. Thirteen or 14, yeah. 9 (Telephone interruption.) 9 Q. Did you ever ask any of the girls if 3. A. He had a problem, you know. I cannot 1 0 they were sexually involved with canwLue andfor Ii 1 say i saw them, look, because i wouid be lying. if. 3. Jeffrey Epstein? 1 2 And I'm not going to say any lie. But the only 12 A. No. One time there was a problem with 13 thing that i can tell you that what I saw about 1 3 Juliana. And she was beiievc she was 1 4 lean?Luc is that lean-Lac is a drug addict, a 3.4 14 years old. And she tried to go m? or they took 1 5 cocaine addict. 3. 5 her to a discotheque in Miami Beach. And when I 6 Q. At some point in time you actually saw 1 6 went to work the day after, they told me that the 1 7 evidence of that, right? 17 police was asking. So since she was doing 1 8 A. Yes. 1 8 whatever she wanted, you know, I brought her to my 1 9 Q. i mean, him using cocaine that somebody 9 house and I said, you're not going out at night; 2 0 does every day? 2 0 you're only 13, i4, and that?s my responsibility. 2 1 A. Yeah. He?s an addict. He's used to 2 1 Q. Do you know Sergio Cordero? 22 drugs, as well as, you know -- I know Mr. Epstein 22 A. Yes. 2 3 doesn't take any alcohol, drugs. 1 know that. 23 Q. And do you know what Sergio's role was 2 4 heard that. 2 4 in getting girls or something for Jeffrey Epstein? 2 5 Q. How do you know? 2 5 A. Yeah. That -- that is something that 6 (Pages 18 to 21) U.S. Legal Support (305) 373?8404 2 2 2 4 1 Sergio, you know, comment with me. And he said 1 with Fulanita (phonetic), and we knew Fuianita was 2 that when Jeffrey Epstein went to Ecuador, 2 oniy 18 years old. She is a young girl. So 3 Jean-Lac told me that he has to bring girls and 3 that's the kind of girl he iikes. You know what i a this and that, because Jeffrey was coming to 4 mean? 5 Ecuador. So they did such a big thing. 5 Q. But there is nothing illegai going out 6 Q. Right. But in terms of bringing girls, 6 with an 18?year~eld giri. And that?s what Pro 7 speci?caiiy giris, that were very young? 7 asking. 8 A. Yeah, but there was girls from Ecuador. 8 A. No. 9 There is nothing you can do there. It?s South 9 Q. What information do we have that Jeffrey 1 0 America. 1 0 Epstein was involved with underage girls? i mean, 3. 3. Q. I understand that. I?m not saying 1 I have a lot of information of my own. But I?m 3. 2 whether it was iegai or iliegai. I'm just asking 3.2 asking what information do you know. 1 3 you, the direction was that Jean-Lac told 1 3 A. The only thing i heard in the Of?ce: 1 4 Sergio 1 4 that Jean?Lac say it, that they iihe when they 1 5 A. Not to bring girls. Never said 1 5 say, oh, i wish i couid steep with this girE or 1 6 never Sergio knew that they iike young girls. 3. 6 the fact that he was taking i5, 16~year~old girls 1 7 Q. By young, what are we talking about? 1 7 to his house. 1 8 A. Eighteen, 19. Sergio you know, I 8 Q. Who? 1 9 know Sergio. And more than anything, like, Sergio 9 A. iknow that because I saw him. 2 0 is a father. And I don't think he wili put his 2 0 Q. Jean~Luc was taking 15-year-old girls to 2 1 hands on a ten, 11, 12, 13?year?old giri. You 2 3. his own piaee? 2 2 know what i mean? 22 A. No, to Jeffrey's house. 23 Q. I?m not asking about him. Do you know 23 Q. To Jeffrey?s house? 2 4 of Jeffrey Epstein being involved with underage 2 4 A. Yes. 25 girls? 25 Q. And what 15-year-old giris was he taking 2 3 2 5 A. I heard that, yeah. 1 to Jeffrey's house? 2 Q. You heard that through whom? i don't 2 A. At the time i?m you it was Lila, 3 mean just the newspapers and things like that. I 3 Mohini. i don?t know remember the other two 4 mean - 4 girls. There is two gins. I gave it 5 A. No. Through through the office. 5 to you before, the names. 1 don't remember right 6 Through Jean-visas. Through there were 6 now. 7 conversations of 5ean~Luc saying that, you know. 7 Q. Do you know Leslie Groff? 8 Q. Saying whatThat Jeffrey likes underage giris. And 9 Q. Do you know Khalid Mohammed? 0 never directiy but, you know, his conversations 3. A. Yes. 3. 3. were like that. 1 3. Q. What did he do? 3.2 Q. Okay. But, specificaily, I just want to 2 A. He was a scooter and a hooker. 1 3 know what evidence that we have, what real 13 Q. Scouter; what does that mean? 1 4 conversations that you heard, about Jeffrey i 4 A. Person looking for models. 1 5 Epstein tilting underage giris. 5 Q. And how iegitirnate was 3. 6 A. i?m you .iean?Luc saying it from 1 6 A. Khaiid Saiaam. 1 7 his mouth. 1 7 Q. Saiaam? i 8 Q. Okay. And, speci?cally, he says 1 8 A. Yeah. 3. 9 Jeffrey Epstein iikes underage girls or he likes 1 9 Q. Right. Where was he bringing models in 2 0 iZ~year~oids or iikes what? 2 0 from or looking for models? Outside the country 2 A. No, he likes young giris. When they 2 1 or 22 were taiking in the of?ce, there were a lot of 22 A. inside the country. Very not often 2 3 people. So they were not stupid. They were 2 3 from outside the country, no, no. From inside. 2 4 knowing how to taik. Because they were making, 2 a Q. Did you ever hear of any of the parties 2 5 iike, a big thing of, oh, iook, he?s going out 2 5 that took place on Jeffrey Epstein's isiand? 7 (Pages 22 to 25) U.S. Legal Support (305) 373~8404 What did he accuse you of? 2 Q. Littie St. James? 2 A. Of stealing money. And I had a- letter 3 A. One New Year's, i believe that was, 3 from JeamLuc authorizing me to get the money that 4 like, 2004, 2005, that New Year's -- they were 4 i had, you know. 5 having a party there. 5 Q. And did you ultimately have to plead to 6 Q. Who was having a party there? 6 criminal charges because of that? 7 A. Mr. Epstein. 7 A. That was my what my attorney toid methe party that you know? 8 Q. Yeah? 9 A. I know Jean-Lac was there. But then 9 A. Yeah. i 0 speci?caiiy, I don?t know if Jean-Luc stay there, 1 Q. So now you're on probation or something? 1 1 because what i do recali is that, during those 1 1 A. Yes. 1 2 days, there was, like, December 30 or 29, 12 Q. How long does the probation last? 3. 3 something like that, Jean-Lac call me from Puerto 13 A. They did it for 20 years. So I?m just 1 4 Rico that he was doing the scooting and he 1 4 trying to reduce that. 5 actually, he was the one who told me that he had 15 Q. Twenty-year probation? 1 6 to go to Jeffrey?s island because they were having 1 6 A. Yeah. 1 7 the party there for New Year's. 17 Q. And other than Jeff Fuller, who else 3. 8 Q. What other girls do you know of that 1 8 was who eise was making these accusations? i. 9 were at that party? 1 9 A. Oniy Jeff. 2 A. I don't know. 2 Q. How about Jean~Luc? 2 1 Q. Do you know of any of the other people 2 1 A. I never my attorney toid me that 2 2 that were at that party? I 22 Jean?Lac was never interviewed, nothingJeffrey Epstein? 2 4 Q. Just Jean?Lac and EpsteinYes. 2 5 Q. Have you talked to Jeau?Luc about the 27 29 Q.?mm?mm?mnmeMJhme 1 2 just the investigative report, which basically was 2 A. 1 spoke with can-Loo on two or three 3 3 4 was written that Ms. Vasquez advised that she, 4 times during -- prior to the middie of the 5 herself, submitted the documents to renew Nadia's 5 process, 1 did and I have an e-maii that 6 foreign visa on at least two occasions. 6 he send me because he wanted to taik was Evelyn Valenzeuia. 7 wanted to talk to him. And I never made the time 8 i never did her visa. That visa was done by 8 because Jeff Fuiier didn't allow him to taik to 9 Evelyn in New York. 9 me. So we never got to get together to taik. Q. When is the first time that you learned 1 0 Q. And they prosecuted the case in Federal 1 that Nadia Marciukova was invoived with Jeffrey 1 Court here in Miami? 1 2 Epstein? 1 2 A. Yes. 2. 3 A. I believe in 2007. After i was out of 3 Q. And your entire sentence was probation; 1 4 the company. 1 4 there was no prison or house arrest? 15 Q. You didn't know, when you were in the 1 5 A. House arrest one year. That, it was 1 6 company, that they were invoived? 1 6 done already. And then probationThe iast time, I have a lot of other 1 8 Q. right. At some point in time, did 3. 8 notes about some of the modeis that were being 1 9 you get in trouble, criminal trouble, related to 3. 9 brought in and signing visas, as if they were 2 0 MC Squared? 2 0 going to work here, but reaiiy they were iiviug in 2 i, A. They accuse me in 2006. 2 1 the apartment and didn't realty do any modeling 22 Q. Who accused you? 2 2 work. 23 A. eff. 2 3 A. Yeah, that is true. That is true. I 2 4 Q. Jeff Potter? 2 4 told you that. Many, many girls were coming here. 2 5 A. Yes. 2 5 Many giris were coming here ?rst without a visa, U.S. Legal Support 8 (Pages 26 to 29) (305) 373-8404 30 32 1 without a working visa. Most of the girls, they 3. balance book or whatever. 2 were coming in to the States as tourists. They 2 I told you the name of the accountant 3 were working whenever they work, they were 3 that you could go and took all those papers, you 4 collecting 30 percent from their income when they 4 know, make a subpoena or whatever, of Richard 5 were not even legal. They didn?t even have a 5 Fernandez, that he could give you all the 6 Social security or nothing but they never pay it. 6 information, 1993, ?99, 2000, after 2005, that he 7 Neither to the government, neither to the girls, 7 did everything and you could see the company was 8 you know. And within the time, I believe Jean?Luc 8 always in red, always. 9 start getting pressure from Mr. Epstein that he 9 Q. So the company wasn?t pro?table but 1 didn't want to get in trouble and he put some 1 0 Jean-Lac falsified documents to show to Jeffrey 1 1 pressure on Jean?Luc. So he wanted all the girls 1 1 Epstein? 1 2 to have a visa. So they start working on the 1 2 A. Yes. 1 3 visas of the girls. 3. 3 Q. And have you seen the real documents and 4 Q. Okay. l. 4 the falsi?ed documents? 3. 5 A. And they were making, like, contracts or 1 5 A. Yes. 1 6 things like that. Because, prior to that, they 1 6 Q. So you know that they were falsi?ed? 1 7 didn't have it. Prior to that, when Jean?Luc 7 A. Yes. 1 8 prior to Iean-Luo getting the money from 1 8 Q. ls it your understanding that Jeffrey 1 9 Mr. Epstein, lean-?Lire was doing whatever he 1 9 Epstein is still involved, from a ?nancial 2 wanted. 2 0 aspect, in MC Squared? 2 1 Q. Okay. 2 1 A. I believe so. BecauseAnd later, you know, Mr. Epstein put the 22 know, the Line of Credit wasn?t paid. The million 23 money that he had to start taking, you know, all 2 3 dollars wasn?t paid. 2 4 the invoices from Mr. Epstein. 2 4 Q. And Jean-Lilo and Jeffrey Epstein are 25 Qmeh?wEmmemkamtm 25 amemdon't know. i don't even know that 2 leffrey Epstein?s apartment in New York. 3 Mr. Epstein knows that Jean?Loo lied you know that? 4 the time. Because when he when I gave the Line 4 A. Well, becauSe because i know. 5 of Credit to Jean?Luc, lean-Lac presented false 5 Q. From Evelyn? 6 statements to him. You know, Mr. Epstein wanted 6 A. Yes. 7 I to see that the company was a pro?table company 7 Q. Is Evelyn still working for MC Squared? 8 and we had to hide all those numbersgive him, like, positive numbers you know who is working for MC 1 0 that the company was making money but in belief Squared? 3. 1 always was in red. 1 it A. It was working until not too long ago a 1 2 Q. What do you mean by that? Jeffrey 12 very Evelyn's goddaughter, Jobelin, she was 1 3 Epstein said, hey, I'm going to give you money as 13 working there. 1 4 long as the company is positive? 1 4 Q. flow do you spell it? 1 5 A. Yeah. Mr. Epstein wanted believe i believe, since he?s a very successful 1 6 Q. Okay. Anybody else? 1 7 person moneywise, he was not stupid Europe? 1 8 money, even though he knew he was able to get 1 8 Q. Yes, or here. 1 9 girls or whatever, you know, if that was the case. 1 9 A. No, that was related to Eve? No, 20 But deep inside he wanted to see if these people 2 0 Evelyn Jobelin. 2 1 really if this company was pro?table for him 2 1 Q. Who works in the MC Squared of?ce here? 2 2 to put a million dollars. 2 2 A. Here, I knew other things, because 2 3 So maybe Eric Garry, at the time, was one 2 3 Amanda Grant and I gave you her name more than 2 4 of his advisers. And they wanted to see the 2 4 one time. Amanda was working with them until 2 5 profit and loss statements and, you know, the 2 5 2008information. And she 9 (9ages 30 to 33) U.S. Legal Support' (305) 373~8404 34 36 1 wanted you know, she call -- I arrange she oali 3. A. Yeah, sometimes -- and that's -- that's 2 Immigration, because they screw her. And, 2 what I can tell you. i know because 1 can teii 3 actually, they made her ieave the company because 3 you about can-Lac, that I know because single mother, four kids. And 4 for ten years. Okay? I can put my hands on ?re 5 they were giving her a lot of had -- bad time. 5 and i can teii you that he did it. About iean~an 6 (Telephone interraptioadon't know about Mr. Epstein "i Q. How do you speii her name, Amanda Grand, 7 because I was never I met him once in my life. 8 8 I saw him once in my life. And after that, when I 9 A. N-T. Amanda Grant. 9 saw him, was in the newspapers; that's it. 3.0 Q. And do you know her address, phone 3. Q. And, otherwise, you just heard that 3.1 number; something like that? 3. 1 Jeffrey Epstein likes underage girls? 12 A. I have you can get it in Facebook. 1 2 A. Underage girls, yeah. 13 She's in Facehook. Amanda Grant. 1 3 Q. And there was a time where Sergio -- 1 4 Q. Do you have it? 1 4 wet], I've tatked to Sergio, so I'll talk this phone. My other phone broke 5 about whatever the Ecuador trip was. 1 6 so I don't. I can get it for you, if you want. 1 6 A. Yes. I 1 7 Q. Yeah, I wouiti appreciate it. 1 7 Q. Ali right. Do you know of this company, 3.8 A. Yeah. 8 COUQ 1 9 Amanda had also the information monies, as I toid you before, that took monies 2 0 Q. -- Foundation. All right. Do yon know 2 3. that they were transferred to the British Virgin 2 3. ot? somebody by the name of 2 2 IslandsMonies transferred to the British Virgin 2 3 Q. Somebody who provided Jeffrey Epstein 2 4 Isiands? 2 4 girls? 25 A. YesFrom what account to what? 1 Q. How about Jileta (phonetic)? 2 A. Iean?Luc opened an account there because 2 A. No. 3 Jeffrey toIcI him that it was better to open an 3 Q. Never heard that name? 4 account there. So there was money -- iike, for 4 A. No. 5 exampie, if the monies were going to Manuel Cruz 5 Q. Dana Burns? 6 to do a shoot or something, Jean-Lac was 6 A. I heiieve I heard that name. But I 7 negotiating with the girls and say, okay, if you 7 Q. She works up in New York and I believe 8 go to do the sunny photos, I give you $2,000 cash, 8 she works for Jeffrey Epstein in some capacity. 9 no reports, whatever. 9 Do you know what that is? 1 0 So Jean-Lac had -- as that 1 0 A, I believe so. No. 3. 1 company from another company, or from the British 1 1 Q. Okay. 3.2 Virgin Isiands. So he was neither paying taxes 1 2 A. The person who can teii you that is five. 13 here and maybe he was making $20,000 on that 3. 3 Because Eve was very invoived with Jeffrey 1 4 shooting and he was giving the girl oniy $2,000 1 4 Epstein's of?ce. 15 and that money never came to he reported here. 1 5 Q. What is Eve's number again? 1 6 Q. Okay. Other than you saying that you 1 6 A. (917) 648-6433. 3.7 know that a 15~year~oid or so went to Jean?Luc's 17 Q, Do you know Jojo Fontanelza? 18 house with him, how else do we know that Jean-Lac 3. 8 A. No. 19 andfor Jeffrey Epstein, I'm more concerned with 9 Q. No? Other than Jean?Lac, what other 2 0 Jeffrey Epstein, were involved sexnaIIy with 20 peopie that are friends with Jean-Lac share this 2 1 underage girls? 2 1 interest in underage girls, that you know ofknow? I I I cannot tail 2 2 A. No. 23 you that I saw -- that I was there because that?s 2 3 Q. I mean, who are his friends? Who are 2 4 not true. I never saw anything. 2 4 the guys he hangs out with? 25 Q. Right. But sometimes you just know? 25 A. Jeff. When he was in Miami, .Ieff, 10 (Pages 34 to 37) 13.3. Legal Support (305) 373-8404 38 40 3. Corrado. 3. A. Yes. 2 Q. Who is Corrado? 2 Q. And they come in the country and they 3 A. A friend of Jean-L120. An ltalian guy. 3 don?t have their parents? 4 They were always that, Corrado and Lac. 1 . 4 A. Yes. 5 met Jean?Lads friends in Ecuador, like people 5 Q. So they don't realiy have any parental 6 that had to be -- people that they were involved 6 supervision while they're here? 8 America, but very different people, very different 8 Q. So the modeling industry is one that 9 people. i met some peeple from France. Pero, 9 some guys use that to get underage girls and 10 really, even if they were guys or whatever, 1 that?s happened for a long time, reaiiy, right? 1 1 gentlemen. You know, like, very proper people. 1 3. A. Yes. 12 Like, from Brazil, too. And the wetness, you know. 3. 2 Q. So is that what Jean-Lac Brunei still 3.3 Q. How about Simon Parra; you know who that 1 3 doesSimon Parra, yeah. 15 Q. Still uses it to get underage giris to 16 Q. How do you know him? 3. 6 sleep with, really, right? 1? A. I met him through Jean~Luc. 17 A. Yes. 18 Q. And what's his story? 1 8 Q. And Jeffrey Epstein, too? 1 9 A. Mr. Parra was a very good friend of the 3. 9 A. i cannot tell you that because i don?t 2 0 of?ce. i cannot say of Jean-Lac because he was 2 0 know. I know if there is -- there is kind of a 2 1 only a friend of him. He was a very good friend 2 1 relationship, i believe they will or he will. You 2 2 of the office, because Mr. Parra is a gentleman. 2 2 know, he still does it. But I don't know. I 2 3 He was lending money to the of?ce. Whenever i 2 3 cannot tell you because i was never 1 was 2 4 requested, he always gave it to me for the of?ce. 2 4 never -- what I can say that i know, because I was 25 You know, that I signed i had to sign papers 2 5 with that person for the iongest, was with 39 41 1 for him or whatever, to -- to do the payrolls or 1 Jeanine. The same thing that {can tell you, 2 whatever. But Mr. Parra is a guy that he likes to 2 that even if he has a daughter, whatever, I put my 3 be surrounded by girls. But not underage girls. 3 hands on fire that Ieff Fuller is gay. 4 Q. Okay. What was Jeffrey Epstein getting 4 Q. Okay. And Jeau~LucSquared? 5 cocaine at work? 6 A. The oniy thing that i can think he was 6 A. Not in the of?ce. But sometimes he was 7 getting was the giris. Nothing else. Because he 7 coming to the office, like, with blood coming from 8 has ail the money. 8 the nose and white things here, that he had to go, 9 Q. And the company wasn?t making money 9 oh, you go and clean yourself or whatever, you 1 0 anyway? 1 0 know. 1 A. No. 1 Q. Wouid he talk about his cocaine 12 Q. And you know the company wasn?t making 12 addiction? il 3 money? 1 3 A. Not directiy, but it was a box properly, 3. 4 A. it wasn't at all. At all. So the only 3. 4 everyone knew about thatthing that he was -- I believe that he wanted to it 5 the kind of person who didn?t feel ashamed to 1 6 get involved was because of the giris, that?s it. 1 6 tell. For example, Sergio was there and i was 1 7 Pete, he wanted to do it legally, like, girls 1 7 here and he was there and he was, like, Sergio, go 1 8 coming here, even if they were underage or 8 and get me the best one, you know. And Sergio was 1 9 whatever, with visas. 3. 9 going and getting it for him. 2 Q. Because the modeling industry didn't really hide the fact that 2 3. those industries where there is a lot of girls 2 1 he used cocaine? 2 2 underage coming in the country, rightthe office, not in 2 3 A. Yes. 2 3 front of the hookers. 2 4 Q. That?s pretty easy access to underage 2 4 Q. Where is the of?ce in New York? 2 5 girls? 2 5 A. Six West 14th Street. 11 (Pages 38 to 41) U.S. Legal Support (305) 373~8404 42 44 1 2 now? 2 same thing. She wilt teil you everything. 3 A. No. 3 Jean-Lac came from Paris 4 Q. Is he in Miami? 4 Q. How do you spelt her name? 5 A. Yes, he?s in Miami. 5 A. I don?tlmow her name. Her East name i 6 Q. Do you know his number? 6 don't know. Her name is Rath. Like, he 7 A. No, I don't know his number. 7 came from Paris. Because if he stay in i?aris, he 8 Q. How about Mike Sanka? 8 had to pay taxes and this and that. Everything 9 A. Michael Sanka, he's in California. 9 that he was avoiding. 0 Q. What did he do? 1 Q. Who, Jean~Lue? 1 A. He represents -- he represents artists, 1 A. Jean~Luo. 2 piayers. He is, like, a manager. 1 2 Q. Do yon know how he and Jeffrey Epstein 13 Q. Did he have any roie in procuring 13 became friends? 1 4 underage girls for anybodyNever. No. Not at all. 15 Q. Or why they became friends? 3. 6 Q. How about Arnanci Bruneii-ie's .ieamLuo's brother. 1 7 Q. I mean, other than underage girls, what 1 8 Q. Is-he here in Miami? 18 else do those two have in commonThat?s the only thing, I believe. And 2 0 Q. Where is he? 2 0 it?s very yon know, like, I saw Mr. Epstein 2 1 A. France. 2 1 once in a gym, in a church, very simpieever been here in Miami? 22 see jean-too on the same place and you see 2 3 A. Yes. 2 3 iean-Luc with a Prado pants and with a Gucci 2 4 Q. When is the iast time you taiked to him? 2 4 T?shirt and with 130106 Cabana sunglasses. It?s 2 5 Been a white? 25 like two different characters. 43 45 1 A. 2006. No, 2003. 1 Q. And how many giris, at any one time, 2 Q. Okay. Is he close with Jean-Lac? 2 wouid MC Squared have under them? 3 A. No. Well, he's his brother, you know. 3 A. A lot. Like, over 200, 300. 4 Q. Yeah. 4 Q. Other than the one time where {our girls 5 A. There is a blood relation there. But I 5 were taken to Jeffrey Epstein's house and all 6 can teli you it?s, iike, and water, two 6 four of those giris were underage at the time, 7 different persons. Two different heads. Two 7 right? 8 different mentalities. 8 A. Yes. 9 Q. Who are the peopie -- 9 Q. They were 14 or 15 at the time? 3. A. A gentieinan and a beast. Mr, Armand 10 A. Yeah, 15, 16, 14; something like that. 3. Brunei is a gentleman, a very correct person, very 3? 1 Q. Other than that time, what other 1 2 transparent. The other is the opposite. 12 occasion iog your memory, think this through 13 Q. Do you know this guy, Etienne? 3 have you known of Jeffrey Epstein to he in the 4 A. Etienne Rau. He was another partner of 4 same vicinity as any of the modeis? Was there 1 5 eon?Lao, in Karin's. Another gentiernan, another 3. 5 ever a time that Jean-Lac Says. 1183?, Jeffrey 1 6 real good person. Aotnaily, iean-Luc screw hirn 6 Epstein is coming a[3 *0 New York this weekend, 1 7 and he took him out from Karin?s. He closed 17 we're going to hang out at the apartment or 1 8 Karin's here in Miami, without Mr. Etienne?s 8 Jeffrey Epstein is this? 1 9 knowledge. 1 9 A. No. Never. Jean?Loo never mentioned 20 20 2 have nice things to say about Jean-Lac? 2 it got invoived. To me, you know, to me. i?rior all. 22 that, one more time, you can talk to Eve. She 2 3 Q. What about 2 3 knew Eeffrey Epstein prior -- prior to me. 2 4 A. Ruth. 2 4 Q. Before you did? 25 (L ?Moh?m? 25 12 (Pages 42 to 45) U.S. Legal Support (305) 373*8404 46 48 1 Q. And she has seen him more often than you 1 leffrey. She was living in his place. 2 have? 2 Q. Anything else about him that 3 A. Of course, because she was in New York 3 A. No. 4 all the time. She live in New York and I never 4 Q. Or about her? 5 live there. I was, like, cemmuting one week in 5 A. No. 6 New York, two weeks in Miami. One week in New 6 Q. Inka Dory? 7 York, two weeks in Miami. 7 A. No. 8 Q. Are you leaving to go to Colombia soon? 8 Q. Any other people that you know that were 9 A. To Peru. 9 living in that apartment at any time? 1 0 Q. To f'ern? A. No. l. A. Yeah. 1 Q. Other than the people that you named 3.2 Q. When? 1 2 already, which are new Cindy Lopez, Juliana 3 A. The 24th. 1 3 Barhosa, Elena Weber? 1 4 Q. And do you know when you're going to be 1 4 A. I don't think Elena lived there. Elena 1 5 hack? 1 5 was living in one of the models? apartment that we 1 6 A. The 28th. 1 6 rent. Because besides those two apartments, we 1 7 Q. All right. Like I said, I would hope 17 rent apartments in New York for the girls. 1 8 and think that this whole thing - that your 1 8 Q. Who decides whether the girls live in - 1 9 involvement is completely done. However, there is 9 A. lean-Loo. 2 0 one case that Jeffrey Epstein has not settled 2 0 Q. Jean-Lac decides whether the girls live 2 1 right now that could go to trial. If it went to 2 1 at 381 that's owned by Jeffrey Epstein or the 22 trial, then we could be called at trial. But it's 22 other apartments that are renter! by MC Squared? 2 3 highly unlikely that is going to happen. I'm inst 2 3 A. Yeah. 2 4 letting you know there is a possibility. 2 4 Q. And how does he make that determination? 2 5 Emmy Taylor, do you know who that is? 2 5 A. He's the owner021, but, I mean, what are the 2 Q. Claire Hazel? 2 qualifications? 1 mean, if he likes the girl or 3 A. No. 3 they?re underage or they're -- 4 Q. Joelle Pashcow? 4 A. No, if there were, like, good girls, 5 A. No. 5 girls that they could make money, they were living 6 Q. Fontanella? 6 in an expensive place. If they were, like, 7 A. No. 7 regular girls, they were living in shitty places. 8 Q. Sophie Biddle? 8 Q. Okay. Bot which one is Jeffrey 9 A. No. 9 Epstein?s place? 10 Q. Cindy Lopez? 10 A. An expensive place. 1 A. Cindy Lopez, I know -- I didn't mention 3. 1 Q. Okay. So the better models were living 1 2 her because I didn't remember her name. Now you 3. 2 there? 1 3 say it, Cindy Lopez was a girl who was working for 1 3 A. Yes. 1 4 Karla's. She was not underage but she was a young 1 4 Q. ?lo you know who that 3. 5 girl. She was working for Karin'studying and she was living at Jeffrey Epstein's 6 A. No. 1 7 apartment. She was living at his place. 1 7 Q. Did you ever meet with Naomi Campbell? 1 8 Q. Ami what was her involvement with l. 8 A. No. 1 9 Jean-Lee andlor Jeffrey Epstein? 3. 9 Q. Did you know that she was friends with 2 0 A. She was working at Karla's. 2 0 Jeffrey Epstein? 2 3. Q. Okay. As a modelemployee. 2 2 Q. Did you ever meet Leslie Wexner? 23 Q. She traveled on his airplane with him a 2 3 A. That?s the woman that was involved with 2 4 lot? 2 4 Mr. Epstein, no? 2 5 A. Yeah, because she's a personal friend of 2 5 Q. No. Leslie Wexner is the owner of 13 (Pages 46 to 49) U.S. Legal Support (305) 373-8404 50 52 Vieto ria's Secret? 1 A. Not real iy. Not really. Not real writer. 2 that because i wouid never think that they were 3 Q. No. He?s the owner of Victoria's 3 going to a party. Andi didn?t know Mr. Epstein 4 Secret, The Limited, Abercrombie. 4 in that scenario, you know. i know Jearr?Lue was 5 A. No. No. 5 crazy or is crazy, but not stupid to he with those 6 Q. Did you ever hear anything about Jeffrey 6 particular giris, because these giris were coming 7 Epstein's relationships, who he was with: Mate, 7 from a very good friend of him in Brazil. 8 femaie, a person's name? 8 Q. Who is that? 9 A. i know, because Eve toid me that he had 9 A. And he didn't -- i don't remember her 1 0 a relationship with a woman that her father was 10 name. The mother agent of these four giris. i 3. very wealthy and that?s how he started his own 1 1 gave it to you before. i don't remember her name. 12 money. And if you tell me the name, maybe I can 12 it?s a black woman. 13 remember. But i don?t -- 1 3 Q. it's not Cache? 4 Q. Ghislaine Maxweii? 1 4 A. No. What's her name? 15 A. Yes. 1 5 Q. Because I have that part of the report 1 6 Q. And her father was Robert Maxweii? 1 6 right here, stating that Brunei had a connection 3.7 A. Yes. 3. 7 with a young Brazilian woman but I don't have a 3.8 Q. Other than that relationship, are you 3. 8 name {or that person. 1 9 aware of any other relationships of Jeffrey 1 9 A. No. He was having a connection with a $3 swam? 20 2 A. No. 2 prostitutes when he needed it. 22 Q. How many times are you aware of Jeanane 2 2 Q. The connection woman in Brazii was 2 3 bringing underage girls to Jeffrey Epstein's home 2 3 giving can-Lac prostitutes? 2 4 in i?aim Beach? 2 4 A. Reai prostitutes when he needed it. 25 A. While 1 was there, when i was working 2 5 Q. How oid were these prostitutes? 51 53 with them, maybe -- maybe two, three times a year. 1 A. I don't know. i don't know because I 2 The East year; you know, 2003, 2004, 2005. 2 was never in Brazil with him or nothing like that. 3 Q. And how would yon know -- 3 Q. In Brazil? 4 A. Not prior to that. 4 A. In Brazil. That was in Brazil. 5 Q. How wouid you know that Jean-Lac was 5 Q. Was Jeffrey Epstein involved in these -- 6 taking underage giris to Jeffrey Epstein's house 6 A. Jeffrey Epstein was going to Brazil 7 during those years? 7 because he has one or two ciients that they?re 8 A. Because he was saying in the office: 8 from there. So they were going, they were meeting 9 There is a party at feffrey's honse; i?m taking 9 there and everything like that. 3. the giris. And the girls, that they were in town, 1 0 Q. So you know of at least occasions where 3. 3. they were, iike, underage girls. 1 1 Jeffrey Epstein and Jean-an were in Brazii m- 1 2 Q. We are still taiking ahont 14, 15? 1 2 A. Yes. 1 3 A. Sixteen, yeah. 13 Q. m- and there was a particular person 1 4 Q. Sixteen, at the oldest? 3. 4 that would provide prostitutes for them? 1 5 A. Yes. And they were going, the other 1 5 A. Yeah, because one time i know because 1 6 girls, too, but he he personaiiy was taking the 1 6 Jean~Luc say-itto me openly. 1 7 Eittle ones. Because the other ones, they conid 1 Q. What did he say? 1 8 go in their own cars or whatever, you know, with 8 A. That that woman was giving him, not 1 9 their boyfriends. 1 9 modeis; they were prostitutes. 2 Q. Did you ever say anything to him about 2 Q. In my notes it says nnderage 2 1 taking underage girls to Jeffrey Epstein?s house? 2 prostitutes. Is that something that 22 22 23 that they were underage giris. And he was saying, 23 Like, 16, 17, 18. 2 4 oh, that I'm the father. 2 4 Q. Ms. Vasquez stated, tell me if you agree 2 5 Q. But you knew what was going on? 2 5 with this, that Brunei would have her prepare a 14 {Pages 58 to 53) U.S. Legal Support (305) 373*8404 54 56 1 Iist on a weekly basis that covered changing out 1 Q. The 1323.1. 2 or replacing the giris staying in Epstein's 2 A. Yes. 3 apartment and providing them with iiving expenses, 3 Q. When was that? 4 as weii. And then it goes on, saying that he 4 A. In 2008. 5 charged them rent? 5 Q. 2988? 6 A. Yeah, yeah. He was the one who said who 6 A. Yes. 7 stays in what apartment and actuaiiy, what he 7 Q. And where did you meet with them? 8 said is, iike, A, B, C, stays in Jeffrey's 8 A. In my office at the Four Ambassadors. 9 apartment. So that was the order. That's it. So 9 Q. At the Four Ambassadors. That's where 10 the rest, Eve was supposed to put in whatever she 1 0 Sergio is, too, right? 3. 3. wanted. 1 1 A. Yeah. 12 Q. The notes indicate that you you were 1 2 Q. So do you still see Sergio? 3.3 taiking about Nadia Marcinkova being a Russian, 1 3 A. 1 spoke with him sometimes; once in a 1 4 14 years old, that lived in Epstein?s apartment? 1 4 while. 15 A. No. i never said that. 1 5 Q. Did Sergio have to speak with the 1 6 Q. You weren't there then? 1 6 F.B.I., as weil? A. No. I never said that. So whoever 1 7 A. {don't know. 18 wrote that, I was never 8 Q. Do you know of anybody eise that spoke 1 9 Q. This is written off typing notes because 1 9 with the F.B.I. about Jeffrey Epstein? 2 obviously we didn?t have a reporter to get it 2 A. i don't know. I don?t think Eva spoke 2 1 down. So that's why I wanted to get her here so 2 1 with him -- with them. I don?t know. 2 2 that we know exactiy what your story is. It would 2 2 Q. And what did you tell the 2 3 make it easier. 2 3 A. i toid them everything that I the 2 4 A. i heard of that girl. And I remember 2 4 same thing that I knew. At that time I even had 2 5 eleariy that it was a prohiern with her visa. And 2 5 maybe more information. I gave everything from 55 5? that?s why she i remember there was a end of 3. Amanda and everything iike that. But the lad -- 2 the year and I was with Eve in New York and she 2 . Q. Nesbitt? 3 was, like, really upset because they were, 3 A. Yeah, Nesbitt. That was her name. She 4 mien-eating her because of that; the fact that 4 was, iike I told her, you have to go go to 5 they were blaming her for the papers, doing it 5 immigration. I say, go visit over there. And 6 incorrectiy. And then Eve toid me, you know, that 6 when i her once she told me: You know what? 7 girl never work, she was never a model. She was 7 i need I need fact. I need proof, 1 need 8 iiving in his piece but she disappear. So she 8 girls. 9 actually never even worked as a model. 9 I say, weii, Fm giving you the tools 10 Q. Nadia? that i have. There is nothing else that i can 1 1 A. Yeah. 1 1 I cannot create something because I don't create a 12 Q. And that's gust something Eve knows 1 2 story. iteii you what it is. This is the fact. 1 3 because Eve was there? 1 3 You go and you can use this to aiso do something 1 4 A. Yes. 1 4 eise. But if your point is, you know, minor 3. 5 Q. All right. Do you know where Eve works 3. 5 accusations, like underage girls being with him in 3. 6 new? 3. 6 the bed, I?m not going to say anything because I 1 7 A. At Hope Community. 1 '7 don?t know. I wasn't there. I don?t know. What 1 8 Q. What's that? 8 i heard, my ears heard, you heard, she heard, 1 9 A. It?s a government organization in New 1 9 whatever. 20 York. 20 Q. From Jean~Luc is the oniy person you 2 1 Q. Has she spoken with the 2 i heard it? 2 2 A. I don't know. 2 2 A. Yeah. 23 Q. Have you been contacted by the EBJ. or 23 Q. Or Eveiyn? 2 4 any government agency related to Jeffrey Epstein? 2 4 A. Yes. That?s it. 25 A. 25 Q. Who probably heard it from Jean-Lac? 15 (Pages 54 to 57) U.S. Legal Support (305) 373?8404 58 6O 3. A. And who probably heard it from Jeffrey?s 1 underage girls? 2 of?ce. I don?t know. 2 A. At that time, it was Evelyn Valenzuela 3 Q. Okay. But in terms of things that 3 in New York. And whenever she was not able to do 4 happened at Jeffrey Epstein's house or homes 4 it, she hired an attorney. don?t know the name 5 around the country, you don't know? 5 of the attorney in New York. And in Miami the 6 A. Nothing. We have never been invoived 6 person who was doing everything for visas was Luis 7 with that gentleman or his own things. Never. 7 Font. 8 Q. It was only a relationship with 8 Q. Who are the people that that are 9 can-Lac? 9 you know most of ean-Lue's friends. Who are the 1 A. For the of?ce. That started 2003. 0 people who dislike Jean-Lac? Who are the people 1 1 That's when he -- that?s when he actually gets 3. 3. we should talk to about they know him, they're 12 involved. 1 2 familiar with him, but they're going to tell as l. 3 MR. EDWARDS: All right. I believe 3. 3 A. Talk to Khalid. 1 4 I?m done. Hoid on a second. 1 4 Q. Khalid? i. 5 BY MR. EDWARDS: 3. 5 A. Yeah, talk to Khalid. Tatk to Amanda. 1 6 Q. When Jeffrey Epstein was in jail, did 16 Q. You don't know how to track Khalid down 1 7 you know of Jean-Lac going to see him regularly? 17 right new? 18 A. No. 18 A. Amanda can give you the information of 9 Q. Did you even know that he went to gait? 1 9 Khalid. .2 A. Yeah. 2 Q. Amanda Grant? 2 1 Q. I mean, at some point in time, but while 2 A. Yes. And I'm going to give you a 22 he was in jail, did you know for any other reason 2 2 letter i'll send you an e-mail of Amanda's 2 3 other than newspapers that he was there? 23 telephone number. i go into my Facebook and her. 2 5 Q. Have you ever heard of this guy, Joe 2 5 Q. Okay. 59 61 1 Pagano (phonetic)? A. And who else? Who else? Talk to Elit. 2 A. No. 2 There is -- there is a lot of people in New York. 3 Q. Larry Vasasky (phonetic), do you know 3 But you ask Eve. Ale Eve. She can give you the 4 the pilot? 4 names. I don?t know the names exactly. 1 gave 5 A. No. With his personal things, we 5 Conchita a name. And I thought that this woman 6 never as far as i know, me personally, never. 6 was really upset with him. But when she call her, 7 Q. Yeah, no, I'm only asking you about 7 it was, like, the girl was talking too much 8 people who were on ?ights with Jeffrey Epstein 8 ?owers about him. So it's, you know 9 and Jean~an. So that's why I was thinking that 9 Q. So you never know? It 0 maybe Jean-Lac would say who was on that flight. A. Yeah. You never know. That is true. 1 A. No, because I know one time I know he 1 1 You never know. Five thousand dollars in Brazil 12 came in his plane and he forgot Gucci pants money. You know, you can buy a house. 1 3 airplanethe airport to pick 1 3 Q. So you can also buy somebody to be i. 4 up the pants. But I had to wait outside and quiet? 3. 5 somebody went inside to pick up the pants. 15 A. Money talks. That's what they doing all 1 6 Q. Adriana Machinska (phonetic); do you 3. 6 the time. 1 7 know who that is? 7 Q. Do you know of Epstein paying anybody 8 A. No. 8 off during this whole litigation? 1 9 Q. Was there a Colombian giri, 13 years 1 9 A. If i know, I don?t knowold, approximately, being protected by Jean~Luc? 2 that, yes, because if it wasn't leffrey Epstein, 2 A. Colombian girl? 2 1 if it would be Juan Perez, believe me, Iuan Perez 22 Q. That's at! the information that I have. 22 would be put injail forever and ever. 23 No? 23 Q. Whoi?rn giving you a name. 2 Q. Who else would process the visas for the 25 Q. 0h, right. Right. 16 (Pages 58 to 61) U.S. Legal Support (305) 373~8404 62 64 1 A. Because he?s Jeffrey Epstein and he has 1 But my contract was for three days. That's not my 2 all the money he has, he could shut up everybody. 2 problem. 3 But if it would have been Juan Perez in the same 3 Q. Who were some of the other people that 4 situation, Juan Perez would be right now all his 4 you found out later were trying to molest the 5 life in jail. 5 girls? 6 Q. But do you know of any people that 6 A. No; I found out because i had a very 7 Jeffrey Epstein had paid during the civil 7 good relation with Adirarntni. Adirammi called to 8 litigation -- 8 complain and she want all her money. if not, we 9 A. i don?t know. 9 are suing them. So I had to call them: You know, 1 0 Q. -- to not talk or to go away? 1 0 either you pay or we sue you for this. So they 1 3. A. i don?t know. 1 3. pay. 12 Q. 01' I mean, I'm sort of surprised that 1.2 But with the other girls, i would always 1 3 we haven't heard more from the models who were in 1 3 say, you are going to do this job, we're 3.4 New York, didn't make it as models and were only 1 4 responsible to pay you for the job. Whatever you 15 up there in the apartments for Jeffrey Epstein or 15 want to do after is not our concern. That is up 1 6 Jean?Lac. 1 6 to you. You're already old enough to do what A. Because not all the models, even if they 1 7 you're going to do. So that?s why I believe most 18 are underage, they agree to do whatever they want. 1 8 of the models are not saying anything because what 1 9 You know, like, in my case, I was -- when was 1 9 they going to do? You know, like, they were not 2 0 with the girls and was talking to the girls, i 2 0 stupid. 2 1 always said, you know, like, you are going to do a 2 3. Q. I'm more concerned with the girls who 22 job. You?re not being hired to do nothing else. 2 2 were staying at the 30; East 66th Street 2 3 You work for nine to five. Even apartments. 2 4 three-day in San Francisco and the owner of this 2 4 A. You can get all that information from 2 5 company wants to ask you something, it?s up to 25 Eve. Eve has all of that. Because Eve was 63 65 1 you. You're hired to do yourjob. After that, we 1 actually the one who was buying everything for 2 have no control. 2 that place and things like that. She -- you lcnow, 3 You know, they were -- there were girls 3 if she has all that information, she will give it 4 that they were going to do jobs of 100,000, 4 to you. 3 $200,000. And they were coming, they?re real 5 Q. She would have the first and last names? 6 upset, that they never wanted to work again with 6 A. Everything. 7 those people, even though they were paying. 7 Q. And lists and everything? 8 Because they were, like, molesting. No way; Pro 8 A. Everything. 9 here to work. That's it. 9 Q. Okay. So she seems like the right 3. 0 Q. Who were those people? 3.0 person to talk to? 3.. A. For example, there is a girl, a A. Yes. You know, Eve will give you 1 2 Brazilian girl, what's her name? Adirarnmi. 1 2 details on everything that has to be with New 1 3 Adiramini. She did ajob in San Francisco. And 1 3 York. Everything related to New York, Eve will 1 {l the guy wanted to 1 4 give it to you. 3.5 Q. Do you know her last name? 15 Q. Other than that, your recommendation don?t remembertalk to Khalid? 17 wanted to take her out in his yacht. And she 17 A. ?i?alk to Khalid. Talk to Amanda. 1 8 said, no, I'm going back to my hotel. l'rn hereto 1 8 Q. Amanda Grant? 1 9 do my shooting from nine to five and that's it. 1 9 A. Amanda will tell you a lot of things. 2 0 And the guy didn't want to shoot her that next day 2 0 Q. And she is here? 2 3. and he return her in a private plane. But we had 2 A. She's in Miami. Yeah, she's in Miami. 22 to ?nd for her money because she had a three?day 2 2 Q. if I find Juliana Barhosa, will she 2 3 shooting for $15,000 for each day or $20,000 each 2 3 talk? 2 4 day. And because she didn?t want to go with him 24 A. You can trymean, she is obviously someone who in the boat, he didn't want to have her anymore. 3.7 (Pages 62 to 65} U.S. Legal Support (305) 373?8404 66 68 1 knows, right? 1 A. He used to live in 1100 West Avenue in 2 A. Yeah, you can try. 2 the penthouse. Not anymore. 3 Q. i mean, you know her as a person. 3 Q. Other than Jeff Fuller, that's the only 4 4 5 Q. So is she somebody who seems like 5 A. Other than .leff Fuller. .leff Fuller is 6 would 6 his partner. You know, Corrado is another friend '7 A. if you start saying that she can make a 7 of him but 1 don't know his last name. He lives 8 lot of money, she will talk. 'i?hat?s it. That's 8 here in Miami. 9 the only way ydu?re going to get what you want. 9 Q. How do you spell the ?rst name? 1 0 Q. That's the only reason why anybody is 0 A. He?s an itaiian guy. 1 3. going to talk? 1 1 That's another person he is very close, very 1 2 A. Yeah. You have to start if you don't 1 2 close, friend of lean-Lac since Europe. But if 13 start with that, nobody is going to open their 1 3 you don?t go to him saying about the money, 1 4 mouth. Why? For what? They have to know that if 1 ti Corrado is not going to talk. And if you talk to 1 5 they?re going to open their mouth, they're going 1 5 Corrado about money, believe me, you?re not going 1 6 to get something for their words. if everybody i. 6 to have one; you're going to have 20 names and 17 start knowing that they will be able to make I 1 7 you*re going to have 20 cases. 1 8 money, you?re not going to have one; you?re going 1 8 Pero, if you don't go with your tool, 1 9 to have hundreds. You know, if if talk to 1 9 which is going to be, okay, we can make money, we 2 0 Eve. Ask Eve. And, you know, give me a call 2 0 can do this, we can do that, they're not going 2 1 later. And if you want, give you the name of 2 1 to -- they?re not go to seli his friend because 2 2 people in Brazil that you?re going to call and 2 2 they go out with him. Because when they go out 2 3 start if you start saying, look, if you 2 3 with Jean-L110, Jean?Lac pays for the bills, 2 4 cooperate and you tell me everything you know 2 4 Jeanaisuc pays for the gas, Jean-Luc pays for the 2 5 because, you know, you will be able to make 2 5 vacation, Jean-Luc pays for this and that; even if 67 69 1 $50 million, $20 million, how much you want, let?s he doesn?t have any money to pay his payroll. 2 find it. if they don't get anything like that, 2 Q, How much time does Jean?.an spend in 3 they?re not going to do anything. Theyre not 3 France? 4 going to move a pencil. Because he goes with 4 A. Very little. Very littie. He's 5 $5,000 and they?re happy. 3 traveling all over the world. He?s traveling all 6 Q. Right. 6 over the world. 7 A. They?re happy. 7 Q. And does he have money problems? 8 Q. Do you know of that happening already? 8 A. Yeah. He doesn't have any money. 9 A. Yeah. can say with with this 9 Q. He doesn't? 1 0 woman, that is probably with Conchita. That woman 1 0 A. Jean?Luc doesn?t have any money. 1 3. hate him. - 1 Q. Where does he get the money from, then? 12 Q. Hates Jeff Epstein? 1 2 A. From the company. First you have to pay 1 3 A. No, Jeanine. And now she?s, like, the 1 3 Jean-Luck credit cards and expenses before you 1 4 best friend. Jean~Luc never pay her $50,000 he 1 4 pay anybody else. 1 5 owe her. And maybe, finallyThat?s the rules? 1 6 whateverhis pocket. 1 6 A. Yeah. He's -- his American Express 1 7 Q. Who else does Jean-Lilo stay with when 3. 7 comes for $5 0,000. Of course, maybe 20 are 2 8 he?s here? 1 8 tickets for the models, that they going to he 1 9 A. i don?t know he doesn't stay anymore 1 9 reimbursed by the client, but 30,000 are his 2 0 in his apartment. He has a house now. He rents a 2 0 expenses. And he says, no, that?s scouting. So 2 1 house. So i know 2 1 we have to pay for that. 2 2 Q. In New York? 2 2 Q. Okay. Who are the other scouts for MC 23 A. No, in Miami. in New York, he?s still 23 Squared? 2 a in the place of Jeffrey Epstein. 2 4 A. Khalid was one. Jeff Fuller is another 2 5 Q. Oh, okay. And down here he stays 2 5 one. There is another woman, Nicolette. What?s 18 (Pages 66 to 69) U.S. Legal Support (305) 373-8404 7O 72 1 her name? Something like that, is her name. i 1 to be in touch, maybe with the trial 2 don't reeail her name. She does the scouting, 2 subpoena. Hopefully we can jUS?t ten 3 too. 3 you that it?s off, if things are off. 4 4 5 A. in New York he had another scooter. A 5 you can jest cali my office and {'11 6 Jewish guy. But now he has the of?ce of MC 6 toil you. I 7 Squared in Tel Aviv. You can taiic to him, too. I 7 THE WITNESS: Okay. But I?m going 8 don't recall his name. But it?s in the Web page 8 to call you -- 9 of MC Squared. 9 MR. EDWARDS: All of the Federal 1 Q. Okay. Yeah, but he's Jean-Luc's friend, 1 0 trial snbpoenas teli you that you have 1 1 right? 1 1 to be there on that day. But you can 12 A. Yeah, but money talks. 1 2 just call me and I?ll tell you whether 1 3 Q. Are there any of the other modeling 1 3 you really have to be there or you 1 4 agencies that are not friendly with MC Squared? 4 don't. 3.5 Such as Ford Modeling Agency; is that someone? 15 THE WITNESS: This is July 19. 1 6 A. There is a guy in New York that you have 1 6 MR. EDWARDS: Right. 3.7 to talk to. 17 THE WITNESS: This is for which 1 8 Q. Who is that? 1 8 one? 1 9 A. Uh, what his name? What his name? 1 9 MR, EDWARDS: It's just one of the 20 Jean?Loo sue him and then he sue him and he won, 2 0 very many Jane Does. 2 1 because Iean~Luc never paid two girls. And he was 2 1 THE WITNESS: And this is another 22 the the genera! manager of New York. And he 2 2 subpoena? 2 3 opened his own agency and he did much better than 2 3 MR, EDWARDS: It?s for trial, 2 4 Jean~Luc. 2 4 MR. FISTEN: It?s just for trial. 2 5 Q. Do you remember the name of the agency? 2 5 (Thereupon, the Sworn Statement was 7 3. 7 3 1 A. it's one -- can be One Model. 1 concluded 5:23 pm.) 2 (2. 2 3 A. Yeah. It's Scott. That's his name, 3 4 Scott and One Management. If there is a person 4 5 that is going to tail; everything for Jean-Loo, 5 6 it's going to be him. 6 7 Q. And have you seen pictures of Jean~Luc 7 8 and underage girls in any other context other than 8 9 at model shoots, parties or whatever? 9 3. A. Parties, yeah. There were pictures. He 1 1 1 has pictures in his Faeebook with the giris, 1 1 1 2 hugging the giris or whatever. 1 2 3 Q. Right. Any with Jeffrey Epsteindon?t think so. 1 4 1 5 Q. Have you ever seen any pictures with 5 1 6 Jeffrey Epstein and the modeis? 6 1 7 A. The ones that he took at the partyyou know where those areJean-Luc's computer. 1 9 2 Q. Okay. Has can?Lac ever taiked about 2 2 1 any of the cases invoiving Jeffrey Epstein? 2 1 2 2 A. Neveranybody else that you know? 2 3 2 4 A. No, not that i know. 2 4 25 MR. EDWARDS: All right. Fm going 2 5 19 (Pages 70 to 73) U.S. Legal Support (305) 373-8404 74 1. CERTIFICATE OF OATH 2 3 41 STATE OF FLORIDA 5 6 7 8 I, the undersigned authority, certify that 9 MARITZA VASQUEZ personaity appeared before me and 1 0 was duty sworn. 3.1 WITNESS my hand and of?cial seal this 24th 12 dayofiune,2010. 13 14 1 5 ELAINE CRANDALL Notary Pubiic State of Florida 1 6 My Commission No. 1313710458 Expires: December 28, 2011 CERTIFICATE OF REPORTER 2 3 4 STATE OF FLORIDA SS. 5 6 7 8 I, BLAME CRANDALL, Registered Professional Reporter and Notary Public in and for the State of 9 Florida at Large, do hereby certify that I reported the Sworn Statement of MARITZA VASQUEZ, a 1 witness caiied in the above-styied cause; and that the foregoing pages, numbered from 1 to 74, 3. inciusive, constitute a two and correct transcription of my shorthand report of the 12 deposition by said witness. 1 3 I further certify that I am not an attorney or counsel of any of the parties, nor a retative 4 or employee of any attorney or counsel connected with the action, nor ?nancially interested in the 15 action. 3.6 WITNESS my hand and official seal in the City of Miami, County of Miami-Dado, State of Fioridaa 3.7 this 24th day of June, 2010. 18 19 20 2 ELAINE CRANDALL, R.P.R. 22 23 24 25 U.S. Legal Support (305) 373*8404 20 (Pages 74 to 75) DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, 61? a1. Case No. 50 2009 CA 040800MMBAG I EXHIBIT "Wi?fa?a. Ann Marie C- To "Jay Lefkowitz? <3Lefkowitz?kirklan?con sAnnMarle?Nillafananusdo 0" 1.90? 09.!1932007 12:14 PM Judge Johnson has duty next week. Jay I hate to have to be firm about this, but we need to wrap this up by Monday. I will not miss my indictment date when this has dragged on for several weeks already and then, if things fall apart, be left in a less advantageous position than before the negotiations. [have had an 82~page pros memo and 53-page indictment sitting on the shelf since May to engage in these negotiations. There has to be an ending date, and that date is Monday. A. Marie Vizzafa?a Assistant US. Attorney 561 209?1047 m? Original Message From: "Viliafana, Ann Marie C. Sent: 09/19/2007 11:51 AM AST To: Jay Le?cowitz Subject: Meeting Barry is available Monday morning. Our most ?exible West Palm Beach magistrate is on duty on Monday, so, assuming we have signed documents by 1:30 or so, we should be able to get Mr. Epstein arraigned on Monday. I doubt that we will be able to get everything ?nished up here, got down to Miami, and try to ?nd a Miami mag by close of business on Monday. A. Marie Villafa?a US. Department of Justice United States Attorney Southern District ofFZorfda 500 Australian Ave, Ste 400 West Palm Beach, FL 3340! 820?8711 Facsimile: (561) December 13, 2007 DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022?4675 Re: Ief?ey Epstein Dear Jay: I am writing not to reSpond to your asserted ?policy concerns? regarding Mr. Epstein?sNom Prosecution Agreement, which will be addressed by the United States Attorney, but the time has come for me to respond to the ever?increasing attacks on my role in the investigation and negotiations. It is an understatement to say that I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent-over backwards to keep in mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement. For example, I brought to your attention that one potential plea could result in no gain time for your client; I corrected one of your calculations of the Sentencing Guidelines that would have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the Bureau of Prisons to see whether Mr. Epstein Would be eligible for the prison camp that you desired; and I told you my suspicions about the source of the press ?leak? and suggested ways to avoid the press. Importantly, I continued to work with you in a professional manner even after I learned that you had been proceeding in bad faith for several weeks thinking thatl had incorrectly concluded that solicitation of minors to engage in prostitution was a registrable offense and that you would ?fool? our Of?ce into letting Mr. Epstein plead to a non~registrable offense. Even now, when it is clear that neither you nor your client ever intended to abide by the icons of the agreement that he signed, I have never alleged misconduct on your part. The first allegation that you raise is that I ?assiduously? hid from you the fact that Bert Ocariz is a friend of my boyfriend and that I have a ?longstanding relationship? with Mr. Ocariz. JAY P. Laraowrrz, ESQ. Becomes. 13, 2007 Pass. 2 or 5 I informed you that I selected Mr. Ocariz: because he was a friend and classmate of two people whom I respected, and thatl had never met or spoken with Mr. Ocariz prior to contacting him about this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and I spoke about this case, he did not know about my relationship with his friend. You suggest that I should have explicitly informed you that one of the referrals came from my ?boy?iend? rather than simply a ??iend,? which is the term I used, but it is not my nature to discuss my personal relationships with opposing counsel. Your attacks on me and on the victims establish Why I wanted to find someone whom I could trust with safeguarding the victims? best interests in the face of intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz was that person. One of your letters suggests a business relationship between Mr. Ocaria and my boyfriend. This is patently untrue and neither my boyfriend nor I would have received any financial bene?t from Mr. Ocariz?s appointment. Furthermore, a?er Mr. Ocariz leamed more about Ivlr. Epstein?s actions (as described below), he expressed a willingness to handle the case pro bcac,,witl1 no ?nancial bene?t even to himself. Furthermore, you were given several other options to choose ?'orn, including the Podhurst firm, which was later selected by Judge Davis. You rejected those other options. You also allege that I improperly disclosed information about the case to Mr. Ocaria. I provided Mr. Ocariz with a bare bones Summary of the agreement?s terms related to his appointment to help him decide whether the case was something he and his ?im would be Willing to undertake. I did not provide Mr. Ocariz with facts related to the investigation because they were con?dential and instead recommended that he ?Google? Mr. Epstein?s name for background information. When Mr. Ocariz asked for additional information to assist his ?rm in addressing conflicts issues, I forwarded those questions to you, and you raised objections for the ?rst time. I did not share any further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Of?ce?s decision to use a Special Master to make the selection and told him that the Office had made contact with Judge Davis. We have had no further contact since then and I have never had contact with Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to try to ?lobby? him to select someone to your liking, despite the fact that the Noanrosecutioo Agreement vested the Office with the exclusive right to select the attorney representative. Another reason for my surprise about your allegations regarding misconduct related to the Section 2255 litigation is your earlier desire to have me perform the role of ?facilitator? to convince the victims that the lawyer representative was selected by the Office to represent their interests alone and that the out~of~court settlement of their claims was in their best interests. You now state that doing the same things that you had asked me to do earlier is imprOper meddling in civil litigation. Much of your letter reiterates the challenges to Detective Recarey?s investigation that have JAY P. Lassowrrz, Eso. Decca/sees 13, 2007 PAGE 3 OF 5 already been submitted to the Of?ce on several occasions and you suggest that I have kept that information from those who reviewed the proposed indictment package. Contrary to your suggestion, those submissions were attached to and incorporated in the proposed indictment package, so your suggestion that I tried to hide something from the reviewers is false. I also take issue with the duplicity of stating that we ms; accept as true those parts of the Recarey reports and witness statements that you like and we mg; accept as false those parts that you do not like. You and your co?courisel also impressed upon me from the beginning the need to undertake an independent investigation. It seems inappropriate now to complain because our independent investigation uncovered facts that are unfavorable to your client. You complain that I ?forced? your client and the State Attorney?s Of?ce to proceed on charges that they do not believe in, yet you do not want our Of?ce to inform the State Attorney?s Office of facts that support the additional charge nor do you want any of the victims of that charge to contact Ms. Belohlavek or the Court. Ms. Belohlavek? 5 Opinion may change if she knows the full scope of your client?s aotions.? You and I spent several weeks trying to identify and put together a plea to federal charges that your client was willing to accept. Yet your letter now accuses me of ?manufacturing? charges of obstruction of justice, making obs cone phone calls, and violating child privacy laws. When Mr. Lourie told you that those charges would ?embarrass the Of?ce,? he meant that the Of?ce was unwilling to bend the facts to satisfy Mr. Epstein?s desired prison sentence a statement with which I agree. I hope that you understand how your accusations thatl imposed ?ultimatums? and ?forced? you and your client to agree to unconscionable contract terms cachet square with the true facts of this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed for more than five months to allow you and Mr. Epstein?s other attorneys to make presentations to the Of?ce to convince the Of? ce not to prosecute. Those presentations were unsuccess?ll. As you mention in your letter, I ma simple line AUSA - handled the primary negotiations for the Of?ce, and conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly _skilled and experienced practitioners. As you put it, your group has a ?combined 250 years experience? to my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcourt, whose experience Speaks for itself. You and I spent hours negotiating the terms, including when to use versus ?the? and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, layolving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times. In any and all plea negotiations the defendant understands that his options are to plead or to continue with the investigation and proceed to trial. Those were the same optioos that were proposed to Mr. Epstein, and they are not ?persecution or intimidation tactics.? Mr. Epstein chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel. You also make much of the fact that the names of the victims were not released to Mr. Epstein prior to signing the Agreement. You never asked for such a term. During an earlier meeting, where Mr. Black was present, he raised the coocern that you new voice. Mr.- Black and I did not have a chance to discuss the issue, but i had already conceived of a way to resolve that JAY P. ESQ. DECEMBER 13, 2007 PAGE at ca 5 issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was not a matter of concern to the defense. Since the signing of the Noanrosecution Agreement, the agents and I have vetted the list of victims more than once. In one instance, we decided to remove a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided that the link to a payment was insuf?cient to call it ?prostitution.? I have always remained open to a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is simply unfounded. Your last set of allegations relates to the investigation of the matter. For instance, you claim that some of the victims were informed of their right to collect damages prior to a thorough investigation of their allegations against Mr. Epstein. This also is false. None of the victims was infomed of the right to sue under Section 2255 prior to the investigation of the claims. Three victims were notified shortly after the signing of the Non~Prosecution Agreement of the general terms of that Agreement. You raised objections to any victim noti?cation, and no thither noti?cations were done. Throughout this process you have seen that I have prepared this case as though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior to concluding the matter by plea or trial would only unde?nine my case. If my reassurances are insuf?cient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of the integrity of the investigation.I IThere are numerous other unfounded allegations in your letter about document demands, the money laundering investigation, contacting potential witnesses, speaking with the press, and the like. For the most part, these allegations have been raised and disproven earlier and need not be readdressed. Howevei?, with respect to the subpoena served upon the private investigator, contrary to your assertion, and as your co~counsel has already been told, I did consult with the Justice Department prior to issuing the subpoena and I was told that because I was go: subpoenaing an attorney?s office or an of?ce physically located within an attorney?s office, and because the business did private investigation work for individuals (rather than working exclusively for Mr. Black), I could issue a grand jury subpoena in the normal course, which is What I did. i also did not ?threaten? the State Attomey?s Office with a grand jury subpoena, as the correspondence with their grand jury coordinator makes perfectly clear. With regard to your allegation of my filing the Palm Beach Police Department?s probable cause affidavit ?with the court knowing that the public could access it,? I do not know to what you lid?tli? 'gr'a'?d'j?fy 'i?ves'ti?gatioa?have been ?l?d under the Palm Beach Police Department?s probable cause affidavit has never been filed with the Court. If, in fact, you are referring to the Ex Ports Declaration ofloseph Recarey that was ?led in response to the motion to quash the grandjury subpoena, it was filed both under seal and exports, so no one should have access to it except the Court and myself. Those documents are still in the Court ?le only because mhave violated one of the terms of the Agreement by failing to ?withdraw [Epstein?s] pending motion to intervene and to quash certain grandjury subpoenas.? JAY P. LEFKOWITZ, ESQ. DECEMBER 13, 2007 PAGE 5 or 5 With respect t_ I contacted her attorney - who was paid for by Mr. Epstein and was directed by coonse for Mr. Epstein to demand immunity - and asked only whether he still represented Ms. and if he wanted me to send the victim noti?cation letter to him. He asked what the letter we say and I told him that the letter would be forthcoming in about a week and that I could not provide him with the terms. With reapect to Ms.? status as a victim, you again want us to accept as true 0 acts that are bene?cial to your mat and to reject as false anything detrimental to him. his,? made a number of statements that are contradicted by documentary evidence and a review of or recorded statement shows her lack of credibility with respect to a number of statements. Based upon all of the evidence collected, Ms classified as a victim as defined by statute. Of course, that does not mean that considers herself a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identi?ed victims will not seek damages, but that does not negate their legal status as victims. I hope that you now understand that your accusations against myself and the agents are unfounded. In the future, I recommend that you address your accusations to me so thatI can correct any misunderstandings before you make false allegations to others in the Department. I hope that we can move forward with a professional resolution of this matter, whether that be by your client?s adherence to the contract that he signed, or by virtue of a trial. Sincerely, R. Alexander Acosta United States Attorney By: s/A. Maria Villafa?a A. Marie Villafa?a Assistant United States Attorney cc: R. Alexander Acosta, U.S. Attorney Jeffrey Sloman, First Assistant US. Attorney You also accuse me of ?broadcn?n g] the scope of the investigation without any foundation for doing so by adding charges ofmoney laundering and violations ofa money transmitting business to the investigation.? Again, I consulted with the Justice Department?s Money Laundering Section about my analysis before eXpanding that scope. he duty attorney agreed with my analysis. "Villafana. Arm Yo "Jay Lafkowitz? Marie C. > Regards, Maria A. Marie Villafa?a Assistant US. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone-561 2094047 I Fax 561 820-8777 is Information charging 1512 and 113.pdf OLY Plea Agreement v4 1512 and 113 violations?df UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA D. CASE NO. 18 U.S.C. 1512(d)(2) 18 U.S.C. ll3(a)(5) UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, Defendant. ORMATION The United States Attomey charges that: COUNT 1 In or around October 2005, in Palm Beach County, in the Southern District of Flbrida, and elsewhere, the defendant, JEFFREY EPSTEIN, did intentionally harass another person, that is, Jane Doe in an attempt to delay, prevent, and dissuade Jane Doe #1 from reporting to a law enforcement of?cer of the United States the commission of a federal offense; in violation of Title 18, United Staq??ide, Sections 1512(d)(2) and 2. COQET 2 In or around 2005, in the special territorial jurisdiction of the United States, that is, in an aircraft owned by a United States citizen while in ?ight over the high seas, and elsewhere, the defendant, JEFFREY EPSTEIN, commit a simple assault on a person who was over the age of 16 years, that is, in violat Title 18, United States Code, Section 113(a)(5). R. ALEXANDER pack UNITED STATES ATTORNEY A. VILLAFANA ASSISTANT UNITED STATES ATT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. UNITEIQATES OF VS. JEFFREY EPSTEIN, Defendant. PEAG The United States Attorney for the Southern District of Florida (?the United States?), and Jef??ey Epstein (hereinafter referred to as erndant?) enter into the following agreement: 1. The defendant agrees to plead guilty to the Information which charges the defendant as follows: Count 1 charges that the defendant intentionally harassed another person, that is, Jane Doc in an attempt to delay, prevent, and dissuade JaFoe #1 from reporting to a law enforcement officer of the United States the commission of a federal offense; in violation of Title 18, United States Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant, while in an airplane over the high seas, did knowingly commit a simple assault on a person who was over the age of 16 years, that is, in violation of Title 18, United States Code, SEW 2. The defendant is aware that the sentence will be imposed by the Court after considering the Federal Sentencing Guidelines and Policy Statements (hereinafter Page 1 of 7 ?Sentencing Guidelines?). The defendant acknowledges and uriderstands that the Court will compute an advisory sentence under the Sentencing Guidelines and that the applicable - ill be determined by the Court relying in part on the results of a Pro?Sentence by the Court?s probation of?ce, which investigation will comer-ice after the guilty plea has been entered. The defendant is also aware that, under certain circumstances, the Court may depart from the advisory sentencing guideline range that it has computed, and may raise or lower that advisory se if" under the Sentencing Guidelines. The defendant is ?rrther aware and understands the th curt is required to consider the advisory guideline range determined under the Sentencing Guidelines, but is not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in light of other statutory concerns, and such sentence may be either more severe or lesAe than the Sentencing Guidelines? advisory sentence. Knowing these facts, the defendant understands and acknowledges that the Court has the authority to impose any sentence within and up to the statutory maximum authorized by law for the offenses identi?ed in paragraph 1 an at the defendant may not withdraw the plea solely as a result of. the sentence iruposed. 3. The defendant ?mher understands and acknowledges that, as to Count 1 of the Information, the Court may impose a statutory maximum term of imprisonment of up to one (1) year, to be followed by a term of supervised release of up to a maximum 0 (1) year. In addition to terms of imprisonment and supervised release, the Court may impose a ?ne of up to $100,000. The defendant further understands and acknowledges that, as to Count 2 of the Information, the Court may impose a statutory maximum term of imprisonment of up to Page 2 of 7 six (6) months, to be followed by a term of supervised release of up to a maximum of one (1) year. In addition to terms of imprisonment and supervised release, the Court may impose a fine of $100,000. The defendant ?nther understands and acknowledges that, in addition to any sentence imposed under paragraph 3 of this Agreement, a special assessment in the ainount of $50 will be imposed on the defendant, which must be paid at or before the time of sentencing. 5. The defendant understands that the Court will order that he must pay full restitution to all victims of the offense to which he is pleading guilty. The defendant understands that the amount of restitution owed to each victim will be determined at or before sentencing. A 6. The parties agree to jointly recommend that the defendant receive a sentence of eighteen (18) months? imprisonment, to be followed by two (2) years of supervised release; and a ?ne of $200,000. I 7. The defendant agrees that, if any of the victims identi?n the federal investigation ?le suit pursuant to 18 U.S.C. 2255, the defendant will not contest the jurisdiction of the 11.8. District Court for the Southern District of Florida over his person and/or the subject matter, and the defendant will not contest that the identi?ed victims are persons who, while minor victims of violations of Title 13, United States Code, Sections(s) 2422 andfor 2423. m1; States agrees to provide the defendant?s attorneys with a list of the identi?ed victims, which will not exceed forty, after the defendant has signed this agreement and has been sentenced. The United Page 3 of 7 States ?ll-that agrees to make a motion with the United States District Court for the Southern District of Florida for the appointinent of a guardian ad litem for the identi?ed victims and the defendant?s counsel contact the identi?ed victims through that guardian. The defendant agrees to plead guilty (not nolo contendere) to an Information ?led by the Palm Beach County State Attomey? Of?ce charging an offense for which the defendant must register as a sex offender, that is, solicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03. The defendant agrees the the Palm Beach County State Attorney?s Of?ce wi ll make a joint, binding recomendatiH the Court impose a sentence of at least thirty (3 0) months, to be divided as follows: the defendant shall begin by serving at least twenty (20) months in prison, without any opportunity for wi holding adjudication or sentencing, and without probation or oommun' 0 01 in lieu of imprisonment; and following the tour: of imprisonment, the defendant shall serve ten (1 0) months of community control/home con?nement with electronic monitoring. 9. The defendant agrees to waive all challenges to the ation filed by the State El? once in the state court. Attorney?s Of?ce and to waive the right to appeal his conviction an 10. The defendant agrees that he will provide to the US. Attorney?s Of?ce copies of all proposed agrecxnents with the Palm Beach County State Attorney?s Of?ce prior to entering into those agreements. 11. - The United States reserves the right to inform the Court and Imitation office of all facts pertinent to the sentencing process, including all relevant information concerning the offenses committed, whether charged or not, as well as concerning the Page 4 of 7 defendant and the defendant?s background, and to respond to any questions from the Court and the Probation Of?ce and to any misstatements of fact or law. Subject only to the express terms agreed-upon sentencing recommendations contained in this Agreement, this (Ethan reserves the right to make any recommendation as to the quality and quantity of punishment. 12. The defendant is aware that the sentence has not yet been determined by the Court. The defendant also is awar any estimate of the probable sentencing range or sentence that the defendant may receive, whether that estimate comes from the defendant?s attorney, the government, or the probation of?ce, is a prediction, not a promise, and is not binding on the the probation of?ce or the Court. The defendant understands further that any that the gove akes to the Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on the Court and the Court may disregard the recommendation in its entirety. The defendant understands and acknowledges, as previously acknowledged in paragraph 2 abov - the defendant may not withdraw his plea based upon the Court?s decision notF: accept a sentencing recommendation made by the defendant, the government, or a recommendation madejointly by both the defendant and the government. 13. WAIVER OF RIGHT TO APPEAL AND THE SENTENCE. The defendant is aware that Title 18, United States Code, Section 3742 affords the defendant the right to appeal the sentence imposed in this case. Acknowledging this, in exchange for the undertakings made by the United States in this plea agreement, the Page 5 of 7 defendant hereby waives all rights conferred by Section 3742 to appeal any sentence imposed, including any restitution order, or to appeal the mazmer in which the sentence was impos see the sentence exceeds the maximum permitted by stamte or is the result of an uptmpatture or upward variance from the guideline range that the Court establishes at sentencing. The defendant thither voluntarily and expressly waives, to the maximum extent permitted by federal law, the right to collaterally attack his sentence in any post- conviction proceeding, including a on on any ground brought under 28 U.S.C. 2254, 28 U.S.C. 2255, 18 U.S.C. {33572, or 18 U.S.C. 3771. The defendant ?lrther understands that nothing in this agreement shall affect the government's right andfor duty to appeal as set forth in Title 18, United States Code, Section 374203). However, if the United States appeals the defendant?s sentence pursnant to Section 374A?m defendant shall be released from the above waiver of appellate rights. By signing this agreement, the defendant acknowledges that he has discussed the appeal waiver set forth in this agreement with his attorney. 14. If the defendant fails in any way to fulfill each on 's obligations under this Plea Agreement, the United States, and only the United States, :Elwt to be released from its commitments under this Plea Agreement. If the United States elects to void the Plea Agreement because of a breach by the defendant, then the United States agrees not to use the defendant?s guilty plea against him. However, the United States may prosecute defendant for any and all Federal crimes that he has committed related to this case and may seek any sentence for such crimes up to and including the statutory maximums. The defendant expressly waives any statute of limitations defense and any constitutional or statutory speedy Page 6 of ?7 . . a "W?afana. Ann Marie C. To ?Jay Lemowitz? Hi Jay Sorry to trouble you over the weekend. Here are the revised documents with the 403 charge. Ihave gotten some negative reaction to the assault charge with Sarah Kellen as the victim, since she is considered one of the main perpetrators of the offenses that we planned to charge in. the indictment. Can you talk to Mr. Epstein about a young woman name We have hearsay evidence that she traveled on Mr. Epstein's airplane when she was under 18, in around the 2000 or 2001 time frame. That falls outside the statute of limitations, but perhaps we could construct a 371 conspiracy around that? Let me know what you think. Thank you. Ann Marie Villafana ?e char in 403 a 3. df? has been archived by u?er on 01 '07:57'. Attachmegg Elea Agreement V5403 and 113 violations.ng hag been archived by user on 01:07:57: "Ann Marie Tc latkowitz?kirktandcom itefkowitz?kirklandcom UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 18 U.S.C. 403 18 U.S.C. 113(a)(5) UNITED STATES OF RICA vs. JEFFREY BPSTEIN, Defendant. INFORMATIOE The United States Attorney charges that: COUNT 1 In or around August 2006, in Palm Beach (ZOE, in the Southern District of Florida, and elsewhere, the defendant, JEFFREY EPSTEIN, did knowingly and intentionally violate the privacy protection accord 18 U.S.C. 3509 to a child victim, that is, Jane Doe in violation of Title 18, United Smt?de, Sections 403 and 2. COUNT 2 In or around 2005, in the special territorial jurisdiction of the United States, that is, in an aircraft owned by a United States citizen while in ?ight over the high seas, and elsewhere, the defendant, JEFFREY did knowingly commit a simple assault on a person who was over the age of 16 years, that is, 8.31.; in violation of Title 18, United States Code, Section 113(a)(5). R. ALEXANDER ACOSTA UNITED STATES A. VILLAFANA ASSISTANT UNITED STATES ATTORNEY A . UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. UNITED STATES OF ANIERICA vs. I JEFFREY Defend a The United States Attorney for I eSoathern of Florida (?the United States?), and Jeffrey Epstein (hereinafter rEAt} to as the ?defendant?) enter into the following agreement: I 1. The defendant agrees to plead guilty to the Information which charges the defendant follows: Count 1 charges that the fendant knowingly and attentional?)! violated the privacy protection accorded to child victims by 18 U.S.C. 3509; in violation of Title 18, United States Code, Sections 403 and 2; and Count 2 charges that the defendant, while in an airplane over the high seas, did knowingly conanit Wye assault on a person who was over the age of 16 years, that is, in violation of Title 18, United States-Code, Section 113(a)(5). 2. The defendant is aware that the sentence will be imposed by the Court after considering the Federal Sentencing Guidelines and Policy Statements (hereinafter Page I of 7 ?Sentencing Guidelines?). The defendant acknowledges and understands that the Court will compute an advisory sentence under the Sentencing Guidelines and that the applicable guideli ill be detennined by the Court relying in part on the results of a Pro?Sentence Investigation by the Court?s probation of?ce, which investigation will commence after the guilty plea has been entered. "I?he defendant is also aware that, under certain circumstances, the Court may depart ft the advisory sentencing guideline range that it has computed, and may raise or loWer sentence under the Sentencing Guidelines. The defendant is further aware and understands that the Court is required to consider the advisory guideline - range determined under the Sentencing Guidelines, but is not bound to impose that sentence; the Court is permitted to tailor the UWG sentence in light of other statutory concerns, and each sentence may be either more severe or less severe than the Sentencing Guidelines? advisory sentence. Knowing these facts, the defendant understands and aclmowledges that the Court has the authority to impose any sentenc thin and up to the statutory maahnmn authorized bylaw for the offenses identi?ed in paragraph 1 and that the defendant may not withdraw the plea solely as a result of the sentence imposed. 3. The defendant understands and acknowledges that, as to Count 1? of the Information, the Court may impose a statutory maximum term of prisonment of up to one (1) year, to be followed by a term of supervised release of up to a maximum of one 1) year. In addition to terms of imprisonment and supervised release, the Court may impose a ?ne of up to $100,000. The defendant further understands and acknowledges that, as to Count 2 of the Infonnation, the Court may impose a statutmy maximum term of imprisonment of up to Page 2 of 7 six (6) months, to be followed by a term of supervised release ofup to a maximum of one (1) year. In addition to terms of imprisonment and supervised release, the Court may impose a ?ne of BSHOQODO. 4. The defendant further understands and acknowledges that, in addition teeny sentence imposed under paragraph 3 of this Agreement, a special assessment in the amount of $50 Will be impo on the defendant, which must be paid at or before the time of sentencing. 5. The defendant understands that the Court will order that he must pay full restitution to all victims of the offense to which he is pleading guilty. The defendant understands that the amount of re?on owed to each victim will be determined at or before sentencing. 6. The parties agree to jointly recomend that the defendant receive a sentence of eighteen (18) months? imprisonment, to be fF?wed by two (2) years of supervised release; and a fine of $200,000. I I 7. I The defendant agrees that, if any of the victims identi?ed in the federal investigation ?le suit pursuant to 18 U.S.C. 2255, the defendant will not contest the jurisdiction of the US. District Court for the Southern DistrictItFlorida over his person andfor the subject matter, and the defendant will not contest that the identi?ed victims are persons who, while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 andfor 2423. The United States agrees to provide the defendant?s attorneys with a list of the identi?ed victims, which will not exceed forty, after the defendant has Page 3 of 7 signed this agreement and has been sentenced. The United States ?nther agrees to make a motion with the United States District Court for the Southern District of Florida for the appoin aw], contact identi?ed victims through that guardian. of a guardian ad litem for the identi?ed victims and the defendant? 3 counsel may 8. The defendant agrees to plead guilty (not nolo contendere) to an Information ?led by the Palm Bea County State Attorney?s Office charging an offense for which the defendant must regiR: a sex offender, that is, solicitation of minors to engage in prostitution, in violation of F1. Stat. 796.03. The defendant agrees that he and the Palm Beach County State Attorney?s Of?ce will make ajoint, binding recommendation that the Court impose a sentence of at least (30) months, to be divided as follows: the defendant shall begin by serving at least twenty (20) months in' prison, without any opporttmity for Widiholding adjudication or sentencing, and without erion or community control in lieu of imprisonment; and following the term of imprisonment, the defendant shall serve ten (10) months of community conothome con?nement with electronic monitoring; 9. The defendant agrees to waive all challenges to the Information filed by the State Attorney?s Of?ce and to waive the right to appeal his conviction and sentence in the state court. 10. The defendant agrees that he will provide to the US. Attorney?s Of?ce ?copies Page 4of 7 of all preposed agreements with the Palm Beach County State Attomey?s Of?ce pi?ior to entering into those agreements. The United States reserves the right to inform the Court and the probation office of all facts pertinent to the sentencing process, including all relevant infantiation concealing the offenses committed, whether charged or not, as Well as concerning the defendant and the defe dent?s background, and to respond to any questions ?ow the Court and the Probation OfCRod to any misstatements of fact or law. Subject only to the express terms of any agreed?upon sentencing recommendations contained in this Agreement, this Of?ce ?nther reserves the right to make any reconmendation as to the quality and quantity A 12. The defendant is aware that the sentence has not yet been determined by the of punishment. Court. The defendant also is aware that any estimate of the probable sentencing range or sentence that the defendant may receive, whether estimate comes from the defendant?s attorney, the govermnent, or the probation of?ce, 13 a prediction, not a promise, and is not binding on the government, the probation of?ce or the Court. The defendant understands fm'ther that any recommendation that the government makes to the Conrt as to sentehcing, whether pursuant to this agreement or othetwise, is not Court and the Court may disregard the recommendation in its entirety. The defendant understands and acknowledges, as previously acknowledged in paragraph 2 above, that the defendant may not withdraw his plea based upon the Court?s decision not to accept a sentencing recommendation made by the defendant, the govemment, or a recommendation made jointly Page 5 of 7 by both the defendant and the government. 13. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY ATTACK THE NCE. The defendant is aware that Title 18, United States Code, Section 3742 affords the defendant the right to appeal the sentence imposed in this case. Acknowledging this, in exchange for the undertakings made by the United States in this plea agreement, the defendant hereby all rights conferred by Section 3742 to appeal any sentence imposed, including aRtitution order, or to appeal the manner in which the sentence was imposed, unless the sentence exceeds the maximmn permitted by statute or is the result of an upward depaxture or upward variance from the guideline range that the Court establishes at sentencing. The defendant ?ntl?luntarily and expressly waives, to the manimmn extent permitted by federal law, the right to collaterally attack his sentence in any post?- conviction proceeding, including a motion on any ground brought under 28 U.S.C. 2254, 28 U.S.C. ?2255, 18 U.S.C. 3572, or 18 U.S.C. l. The defendant ?nther understands that nothing in this agreement shall affect the govenunent?s right andx? or duty to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant shall be released ?'orn the above waiver of appellate rights. By signing this agreement, defendant acknowledges that he has discussed the appeal waiver set forth in this agreement with his attorney.? 14. Ifthe defendant fails in any way to ful?ll each one of his obligations under this Plea Agreement, the United States, and only the United States, may elect to be released from its under this Plea Agreement. If the United States elects to void the Plea Page 6 of 7 . Agreement because of a breach by the defendant, then the United States agrees not to use the defendant?s guilty plea against him. However, the United States may prosecute the defendant for any 1 Federal crimes that he has committed related to this case and may seek any sentence for such crimes up to and including the statutory maximum. The defendant expressly waives any statute of limitations defense and any constitutional or statutory speedy trial defense to such osecution, except to the extent that such a defense exists as of the date he signs this PleReement. Finally, the defendant understands that his violation of the tones of this Plea Agreement would not entitle him to withdraw his guilty plea. 15. This is the entire agreement and understanding between the United States and the defendant. There are no other a?ents, promises, representations, or understandings. Date: By: R. AL ER ACOSTA UNITE TATES ATTORNEY Date: By: JEFFREY EPSTEIN, DEFENDANT Date: By: JAY LEFKOWITZ, ES Q. ATTORNEY FOR DEFENDANT Page 7 of 7 "Ann Marie Villafane" omz- - 09116I2007 03:54 PM To "Jay Lefkowltz? Marie C. cMn.Madrle.c.Vliiaf ana as o. cw ?9 Subject Factual proffer 09f1812007 02:53 PM El. . as eta-?teem 1 gee: . 'v a" ?"lxa n3? laid; it? . Ragga ea Hi Jay I didn?t want us to get sidetracked during the conference call. I want to makesure that we have a factual basis for ?harassment.? Forciny ?ying Sarah and Nadia somewhere else is a different 1512 offense with a 10 yea: cap. This is the factual proffer that I drafted up earlier this a?emoon, to give you an idea of what it would look like. When I include a factual proffer in a plea agreement, I usually use prefatory language like: The parties agree that, had this case proceeded to trial, the United States would have proven the following facts beyond a reasonable doubt, and that the following facts are true and correct and are suf?cient - to support a plea of guilty . <awh . Q?)77?w6676 SSH 25373465xvLew gf?i :xhk, M. V?rwa? ?93% Tabb?, E317 Hakim rat-1) 264m 3686 I 774*?3?06) m?ckmv 5&9 AA mm {Maz- jahhx - Kat-x km [vim ETXH Z7 72;. 313;) game-?353 Zi?liw ?63.37 E133) 623%? 2 Melissa. 36951.2, Wan}; \Z/ai?y a, i?XicLz 556? 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Road Satem, NY 10560 8-4de i as? 5349 3: ?28?-49?7 mrec: -ss&4551 North Saiem -66 3mm Dubin, Louis 8: Tiffany The Grasp 001 212 327 033391} Emmi: IZ .. 212 419 7493 Jensen: '0 Si. . ?pg. .. 7930?332 959 Sophie 13 rue Muai??var Hm329 3- 207-689 8625 50133118 75008 Pans ?13321 67; Ba more 00 33 1 4265223182} 091 212 459 2602 iwf Enemy-Giordano, ?031223?ng2 I 8? 001 212 32? 0883 h) Francesco ?31 212 535 8552 Sir An?ca Di San Vito Dunbar Johns? Duthte, John 8. Chariotte on 3 1 5054 32210?5 eranda Egnag?en?ug?? Tame Dubin, Peter . 27A Leamington Rd 0207639 7993 0207 376 8755 . . Landau W1 1HT Duesin Paui mm? gags? ai 3525:}? Ventures 02? '3 3 3695 pmar a Duchess of York 3?3?;ng - 33 Sunninghifi Fag-E: g: Daiias TX 75201 - Dunne, Griffin Email: umar umarm . Ascot 5 71% 214 3?20 0212 . 145 6th Ave 3 90309 5923 m) i; ?31144??68 15121519} 214 794 3591 New York $10013 I {Eljg?i? 335%319 co uk 234 no 0052 091 212 343 8830 . - . - . 901212614092? 21 3- gig? 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Lucinda 1 +44 20? 30? 1753 diract 9297.213 5245 odem . 53 The Chase +44 20? 307 1151 020?. 024 58883 Sophia 3: Bursa Lungi Landon SW3. 1 212 419 7433 Jenean 0207.930 200? Mas de Fressa?ga 026N322 3?38 1? 2.3 wing-aw .I. . .1 . Edwards. Andrew Tracy 9 Eaton Mews Scum London SW1W QHP. 4121 Elian, Johnathan 7 Rqad Greanwmh CT 830 1301 203 422 77 1 901 283.495 625 Emaik eahan stamood?com 1 203 249 8 Get! Elias, Brian 001 305 738 3331 {p (391 305 789 9242 Email: 001 305 5 010 home Etiascb, Johan Amanda 31 Chester 8 uare London QHT ux - +44 29? 730 8459 n} E44 210?a32?b433@93 com maz: ta 3 o. South audiey STmat +44 6? a? 2959 Amanda 3:13? g4? - {30 43 BS 4381 $293 39113:) E?ngwodh, Charlie Amanda The Basement 80 Oxford Gardens Lander: 0208-96 6? 0208343 5129 370754 car 0203-994 31"6 Etizabeth 9033 660 595 26? Ellenbagen Eric: 22 Gramerza,? Park NY NY 180 3 {101 212 65919179 001212 353 135 -~Ellingworth, Mr The id House Lang {on Lutierworih Lexus 020 ?994 3782 0203~734 5129 GMT 870754 {c El?ot, Ben Quintesmn?afly 80 Broad Street 5111 Hour at NY 18004 cm 212 8?3? ?740 {w 991 91? 320 495 Emmi: Hm 15-19 Great Titch?eld s'ggez' Erba Noam 8 020? 908 72m 020? 436 8980 001 917 553 67 1'2 Reade Street E?ison, Mandy 8: Ralph 218 Mediierranaan Fgc?ad 561 881 5mg :1 561-881o9093 :21 561 561 3 4791 Voace Mai: 88 331-5748 {21} on on, United Kingdom W1 AZ 4 p) El?ot, Gail 8: Joe Coffey 5 Eiwes, Anabei 41A Limersian Skeet London 5 10 0207-629 5955 Epstein, Ed 439 East 863} St. New York NY 100 001 212 249 4003 28 (all bla?de armzma 0 39 02 48?! 734 0039 D2 550 05108.5; Espirito Same, Manual and Res 00 35 so 35 935 44537 920mm} Imam) Estiin, Jean-Marc 7 Rue des SainiswPeres 005 ads DU 331 333341.?) ome Estrada Juffaii, Chris- ti 3 Ju?a?, Wa?d 50 de Park Gate ton on 50H 0207-823 8822 07mg Email: chris?naestrada?zlchotmaii. Box 364 ed ah 21431 Saudi Arabia 00 9662 66000105 Home and fax?38udi Arabsa ONES 678 (33) EZ 2. Evans Chri? 0207-663 3601 044?!- Evehart Angie 003 .310 568 515001} Emmi: Faber David Faber Sain 8: Brock Johnson Chariton Down Estate Chariien Down?etburg Glozgcesiagshige?sm TZ ii: saii faber hotmait.com Faibairh,? Charlotte 5 Hamish Fraser 199 Elslesg??cad London 11 Fairfax. The Hon Rupezrt The Coach Rouse ?ail an 191': Shrawsbury 411 922 14003 mail: m1partfarrfax@thorowgood? 01922 7 1676 07801248146{ rt} Q1743 709353 h} 0468 Fair-weather Natasha MOSCOW 00 ms 2436722 h} 00 1?95 2439762 f) Fairweather, his Catherine 162 iancaster rd London 0958 72688? may-43950011 5560 0207??92 32d? 91 82 Fainveather,Amba?ssa- dot Lady Patrick 6 ?a?a ?at 1 13 Wetherb ondcn 020?~244 969m) Armada 8: Jas- mine 19 The Balkans m? m. London SW19. 3 3990 92074 2 270? Fakhre, Danny Chris? tine 9? 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South Africa 2? 33 323 7007(1)} 87947 131910 Emait; ?erem @bugan.corn Hm)l1 ,3 Vac Una Junction res wish, Skeet Green Pomt. 3005 . Ca 3 Town South Africa ?g 5% 3?44?P39?3m 27 21 425 5383 Jeanine Green, Judy 555 Park Ave. New York NY 19021 cm 212 486-10217 . {Haas Gregg Geordie &Kath? e?ne 1 s3 ?5 029L221 5758 h} 0207? 351 141 07? 4? 695 330 can Grenfeii, Natasha 19 Che na E'lace Royal cs :tai Road do 8 3. gangs? 1413 Griffen. Ted 001 645 486 65?3 Griscom. Nina asst. Kali}! 640 park Avenue New York NY 20021 a 2122 7?44 9442 001 $31 233 8505 gagg . 12 3 3 3%344-1 805 Horrge?ax Gross, Pamela 8; Jimmy kaeist 655 Park Avenue New York. NY10821 21 73? 4292 {h 23 2 33 13:4 com ipamei?a) ma 1 . i Firs Neck Lane 62 South a? 53%? g? hf 212 330 813 52?5 gmsla mg?wm 5:5 ?333 gaze ?nes 212 689 4013 Ffoma Grossman a 6 926?-?36 ?3?6 Gubeimann adone 4o Ea Naw ?rgmd St a Guccioni212 226 Gude Deutshciigsng hrmtia 01 212 250 6468 01 232 1?22 33762:; Email: christian. . 39353333838??th GEN-961 3333 Guedroitz 3 oiina ?3 and SW1WS 011 44 29;? LJ 011 44 207 733 1333111: Guarini Aiessang?f?raidi, 31 Lon 63:1 F?ark Rd. $3521 385? 7?522 1 917 4801144fp} Guest. Come?a 001 91? 85 091 51a 99:; Ga age?ggeim. Barbara Barb? 9039mm? 3328 Marl-non: Lane Log An eies.CA 984369 61) 53 8 8236} Street as 10023 a 5 8 0 ?ame Horn gsgaa m3 0'33 33w .5 C) *4 i454 Burt's work 6833 Burt NY heme 9521 Barb 8624 baach house OONOMM 458 Guineas, Sabrina 301 56?! 964?3315 001 213 655 0470 Gufnnass, Mr Hugo 29 Brachin Place Landau 920mm 194?; Guissaini, Luca 1 9811 3% 48? :73? 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Georgina 31 Nexander Street London . ?568 Hunter, Carlyn 8: Laurie 9 Matiard 8L London Engiand SW3 EDT 0207?3?6 1* 52 9207-534 4168 001 38? 733 71 . Huntsman, Jon Mary Kaye 1389 Satha??ach Sign 84103 031391 354 9939.?) Hard, Nick Kim Hawe Court Readin Berkshire 820? 7 2 535481} 0781' 804 8464 Email: nhurd?nhmd.homecholce.ca :11 2A Chepsiow Place 0208-935 31331 0207-792 535% 0993 641828 {np 811113; Liz Simian {?ns 3 Cromweil Place . London SW7 2d 029?~539 6822{w} - ES Hurst, Anne 212 744 831 537 ursih?gben J. 9375;? Sachs a on. 323393;; 212 99% 52s ?st?ssain, ioadway aw a 10012 212 343 560 212 343 16710 ?3 Email: Husimy Simon Lon HT {mm?352 2310 3: 0207-557 azsfw?; Hutley, Henry ES Crescent 0486 32345 0207.?27 8782 {m gage; Lulu 8; EdWa?rd na Street Lands Sgades Far?m, 1? hommabeugt], Near Sum? 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LUCY Streat ?wv: 788 0287?235 2088 ?11 020?~3?8 "(070 Jones Ann Mick 007 212 799 "242431) Josephsan. 33?? 3? Jackie Barry w} a CA 90933 gm gee 0898 ib?f} mai: . - ontemlo [c.com 'Tg?sa?xsgassgw? an MoxggagM 71 ar 2168 whisper} 83 5969 pp} 3 5333 2g 8142gac ia's parenis in em 9 1531 net 2% 338 Jan 200?: Kasfner, 8267-2335-2313? - 39.9601. 091 Kat: Anton Rabi? Piani 200 E. 55%: at. New York, NY 10021 234 gatzenelf a stem 001? 2 00 321 Y54 0070 {'33 8 1gig/cap:earn {robin p} anion anion v.3 enbagan, Mark .49?tggl6hoAfrica 12733375 9993 Keeling: Sarah 0410455738? gegan. Rory Piece 0207.. 823 Y- 799 no ?ag? Keidan, Jon 91 2 210 626 5323 Email: faker Georgie - 01 780 3 07712 421233046 6929 Kelfett Fra ?ne 3539: Cara- @6841me L0 Keimenson . Eggaggabs 80 Arm ?g W?efgt 23:63: ?mm 6 mag-$901 212 933 'Kenned draw 8: garagmo? An. 13 Read MC 9312. 001 202 as? f??gfw Kennedy Jr, Ted Box 44? anannis Port Mass 8263?? USA 051508 :75 7177 h} 001 508 543 1400 ex: 2216 Kennedy, Bobby 85 Mary 326 5. Bradford Road Mount KESCO, NY 18549 914441?2313 h} 914 {?22 4343 w} Emari: mposim?angglaw?acgedu [,gnmwaca Envzronmantal (.1393- . tunic Kennedy, Ethet gamgogh?'mb ear: USA {301 395 4375 {it} Kennedy, do 73 BE eiow St Bri ham Mass 021 5 USA on 202 225 5111 Kengady, Senator Ed- 636 Ch inb 'd ad Melisa: vi?z??af 801 703-524-0733 Home Kersner, Sol Cafetown271465 V303 309 363 30003391 6 mo Khayat, Antoine, Jana George 4? Perrymead Street Loader: SW6 33 {3207-731 51m Kidd Jemma ?2 88% $33 King, Abby 10 Smeakon Road Eamon SW18 Email: Ben-Imam id .16: Lyman Nr Basie? GL6 020? 7 5522 820 7734 5565 98 air" Koch, David Kirwin Ta 001 212 332 Helen Charlie cm 212 age-Egg? Egn?ggci?e Square 0207-321: 3839 . . Astrid 028?~623 3000 5 Rye Bonaparte ?831? 252336 5? 57 11} Kim?? Ta ?0 so 33 1 4633 612 1' Fe a ter Ecmasi. thcom 092 212 888 0029 91 21 90 49 1%17g326239 Kissin e' 350 Parka?; at Henry A Km?: 30"? gstg?gznd Street 33? 333 2233 091 I su? a 21:33 9! 1913 4 Email. BKotrck@activision.com 1800 Street NW Washin to 091 20 6 Kotze, Aiex van 5? $033 Gardens gee, Rupert Charlotte 0207491 4336?? Egn?igsiw?on Palace Gardens Kravetz Anna cm 212 253 2815 0350 360843 Krooth Caryn Kiesch Jghnathan 901 323 332 63289:} 0335 3Y2672 Emmi: }ohnaman@kiesch.co.uk Kudrow, Aiistar cm 331 533 94?62{w} 011 3342527234m} La! Daiamal York Gate oration 406. Email: laidalamal@aut.com Hm}Akron House BA After: Avenue ke'a? L3 as. Ni 020; 93 70?? a: - . 5 {widrrectlme w? 4 K9) Laiaunis, Demetra 47 East 54%; Sires: NY NY10021 {30% 212 265 0590 Lambert, Christopher 001 213 55V1401 001 213 276 4337 90 33?! 4723 8184 ?Kw409807?) Lambert, David 212 8641535 in 91 a 3945 3'4 563 863 4148 Lambert, Edward ESL Partners 11 5 ?331 Puznam Avenue Graeme Connecticut 05330 001 203 522 4293 1 203 381 4600 go .. 601 212 885 5640 0th om 212 727 13363 cake?) 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"at 52 23 2717 2144 w) am 2 2 9055 .1 . 2?2 75? 4515? 331 33% 333 $399ng Lester: gfga?zsg?aggemgg? avg-cam 41 295045312 aura can 13?: 53.; 73?? Sl? 6250533601g?630r93 NOTE 6 53% 4705 4501 $315392 a g? ?53365?0296?36$g 382%?" Lawford Christopher 8; no 33 4705 4592 901 232 32? zagg 0?31 23% 332 2419 Roger's can Jean 331 9752 5725 {m ?261 9 33}: $31 237 2233 pawn?) 88138595 HQ [33 85 I 333.?995?9949 pal-{able L8 Mara, i874 762 463283 The A?ela 310 453 CA on; 55 E. 1?68?! Law {313? orationp 05313561 555 2925 {Shane 51mm} 3105954) 40 Portal)? 35%73 31500 gag 5 310 230 33 hams brace 00?! 21% A03 3507(w) 8E -. . w_ 1 mm; 7/30 Park A 3? 9&?4?053?23935?: 10A 917 374 .1 7531p 001 21 94 45 Lindemann, 60 Bfosso Paim $333480 001 561 336 055? 001 562 655 3011 5324413 8 gigs! 0433;3352 05150 11 (17?832 1094155 Em 087%]? Lingssay, Aiex Jaclyn Ludovic 3600 EN Rd on 1 0207?221 53133 ?me? 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(gt/x75 OF MOBILE i TELEPHONED CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE You RUSH RETURNED YOUR cm. SPECIAL ATTENTION -mo45?{? Md he 5.: we??m {Eggdg [VI-lac hon/e Ch. kilo??2}; 61' has 3 ?66m ?Mr: .0wa ?ihaw 4294 Quay/y. ?4 DEFENDANT BRADLEY .I EDWARDS STATEMENT OF UNDISPUTED FACTS Epsteirz 1). Edwards, 61? al. Case No. 50 2009 CA 040800MMBAG EXHIBIT Case Document 197 Entered on FLSD Docket 07/02/2010 Page 1 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-80119, 0680232, 0880380, 08-80381, 08-80994, 08-80811, 0880893, 0980469, 0980591, 0980656, 09-80802, 09-81092 I PLAINTIFF JANE NOTICE REGARDING EVIQENCE OF SIMILAR ACTS OF ASSAULT Plaintiff, Jane Doe, through undersigned counsel, hereby files this notice pursuant to Fed. R. Evid. 415(b), that she intends to offer evidence under the rule of other acts of sexual abuse and child molestation by Epstein at her trial. In compliance with the Rule, this pleading briefly sets out ?a summary of the substance of any testimony? that she plans to offer under the Rule. For the convenience of the Court, Jane Doe also provides brief background about the rule and about how the testimony of these other girls fits into the trial. Case Document 197 Entered on FLSD Docket 07/02/2010 Page 2 of 19 CASE NO: BACKGROUND Federal Rule of Evidence 415 Jane Doe provides this notice pursuant to Federal Rule of Evidence 415. Congress added Rule 415 into the federal rules in 1994. The rule makes evidence of other acts of sexual assault or child molestation automatically admissible in any cases (like Jane Doe?s) involving allegations of sexual assault by a victim. Congress explained that "[t]he reform effected by these rules is critical to the protection of the public from rapists and child molesters, and is justi?ed by the distinctive characteristics of the cases to which it applies. in child molestation cases, for example, a history of similar acts tends to be exceptionally probative because it shows an unusual disposition of the defendant -- a sexual or sado~sexuai interest in children that simply does not exist in ordinary people. Moreover, such cases require reliance on child victims whose credibility can readily be attacked in the absence of substantial corroboration. In such cases, there is a compelling public interest in admitting all significant evidence that will shed some light on the credibility of the charge and any denial by the defense.? 140 CONG. REC. 812990-01,812990 (Sept. 20, 1994) (statement of Sen. Dole). Congress also asked that the rule be liberally construed. As the Senate sponsor explained: ?The courts should liberally construe the rules so that the defendant's propensities, as well as questions of probability in light of the defendant's past conduct, can be properly assessed.? Id. See generally Karp, Evidence of Propensity and Probability in Sex Offense Cases and Other Cases, 70 CHL-KENT. L. REV. 15 (1994) (statement by principal dra?sman of Fed. R. Evid. 413-15 that has been incorporated as part of the legislative history of the rules, see 140 Cong Rec. H8991-92 (Aug. 21, 1994)). Case Document 197 Entered on FLSD Docket 07/02/2010 Page 3 of 19 CASE NO: Federal Rule of Evidence 415 is directly applicable to Jane Doe?s case. The Rule provided that a civil case in which a claim for damages or other relief is predicated on a party's alleged commission of conduct constituting an offense of sexual assault or child molestation, evidence of that party's commission of another offense or offenses of sexual assault or child molestation is admissible and may be considered as provided in Rule 413 and Rule 414 of these rules.? Fed. R. Evid. 415(a). Rule 413 defines an ?offense of sexual assault? as any ?crime under Federal law or the law of a State . . . that involved . . . any conduct proscribed by chapter 109A of title 18, United States Code? federal sex offenses against children. Fed. R. Evid. 413(d). Jane Doe?s First Amended Complaint alleges that Epstein committed many such state and federal offenses against her. See First Amended Complaint, case no. KAM, doc. #38 at 5 (state offenses), 7?8 (federal offenses). She also alleges that Epstein committed many such offenses against other then~minor girls. Id. at 2. The testimony described below easily fits within the rule. Requirement of Advance Notice Under Fed. R. Evid. 415(b) Fed. R. Evid. 415(b) requires that a ?party who intends to offer evidence under this Rule shall disclose the evidence to the party against whom it will be offered, including statements of witnesses or a summary of the substance of any testimony that is expected to be offered, at least fifteen days before the scheduled date of trial or at such later time as the court may allow for good cause.? To ensure full compliance with this rule, Jane Doe is filing this detailed notice, more than 15 days in advance of trial. Case Document 197 Entered on FLSD Docket 07/02l2010 Page 4 of 19 CASE NO: Jane Doe, however, has done far more than simply ?le this notice to give Epstein full notice of his intent to use such evidence. Indeed, as the Court is aware from earlier filings, Epstein has already received a witness list from Jane Doe with the names of other witnesses he is intending to call. Jane Doe has also given Epstein, both orally and in writing, ample notice that she intends to call the other girls that he abused at trial. in fact, from the onset of this litigation nearly two years ago, Epstein was provided with such notice. (Plaintiff, Jane Doe?s Disclosure Pursuant to Fed.R.Civ.P. 26 attached hereto as Exhibit A). Epstein is already preparing his motion in limine to object to the introduction of this evidence, as he has sought (and received) permission to file a pleading in excess of twenty-pages on the subject. See Defendant Epstein?s Motion in Exceed Page Limitation in Motion in Limine to Exclude Similar Fact Evidence, case no. doc. #167. Moreover, Epstein has obtained ample advanced notice of the substance of the testimony of the girls who will testify against him. These girls were the victims in the criminal investigation against him that was prosecuted by the State and Federal government. Epstein has received the Palm Beach Police Department incident Report, many of their statements to iocal poiice and FBI. and a list of approximately 40 underage minor victims was provided to him by the United States Attorney?s Office as an addendum to the Non?Prosecution Agreement. Through iegal counsel, he has received voluminous correspondence, discovery and information from state criminal investigators who investigated his sexual offenses of young girls. Through legal counsel, he has also participated in depositions of a number of these girls, including Case Document 197 Entered on FLSD Docket 07/02/2010 Page 5 of 19 CASE NO: Jane Doe, Jane Doe?s 2~8, CMA, EW, and LM. While settlement discussions are con?dential, the fact that Jeffrey Epstein settled the cases against him that were ?led by other girls who were not deposed is not secret, and Epstein negotiated those cases on the specific facts of those individual cases. in fact, he has apparently paid money to settle the sexual assault claims against him by more than 25 girls. He knows the nature of their allegations. ln such circumstances, no additional notice is required. See Johnson v. Elk Lake School Dist, 2083 F.3d 138, 150 n.6 (3m Cir. 2002) (finding no need for notice under Fed. R. Evid. 415 where defense counsel had participated in deposition involving the allegation of abuse; "the primary purpose of Rule disclosure provision [is] preventing a plaintiff from unfairly surprising a defendant at trial with evidence of an alleged past offense of sexual assault). The Need for Other Acts Testimony Similar fact evidence under F.R.Evidence 415 is extremely relevant and necessary in this case. Plaintiff Jane Doe will testify that she was at defendant Epstein?s home on numerous occasions between 2003 and 2005, beginning at a time when she was 14 years old. She was brought to his house by another underage minor victim of Epstein, consistent with Epstein?s designed scheme to access underage minors for sex. She was taken up to Epstein?s bedroom, and he told her to undress and massage him. Then he rolled over and began masturbating as he also touched Jane Doe?s naked breasts, buttocks and vagina. At times Epstein inserted his fingers into her vagina and used a vibrator on Jane Doe?s vagina. He and his assistants contacted Case Document 197 Entered on FLSD Docket 07/02/2010 Page 6 of 19 CASE NO: Jane Doe by telephone (a means of interstate communication) on numerous occasions for her to go ?work? at his house or give him a ?massage?. While Epstein has not denied any of these charges directly (he has asserted a 5th amendment right against self~incrimination), he also has not admitted to the allegations and has in fact tiled an answer to the complaint denying all of Jane Doe?s allegations. Case no. 9:08-cv-80893, doc. #131 (answer to complaint). Epstein has also raised several affirmative defenses, including ?[Jane Doe] consented to and was a willing participant in the acts alleged,? id. at 8; ?Defendant reasonably believed or was told that Jane Doe had attained the age of 18 years old at the time of the alleged acts,? id; Jane Doe cannot show that a means of interstate communication or transportation was involved in her abuse, id. in addition, Epstein, through counsel, has attacked the credibility of Jane Doe, as character assassination is his primary defense and he is attempting to call into the question the truthfulness of her testimony that she was sexually abused. For example, in deposition, Epstein has shaken his head and laughed and given other non?verbal responses when confronted with questions related to his scheme of accessing underage girls for sex and questions about the ritual that he engaged in with each of his underage victims. His attorneys have implied in deposition that Jane Doe was responsible, rather than Epstein, for this abuse, and that she was just a prostitute (although she has never received money for sex with anyone other than Epstein). He has cast her as a "bad girl? that went voluntarily and could have easily refused any of Epstein?s requests, if he indeed made any. In the face of such attacks, Case Document 197 Entered on FLSD Docket 07/02/2010 Page 7 of 19 CASE NO: Jane Doe needs to establish that Epstein is experienced at accessing and manipulating adolescent and teenage children into engaging in sex acts with him. There are also ample other reasons for needing the testimony of other victims of Epstein?s attacks. Notable among these is Jane Doe?s punitive damages case, which will include proof that Epstein has committed repeated acts of sexual abuse of others similar to Jane Doe. Juries considering punitive damages issues are plainly entitled to consider ?the existence and frequency of similar past conduct.? TXO Production Corp. v. Alliance Resources Corp, 509 US. 443, 462 n.28 (1993). This is because Supreme Court holdings recognize ?that a tecidivist may be punished more severely than a first offender . . . [because] repeated misconduct is more reprehensible than an individual instance of malfeasance.? BMW of North America, Inc. v. Gore, 517 US. 559, 577 (1996) (supporting citations omitted). in addition, under Rule 404(b), Jane Doe is entitled to offer the evidence to prove such things as (inter alia) absence of mistake absence of a reasonable belief that the girls were 18 years of age or older), common scheme or plan, ?modus operandi,? coercion, uneven bargaining power, premeditation, knowledge of age, and many other bases. NOTICE OF THE SUQSTANCE OF TESTIMONY TO BE OFFg?gg Jane Doe intends to offer two forms of testimony about other acts of sexual abuse by Epstein: direct and indirect. Direct testimony will come from then-minor girls who were sexually abused by Epstein and from Epstein himself. (Jane Doe intends to ask Epstein at trial whether the girls? testimony about his abuse was accurate; Epstein will then need to either fully confirm directly the accuracy of their testimony or, as he has Case Document 197 Entered on FLSD Docket 07/02/2010 Page 8 of 19 CASE NO: done during deposition, take the Fifth rather than answer.) This testimony will be direct testimony about Epstein?s acts of sexual abuse. Indirect testimony will come from others, such as Aifredo Rodriguez, who will indirectly con?rm the accuracy of the girls testimony through testimony. While Jane Doe has discovered more than 40 girls that could easily provide similar fact evidence, we have reduced that iist of witnesses to 15. Each of the 15 girls listed in this disclosure will testify that they were at Epstein?s house while minors between 2002 and 2005 - the same time frame relevant to the abuse alleged in Jane Doe?s complaint. They are all of similar age to Jane Doe. Each of the girls will testify to improper sexuai contact against them by Epstein in circumstances eerily similar to Jane Doe?s a common ?modus operandi.? None of the girls had massage experience although each physical encounter with Epstein included a massage. These other girls understand what was meant when Epstein and his conspirators used their common terms, ?work? and ?massage?. None of these girls were prostitutes before meeting Jeffrey Epstein. Each of the underage girls were paid cash by Epstein in exchange for sexual performance. Each was lead into the same home; each was lead into the same bedroom; each was lead to the same ?massage room? within the bedroom. Epstein had similar conversations with each of them. Their physical appearance was similar and such that Epstein could not have reasonably believed that they were 18 years of age or older when he was sexuain abusing them. While this notice provides the substance of the testimony of 15 girls, at trial Jane Doe intends to offer the testimony of only a few girls m- approximately 7 to 10 girls. The Case Document 197 Entered on FLSD Docket 07/02/2010 Page 9 of 19 CASE NO: 08-CV-80893-MARRAIJOHNSON expected length of the testimony of each of these girls is 20 to 30 minutes of direct testimony. As such, the direct testimony can easily be covered in less than one full trial day. C.W.1 When she was 14 years old, she was brought to Epstein?s home by another underage victirn. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein also demanded that she bring him other underage girls, and Epstein and his co-conspirators used the telephone to contact her to entice or induce her into going to his house for sex/prostitution. C.L. When she was approximately 15 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein aiso demanded that she bring him 1 To preserve the privacy of these giris, they wilt be identi?ed by initials. Epstein is well aware of the tuli names of these girls, which wilt be provided to hire by Jane Doe?s counsel. Case Document 197 Entered on FLSD Docket 07/02/2010 Page 10 of 19 CASE NO: other underage girls, and Epstein and his co~conspirators used the telephone to contact her to entice or induce her into going to his house for sex/prostitution. A.H. When she was approximately 16 years old, she was brought to Epstein?s horse by another underage victim. While a mirror, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein also demanded that she bring him other underage girls, and Epstein and his co-conspirators used the telephone to contact her to entice or induce her into going to his house for sex/prostitution. S.G. When she was approximately 14 years old, she was brought to Epstein?s I home by another underage victim. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a mirror at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein's presence. Epstein and his co~conspirators used the telephone to Contact her to entice or induce her into going to his house for sex/prostitution. 10 Case Document 197 Entered on FLSD Docket 07/02/2010 Page 11 of 19 CASE NO: AD. - When she was approximately 16 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the ciothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein also demanded that she bring him other underage girls, and Epstein and his co~conspirators used the telephone to contact her to entice or induce her into going to his house for sex/prostitution. VA. - When she was approximately 13 years old, she was brought to Epstein?s home by another underage victim. White a minor, she was at Epstein?s home on one occasion. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completer nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkcva in Epstein?s presence. N.R. - When she was approximately 17 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on one occasion. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a 11 Case Document 197 Entered on FLSD Docket 07/032010 Page 12 of 19 CASE NO: vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. J.S. - When she was approximately 16 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the foilowing acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. V.Z. When she was approximately 16 years old; she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbate-d in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein also demanded that she bring him other underage girls, and Epstein and his co~conspirators used the telephone to contact her to entice or induce her into going to his house for sex/prostitution. 12 Case Document 197 Entered on FLSD Docket 07/02/2010 Page 13 of 19 CASE NO: J.A. When she was approximately 16 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein also demanded that she bring him other underage girls, and Epstein and his co~conspirators used the telephone to contact her to entice or induce her into going to his house for sex/prostitution. F.E. -- When she was approximately 16 years old, she was brought to Epstein?s horne by another underage victirn. While a rninor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a rninor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejacuiated in her presence; Epstein touched her breast or buttock or vagina or the ciothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein and his co~conspirators used the telephone to contact her to entice or induce her into going to his house for sex/prostitution. M.L. When she was approximately 16 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on one 13 Case Document 197 Entered on FLSD Docket 07/02/2010 Page 14 of 19 CASE NO: OB-CV-80893-MARRAIJOHNSON occasion. Epstein engaged in one or more of the following acts with her while she was a minor at his house topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. MD. -- When she was approximately 16 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. D.D.--When she was approximately 16 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on muitiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein and his co-conspirators used the 14 Case Document 197 Entered on FLSD Docket 07/02/2010 Page 15 of 19 CASE NO: OB-CV-80893-MARRAIJOHNSON telephone to contact her to entice or induce her into going to his house for sex/prostitution. D.N. When she was approximately 17 years old, she was brought to Epstein?s home by another underage victim. While a minor, she was at Epstein?s home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on Nadia Marcinkova in Epstein?s presence. Epstein also demanded that she bring him other underage girls, and Epstein and his oo-conspirators used the telephone to contact her to entice or induce her into going to his house for sex/prostitution. Defendant Jeffrey Epstein The final witness Jane Doe intends to sail to provide direct evidence of sexual abuse is obviously defendant Jeffrey Epstein. Defendant Epstein knows about the acts of abuse that he inflicted on Jane Doe and the other girls. Jane Doe plans to ask him to admit the truth and accuracy of her testimony as well as the truth and accuracy of the testimony of the other girls described above. Jane Doe, of course, pians to ask him questions on other subjects as well (such as the tape recorded interview he gave to The Daily News). Jane Doe will aiso have Epstein authenticate many of the exhibits that she is using (either directly or by taking the Fifth, whichever his choice). For example, Epstein will authenticate the Daily News tape recording, all of the 15 Case Document 197 Entered on FLSD Docket 07/02/2010 Page 16 of 19 CASE NO: 08-CV-80893-MARRAIJOH NSON discovery provided in state and federal criminal investigations against him, and other materials. Indirect Testimony In addition to the direct testimony described above, Jane Doe also intends to offer what might be called indirect or circumstantial evidence supporting the accuracy of her testimony and that of the other girls. It is not clear that Rule 415 applies to such indirect or circumstantial evidence. Out of an abundance of caution, however, Jane Doe hereby gives notice that she will be calling witnesses who will corroborate the testimony of the girls. The most important of these witnesses are: Alfredo Rodriguez -- The Court is familiar with Mr. Alfredo Rodriguez, having sentenced him for activities associated with this case. His testimony is described at greater length in Jane Doe?s Motion for a Writ Ad Testi?candum, case no. 9:08-01:- 80893, doc. #181. in brief, Mr. Rodriguez saw numerous underage girls coming into Epstein?s mansion for purported ?massages.? Mr. Rodriguez was aware that ?sex toys? and vibrators were found in Epstein?s bed room after the purported massages. Rodriguez thought this was wrong, given the extreme youth of the girls he saw. in addition, Mr. Rodriguez will testify about ?The Holy Grail? a book he kept containing the names of apparently minor girls who were sexually abused by Epstein. Most (if not all) of the girls listed above are found in the black book. Sarah Kellen -- Sarah Kellen was one of Epstein?s household employees. Jane Doe intends to call her to confirm Epstein?s plan for telephoning the girls before each act of abuse and requesting a purported ?massage.? Further details of her the substance of 16 Case Document 197 Entered on FLSD Docket 07/02/2010 Pager-'17 of 19 CASE NO: the testimony Jane Doe hopes to elicit through her are found in Jane Doe?s Civil RICO statement, case no. doc. #38, exh. 1. (Kellen invoked the Fifth Amendment at her deposition.) Nadia Marcinkova Nadia Marcinkova has been described by Epstein as ?his sex slave.? Marcinkova also participant in some of the sexual activity with Epstein and young girls, as noted above. Further details of her the substance of the testimony Jane Doe hopes to elicit through her are found in Jane Doe?s Civil RICO statement, case no. doc. #38, exh. 1. (Marcinkova invoked the Fifth Amendment at her deposition.) Detective Recarey and Former Chief Joseph Rafter of the Palm Beach Police Department - These police officers helped conduct the criminal investigation into defendant Epstein?s sexual abuse. They will provide testimony about their investigation, and the evidence that they obtained, which will corroborate Jane Doe?s and the other girls testimonies. The substance of their testimony is also contained in their depositions in this case and related cases. No Need for Prior Hearing on the Girls Testimony in his Motion to Continue Trial, case no. 08-cv?80893, doc. #185, defendant Epstein seems to suggest that the Court will need to hold some sort of burdensome pre? trial hearing before admitting the testimony of these girls. Id. at 5. No such hearing is required. See, Johnson v. Elk Lake School Dist, 283 F.3d 138, 152-53 (3ml Cir. 2002) (to admit evidence under Rule 415, a trial judge need only decide, as with any other piece of evidence, that under Rule 104(b) . . . a reasonable jury could find by a 17 Case Document 197 Entered on FLSD Docket 07/02/2010 Page 18 of 19 CASE NO: preponderance of the evidence that the past act was an 'oflense of sexual assault? under Rule definition and that it was committed by the defendant?). There is ample evidence from which to infer that a reasonable jury could find the statements of the girls to be accurate, including defendant Epstein?s invocation of the Fifth Amendment rather than answer questions about them, as well as the identical ?modus operandi? to which all of the girls will testify and the evidence that was taken from Epstein?s home supporting same. CONCLUSION Jane Doe has complied with the notification requirements of Rule 415 by providing the notice herein. DATED: Julv 2, 2010 18 Respectfully Submitted, 31 Bradlev J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 Email: brad@pathtojustice.com and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801685-5202 Facsimile: 80168543833 EeMail: cassellp@iaw.utah.edu Case Document 197 Entered on FLSD Docket 07/02/2010 Page 19 of 19 CASE NO: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 2, 2010 electronically filed the foregoing document with the Clerk of the Court using also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CMIECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing. @radlev J. Edwards Bradiey J. Edwards SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Jooldberoer@agwoa.com Robert D. Critton, Esq. Isidro Manual Garcia isidrooarcia@bellsouth.net Michael James Pike Paul G. Cassell cassellp@law.utah.com 19 Case Document 1974 Entered on FLSD Docket 07/02/2010 Page 1 of 12 CASE NO: 08-CV-80893-MARRAIJOHNSON Plaintiff Jane Doe?s Notice Regarding Simiiar Acts of Sexuai Assauit EXHIBIT A Case Document 197?1 Entered on FLSD Docket 07/02/2010 Page 2 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: JANE DOE, Plaintiff vs. JEFFREY Defendant PLAINTIFF, JANE DISCLOSURE PURSUANT TO ED.R.CIV.P. 2615115 1 COMES NOW the Plaintiff, Jane Doe, by and through her undersigned counsel, and files this disclosure pursuant to Fed.R.Civ.P. 26(a)(i)(AwD) and states as follows: A. Witnesses: 1. Jane Doe c/o Brad Edwards Associates 2028 Harrison Street Suite 202 Hollywood, Fiorida 33020 954?414?8033 Plaintiff information regarding Defendant, Jeffrey Epstein's conduct that is the subject of this action 2. Juan Alessi Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 3. Maria Alessi Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Case Document 197?1 10. 11. 12. Entered on FLSD Docket 07/02/2010 Page 3 of 12 Jim Baca Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant, Jeffrey Epstein?s conduct and ?nances anusz Banasiak Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Leon Black Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant, Jeffrey Epstein?s conduct and ?nances Keith Blumberg Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Brice (last name unknown at this time) Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Michelle Campos Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Jimmy Cayne Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant, Jeffrey Epstein's conduct and finances Cecelia (last name unknown at this time) Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Max imilia Cordero Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Case Document 197?1 Entered on FLSD Docket Page 4 of 12 i3. Valdson Cotrim Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of {his action 14. John Cunningham 353 El Brillo Way West Palm Beach, Florida Knowledge of Defendant?s conduct that is the subject of this action 15. Ellen Cunningham 353 El Brillo Way West Palm Beach, Florida Knowledge of Defendant?s conduct that is the subject of this action 16. Dave (last name unknown at this time) Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action (pilot for Defendant) 17. Ryan Dionne Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 18. Jenn Doyle Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 19. Michael Friedman Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 20. Rosalie Friedman Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 21. Eric Gany Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s finances that is the subject of this action Case Document 197?4 22. 23. 24. 25. 26. 27. 28. 29. 30. Entered on FLSD Docket 07/02/2010 Page 5 of 12 Leslie Groff Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Nicole Hessey Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Jennifer (last name unknown at this time) Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Jojo (last name unknown at this time) Address unknown at this time 917?975-4500 Defendant's staff member in New York with knowledge of Defendant?s inappropriate conduct with underage girls Karen (last name unknown at this time) Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Sarah Kellen Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Helen Kim Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Gmmeg Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant, Jeffrey Epstein's conduct and ?nances Bella Klein Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s ?nances that is the subject of this action Case Document 197?1 Entered on FLSD Docket 07/02/2010 Page 6 of 12 3 1. L.M. c/o Bred Edwards Associates 2028 Harrison Street Suite 202 Hollywood, Florida 33020 954-414-8033 Information regarding Defendant, Jeffrey Epstein's conduct that is the subject of this action 32. Adam Perry Lang Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 33. Michael Liffman Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 34. Mark Lumberg Address unknown at this time 614-939?6005 Knowledge of Defendant?s conduct that is the subject of this action 35. Cherie Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 36. (last name unknown at this time) Address unknown at this time 917~856?1285 Knowledge of Defendant?s conduct that is the subject of this action 37. Nadia Marcinkova Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 38. Ghislaine Maxwell Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Case Document 197-1 Entered on FLSD Docket 07/02/2010 Page 7 of 12 39. Brahakmana Mellawa Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 40. Mellawa Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 41. David Mullen Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 42. Gary Nikolitis Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant, Jeffrey Epstein's conduct and finances 43. David Norr Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 44. Bill Peadon Address unknown at this time - Telephone number unknown at this time - Knowledge of Defendant?s conduct that is the subject of this action 45. Francis Peadon Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 46. Jerome Pierre Address unknown at this time 561304?2747 Knowledge of Defendant?s conduct that is the subject of this action 47. Louella Rebuyo Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Case Document 197-1 Entered on FLSD Docket 07/02/2010 Page 8 of 12 48. Governor Bill Richardson Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant, Jeffrey Epstein's conduct and ?nances 49. Haley Robson Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 50. Alfredo Rodriguez Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 51. David Rogers Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 52. Adriana Ross Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 53. Howard Rubenstein Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 54. Florena Rueda Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 55. Joseph Rueda Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action 56. Joanna Sjoberg Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Case Document 197?1 57. 58. S9. 60. 61. 62. 63. 64. 65. Entered on FLSD Docket 07/02/2010 Page 9 of 12 Santa Fe County Sheriff Solano Address unknown at this time Telephone number unknown at this time Knowledge conceming Defendant, Jeffrey Epstein's conduct and ?nances Alan Stopeck Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Mark Tafoya Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Brent Tindali Address unknown at this time 917-601-4143 Knowledge of Defendant?s conduct that is the subject of this action Larry Visosky Address unknown at this time Telephone number unknown at this time Knowledge of Defendant?s conduct that is the subject of this action Lelie Wexner Address unknown at this time Telephone number unknown at this time Knowledge concerning Defendant, Jeffrey Epstein's conduct and finances All girls identified in the attachment to the nomprosmution agreement that Defendant, Jeffrey Epstein, has entered with the United States and all other similariy~situated girls, whose identities Plaintiff will attempt to determine (and with regard to whom Defendant, Jeffrey Epstein, has invoked the Fifth Amendment rather than disclose their identities). All other themminor girls (those not listed in the attachment to the non- prosecution agreement), whose identities Plaintiff will attempt to determine, with whom Defendant, Jeffrey Epstein, has engaged in sexual activity. FBI agents, whose names, addresses and telephone numbers are unknown at this time, that investigated the criminal case(s) and the allegations made against Defendant, Jeffrey Epstein. Case Document 197??1 Entered on FLSD Docket 07/02/2010 Page 10 of 12 66. Palm Beach Police of?cers, whose names, addresses and telephone numbers are unknown at this time that investigated Defendant, Jeffrey Epstein, for criminal conduct. 67. State Prosecutors, whose names, addresses and telephone numbers are unknown at this time, including but not limited to: ASA Lanna Leigh Belohlavek State Attorney's Of?ce 15th Judicial Circuit (13) ASA Weiss State Attorney's Office 15th Judicial Circuit 68. United States' Prosecutors, whose names, addresses and telephone numbers are unknown at this time, including but not limited to: AUSA Ann Marie C. Villafa?a. United States Attorney's Office 500 South Australian Avenue West Paim Beach, Florida 33401 561-820?87l 69. All accountants, bookkeepers, bankers, ?nancial institutions, representatives, real estate advisors, financial planners, employees, governmental persons or entities, and unknown others that may have discoverable information related to Defendant, Jeffrey Epstein?s net worth and finances. 70. Any and all persons and/or entities identi?ed through discovery having any knowledge of Defendant, Jeffrey Epstein's charitable, political or other donations made in the past. 71. Any and all persons and/or entities identified through discovery that were sued in the past by the Defendant, Jeffrey Epstein, andfor by any company or entity that the Defendant, Jeffrey Epstein, owned and/or managed 72. Reporters and other media persons, whose names, addresses and telephone numbers are unknown at this time. 73 All other witnesses learned through discovery process. B. Exhibits: 1. Palm Beach Police Department report and documents contained within Defendant, Jeffrey Epstein's, criminal files Case Document 197?1 Entered on FLSD Docket 07/02/2010 Page 11 of 12 2. All documents and pleadings from all criminal and civil cases filed on behalf of Jeffrey Epstein or his corporations and against Jeffery Epstein or his corporations C. Computation of damages: 1. Physical, and injuries and resulting medical expenses precise amount yet to be computed, but not less than $15,000.00. 2. Past, present and future pain and suffering, mental anguish, humiliation, embarrassment, loss of self?esteem, loss of dignity and invasion of privacy - precise amount yet to be computed, but not less than $10,000,00000. 3. Past and future lost wages and past and future loss of earning capacity and actual earnings precise amounts yet to be computed, but not less than $1,000,000.00. 4. Punitive Damages to be based upon all relevant factors, including the egregious and criminal nature of Defendant, Jeffrey Epstein?s conduct and the need for a large award to punish and deter conduct in View of the vast wealth of Defendant, Jeffrey Epstein, in an amount not less than $20,000,00000 WE HEREBY CERTIFY that a true and correct copy of the above and foregoing Disclosure Pursuant to Fed.R.Civ.P. has been provided by United States mail and facsimile transmission to all counsel of record identi?ed below this l_9_tl_1 day of November, 2008, and that no copy has been filed with the Court. Robert D. Critton, Esquire Michael J. Pike, Esquire Barman, Critton, Luttier Coleman, LLP 515 North Flagler Drive Suite 400 West Palm Beach, Florida 33401 Jack Alan Goldberger, Esquire Atterbuz?ty, Goldberger Weiss, PA. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 jagesu?bellsouthnet Case Document 197?1 Entered on FLSD Docket 07/02/2010 Page 12 of 12 Michael R. Tein, Esquire Lewis Tein, PL. 3059 Grand Avenue Suite 340 Coconut Grove, Florida 33133 tein?lewistein.com Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS ASSOCIATES, LLC By: Brad Edwards, Esquire Attorney for Plaintiff Florida Bar No. 542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414w8033 Facsimile: 954324-1530 E?Mail: be@bradedwardslaw.com Paul G. Cassell Attorney for Plaintiff Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801685?5202 Facsimile: 801685-6833 E?Mail: cassello?law.utah.edu DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISP TED FA TS Epstein v. Edwards, 92? al. Case No. 50 2009 CA 040800WMBAG EXHIBIT DD wEEKva BACHELOEE ALI TALKS TO Us SCOTT ACTS 0U Kourtney': - Hun! Humiliatio . 1'un 2f '4 15. PAGE BONU HOLLYWOO th'Ir plans to say do' MOMS 34190 6 72440 nu A I A 3 your daughter says do? is enoughto make any mom ely and Hillary Clinton was no exception. While her daughter?s groom, Mare Mezvinsky, spoke to 500 guests about Chelsea Clinton, 30, during the pair?s Rhinebeck, New York, wed- ding reception July 31, the usually reserved secretary of state struggled to hold back tears. ?When Marc gave his toast, he said he was ?blessed' to have Chelsea,? 3. source Us. saw Hillary trying to secretly dab her eyes to make sure she didn?t look like she was crying.? Getting to that joyous mo? ment was no easy feat. For months, the couple he?s a banker at G3 Capital, she justreceived her second mas- ter?s degree, from Columbia University painstakingly planned theirtop?secret nup? tials with wedding designer Bryan Rafanelli. The result: a chic, flower-?lled affair at the famed Astor Courts mansion in Rhinebeck (recent sale listing: $12 mil? lionl), with green lovelight hydrangea, parrot tulips 7 After months of top-secret planning, America?s former first daughter marries her longtime beau 3v LAUREN SCHUTTE Barack Obama and Oprah close to the groom, 32, tells I .4 .Sll and Iavenderroses sprinkled . throughout. And despite worldwide interest and I the bride?s high-pro?le folks the event felt warm? and intimate. ?Chelsea made a simple rule regarding guests: - If she or Marc didn?t know the person or hadn?t at least met them, they could not be invited,? the sonrce tells Us. 'Sure enough, despite speculation that President Winfrey would be present, very fewVIPs attended. The ?They make a phenomenal .. The father of the bride ?was nodding his head at guests, but you could tell he was nervous," says a source. .3 .. . . From the bling to bouquets, each part was prepped to perfectionThe. Venue Five hundred guests convened on the Stanford White?designed, century-old Astor Courts mansion in Rhinebeck for the wedding day. a Awaiting out-of?towners? Farmers' market bags - - full of goodies including Cheree Berry stationery and Tribute wine from Clinton Vineyards. The Flowers The bride carried a ?simple ball of gar- denias," florist Jeff Leatham tells Us. The men wore freesia boutonnieres, while 1, Chelsea's flower girls held lily of the valley. f, The Ring Jewelry and style expert Michael O'Connor estimates Chelsea's platinum?set, 3?carat 3 - square?cut center dia- mond sparkler (similar i ,3 to above) is worth ap- proximately $75,000. . . he Ala-1 22' can '63 Chelsea's bridesmaids brought their own Eton canon Ltr' nun-am: ?scum- polish, OPI shade Pri? 5 vacy Please I: J- 9 i I opi.com), for their. IL If, I preceremony manl? 1 I I. i, I cures-and pedicures Rhmebeck Haven i . Spa, a source says. I I USMAGAZINE-COM [67 DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein 12. Edwards, er Case No. 50 2009 CA EXHIBIT "Viilafana. Ann Marie To "Jay Lefkowitz" 1010?12007 04:24 PM Subject Proposed Letter to Special Master a? . a m?ii- m. Hi Jay To move things along, I also have enclosed the proposed text of a leiter to ?le Special Master. Lem to Special A. Marie Wllafa?a Assistant US. Attorney 561 209*1047 Fax 561 8208777 ?ta Attachment Letter to Special Master.gdf? has been agchived by user an ?1210412007 00:50:12. PROEOSED LETTER TO THE SPECIAL MASTER Re: {Special Master: Prim'leged and Confiden?al Dear Sir: The undersigned, as counsel for the United States of America and Jeffrey Epstein, jointly write to you to provide information relevant to your service as a Special Master in the selection of an attorney to represent several young women Who may have civil datnages claims against Mr. Epstein; The US. Attorney?s Of?ce and the Federal Bureau oflnvestigation (jointly referred to as the ?United States?) have conducted an investigation of Jef?ey Epetein regarding his solicitatioe~ of minor females in Palm Beach County to engage in prostimtion. Mr. Epstein, through his assistants, would recruit underage females to Havel to his home in Palm Beach to engage in lewd conduct in exchange for money. Based upon the investigation, the United States has identi?ed 40 young women who can be characterized as victims pursuant to 18 U.S.C. 2255. Some of those Werner: went to Mr. Epsteia?s home only once, some went there as touch as 100 times or more. Some of the women?s conduct was liirtited to performing a topless or nude massage while Mr. Epstein masturbated himself. For other women, the conduct escalated to full sexual intercourse. As part of the resolution of the case, Mr. Epstein agreed that he would not contest jurisdiction in the Southern District of Florida for any victim who chose to see him for damages pmsuant to 18 US .0. 2255 . Mr. Epstein agreed to provide an attorney for victims who elected to proceed exclusively pursuant to that section, and agreed to waive any challenge to liability under that section up to an mount agreed to by the parties. The parties have agreed to submit the selection of an attorney to a Special Master. Attached hereto is a list of ?ve attorneys whom the parties have agreed should be considered by the Special Master for selection. Also attached hereto is a memorandum explaining the anticipated duties and responsibilities of the attorney who is selected, and that portion of the agreement between the United States and Mr. Epstein addressing the attorney?s role. Each attorney has provided. Some background information regarding his or he; practice, experience, and otlie:~ relevant factors. The Special Master may contact any or all of those attorneys for additional information, as the Special Master deems appropriate. Each party will also provide the Special Master with a list of the criteria that the party believes should be considered in making the selection. If the Special Master has any questions regarding the criteria, he may contact the relevant party to inquire further, as he deems appropriate. The parties ask that the special Master ?rank? the top three attorneys, in case one or more has a con?ict that presents him or her ?om accepting the representation. The parties thank you for your willingness to conduct this task as a pro bone pubh?cc matter. Please do not hesitate to contact us if you need any ?arther information. DEFENDANT BRADLEY J. EDWARDS STATEMENT OF UNDISP UTED FACTS Epstein v. Edwards, et al. Case No. 50 2009 CA 040800WMBAG EXHIBIT CC ?36! 23/2613 11:33 581333313? FIRM Win PQGE 8233'? WWI) STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK v. ?Mummy: Jaw Dew, Plaintiff, as-cvwsimw (Squthem District anlorida) ?againmw m? JEFFREY EPSTEEN: i? f? . Defenciant. WHEREAS, plai??ff Jam Due am! defendant Jeffrey Epstnin (?Epstein?) are engaged in discavery in the above-captivated civil amen pending in the Unimd Statea Bimini Calif: for the Southern ?istrict (3f Flm-ida; WRBAS, thirteexi related civil actions are amenity wading against defendant Epstein: {milent?wly with tha abovsuaaptioned action, the ?Related Pending Actions?). The Raiamci Pending Aeticns are; idanti?ed on Sammie A. amha? harm; counsel in all Relaisd Pending Actions shall ?e ml?ec?veiy rammed to harem as C?Caunsei" mamas. Ghislaine Noam Maxwell {?Maxwall?m a nemparty, wag servant with a $pr dam} Samantha: 21, 2009 ?nned am of tha Unitezi States District Court for she Sauthem maria: York (the ??Suhpaena") to testify at a depnsiticm in wmwtian with the; above-captiamd mm: WHEREAS, Maxweil has mammal, and has agae?, mat all aspects of hm" involvemem in this matter, inciuciing ?but no: Iimiteti we the 5.33123.an of Subpuena, the fact of 931? 23! 2&18 11:33 ?561332?137 emcm LAN FIRM 5% PAGE 83.13? Wmll?s appem?auce for deposi?an, wafer ma substance at Maxwen?s testimony is to be mffarded the t?ghest degraa bf wn?dentla'iim IT IS HEREBY AND MEREED as faiittws: I. The depositien taken pumzmt tn the subpom (the ?Maxwa? Depasitian?) win he Cou?sel?s sole nppormi?ty to examine Maxwelt in connection with the Ralatad Pending Actions. Failure cf any Counsei ta participate in the Maxwell ?aposi?on shall waivc that aaunscl?s right to examine Maxwell in mn?ection ?5:11 any of the Related Pending Actions; 2. The Mat-await Heposi?on Wm be Ignited to one seven ham: day am?. will be condude at the offin of her counsel, Cohen Greater LLP, 1043 Park Avenutt, NW Yak. 3. Cantata! will not examina, or attempt to 9mm, Maxwell mgar? to has: personal sexual conduct or her gamut relatioan with defendant Jamey Epstein except to the axtent that com! 1183 a gaod faith basis t9 believa that such mnduct is directly miated ta Grimm activity an m6 partaf Jamey Epstaitt; 4. Counsel shall km}: can?demia?i and m??ain any public ditclam 9r dissemination whatsoetmr the transctiyt andfor any audit: at videotaps rewarding afthe Mammal! Datamation. To the extent attempts from or hantc?pts {3f the Maxwell Depesition am be ?led with any court in wmnactian with any as? the: Relatad Pem??g Ass-titans, Cumsti must make hast afforts to secure an order permitting ma ??ittg at? time materials under scat. Gamma! for Maxwell will be given EDti?e 0f any such filing prim to Counsel Waking such a waiting mitt from the cam All parties mkuawladge that she-111:3 any at? the Related Pendirtg Actiens against Jeffrey Epstein proceedm trtal, depesition vicieo andfor tramcript wilt likely be pubiished to t1:th it: whole part; mt}:ng in this amment that! pmhibit such urdinmy 233? 2613 11:83 863.832?i?3? mam Lab! Pile FQGEI 9141' 87? trial usaga ofMaxwell?s depasitim :30: plaza any additional a:an on any party related to the usage 0f Maxwell?a depasi?on in the trial. 5. (tonnes! shall lamp con?dential and m?ain my public cement at disclusma whamver (lmluding but not limitai to disclosure a: t0 the pass main! ma?a): the fact that Maxwell has been subpomci fur depasitlnn in camwticn with ma Rclated Fading Antlons; (ii) 1:119 East that Mmcwall has appeared far depositlan in the Related Pending Actions; any an:wa whatsaevar of tha Maxwell Deposition; or (iv) any facts at upiniom whats-waver referring to at ramming Maxwell in emanation: with the Relawtl Pending Minions. This pmvisian shall be: constmed as broadly 93 possible ta expressly prohibit my public comment at disclosum (imluding but not [in-med to the 53mg andfor media) by "Flaiuti?ls? Gama} with regarcl t0 Maxwell. or her invalvament inthis matter. 6. Upon the conclusim 01" ml: (31? the Related Pending An?cns, all amalgam audior any audio or videatape rammings oft!? Maxwall Deposition maintained in mammalian with the mmaluded Related ?nding Man, Shall be ?swayed wl??n thirty (30) days. Certi?cation of shall be pI?Wide? t0 Maxwell's mm! within thirty (.30) daya such dastms?cn. Flainti?a? Cami hamby that my vinlatiau of the: Tamas and Conditlans in Paragraphs 4 and 5 abow {the ?Can?demlality Elmvisions"), will maul? ?11 irreparabla ham. to Maxwell. in ?lm amt of wall violations Counsel agrees: a. ?lm such a violation caustimtes sane?cnable can?um pursuant tea the law, Fatima! Rules of Civil Pmdme, and mutt rules (3f the United States Ekim?ict ?20m of?w Southem mantis: afNew Yvrk; 6&32322318 11:33 5518327137 QQRCIQ LAW FIRM Pa B5IB7 To immadiately all efforts to prevent 11m flatlch public dissemination 0f disclosums ma?a in vialation 9f the Con?dentiality l?mvlsiaas; That Maxwell newsman shall be: rende mill and void, and 031mm be useti in any way in cumml on will: the ?nding Related Actions 0: my other li?ga?an; That Maxwell may seek injunctive reliaf a Tgmporary Ramalning Grdar), to prevent the use: or ?i?har dissam?uaz?ion cf the Maxwell Deposition, and that Maxwell will not be mquixed. to p-DS?t a band in cameetion with obtaining such mlief; and T0 pay a ?gment-3d damages to Maxmll 11530:: Maxwell?s pmvailing in whale: or in. part in any action alleging a breach of this agreement aqua} to Maxwall?s total legal fees and Wm related to the Subpoena andfor Wall?s in the Related l?erzding Ac?cns. 8. The Unitad States {ileum {3mm of?m Southern malarial of Naw shall have mcluslve ju?sdi?icn all claims or ampules arising out of ear related to this agreement. This agxaemem shall ha Interpreted in accordance with New Yark law, without mgard to shame of law principlas. 9. Nuthing in this shall aawa l0 waive any substantive right provided by applicable law andfor the Farleral Rubs cf Civil Pmcaduxc, and all signatories harem reams all substantive rights with ?mgar? to the Daposi?an, The panics hereto reserve the right lo seek Cam. immtlan in aid of such Magmath rights. ll??3 551832713? CGHEN Brett D. 106 ?venua, 23rd Floor New ork,NY mm? (212) A?crneym?br Ghz?sia??na Noefie Mmeli Danni: L?w PIER Pa 36(8? FWER, JAFFB. MISSING, EDWARDS, HSTOS LEW. PL Brasilia? 1. Edwards 425 N. Andrews Sum 2 Fort Landemdale, 53L 333m (954} 52?2820 Plainn?Jane Doe my: Emmi: West Palm Emu, FL 3348: ssz-mz . Dated: CQLEMAN, LL19. . x? . Wuhan! 693 Pike 303 Ban. Boulevard, Suite 406 West. mash, Fla?da 33491 .?rwm?ysfar $123? Dated: @64?23a?261? 11:63 561332713? GNQCIQ LAN FERN PA