ATTERBURY GOLDBERGER AIG
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250 Australian Avenue South, One Clearlake C9Itre
Suite 1400, West Palm Beach, FL 33401

17.1 -

5645974

Lanna Belohlavek, Esquire
State Attorney's Office
401 North Dixie Highway
West Palm Beach, Florida 33401

3340i+4209-01 CO2i

07/26/17

Page 1 of 131

Public Records Request No.: 17-295

 ATTERBURY GOLDBERGER
RICHARDSON & WEISS, P.A.

RIW

JOSEPH R. ATTERBURY'
JACK A. GOLDRERGER't

SCOTT N. RICHARDSON'
JASON S. WEISS
BOARD CERTIFIED CRIMINAL TRIAL ATTORNEY
T MEMBER OF NEW JERSEY & FLORIDA BARS

June 22, 2006
Barry Krischer
Florida State Attorney's Office
401 North Dixie Highway
West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Mr. Krischer:
I write to you to confirm our meeting with'Lanna on June 14, 2006. It is our hope
that in light of the recent developments in this case which we have set forth in our letter
of June 5, 2006, our meetings, and herein, in particulaf the fact that there is no sex
alleged, this case can be disposed of with, at most, an informal agreement, or more
appropriately, no charges being filed at all.
As you know, it was only at the June 1, 2006 meeting, after eight months of
investigation, that you and I both learned, for the very first time, and I believe to our
collective disbelief, that the allegation of the girl did not raise the slightest hint of actual
sex. Up until that point, we had all been laboring under the assumption this girl had
alleged multiple sexual encounters with my client. In fact, as you are aware, it was with
this in mind that we hired George Slattery, a highly respected polygraph expert, who
unequivocally confirmed our client's long held position both that there was no sex and
that the girl clearly stated she was 18 years old. Since, we now know with certainty that
there are in fact no allegations of sex, and no sex occurred between my client and this
girl, I would ask you to consider your previous statements to the effect that you would not
bring a "touching case" — NO sex, NO charge — in fashioning an appropriate resolution to
this matter.
As we have discussed many times, the girl's credibility is highly questionable and
has been severely undermined by her actions over the past few months in: (1) repeatedly
changing her age on her web page (first 17, then 16, then 15) and posting graphic nude
and suggestive photographs of herself; (2) boasting about shoplifting, underage drinking,

250 Australian Avenue South, One Cleartake Centre, Suite 1400, West Palm Beach, FL 33401
07/26/17

Telephone: 561.659.8300
561.835.8691
Page •2 Facsimile:
of 131

Public Records Request No.: 17-295

 smoking, and having sex; (3) being observed by the police as clearly on drugs; and, (5)
running away to an unsafe drug location. With this background, it has certainly taken a
while to sort things out, but, the agreed to facts of this case are that: (1) this girl, was
driven to my clients' home with the express and sole purpose of providing a topless
massage; (2) she told my client she was 18 years old; (3) she received her agreed upon
two hundred dollars; (4) before leaving she wrote down her phone number and stated next
time she wanted to bring her twin sister along; (5) my client never saw her again; and,
most importantly (6) no sex occurred. It was only several MONTHS later, that we are led
to believe, one of her parents, both of whom have criminal records for fraud, contacted
the police.
Finally, as you consider your options, I quite frankly think it unfair to give much
weight to the pressure being brought to bear by law enforcement. Their comments which
have been brought to my attention certainly indicate, at a minimum, a lack of objectivity.
With all this in mind, I believe that it is only just, especially now that we are both certain
there was no sex involved, that your office opt NOT to prosecute this case. However,
given the totality of the circumstances, coupled with the fact that a "Google search" is
now a "forever" reference on any job application, I believe that the girls involved, my
client, and all concerned would be better served with at worst an informal resolution of
this matter. Certainly it seems preferable to filing a charge that we all currently concede
would likely not succeed if brought to trial. I appreciate the personal attention you have
given to this matter, and look forward to you response.

Very ty y yours,

A. GOLDBERGER

cc: Lanna Belohlavek, Esquire

07/26/17

Page 3 of 131

Public Records Request No.: 17-295

 A
RICHARDSON & WEISS, P.A. R
ATTERBURY GOLDBERGER

MP 80.390 $0.390 80.560
m" 0.390 ArmErea

250 Australian Avenue South, One Clearlake Centre
Suite 1400, West Palm Beach, FL 33401

JUN 22 06

'06 ju

Lanna Belohlavek, Esquire
Office of the State Attorney
401 North Dixie Highway
West Palm Beach, FL 33401

3340i-1.4209 —u1 CO21

07/26/17

N23F,N12:08

11111 111111IIIIIIIi11111111111111i,Ii1,n11111II

Page 4 of 131

3843979

II II

II I I

Public Records Request No.: 17-295

 ATTERBURY GOLDBERGER
RICHARDSON & WEISS, P.A.

AG
RW

JOSEPH R. ATrERBURY•
JACK A. GOLDBERGER •I'
SCOTT N. RICHARDSON
JASON S. WEISS
/77.—
V
C-- • BOARD
, CERTIFIED CRIMINAL TRIAL ATTORNEY
ze
I MEMBER OF NEW JERSEY & FLORIDA BARS

June 22, 2006
Barry Krischer
Florida State Attorney's Office
401 North Dixie Highway
West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Mr. Krischer:
I write to you to confirm our meeting with Lanna on June 14, 2006. It is our hope
that in light of the recent developments in this case which we have set forth in our letter
of June 5, 2006, our meetings, and herein, in particular the fact that there is no sex
alleged, this case can be disposed of with, at most, an informal agreement, or more
appropriately, no charges being filed at all.
As you know, it was only at the June 1, 2006 meeting, after eight months of
investigation, that you and I both learned, for the very first time, and I believe to our
collective disbelief, that the allegation of the girl did not raise the slightest hint of actual
sex. Up until that point, we had all been laboring under the assumption this girl had
alleged multiple sexual encounters with my client. In fact, as you are aware, it was with
this in mind that we hired George Slattery, a highly respected polygraph expert, who
unequivocally confirmed our client's long held position both that there was no sex and
that the girl clearly stated she was 18 years old. Since, we now know with certainty that
there are in fact no allegations of sex, and no sex occurred between my client and this
girl, I would ask you to consider your previous statements to the effect that you would not
bring a "touching case" — NO sex, NO charge — in fashioning an appropriate resolution to
this matter.
As we have discussed many times, the girl's credibility is highly questionable and
has been severely undermined by her actions over the past few months in: (1) repeatedly
changing her age on her web page (first 17, then 16, then 15) and posting graphic nude
and suggestive photographs of herself; (2) boasting about shoplifting, underage drinking,

07/26/17

250 Australian Avenue South, One Clearlake Centre, Suite 1400, West Palm Beach, FL 33401
Telephone: 561.659.8300
561.835.8691
Page• 5Facsimile:
of 131
Public Records Request No.: 17-295

 smoking, and having sex; (3) being observed by the police as clearly on drugs; and, (5)
running away to an unsafe drug location. With this background, it has certainly taken a
while to sort things out, but, the agreed to facts of this case are that: (1) this girl, was
driven to my clients' home with the express and sole purpose of providing a topless
massage; (2) she told my client she was 18 years old; (3) she received her agreed upon
two hundred dollars; (4) before leaving she wrote down her phone number and stated next
time she wanted to bring her twin sister along; (5) my client never saw her again; and,
most importantly (6) no sex occurred. It was only several MONTHS later, that we are led
to believe, one of her parents, both of whom have criminal records for fraud, contacted
the police.
Finally, as you consider your options, I quite frankly think it unfair to give much
weight to the pressure being brought to bear by law enforcement. Their comments which
have been brought to my attention certainly indicate, at a minimum, a lack of objectivity.
With all this in mind,.I believe that it is only just, especially now that we are both certain
there was no sex involved, that your office opt NOT to prosecute this case. However,
given the totality of the circumstances, coupled with the fact that a "Google search" is
now a "forever" reference on any job application, I believe that the girls involved, my
client, and all concerned would be better served with at worst an informal resolution of
this matter. Certainly it seems preferable to filing a charge that we all currently concede
would likely not succeed if brought to trial. I appreciate the personal attention you have
given to this matter, and look forward to you response.

Very

yours,

A. GOLDBERGER

cc: Lanna Belohlavek, Esquire

07/26/17

Page 6 of 131

Public Records Request No.: 17-295

 KEST Pfli It REACH
tattir"'
FL 33401
1111 $0.39(
71
-0:iiricTi90

ATTERBURY GOLDBERGER A G
RICHARDSON & WEISS, P.A. R W 0
„2.50 Australian Avenue South, One Clearlake Centre
ite 1400, West Palm Beach, FL 33401

$0. 390 AI METER
JUN 22 ON

co
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38/ 3379 1

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0

Barry Krischer, Esquire
Office of the State Attorney
401 North Dixie Highway
West Palm Beach, FL 33401

33401+420S —0i CO21

07/26/17

11111111I111111111 I 11111111111 I I I I II I I I 1111111111111111 1111

Page 7 of 131

Public Records Request No.: 17-295

 ATTERBURY GOLDBERGER
RICHARDSON & WEISS, P.A.
250 Australian Avenue South
One Clearlake Centre, Suite #1400
West Palm Beach, FL 33401
Phone: (561) 659-8300
Fax: (561) 835-8691

FAX TRANSMITTAL COVER SHEET
DATE:

June 16, 2006

TO:

Lanna Belohlavek, Esquire

FAX:

355-7302

FROM:

Jessica Cadwell, Assistant to Jack A. Goldberger, Esq.

RE:

Epstein

REMARKS:
TOTAL PAGES: 8, including cover sheet

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recipient or the employee or agent responsible for delivering the message to the intended recipient, you are hereby
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received this communication in error, please notify us immediately by telephone, and return the original message
to us at the above address via the U.S. Postal Mail Service. Thank you for your cooperation.

07/26/17
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2920
ad 9002-91-NAI
Public Wd
Records
Request
No.: 17-295

 LAW OrricE9 OF

Gm:RALD B. LEFGOUHT, P.C.
A PROFESSIONAL CORPORATION
1 48 EAST 78" STREET
NEW YORIT.,

rraw yowl looei
TELEPHONE

GERALD B. LEFCOURT

121 21 737-0400

letourtantcourtlaw.com

FACSIMILE
(212) 9133-6I92
SHERYL E. REICH
ralLthelecourIlwAcum
RE NATO C. STABILE
etablle0101courtlew
FAITH A. FRIEDMAN
IfriecIrnerelelmutUaw.00nh

June 5, 2006

B Y HAND
Lanna Belohlavek
Florida State Attorney's Office
401 North Dixie Highway
West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Ms. Belohlavek:
As a follow up to our meeting of June 1, 2006, held in an attempt to resolve this matter,
we write to address the following issues which have arisen: (1) the risk, were the client to plead
to aggravated assault in Florida, that he might be subject to sex-offender registration statutes in
other jurisdictions, now or in the future; (2) the nature of the charge of felony "aggravated
assault with intent to commit a felony," and how it does not reflect the allegations herein; and, (3)
whether a felony conviction itself is justified based on the available evidence.
At the outset of our June 1, 2006 meeting, we were mindful that an understanding had
been reached with prior counsel. It was reached, however, with the clear and joint understanding
that the client would not be subjected to sex offender registration requirements in any state or
foreign jurisdiction. Moreover, the limited time provided did not allow for an opportunity to
conduct an even cursory investigation or research into the ramifications. Were any charge to be
brought, having now learned of the serious danger a plea to felony aggravated assault presents
with regard to sex offender registration, coupled with the facts presented at our meeting and
outlined below, we strongly believe that a plea to misdemeanor solicitation is the more
appropriate resolution. As -we discussed, this could include an agreed upon allocution, as we are
mindful of your concern about labeling the girls "prostitutes." In this regard, as we discussed, the
law and relevant statute are clear that the complaining witness need not be a "prostitute" in order
to satisfy the elements of the offense.

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Wd E920
INANo.:
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 LAW OFFICOS OF

GERALD B. 1.arsootristr, P.C.

Ms. Lanna Belohlavek
June 5, 2006
Page 2
I.

An Aggravated Assault Conviction Might Subject the Client to Sex Registration

There is a likely risk that a plea to aggravated assault, F.S.A. § 784.021(1)(b), will expose
the client to registration obligations under the Megan's Law statutes, either as currently written,
or as likely to be amended or expanded in the future, in a number of jurisdictions, including, but
not limited to, ones where he lives, works, or spends time. This is true regardless of whether the
plea expressly specifies that the felony he had the intent to commit was lewd and lascivious
behavior under F.S.A. § 800.04 or sexual battery under F.S.A. § 794.011.
As my client is a full time resident of the Virgin Islands, the most immediate and obvious
unintended result of a plea to felony aggravated assault is the possible registration in his place of
residency. The Virgin Islands statute, 14 V.I.C. § 1722 et seq., is very broad, imposing a duty to
register upon a "person convicted ... on or after July 1, 1994 of a criminal offense against a
minor". 14 V.I.C. § 1722(a) (emphasis added). Under § 1722 (c), "a person convicted ... in a
federal, military or foreign court shall have the same duty to register as any other person under
this statute," Failure to register is a crime. 14 V.I.C. § 1722(d). Further, while the Virgin Islands
registry is currently accessible only to law enforcement, there are ongoing discussions about
opening it to the public. See, Virgin Islands Daily News, May 15, 2006, at
http://www.virginislandsdaily news.com/index.plfarticle_home7id-17296624, I
Tinder current law, a plea to aggravated assault will also likely subject the client to
registration in his secondary domicile of New York. The list of registrable offenses in New York
under the Sex Offender Registration Act (SORA) is a long one, which continues to grow. In
1999, eight new offenses were added to the list of registrable offenses, and again on March 11,
2002, seven new offenses were added.

A non-exhaustive search has identified two other jurisdictions in which the client would appear to be
subject to registration requirements simply on the basis of a plea, in Florida, to aggravated assault - Oklahoma and
Montana.
Oklahoma requires the registration of persons convicted of assault with intent to commit a felony, in
violation of 21 Old. St. Ann. § 681 "if the offense involved sexual assault" See, 57 Old. St. Ann. § 582 (A).
Oklahoma law requires the registration, too, of persons convicted of an offense outside the jurisdiction which, if
committed in the state, would constitute a 'registrable offense. 57 Oki. St. Ann. § 582(B).
Likewise, Montana requires registration of both sexual offenders and violent offenders. 'Violent offenders"
include persons convicted of any violent offense, which is expressly defined to include "aggravated assault" under
MCA 45-05-202, or "any violation of a law of another state reasonably equivalent" to that crime. MCA 46-23502(9).

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 LAW

omicen OF

GE:mm.3D B. LEroomi-r, P.C.

Ms. Lanna Belohlavek
June 5, 2006
Page 3
In New York, a person must register as a sex offender if they are required to register in the
jurisdiction of conviction or, if convicted in a foreign jurisdiction, his conviction there meets "all
the essential elements" of New York's enumerated sexual offenses. See, N.Y. Corr. Law §§ 1681(2)(a)(1), (d), (3). In spite of the statutory reference to "essential elements," some New York
courts have looked at the facts underlying the offense of conviction, rather than the formal
elements of the offense, in determining whether registration is required. Each finding that a
defendant was required to register on the basis of the underlying conduct even though the
essential elements test was not satisfied. See, People v. Burden, 6 Misc.3d 1033(aXSup. Ct.
Bronx Cty. 2005); People v. Milian, 189 Misc.2d 419, 730 N.Y.S.2d 392 (Sup. Ct. N.Y. Cty.
2001).
The same serious concern arises in other states, including California and Colorado, which
authorize courts to look behind the plea, and beyond the formal elements of the offense of
conviction, and enable them on a case by case basis to determine if registration is required.
Like New York, California requires an individual to register if they are required to register
in the state of conviction, or pursuant to CA Penal Code § 290(a)(2)(D)(1) if that individual ". . .
since July 1, 1944, has been, or is hereafter convicted in any other court, including any state,
federal, or military court, of any offense that, if committed or attempted in this state, would have
been punishable as one or more of the offenses described in subparagraph (A)". The wording of
the statute leaves open the possibility that, in determining whether the offense would have been
punishable as one or more of the registrable offenses, one looks at the underlying facts, and not at
the formal elements of the crime to which the defendant pled. The registrable California offenses
include commission of "any lewd or lascivious act upon or with the body of child" where the
child is "14 or 15 years" of age and "that person is at least 10 years older than the child" "with
the intent of arousing, appealing to, or gratifying the lust, passions, or sexual desires of that
person or the child". CA Penal Code § 288(a), (c) (I). Thus, an aggravated assault plea may
subject the client to a registration requirement in the State of California.
Colorado likewise has a very broad statute. It requires an individual to register within
five business days of becoming a temporary or permanent resident of the state, if, among other
things, the person has been convicted in Colorado or any other state of an offense involving
sexual behavior (or an attempt, solicitation or conspiracy to commit such an offense), or if they
are required to register in another state or jurisdiction for a sex offense. C.R.S.A. §§ 16-22-103,
16-22-108.
With regard to Florida, as you know, it is reasonably clear that under Florida's current
version of Megan's Law, a plea to aggravated assault would not subject the client to registration
in Florida since it is not included among the state's enumerated "sexual offender" offenses. 5eq

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 a
a

LAW OPPICSEI OP

4

&mama) B Luaccruarr,

Ms. Lanna Belohlavek
June 5, 2006
Page 4
F.S.A. §§ 943.0435, 784.021. However, the offense of sexual battery is on the list, as well as the
charge of lewd and lascivious behavior, so there is no assurance that, in the future, a Florida
prosecutor or court will not take the position that, where the aggravated assault is combined with
what some states have labeled a "sexually motivated intent" registration is required.
Moreover, as you indicated at our meeting, there is no guarantee that the Florida
legislature will not expand the category of persons subject to Megan's law, and expressly make
persons convicted of aggravated assault subject to the law, especially where the felony the actor
had the intent to commit is a sexual offense, and the victim is a minor. The trend today is
towards expansion, not contraction, of these kinds of statutes, arid as you noted, Florida will be
no exception. See,
"Sex Offenders; No More Escaping Registration," 36 McGeorge L. Rev
822 2005 (Over the last twenty years expanded registration requirements, enhanced penalties for
failure to register, and public notification provisions have enlarged the scope of sex offender
registration laws); see news articles of just this past week infra describing many of the
proscriptions being adopted around the nation. And, the ex post facto clause stands as no
significant bar. See Smith y. Doe, 538 U.S. 84 (2003) (upholding Alaska Sex Offender
Registration Act against a challenge that its application to persons whose offenses were
committed prior to its enactment would violate the ex post facto clause). If this trend continues,
as it likely will, the client will almost certainly be subject to sex offender registration.
Even if the client is not and will never be subject to registration requirements under
Florida's laws, a plea to aggravated assault under the circumstances of this case could subject
him to Megan's Law requirements in other jurisdictions. Thus, if the client pleads guilty to the
proposed aggravated assault charge, there is a grave risk that under existing state and Virgin
Islands law quite apart from future expansion or expansive construction of those laws - ho will
be subject to sex offender registration requirements and/or criminal exposure for failure to
register. There is an even graver risk still that there will be future expansion of the statutes or
expansive construction of them that will mean he is covered or arguably so. See, e.g„, Cherry
Hill Sex Offender Ordinance Upheld, Courier Post, June 1, 2006, at
http://www.courierpostonline.com/apps/pbes.d1Warticle/AID-420060601/NEWS01/606010389/1
006;2 More States Move to Use GPS Tracking of Sex Offenders, Fox News, May 31, 2006, at
http://www.foxnews.com/story/0,2933,196455,00.html; Sex Offenders Sue City Over Park, Pools
2

This article discusses a decision handed down by a municipal court judge in New Jersey during the course
of our meeting_ That decision upheld a zoning restriction on sex offenders living within 2500 feet of schools, parks,
playgrounds, public libraries, or day care centers. While other jurisdictions' zoning laws currently restrict such
individuals from living within 1000 feet of these institutions, were they to follow the lead of Cherry Hill, New Jersey,
the client would most certainly be faced with the added burdens of selling his residences and moving in order to be in
compliance with the law.

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Wd VS20
IH No.:
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Y
Y

 LAW OFFICE'S OF

C.YraArJ) B. LasnrouRT, P.C.

Ms. Lanna Belohlavek
June 5, 2006
Page 5
and Playgrounds Ban, Fox News, May 31, 2006, at
hup://www.foxnews.com/story/0,2933,197701,00.html.
Indeed, as you recognized during our meeting, many people who were advised by
competent counsel to plead guilty to offenses when registration was not required have now been
horrified to find themselves subjected to registration laws enacted or expanded after their guilty
pleas, without any recourse. See, Smith v. Doe, supra, 538 U.S. 84. Finally, although there is
some risk that even a plea to a misdemeanor charge could trigger registration in some
jurisdictions, our research suggests that this risk is considerably lower for a misdemeanor plea
than for a felony plea.
H.

Aggravated Assault is Generally Considered A Violent Felony And Does Not Apply to
the Facts of This Case

Assault is generally considered an act of force. It "create[s] in the victims a well founded
fear of imminent violence." Velasouez v. State, 654 So. 2d 1227, 1228 (Fla.2d DCA 1995). The
general public is certainly not aware of Florida's unique nuanced definition. Indeed, as you will
agree, in common usage, aggravated assault, on its face sounds inherently violent. Thus, at the
very least, most people will consider an aggravated assault charge, even of the "intent to commit
a felony" variety, to be a violent crime. In this regard, undifferentiated aggravated assault is one
of only four crimes listed in the FBI's Uniform Crime Report "violent crime" category.3
More importantly, as noted, this crime clearly does not reflect what allegedly occurred
since there has been no suggestion that a threat of serous bodily harm was made or a deadly
weapon used. In addition, most pleas are "downward" — the defendant agrees to waive his right
to trial in return for the prosecution's offer of a downward departure in charging or sentencing.
Further, in the typical case a plea involves crimes that bear a close resemblance to the underlying
events. The facts herein, obviously do not support a charge of aggravated assault, thus a plea to
same would be inappropriate.

The UCR divides its statistics into three major categories: violent crimes, property crimes, and bate crimes.
"Violent crime is composed of four offenses: murder and non:negligent manslaughter, forcible rape, robbery, and
aggravated assmilt." "Violent Criue," Crime in the United States, 2004, at
hthniliwww,112.1a0vAter/cins 04/offeAses_reamtediviolent crinte/badex.lnua.

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Wd 17920 I&1 9002-91-N0f

 LAW OFFMCS b;

GERALD B. LEFOOURT, P.C.

Ms. Lanna Belohlavek
June 5, 2006
Page 6
III. Since the Meeting on February 16, 2006 When Misdemeanor Charges Were Initially
discussed, the State's Case has Gotten Considerably Weaker
At the February 16, 2006 meeting, you suggested the Office was investigating a felony
and you indicated you would consider pleading it down to a misdemeanor. As you are aware,
since then much has happened which makes the alleged case considerably weaker and
undermines the credibility of the witnesses upon which it was based. Indeed as you already
know the following information has come to light severely damaging the reliability of the
witnesses: (i).
background, including a history of theft, confessions and repeated
denials of stealing from employers and customers, lying about her age, sexual promiscuity, and
prostitution; (ii r
" boastful admission of drug use, underage drinking, sexual
activity, shoplifting, wild exaggeration of her income (at least $250,000), representing herself
naked on a website and as 17 years old, then 16, then 15, only changing it to her truthful age,
coincidentally four days before the last scheduled grand jury. In addition, as you have
acknowledged, she was found in an inappropriate place in Georgia after the police were called
when she ran away from home. This is separate and apart from the Florida police report
presented to you, detailing her being dropped off by the local drug dealer at 5:45 a.m., only two
days after returning to West Palm Beach, and being described by the officer as clearly on drugs;
and (iii) both of
parents' criminal history of fraud.
In stark contrast to this is the fact that, as we indicated at the meeting, the client has
passed both a rigorous lie detector test, conducted by the most highly qualified expert we could
find, one whose reputation is beyond reproach, and provided you copies of two psycho-sexual
evaluations prepared by experts that you have agreed are well-recognized and accepted by the
State.

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 LAW OnwICES or

GERALD B. LmtroouRT, P.G.

Ms. Lanna Belohlavek
June 5, 2006
Page 7
il<

Conclusion

Under the circumstances of this case a plea to felony aggravated assault is both
unwarranted and presents a grave risk the client will be brandished a sex offender, bearing the
attendant burdens inherent with that classification. In light of this, and the credibility issues
presented by the complaining witnesses, combined with the client's two psycho-sexual
evaluations and lie detector tests, we believe that at the very most, a misdemeanor plea to
solicitation is appropriate.

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Wd 99021
adNo.:
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 LAW OFFICES OF

Gnau23

B. laarcouirr, P.C.

A PROFESSIONAL CORPORATION
148 EAST 78T" STREET
NEW YORK., NEW YORK 10021

TELEPHONE
(212) 737-0400
FACSIMILE
(212) 988-6192

GERALD B. LEFCOURT
lefcourt@lefcourtlaw.com

SHERYL E. REICH
reich@leicourtlaw.com
RENATO C. STABILE
stabile@lefcourtlawcom
FAITH A. FRIEDMAN
ffriedmen@letcourtlawcom

June 5, 2006

BY HAND
Lanna Belohlavek
Florida State Attorney's Office
401 North Dixie Highway
West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Ms. Belohlavek:
As a follow up to our meeting of June 1, 2006, held in an attempt to resolve this matter,
we write to address the following issues which have arisen: (1) the risk, were the client to plead
to aggravated assault in Florida, that he might be subject to sex-offender registration statutes in
other jurisdictions, now or in the future; (2) the nature of the charge of felony "aggravated
assault with intent to commit a felony," and how it does not reflect the allegations herein; and, (3)
whether a felony conviction itself is justified based on the available evidence.
At the outset of our June 1, 2006 meeting, we were mindful that an understanding had
been reached with prior counsel. It was reached, however, with the clear and joint understanding
that the client would not be subjected to sex offender registration requirements in any state or
foreign jurisdiction. Moreover, the limited time provided did not allow for an opportunity to
conduct an even cursory investigation or research into the ramifications. Were any charge to be
brought, having now learned of the serious danger a plea to felony aggravated assault presents
with regard to sex offender registration, coupled with the facts presented at our meeting and
outlined below, we strongly believe that a plea to misdemeanor solicitation is the more
appropriate resolution. As we discussed, this could include an agreed upon allocution, as we are
mindful of your concern about labeling the girls "prostitutes." In this regard, as we discussed, the
law and relevant statute are clear that the complaining witness need not be a "prostitute" in order
to satisfy the elements of the offense.

07/26/17

Page 16 of 131

Public Records Request No.: 17-295

 LAW OFFICES OF

GnizALD B.

LEYGOTTRT,

P.C.

Ms. Lanna Belohlavek
June 5, 2006
Page 2

I.

An Aggravated Assault Conviction Might Subject the Client to Sex-Registration

There is a likely risk that a plea to aggravated assault, F.S.A. § 784.021(1)(b), will expose
the client to registration obligations under the Megan's Law statutes, either as currently written,
or as likely to be amended or expanded in the future, in a number of jurisdictions, including, but
not limited to, ones where he lives, works, or spends time. This is true regardless of whether the
plea expressly specifies that the felony he had the intent to commit was lewd and lascivious
behavior under F.S.A. § 800.04 or sexual battery under F.S.A. § 794.011.
As my client is a full time resident of the Virgin Islands, the most immediate and obvious
unintended result of a plea to felony aggravated assault is the possible registration in his place of
residency. The Virgin Islands statute, 14 V.I.C. § 1722 et seq., is very broad, imposing a duty to
register upon a "person convicted ... on or after July 1, 1994 of a criminal offense against a
minor". 14 V.I.C. § 1722(a) (emphasis added). Under § 1722 (c), "a person convicted ... in a
federal, military or foreign court shall have the same duty to register as any other person under
this statute." Failure to register is a crime. 14 V.I.C. § 1722(d). Further, while the Virgin Islands
registry is currently accessible only to law enforcement, there are ongoing discussions about
opening it to the public. See, Virgin Islands Daily News, May 15, 2006, at
http://wwwvirginislandsdaily news.com/index.pl/article_home?id=17296624.1
Under current law, a plea to aggravated assault will also likely subject the client to
registration in his secondary domicile of New York. The list of registrable offenses in New York
under the Sex Offender Registration Act (SORA) is a long one, which continues to grow. In
1999, eight new offenses were added to the list of registrable offenses, and again on March 11,
2002, seven new offenses were added.

A non-exhaustive search has identified two other jurisdictions in which the client would appear to be
subject to registration requirements simply on the basis of a plea, in Florida, to aggravated assault - Oklahoma and
Montana.
Oklahoma requires the registration of persons convicted of assault with intent to commit a felony, in
violation of 21 Okl. St. Ann. § 681 "if the offense involved sexual assault." See, 57 Okl. St. Ann. § 582 (A).
Oklahoma law requires the registration, too, of persons convicted of an offense outside the jurisdiction which, if
committed in the state, would constitute a registrable offense. 57 Okl. St. Ann. § 582(B).
Likewise, Montana requires registration of both sexual offenders and violent offenders. "Violent offenders"
include persons convicted of any violent offense, which is expressly defined to include "aggravated assault" under
MCA 45-05-202, or "any violation of a law of another state ... reasonably equivalent" to that crime. MCA 46-23502(9).

07/26/17

Page 17 of 131

Public Records Request No.: 17-295

 LAW OFFICES OF

GERALD

B. LEFOOUR.T, P.C.
Ms: Lanna Belohlavek
June 5, 2006
Page 3

In New York, a person must register as a sex offender if they are required to register in the
jurisdiction of conviction or, if convicted in a foreign jurisdiction, his conviction there meets "all
the essential elements" of New York's enumerated sexual offenses. See, N.Y. Corr. Law §§ 1681(2)(a)(I), (d), (3). In spite of the statutory reference to "essential elements," some New York
courts have looked at the facts underlying the offense of conviction, rather than the formal
elements of the offense, in determining whether registration is required. Each finding that a
defendant was required to register on the basis of the underlying conduct even though the
essential elements test was not satisfied. See, People v. Burden, 6 Misc.3d 1033(a)(Sup. Ct.
Bronx Cty. 2005); People v. Milian, 189 Misc.2d 419, 730 N.Y.S.2d 392 (Sup. Ct. N.Y. Cty.
2001).
The same serious concern arises in other states, including California and Colorado, which
authorize courts to look behind the plea, and beyond the formal elements of the offense of
conviction, and enable them on a case by case basis to determine if registration is required.
Like New York, California requires an individual to register if they are required to register
in the state of conviction, or pursuant to CA Penal Code § 290(a)(2)(D)(I) if that individual ". . .
since July 1, 1944, has been, or is hereafter convicted in any other court, including any state,
federal, or military court, of any offense that, if committed or attempted in this state, would have
been punishable as one or more of the offenses described in subparagraph (A)". The wording of
the statute leaves open the possibility that, in determining whether the offense would have been
punishable as one or more of the registrable offenses, one looks at the underlying facts, and not at
the formal elements of the crime to which the defendant pled. The registrable California offenses
include commission of "any lewd or lascivious act ... upon or with the body of child" where the
child is "14 or 15 years" of age and "that person is at least 10 years older than the child" "with
the intent of arousing, appealing to, or gratifying the lust, passions, or sexual desires of that
person or the child". CA Penal Code § 288(a), (c) (1). Thus, an aggravated assault plea may
subject the client to a registration requirement in the State of California.
Colorado likewise has a very broad statute. It requires an individual to register within
five business days of becoming a temporary or permanent resident of the state, if, among other
things, the person has been convicted in Colorado or any other state of an offense involving
sexual behavior (or an attempt, solicitation or conspiracy to commit such an offense), or if they
are required to register in another state or jurisdiction for a sex offense. C.R.S.A. §§ 16-22-103,
16-22-108.
With regard to Florida, as you know, it is reasonably clear that under Florida's current
version of Megan's Law, a plea to aggravated assault would not subject the client to registration
in Florida since it is not included among the state's enumerated "sexual offender" offenses. See

07/26/17

Page 18 of 131

Public Records Request No.: 17-295

 LAW OFFICES OF

GERALD

B. LErcaumr, P.C.

Ms. Lamm Belohlavek
June 5, 2006
Page 4
F.S.A. §§ 943.0435, 784.021. However, the offense of sexual battery is on the list, as well as the
charge of lewd and lascivious behavior, so there is no assurance that, in the future, a Florida
prosecutor or court will not take the position that, where the aggravated assault is combined with
what some states have labeled a "sexually motivated intent" registration is required.
Moreover, as you indicated at our meeting, there is no guarantee that the Florida
legislature will not expand the category of persons subject to Megan's law, and expressly make
persons convicted of aggravated assault subject to the law, especially where the felony the actor
had the intent to commit is a sexual offense, and the victim is a minor. The trend today is
towards expansion, not contraction, of these kinds of statutes, and as you noted, Florida will be
no exception. See, e.g., "Sex Offenders; No More Escaping Registration," 36 McGeorge L. Rev
822 2005 (Over the last twenty years expanded registration requirements, enhanced penalties for
failure to register, and public notification provisions have enlarged the scope of sex offender
registration laws); see news articles of just this past week infra describing many of the
proscriptions being adopted around the nation. And, the ex post facto clause stands as no
significant bar. See Smith v. Doe, 538 U.S. 84 (2003) (upholding Alaska Sex Offender
Registration Act against a challenge that its application to persons whose offenses were
committed prior to its enactment would violate the ex post facto clause). If this trend continues,
as it likely will, the client will almost certainly be subject to sex offender registration.
Even if the client is not and will never be subject to registration requirements under
Florida's laws, a plea to aggravated assault under the circumstances of this case could subject
him to Megan's Law requirements in other jurisdictions. Thus, if the client pleads guilty to the
proposed aggravated assault charge, there is a grave risk that under existing state and Virgin
Islands law — quite apart from future expansion or expansive construction of those laws — he will
be subject to sex offender registration requirements and/or criminal exposure for failure to
register. There is an even graver risk still that there will be future expansion of the statutes or
expansive construction of them that will mean he is covered or arguably so. See, e.g., Cherry
Hill Sex Offender Ordinance Upheld, Courier Post, June 1, 2006, at
http://www.courierpostonline.com/apps/pbcs.d11/article?AID=/20060601/NEWS01/606010389/1
006;2 More States Move to Use GPS Tracking of Sex Offenders, Fox News, May 31, 2006, at
http://www.foxnews.com/story/0,2933,196455,00.html; Sex Offenders Sue City Over Park, Pools
2

This article discusses a decision handed down by a municipal court judge in New Jersey during the course
of our meeting. That decision upheld a zoning restriction on sex offenders ►iving within 2500 feet of schools, parks,
playgrounds, public libraries, or day care centers. While other jurisdictions' zoning laws currently restrict such
individuals from living within 1000 feet of these institutions, were they to follow the lead of Cherry Hill, New Jersey,
the client would most certainly be faced with the added burdens of selling his residences and moving in order to be in
compliance with the law.

07/26/17

Page 19 of 131

Public Records Request No.: 17-295

 LAW OFFICES OF

GEIRALD

B.

LE:IVA-1311T,

P.C.

Ms. Lanna Belohlavek
June 5, 2006
Page 5
and Playgrounds Ban, Fox News, May 31, 2006, at
http://www.foxnews.com/story/0,2933,197701,00.html.
Indeed, as you recognized during our meeting, many people who were advised by
competent counsel to plead guilty to offenses when registration was not required have now been
horrified to find themselves subjected to registration laws enacted or expanded after their guilty
pleas, without any recourse. See, Smith v. Doe, supra, 538 U.S. 84. Finally, although there is
some risk that even a plea to a misdemeanor charge could trigger registration in some
jurisdictions, our research suggests that this risk is considerably lower for a misdemeanor plea
than for a felony plea.
II.

Aggravated Assault is Generally Considered A Violent Felony And Does Not Apply to
the Facts of This Case

Assault is generally considered an act of force. It "create[s] in the victims a well founded
fear of imminent violence." Velasquez v. State, 654 So. 2d 1227, 1228 (Fla.2d DCA 1995). The
general public is certainly not aware of Florida's unique nuanced definition. Indeed, as you will
agree, in common usage, aggravated assault, on its face sounds inherently violent. Thus, at the
very least, most people will consider an aggravated assault charge, even of the "intent to commit
a felony" variety, to be a violent crime. In this regard, undifferentiated aggravated assault is one
of only four crimes listed in the FBI's Uniform Crime Report "violent crime" category.3
More importantly, as noted, this crime clearly does not reflect what allegedly occurred
since there has been no suggestion that a threat of serous bodily harm was made or a deadly
weapon used. In addition, most pleas are "downward" — the defendant agrees to waive his right
to trial in return for the prosecution's offer of a downward departure in charging or sentencing.
Further, in the typical case a plea involves crimes that bear a close resemblance to the underlying
events. The facts herein, obviously do not support a charge of aggravated assault, thus a plea to
same would be inappropriate.

3

The UCR divides its statistics into three major categories: violent crimes, property crimes, and hate crimes.
"Violent crime is composed of four offenses: murder and nonnegligent manslaughter, forcible rape, robbery, and
aggravated
assault."
"Violent
Crime,"
Crime
in
the
United
States,
2004,
at
http://www.fbi.gov/ucr/cius 04/offenses reported/violent crime/index.html.

07/26/17

Page 20 of 131

Public Records Request No.: 17-295

 LAW OFFICES OF

GERALD B. I ..EFGOTTET, P.G.

Ms. Lanna Belohlavek
June 5, 2006
Page 6
III. Since the Meeting on February 16, 2006 When Misdemeanor Charges Were Initially
discussed, the State's Case has Gotten Considerably Weaker
At the February 16, 2006 meeting, you suggested the Office was investigating a felony
and you indicated you would consider pleading it down to a misdemeanor. As you are aware,
since then much has happened which makes the alleged case considerably weaker and
undermines the credibility of the witnesses upon which it was based. Indeed as you already
know the following information has come to light severely damaging the reliability of the
_ background, including a history of theft, confessions and repeated
witnesses: (i)
denials of stealing from employers and customers, lying about her age, sexual promiscuity, and
prostitution; (ii) *_
boastful admission of drug use, underage drinking, sexual
activity, shoplifting, wild exaggeration of her income (at least $250,000), representing herself
naked on a website and as 17 years old, then 16, then 15, only changing it to her truthful age,
coincidentally four days before the last scheduled grand jury. In addition, as you have
acknowledged, she was found in an inappropriate place in Georgia after the police were called
when she ran away from home. This is separate and apart from the Florida police report
presented to you, detailing her being dropped off by the local drug dealer at 5:45 a.m., only two
days after returning to West Palm Beach, and being described by the officer as clearly on drugs;
and (iii) both of Saige's parents' criminal history of fraud.
In stark contrast to this is the fact that, as we indicated at the meeting, the client has
passed both a rigorous lie detector test, conducted by the most highly qualified expert we could
find, one whose reputation is beyond reproach, and provided you copies of two psycho-sexual
evaluations prepared by experts that you have agreed are well-recognized and accepted by the
State.

07/26/17

Page 21 of 131

Public Records Request No.: 17-295

 LAW OFFICES OF

GERALD B. LEFGOTTRT, P.C.

Ms. Lanna Belohlavek
June 5, 2006
Page 7
IV Conclusion
Under the circumstances of this case a plea to felony aggravated assault is both
unwarranted and presents a grave risk the client will be brandished a sex offender, bearing the
attendant burdens inherent with that classification. In light of this, and the credibility issues
presented by the complaining witnesses, combined with the client's two psycho-sexual
evaluations and lie detector tests, we believe that at the very most, a misdemeanor plea to
solicitation is appropriate.
ery truly yours,

Gerald B. Lefc urt

07/26/17

Page 22 of 131

Public Records Request No.: 17-295

 www.myspace.com/lovely-

Page 1 of 1
YA FUCK YOU 2111111
"twins do have more
fun "

United States
N

Last Login: 6/13/2006
View My: Pits I Videos
Contacting YA FUCK YOU 211.1111
71'7

Send Message
Add to Friends
Instant Message

41, Add to Group

Forviard to Friend

CH Add to Favorkes
Block User
li Rank User

MySpace URL:
http://www.myspace.com/lovelysaige

07/26/17

Page 23 of 131

Public Records Request No.: 17-295

http://profile.myspace.com/index.cfm?fuseaction=usenviewprofile&friendid=76552710

6/13/2006

 www.myspace.com/lovel3

Page 1 of 1

YA FUCK YOU 2

's Blurbs

About me:
[

] The full name is

] I am a twin her..her

name is amber [ ' ] Im the most outgoing person youll ever meet wen u
get to no me [

] I hate drama [

am half cuban and half french/irish [

] I LOVE TO HAVE FUN!!! [
] I love tanning [

] I

] I don't get

jealous very easily [ ' ] I am the biggest flirt ever [ ' ] I love my ass [
' ] I am NOT a phone person [ ' ] I am so easy to get along with [
] Ive been through more then more people think i have [

] I smile

even when i am not happy. [

I want a monkey someday lol [ ' ] I
•;
love all my georgia friends [ ' ] I love music [
] I love to joke around [
I laugh at the stupidest things [ ] I love to sleep [
people so much [

] I love funny

] I hate mean people [ ' ] I am a closet nerd lol jk [

] I love volleyball [

] oh! yeah i was a ballerina for 10 years [ ' ] I

love to dance..no matter where i am at [

] I miss you all in ga an

oh ..winslow lina britt carissa mary katie nikki lea zack .. see ya soon [
If u wanna talk to me .. iloveanirishboi
Who I'd like to meet:
I ALREADY HAVE

07/26/17
httry//www nwertare rnrrifIrvopl-

Page 24 of 131

Public Records Request No.: 17-295
4/1 /./liVIA

 www.myspace.com/lovely,

Page 1 of 3

YA FUCK YOU 2
General

Music

's Interests

love shopping [1 tanning [']
hanging out with friends[']
playing volleyball[lsleeping in
TELL ME ABOUT YOURSELF - The
Survey
Name:
Birthday: Birthday
Birthplace:
Current
Location:
Eye Color:
Hair Color:
Height:
Right Handed
or Left Handed:
Your Heritage
The Shoes
You Wore
Today:
Your
Weakness:
Your Fears:
Your Perfect
Pizza:
Goal You
Would Like To
Achieve This
Year:
Your Most
Overused
Phrase On an
instant
messenger:
Thoughts First
Waking Up:
Your Best
Physical
Feature:
Your Bedtime:
Your Most
Missed
Memory:
Pepsi or Coke:
MacDonalds or
Burger King:
Single or
Group Dates:
Lipton Ice Tea
or Nestea:
Chocolate or
Vanilla:
Cappuccino or
Coffee:
Do you Smoke:
Do you Swear:
Do you Sing:
Do you
Shower Daily:
Have you
Been in Love:

07/26/17

http://www.myspace.com/lovel,

Page 25 of 131

Public Records Request No.: 17-295

6/11/7006

 www.myspace.com/lovell

Page 2 of 3

Do you want to
go to College:
Do you want to
get Married:
Do you belive
in yourself:
Do you get
Motion
Sickness:
Do you think
you are
Attractive:
Are you a
Health Freak:
Do you get
along with your
Parents:
Do you like
Thunderstorms:
Do you play an
Instrument:
In the past
month have
you Drank
Alcohol:
In the past
month have
you Smoked:
In the past
month have
you been on
Drugs:
In the past
month have
you gone on a
Date:
In the past
month have
you gone to a
Mall:
In the past
month have
you eaten a
box of Oreos:
In the past
month have
you eaten
Sushi:
In the past
month have
you been on
Stage:
In the past
month have
you been
Dumped:
In the past
month have
you gone
Skinny Dipping:
In the past
month have
you Stolen
Anything:
Ever been
Drunk:

07/26/17

http://www.myspace.com/loveh

Page 26 of 131

Public Records Request No.: 17-295

6/11/2006

 Page 3 of 3

www.myspace.com/lovel)

Ever been
called a Tease:
Ever been
Beaten up:
Ever
Shoplifted:
How do you
want to Die:
What do you
want to be
when you
Grow Up:
What country
would you
most like to
Visit:
In
Favourite Eye
Color:
Favourite Hair
Color:
Short or Long
Hair:
Height:
Weight:
Best Clothing
Style:
Number of
Drugs I have
taken:
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Tattoos:
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things in my
Past I Regret:

C

Take This Survey

)

CREATE YOUR OWN! - or - GET
PAID TO TAKE SURVEYS!
Movies

07/26/17

httn://www.mvsoace.com/loveh

this layout is from whateverlife.coml

Page 27 of 131

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/ -1 IONIA

 MySpace.com - View Image

Page 1 of 2

tinine

The Web • MiiSpace

(100'444.:

Search I

UNLIMITED ACCESS TO OVER 500
OF THE GREATEST GAMES, ALL. ON YOUR PC.
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From

vThe Lucky One,

June 11, 2006 8:23 AM
f-

im that [x] SuNSHINE •

07/26/17

Page 28 of 131

Get it girl ( 101)

June 10, 2006 6:44 PM
.. sweetie .. PDA 101

Public Records Request No.: 17-295

http://viewmorepics.myspace.com/index.cfm?fuseaction=viewImage&friendID=76552710... 6/13/2006

 MySpace.com - View Image

Page 1 of 2

The Web • 11‘:':;Pkit ,-- •

Search I

When was the last time your doctor
paid YOU for a check-up?

FREE Se

LAWN gia DOCTOR
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;From
- LA Swii;$

07/26/17

June 11, 2006 9:13 AM
I DEF TOOK THAT PIC AND ALL THE OTHER
ONES...damm casey be looking goodd lol jkjkjk..
i mean u.

frlovien a
Choquette •

June 11, 2006 9:12 AM
aw how cute and who Introduced you guys?????
haha that would be me! 101 love you both....omg
casey Is actually kinda smiling holy shit lol

yThe Lucky
One,.

June 11, 2006 8:21 AM
CuTe

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Public Records Request No.: 17-295

http://viewmorepics.myspace.com/index.cfm?fuseaction=viewImage&friendID=76552710... 6/13/2006

 MySpace.com - View Image

Page 2 of 2

Lea <3

June 10, 2006 7:17 AM
aww u guys look so cute

About I FAQ I Term I Privacy I Safety TIPS I Contact MySpace I Promote! I Advertise I MySpace

In

©2003-2006 MvSeace.com. All Rights Reserved.

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 MySpace.com

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The Wpti • !NS-pact

flySpare corn Horn

Search 1

Home I Elrowe I SOW'i ti I itiVitt. I Hilt! I flail I Bk.,9 I Fb.wites I Forum I Groups I Events I ‘/Iticas I Must( I
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A FUCK YOU 2111111's Friends... (41)
Tom

Drake

Killa Cam

sh

KRiSTiE

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07/26/17

Morrida.

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• ..

Kyle

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http://home.myspace.com/index.cfm?fuseaction=user.viewfriends&friendID=76552710

6/13/2006

 MySpace.com

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• Time
ts
0.

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About I FAQ I Terms I Privacy I Safety Tips I contact itapece I Promote! I Advertise I MySpace In
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Public Records Request No.: 17-295

http://home.myspace.com/index.cfm?fuseaction=user.viewfriends&friendID=76552710

6/13/2006

 incident Report
CHEROKEE COUNTY SHERIFF'S OFFICE

05-104607

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Reported Date

498 CHATTIN DRIVE

11/24/2005
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INFO
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07/26/17

Page 33 of 131

Public Records Request No.: 17-295

 Incident Report
CHEROKEE COUNTY SHERIFF'S OFFICE

05-104607

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awommem

,JUVENILE

nvl No

TYPe

Name

1

Individual

JAMES

MNI

Race

i Scf

'258904 !WHITE ;MALE;

Yes
Phone Type PhoneNo

OTHER

(404)316-3145

OTHER 1.

insdNo ;Type
[OTHER 1
Individual
Der a mm,

Name

MM

, Rue

I See

258903 WHITE rraraLra

!NmTAmmile

;03/17/1969 36 No
!Type;
:,Coles
!HOME 411 CHRISTOPHER CT
at,tes.
WALESKA

CitY

WALESKA

Sena

GEORGIA !

Phone Type Phone No

HOME 1 (678)880-2746

Narrative
On 11/24/05 at about 21:49 hours I went to 411 Christopher Court in reference to a
suspicious person. I met with
who stated she has two juvenile daughters.
Tonight she noticed they went across the street to a vacant house with some boys. When she
went to check on them she caught the boys drinking alcohol. She knew the boys were juveniles
so she took the alcohol (tequila) from them she said a couple of the boys ran off. Juvenile one
got in his silver Mitsubishi and went to the end of the street. He then stopped infront of her
house. The juvenile stated he wanted his tequila back and he would come back at midnight.
is concerned juvenile one might return and damage her guests vehicles. Mrs.
asked her juveniles who the subject was and they were unfamiliar. I gave Mrs.
a case card. I returned into service with no further incident. I informed morning watch
of this address for an extra patrol for tonight only.

giiiwaiiii---000202/BRDOYA,BROOKE

07/26/17

charted At

06/06/2006 11:21

Page 34 of 131

Page 2 of

2

Public Records Request No.: 17-295

 Incident Report
CHEROKEE COUNTY SHERIFF'S OFFICE

06-6702

ORIG

Reported Date

498 CHATTIN DRIVE

01/21/2006
Nature of Call

MIS PER
office,

HRYANT,CHRISTOPHER
(678) 493-4200

Administrative information
Age,
,Cy

R eport .No

CHEROKEE COUNTY SHERIFF'S OFFICE

C16-6702

I scats

raWdasNo

itasture eV Call -

Supplement No

Reported

• ORIG 01/21/2006....-09:08
—
--

;060011543 !INCIDENT REPORT (MISSING PERSON (ADULT) j
.0ceee
'city
—I-Iv cods
1 411 CHRISTOPHER'S CT
;CANTON
1 CANTON
1
ITIcatbee,
76——1-Amilitir i-76926re l'i cam
i 01/20/2006 I 1.9 :00 101/21/20.06 ! 13:00 000025/BRTANT, CHRISTOPHER
lAssigmmm
i Ergimpiry- t
BRYANT,CHRISTOPHER (ADULT DETENTION CENTER il/
rii11;
mwi DETENTION CENTER (000025(
!Appayngafter

!ADULT DETENTION CENTER J Successful
rileie
1
07:00:19

Approval puns

i000455

.;01/23/2006

Person Summary
Invi No

•
CLR.2
ere 1 .

•

0.717V11.

Type

Name

MNI

Race

.264217
Name

'See Confidential

Sex

,W F

DateolBaTh

03/17 /1969

Page

Printed At

, CHRISTOPHER
00002S/ERTANT
_.

07/26/17

06/06/2006 11:12

Page 35 of 131

Page 1 of 3

Public Records Request No.: 17-295

 CALLER/COMPLAINANT 2

,hudtvp
5,,,01..,mlem
CALLER/COMPLAINANT ] 2
' So

Race

Type
Individual

supplement No

06-6702

incident Report
CHEROKEE COUNTY SHERIFF'S OFFICE

ORIG

mm
264217

Name
Aaeana4

Age _wen. o"

nate of Birth

WHITE FEMALE 03/17/1969 36 No
: Too

C.:ay

Address

HOME :411 CHRISTOPHER CT

CANTON

GEORGIA

ZIP too*

'CANTON
Type
SOCIAL SECURITY NUMBER

ID 1,M

Mom Type Plow No

HOME (678)880-2746

JUVENILE 1: Confidential
”IvoN ement

JUV

r),.,1

1

rne

See Confidential Page

Narrative
While on patrol, I was dispatched to a missing person call at 411 Christopher Court. I arrived
and made contact with the caller/mother of the missing juvenile female, L
J. She
stated her juvenile daughter left yesterday for school, and had not returned. . told me she
had spoken with her daughter around 1900 and she was going to the high school basketball
game. Later on that night, some of the juveniles's friends called the mother and informed her
they had not seen the juvenile at the game.
When the juvenile didn't return this morning,
said she became worried and started to
contact some of her daughter's friends. They told her they heard she was handing hanging
around with Mr. Byron Elrod in an area known as "The Cur which is located off Old Donaldson
and Highway 140. "The Cut" is a known drug area in the county. I completed a missing person's
checklist and obtained a recent picture of the juvenile. I called Detective Allen and informed her
of the situation. The mother did not want a juvenile complaint filed. I issued f
1 a case card
and asked her to call if she found any more information regarding her daughter. D/S Ballard and
I left the residence and returned to service.
After patrolling Old Donaldson Rd and the Crissler Street area, we were unable to locate any
additional information as to the whereabouts of the female. Around 1200, I received a telephone
stating that she had found her daughter, and she was located at Gregory Lane
call from Apartments off Belts Ferry Rd. The mother told me a friend of the family was going to pick the
female up, and escort her back to the parents house. I told 7.
to call 911 when her daughter
returned and a deputy would be sent out to check on the well being of the juvenile.
When the juvenile returned Sgt Thompson met with the juvenile and parents at the house. The
Juvenile stated she had been drinking and had done some drugs last night, and that she had
been scared to call her parents. She then went to a friends house located at Gregory Lane
Apartments and spent the night.

Printed At

'000025/BREAMT,CHRI$TOPHER

07/26/17

06/06/2006 11:12

Page 36 of 131

Page 2 of 3

Public Records Request No.: 17-295

 FA:niery en,

06-6702
DRAFT

Incident Report

CHEROKEE COUNTY SHERIFF'S OFFICE

0001

Reported Gate

498 CHATTIN DRIVE

01/21/2006
NatureofG4

Officer

ALLEN, AUTUMN
(678) 493-4200

Administrative Information
Agency

RapOrt NO

1 Supplement No : Reported Cab

Reported Tape

06-6702
0001
131/21/2006 15:30
lAssoment.
Entered
j
1C/D DAY SHIFT PERSONS UNIT 1_0002841
ftkppiroNflg mew
iNpowdbm
!

CHEROKEE COUNTY SHERIFF'S OFFICE

Oman
000284/ALLEN,AUTUMN
Assopment

CID DAY SHIFT PERSONS UNIT
Approval That

Narrative
On 012106 I was notified by dispatch to give B-43 a call. I called and spoke with D/S Ballard
and he was taking a report of a missing juvenile age 15. He stated she was supposed to have
went to a basketball game last night but she didn't. He stated she went off with some black
males. He told they were stopped by some white friends of her and they fought with the black
males. D/S Ballard said the mother had contact with her daughter around 8:00 last night but
had not heard from her since then.

Reltort Mar10002114/ALLM,AUTUNN

07/26/17

lisomscim
106/06/2006 11:12

Page 37 of 131

IPage 1 of 1

Public Records Request No.: 17-295

 Page I of I

Case Activity

case Ac ty
• Index

Case Details
Division Asg.n Area Assign Date Charge
Incident No Initial Date Officer Assigned
P1
01/23/2006
MIS RN
060006702
01123/2006
Class Case Control Solve !Status Dispo
CLOSED/CLEARED EXCEPTIONALLY ADULT
27
C
C
27699
Last Activity
Follow Up Due Dt
Prosecute?
Insurance?
01/23/2006
Property Act
# Charges
Status Date
Made Date
0
01/23/2006
Vehicle
Investigation
Property
Booking
Person
E-Mail

Case Activity
Next Next Property
Asgn Act
Officer
Edit
# Minutes
Details Assigned Division Area Type Amount Type Date
Act
Hours
0
060006702
P1
IN
0
0
102612
0
060006702
PI
EA 0
0
102613
Number of Activities: 2
Total Recovered Property: $0
Total Hours: 0:0

Additional Information

.

A

ItAssociated Persons: 2
E ARS Narrative: I
ARS Report Summary: 1
Itnd of document

hup://cherbrow/PRD/Doc/IN/IN_Case_0.asp?DR=060006702
07/26/17

Page 38 of 131

6/6/2006
Public Records Request No.: 17-295

 ALAN M. DERSHOWITZ
1575 MASSACHUSETTS AVENUE
CAMBRIDGE • MASSACHUSETTS • 02138

April 19, 2006

Ms. Lanna Belohlavek
Assistant State Attorney
401 North Dixie Highway
West Palm Beach, FL 33401
Dear Lanna:
Guy has asked me to provide you with the research on why it makes a difference whether Mr.
Epstein pleads "nolo contendere " or "guilty". As you can see from the enclosed statute, a plea of
"nolo contendere" is not admissible as an "admission against interest" in a subsequent civil case.
A plea of guilty — even a so-called "best interest" plea of guilty — is admissible. That is the only
real legal difference. If you need anything further, please do not hesitate to call me or Guy.
Sincerely,

Enclosure: FL ST § 90.410

07/26/17

Page 39 of 131

Public Records Request No.: 17-295

 FL ST S 90 410
West's F.S.A. § 90.410

Page 1

C

Effective: [See Text Amendments]
WEST'S FLORIDA STATUTES ANNOTATED
TITLE VII. EVIDENCE (CHAPTERS 90-92)
CHAPTER 90. EVIDENCE CODE
90A10. Offer to plead guilty; nolo contendere; withdrawn pleas of guilty
Evidence of a plea of guilty, later withdrawn; a plea of nolo contendere; or an offer to plead guilty or nolo
contendere to the crime charged or any other crime is inadmissible in any civil or criminal proceeding. Evidence of
statements made in connection with any of the pleas or offers is inadmissible, except when such statements are
offered in a prosecution under chapter 837.
CREDIT(S)
Laws 1976, c. 76-237, § 1; Laws 1978, c. 78-361, § 8.
HISTORICAL AND STATUTORY NOTES
Amendment Notes:
Laws 1978, c, 78-361, deleted "for impeachment or" preceding "in a prosecution under chapter 837."
Federal Evidence Rules:
For rule relating to offer to plead guilty; nolo contendere; withdrawn plea of guilty, see Rule 410, Fed.Rules Evid ,
23 U.S.C.A.
Uniform Rules of Evidence:
For rule relating to offer to plead guilty; nolo contendere; withdrawn plea of guilty, see Rule 410, Uniform Laws
Annotated, Master Edition, vol. 13.
West's F. S. A. § 90.410, FL. ST § 90.410
Current through Chapter 362 (End) of the 2005 Special 'B' Session of the
Nineteenth Legislature
C 2006 Thomson/West
END OF DOCUMENT

2006 Thomson/West. No Claim to Orig. U.S. Govt. Works.

07/26/17

Page 40 of 131

Public Records Request No.: 17-295

 FAX NO. :5618024121

FROM :

Apr

7 2006 04:02PM P1

LAW OFFICE OF GUY FRONSTIN
515 N. FLAGLER DRIVE, SUITE 300 PAVILION
WEST PALM BEACH, FL 33401
(561) 447-4011 * (561) 802-4121 (Fax)
SENT VIA FACSIMILE TRANSMISSION

April 17, 2006

Lanna Belohlavek
Assistant State Attorney
Office of the State Attorney
401 N. Dixie Highway
West Palm Beach, FL 33401
Re:

Jeffrey Epstein

Dear Lanna:
I am in receipt of your letter, of today's date, confirming the offer of
settlement in the Jeffrey Epstein matter. Please allow this response to
serve as my acceptance with the following clarifications:
1)
You have agreed to allow Mr. Epstein to enter a Guilty Best Interest
Plea. Additionally, you have agreed to review authority I provide
concerning the effect a "guilty" plea has on a civil matter and in good faith
consider allowing Mr. Epstein to plea "No Contest"
2)
Regarding, the supervised contact, your letter refers to an
"approved" adult. In our meeting today, you did not mention that the
supervisor had to be approved. I agree that the supervision must be by an
adult, other than Ms. Marcinkova and Ms. Kellen, with knowledge of the
underlying facts. Additionally, I need to confirm that Mr. Epstein may be
with his goddet.VAeinwithout-su.petvision.
3)
You agreed not to object to my selecting a duly licensed and
experienced psychologist to conduct the evaluation.
I accept the provision for payment of the cost of investigation for the
4)
Palm Beach Police Department as long as the cost is reasonable.
Although your correspondence does not mention travel, I am
5)
confirming your agreement to allow Mr. Epstein to travel for business
purposes. In line with our discussions, I request that you agree to allow
Mr. Epstein to travel for philanth
07/26/17

Page 41 of 131

Public Records Request No.: 17-295

P

6c-A

 FAX NO. :5618024121

FROM :

Api

7 2006 04:02PN P2

Pursuant to this acceptance, I trust you will cancel presenting this matter
to the Grand Jury tomorrow. Please contact me as soon as possible so we
can continue to work through the filing, processing and plea resolution in
this matter.

Very truly yours,

Guy P. Fronstin, Esq.
GPF/mw
Enclosures (as noted)

07/26/17

Page 42 of 131

Public Records Request No.: 17-295

 FROM :

FAX NO. :5619024121

Rp

2 2006 04:51PM P1

LAW OFFICE OF GUY FRONSTIN
515 N. FLAGLER DRIVE, SUITE 300 PAVILION
WEST PALM BEACH, FL 33401
(561) 447-4011 * (561) 802-4121 (Fax)
SENT VIA FACSIMILE TRANSMISSION

April 10, 2006
Daliah Weiss, ASA
Office of the State Attorney
401 N. Dixie Highway
West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Daliah:
Pursuant to our recent conversation and my correspondence of January
13, 2006 (attached), please allow this letter to reconfirm that I am attorney
of record for Mr. Epstein. Additionally, I am clarifying that Mr. Alan
Dershowitz is also counsel for Mr. Epstein.
Currently, the structure of our representation is that I will be the one in
communication with you, Lanna Belohlavek and Detective Recarey
regarding the investigation and prosecution of this matter. Mr. Dershowitz
remains involved however, at this point, I do not anticipate him contacting
you, Ms. Belohlavek or Detective Recarey to discuss any issue relevant to
this investigation. I will notify you if this structure changes.
Please call me if you have any questions or concerns about Mr. Epstein's
representation. Additionally, I anticipate hearing back from you on
Thursday regarding the opportunity for me to meet with you and Lanna
prior to this case being presented to the Grand Jury.
I look forward to continuing to work with you on this matter.
Very truly yours,

uy P. Fronstin, Esq.
GPF/mw
Attachment

07/26/17

Page 43 of 131

Public Records Request No.: 17-295

 FROM :

FAX NO. :5618024121

Apl LO 2006 04:51PM P2 .

LAW OFFICE OF GUY FRONSTIN
FLAGLER DRIVE, SUITE 300 PAVILION
WEST PALM BEACH, .FL 33401
(561) 447-4011. * (561) 802=4121 (Fax)

515

SENT VIA FACSIMILE TRANSMISSION
January 13:2006
Lanna Belahlavek, ASA.
Office of the State Attorney
401. H:-Dixie Highway
West Palm Beach, FL 33401
Re:. Jeffrey Epstein.
Dear Lanna:
Please allow this letter tO• serve CIS formal notice thot I,represent Mr. Jeffrey ,
Epstein in regard to the Investigation your office Is Conducting of Mr.
Epstein. Additionally, Alan Dershowltz, .Esq., who is a close friend of 'Mr.
Epstein's, is serving as counsel to me in my representation of Mr. Epstein.
Mr. Dershowitz is working closely with, me on this matter and; in the event
charges are filed, will likely petition to enter an appearance Pro Hac Vice
along with other counsel.
I appreciate the dialogue you have permitted throughout this
investigation. I trust you will still invite me for a pre-filing interview in the
event the State decides it has enough evidence to charge Mr_ Epstein with
a crime.:
I look forward to continuing to work with you on this matter.
Very truly yours,

Guy P. Fronstin, Esq.
GPF/mw.

07/26/17

Page 44 of 131

Public Records Request No.: 17-295

 LAW OFFICE OF GUY FRONSTIN
515 N. FLAGLER DRIVE, SUITE 300 PAVILION
WEST PALM BEACH, FL 33401
(561) 447-4011 * (561) 802-4121 (Fax)
SENT VIA HAND DELIVERY

February 17, 2006

Lanna Belohlavek
Assistant State Attorney
Office of the State Attorney
401 N. Dixie Highway
West Palm Beach, FL 33401
Re:

Jeffrey Epstein

Dear Lanna:
Thank you for meeting yesterday and allowing Alan and me to address
your investigation of Jeffrey Epstein. Pursuant to our discussion, I am
enclosing an Incident Report from Victoria Secret outlining three (3) recent
incidents of theft committed b
I am submitting this Incident Report with the express understanding that it
will be kept in strict confidence. Specifically, since the Report only
concerns
I believe there is no good faith reason, in any
contact you may have with the store to mention Mr. Epstein's name or the
investigation (especially in light of reports from multiple witnesses
indicating Detective Recarey is providing damaging mis-information).
Please let me know if you have any questions about the report and I will do
whatever I can to immediately resolve your concerns.
Additionally, I am enclosing a credit card receipt (with non-relevant
information redacted) confirming the purchase of the strap-on dildo that
purchased at Guys and Dolls. It will make clear that when
the dildo was purchased
was over 18 years old and she
charged the purchase on Nadia Marcinkova's credit card. Ms. Marcinkova
had never before been to Guys and Dolls and was taken there by ...... who indicated it was her favorite sex shop.

07/26/17

Page 45 of 131

Public Records Request No.: 17-295

 I hope by presenting this meaningful information it will bring us closer to a
resolution. If you have any questions before our next meeting on Thursday
February 23, at 11:00 AM, please do not hesitate to contact me.
Very truly yours,

Guy P. Fronstin, Esq.
GPF/mw
Enclosures (as noted)

07/26/17

Page 46 of 131

Public Records Request No.: 17-295

 OFFICE OF THE

STATE ATTORNEY
FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA
IN AND FOR PALM BEACH COUNTY

BARRY KRISCHER
STATE ATTORNEY

February 9, 2006

Guy Fronstin, Esq.
515 North Flagler Drive
Suite 300 Pavilion
West Palm Beach, FL 33401
Dear Mr. Fronstin:
This is to notify you that certain matters suggesting possible criminal conduct on the part
of your client, Jeffrey Epstein, will be presented for consideration by the current session of the
Palm Beach County Grand Jury. You and your client are invited to appear before the Grand
Jury in the Palm Beach County Courthouse on March 7, 2006 at 9:00 AM, or as soon
thereafter as they are able to hear you.
The invitation is extended to provide an opportunity for your client to present any
personal testimony you may think proper. You should understand, however, that anything your
client testifies to may be used against him in a subsequent criminal prosecution.
In the event you and your client wish to present evidence or testimony of other
witnesses you must submit a written list of names and addresses of potential witnesses by
February 16, 2006 and make them available by February 21, 2006 for a sworn statement at
the State Attorney's Office. Copies of potential physical evidence must be supplied by
February 16, 2006. Keep in mind that only evidence that is relevant to the incident will
be presented to the Grand Jury.
This invitation to your client is not an offer of immunity nor is it an effort to compel your
client to participate in the Grand Jury proceedings in any way. Any participation on his part
must be entirely voluntary, and a decision not to participate cannot be used to raise an
unfavorable presumption against your client.
Thank you for your cooperation in this matter.
Sin lely,

//7

a //(EPe o vek
Assistant State Attorney
Grand Jury/Crimes Against Children
lb/lb
xc:

Clerk's File
SAO File

07/26/17

Page 47 of 131

Public Records Request No.: 17-295

 Alan Dershowitz
1525 Massachusetts Avenue
Cambridge, Massachusetts 02138
617-939-6001
Joseph Recarey
Detective
Palm Beach Police Department
345 S. County Road
Palm Beach, FL 33480
Re: Epstein matter
Dear Detective Recarey:
I am sending you this letter in response to the serious concern you raised at our
meeting regarding an alleged claim that one of our investigators had misrepresented
himself as a police officer and in fact had actually attempted to impersonate you. As I
told you neither I nor my client would ever tolerate any such conduct on the part of our
investigators. With that in mind, I immediately began an inquiry of our staff, and believe
that the contemporaneous notes taken by our investigator, while attempting to interview
will provide the necessary explanation for your thoroughly justified
consternation. It will also, I believe, provide a more troublesome and telling illustration
of her character. At our meeting, you may recall, _I--also advised you that our
investigation had discovered at least one of her web sites and I am enclosing some
examples. You will note that she, herself, has chosen to go by the nickname of "pimp
juice" and the site goes on to detail, 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 both possession of marijuana and drug paraphernalia.
The following raw notes were taken by investigators (one who suffers from a
quite distinct speech impediment, making, therefore, a truly innocent claim of
impersonation virtually impossible). Both of them have many years experience in
conducting defense investigations and debriefing 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 student, might try to mislead them as successfully as she had misled others. They
were instructed to ask detailed questions to further elucidate her previous
pronouncements regarding the extreme lengths she would go to as she put it "to be rich,
no, I mean really, really rich". But as you will read, they never got a chance to ask even a
single question, and could not for a moment be thought of, as attempting to misrepresent
themselves as police officers. 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 furious pace and volume from what initially appeared

07/26/17

Page 48 of 131

Public Records Request No.: 17-295

 onlyth be a young woman of.slight build and soft demeanor. The following,is an excerpt
from the investigator's report detailing her extremely short but none the less pungent
statements;
"11.21.2005, my partner, Steve Kiraly, and I traveled to Orange Park
The purpose of
(Jacksonville), Florida, in order to attempt to intervie '
having two people present was to act as witnesses as to whatever might have been said by
lives with her 18 year old boyfriend,
•• " " during the course of our interview.
William, and his mother and boyfriend at 2768 Kiowa Avenue, Orange Park, FL. At
arrived home. We waited about 10 minutes and approached
approximately 6:30pm
the residence. I knocked on the door and a woman, who I now know as Mary Parker,
She said
• "
answered the door. I told her that we would like to speak wit
" there. I said there must be because her Jeep was parked out
there was no
and I said yes. • then came to the
front. She then said, "I'm sorry, you mean • •
door. The following conversation took place.
[Riley] • • my name is Bill Riley (as I handed her, my business card) and this is my
partner Steve Kiraly. We are investigators from Miami working on behalf of Jeffrey
Epstein.
[ • I don't talk to fucking cops and I'm not talking to you.
[Riley] • • _, we're not cops.
' ] You need to leave. Get the fuck off my property, leave now.
there is no need to be hostile. We are not cops. We are just trying to learn
[Riley] _
the truth.
[ • Get the fuck off my property. What, you're still standing here?
[Riley] We're leaving but we don't understand why you're so hostile.
You have no right to be here. 1 moved. All that shit is behind me in another
world so get the fuck out of here.
•.
goes back inside the house and Mary Parker came outside on the porch
[Riley] 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 her an attorney.
[Riley] I understand but we're not the bad guys and we're not cops.
[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 at 6:45pin but your son, Will, told us we could come back.
[Parker] He doesn't own this property.
;ame back outside
[ • ] You're still here, get the fuck out. I'm calling the cops if you do not leave.
[Riley] ' • , we're talking with Mary and yes, we're leaving, but all we wanted 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 _
; named _
,
, who goes
by the more outlandish self chosen moniker and complete web name of "
••••ucicing
__", whose web page I also enclose.

r--

07/26/17

Page 49 of 131

Public Records Request No.: 17-295

 A

In the event that the source of the allegation is neither of the two women
mentioned above, if you would provide me with the name of the person, or persons,
making the claim , I will check with the relevant investigators and follow through until
we are satisfied that we have gotten to the bottom of this matter.
I trust the information provided in this letter is helpful to you as we all try to bring
this difficult period to a close.
Sincerely,

Alan Dershowitz
cc:

07/26/17

Enclosures
Barry Krischer
Lanna Belohlavek
Daliah Weiss

Page 50 of 131

Public Records Request No.: 17-295

 r rt

Alan Dershowitz
1525 Massachusetts Avenue
Cambridge, Massachusetts 02138
617-939-6001
Joseph Recarey
Detective
Palm Beach Police Department
345 S. County Road
Palm Beach, FL 33480
Re: Epstein matter
Dear Detective Recarey:
I am sending you this letter in response to the serious concern you raised at our
meeting regarding an alleged claim that one of our investigators had misrepresented
himself as a police officer and in fact had actually attempted to impersonate you. As I
told you neither I nor my client would ever tolerate any such conduct on the part of our
investigators. With that in mind, I immediately began an inquiry of our staff, and believe
that the contemporaneous notes taken by our investigator, while attempting to interview
will provide the necessary explanation for your thoroughly justified
consternation. It will also, I believe, provide a more troublesome and telling illustration
of her character. At our meeting, you may recall, -I—also advised you that our
investigation had discovered at least one of her web sites and I am enclosing some
examples. You will note that she, herself, has chosen to go by the nickname of "pimp
juice" and the site goes on to detail, 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 both possession of marijuana and drug paraphernalia.
The following raw notes were taken by investigators (one who suffers from a
quite distinct speech impediment, making, therefore, a truly innocent claim of
impersonation virtually impossible). Both of them have many years experience in
conducting defense investigations and debriefing 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 _ _-____ • • 3 statement verbatim because we feared that she, an accomplished
drama student, might try to mislead them as successfully as she had misled others. They
were instructed to ask detailed questions to further elucidate her previous
pronouncements regarding the extreme lengths she would go to as she put it "to be rich,
no, I mean really, really rich". But as you will read, they never got a chance to ask even a
single question, and could not for a moment be thought of, as attempting to misrepresent
themselves as police officers. 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 furious pace and volume from what initially appeared

07/26/17

Page 51 of 131

Public Records Request No.: 17-295

 only to be a young woman of slight build and soft demeanor. The following is an excerpt
from the investigator's report detailing her extremely short but none the less pungent
statements;
"11.21.2005, my partner, Steve Kiraly, and I traveled to Orange Park
The purpose of
(Jacksonville), Florida, in order to attempt to interview
having two people present was to act as witnesses as to whatever might have been said by
lives with her 18 year old boyfriend,
during the course of our interview.
William, and his mother and boyfriend at 2768 Kiowa Avenue, Orange Park, FL. At
approximately 6:30pm Hall arrived home. We waited about 10 minutes and approached
the residence. I knocked on the door and a woman, who I now lmow as Mary Parker,
-. She said
'
answered the door. I told her that we would like to speak with "
there. I said there must be because her Jeep was parked out
there was no i • __L._
front. She then said, "I'm sorry, you mean ' " and I said yes. • • then came to the
door. The following conversation took place.
my name is Bill Riley (as I handed her my business card) and this is my
[Riley]
partner Steve Kiraly. We are investigators from Miami working on behalf of Jeffrey
Epstein.
[ • • ] I don't talk to fucking cops and I'm not talking to you.
[Riley] • • __, we're not cops.
[ __] You need to leave. Get the fuck off my property, leave now.
[Riley]
; there is no need to be hostile. We are not cops. We are just trying to learn
the truth.
[ • Get the fuck off my property. What, you're still standing here?
[Riley] We're leaving but we don't understand why you're so hostile.
You have no right to be here. I moved. All that shit is behind me in another
world so get the fuck out of here.
goes back inside the house and Mary Parker came outside on the porch
[Riley] 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 her an attorney.
[Riley] I understand but we're not the bad guys and we're not cops.
[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 at 6:45pin but your son, Will, told us we could come back..
[Parker] He doesn't own this property.
•• _ came back outside
[ • • ] You're still here, get the fuck out. I'm calling the cops if you do not leave.
[Riley]: ___.:, we're talking with Mary and yes, we're leaving, but all we wanted 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 i '
' 3, who goes
by the more outlandish self chosen moniker and complete web name of ' • • Fucking
•s", whose web page I also enclose.

07/26/17

Page 52 of 131

Public Records Request No.: 17-295

 In the event that the source of the allegation is neither of the two women
mentioned above, if you would provide me with the name of the person, or persons,
making the claim , I will check with the relevant investigators and follow through until
we are satisfied that we have gotten to the bottom of this matter.
I trust the information provided in this letter is helpful to you as we all try to bring
this difficult period to a close.
Sincerely,
Ca al& OkictaC)
Alan Dershowitz
cc:

07/26/17

Enclosures
Barry ICrischer
Lanna Belohlavek
Daliah Weiss

Page 53 of 131

Public Records Request No.: 17-295

 Alan Dershowitz
1525 Massachusetts Avenue
Cambridge; Massachusetts 02138
617-939-6001
Joseph Recarey
Detective
Palm Beach Police Department
345 S. County Road
Palm Beach, FL 33480
Re: Epstein matter
Dear Detective Recarey:
I am sending you this letter in response to the serious concern you raised at our
meeting regarding an alleged claim that one of our investigators had misrepresented
himself as a police officer and in fact had actually attempted to impersonate you. As I
told you neither I nor my client would ever tolerate any such conduct on the part of our
investigators. With that in mind, I immediately began an inquiry of our staff, and believe
that the contemporaneous notes taken by our investigator, while attempting to interview
•
--., will provide the necessary explanation for your thoroughly justified
consternation. It will also, I believe, provide a more troublesome and telling illustration
of her character. At our meeting, you may recall, _I _also advised you that our
investigation had discovered at least one of her web sites and I am enclosing some
examples. You will note that she, herself, has chosen to go by the nickname of "pimp
juice" and the site goes on to detail, 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 both possession of marijuana and drug paraphernalia.
The following raw notes were taken by investigators (one who suffers from a
quite distinct speech impediment, making, therefore, a truly innocent claim of
impersonation virtually impossible). Both of them have many years experience in
conducting defense investigations and debriefing 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 student, might try to mislead them as successfully as she had misled others. They
were instructed to ask detailed questions to further elucidate her previous
pronouncements regarding the extreme lengths she would go to as she put it "to be rich,
no, I mean really, really rich". But as you will read, they never got a chance to ask even a
single question, and could not for a moment be thought of, as attempting to misrepresent
themselves as police officers. 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 furious pace and volume from what initially appeared

07/26/17

Page 54 of 131

Public Records Request No.: 17-295

 only to be a young woman of slight build and soft demeanor. The following is an excerpt
from the investigator's report detailing her extremely short but none the less pungent
statements;
"11.21.2005, my partner, Steve Kiraly, and I traveled to Orange Park
The purpose of
•
(Jacksonville), Florida, in order to attempt to interview _
having two people present was to act as witnesses as to whatever might have been said by
1 lives with her 18 year old boyfriend,
during the course of our interview.
William, and his mother and boyfriend at 2768 Kiowa Avenue, Orange Park, FL. At
approximately 6:30pm Hall arrived home. We waited about 10 minutes and approached
the residence. I knocked on the door and a woman, who I now know as Mary Parker,
answered the door. I told her that we would like to speak with "
" ". She said
there was no "
" there. I said there must be because her Jeep was parked out
front. She then said, "I'm sorry, you mean _ _" and I said yes. " then came to the
door. The following conversation took place.
[Riley] ; • _, my name is Bill Riley (as I handed her, my business card) and this is my
partner Steve Kiraly. We are investigators from Miami working on behalf of Jeffrey
Epstein.
[
I don't talk to fucking cops and I'm not talking to you.
[Riley] T we're not cops.
[ " ] You need to leave. Get the fuck off my property, leave now.
[Riley] " there is no need to be hostile. We are not cops. We are just trying to learn
the truth.
[ " ] Get the fuck off my property. What, you're still standing here?
[Riley] We're leaving but we don't understand why you're so hostile.
You have no right to be here. I moved. All that shit 'is behind me in another
world so get the fuck out of here.
goes back inside the house and Mary Parker came outside on the porch
[Riley] 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 her an attorney.
[Riley] I understand but we're not the bad guys and we're not cops.
[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 at 6:45pm but your son, Will, told us we could come back.
[Parker] He doesn't own this property.
came back outside
' • _] You're still here, get the fuck out. I'm calling the cops if you do not leave.
[Riley] _
we're talking with Mary and yes, we're leaving, but all we wanted 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 — -'s named
— _ , who goes
by the more outlandish self chosen moniker and complete web name of
' Fucking
_ , whose web page I also enclose.

07/26/17

Page 55 of 131

Public Records Request No.: 17-295

 In the event that the source of the allegation is neither of the two women
mentioned above, if you would provide me with the name of the person, or persons,
making the claim , I will check with the relevant investigators and follow through until
we are satisfied that we have gotten to the bottom of this matter.
I trust the information provided in this letter is helpful to you as we all try to bring
this difficult period to a close.
Sincerely,

Cdcuk

aUtta°

Alan Dershowitz
cc:

07/26/17

Enclosures
Barry Krischer
Lanna Belohlavek
Daliah Weiss

Page 56 of 131

Public Records Request No.: 17-295

 13 2006 05:53PM P1
•
. •

FRX NO. :5618024121
. .

•••

OUY.FR NS
5

0X,0.1*:160.1E.0iiitE 460..
PHi.:F.L 33401' . .
(
3,':401 .St.11.147111B
1 14 :561) 8024121 (Fitif

VI FACS LE.'`['i NSMisiebil
•
a nuary13~.2

ar .

.

ease aitowthit letteriaserve formal riotice:thott rePr
, .O4P.OtMr, Je
ting of

stOk".!:.•:Addiligiiolly;:Akin f'Deiihci
;Esq.,., who: is 'a, Ciose:friend.df44:
pstein`s, is serving
'to, MO. iiii•rilkrOPOOOtaffesn;'Of 416t:;
Mr. berithOwitz:iir Wcirktng.CloseiY.Viith:irie-on this.rnatter anti;:fittrie.
charget.are fled, will likely petitionla enter on oppearonce.r.ri?.Hac Vice
along
other:. coUni
••••
• ."
,
eciate lt
throughout th
. ue :.you .
Iriliestigation. I:trust: you Win Ail inviterme for a_pre-filing Interview.in ihe
. event the State deOldis it hacenough evidence to chargeMr..gpstein
ook forwar d:to continuing: to work With you on this
•••

07/26/17

Page 57 of 131

Public Records Request No.: 17-295

 01/11/2006 13:55

56165907cm

LAW OFFICE

PAGE 02/02

SALNICK & FYJCHS, P.A.
ONE CLEARLAKE CENTRE
250 SOUTH AUSTRALIAN AVENUE

MchaelSalnkk•
Jack K. Fuchs
Flynn R Bertisch

SUITE 1203
WEST PALM BEACH, FLORIDA 33401-5014

• Board Certified Criminal Trial Lawyer

(561) 471-1000

• Member of Colorado, District of Columbia
and New York Bars

Far (561) 659-0793

E-mall: SainickLaw Caol.com
Fuchslawebellsouth.net

Jennifer L. Shand
Certified Leval Assistant

Fbertisch@bellsouth.net

MEMO

DATE:

JANUARY 11, 2006

FROM:

MICHAEL SALNICK

TO:

Daliah Weiss

RE:

Our Client: Janusz Banasiak

One more thing: Can my client pick up his computer and related equipment before our
meeting on Tuesday? Please advise and thank you.
W' h

dest regards,

alnick

07/26/17

Page 58 of 131

Public Records Request No.: 17-295

 01/11/2006 13:55

561659079?

LAW OFFICE

PAGE 01/02

Veceal
SALNICK & FUCHS, PA.
Michael Salnick°
Jack K. Fuchs
Flynn P. Bertisch

ONE CLEARLAKE CENTRE
250 SOUTH AUSTRALIAN AVENUE
SUITE 1203
wEST PALM BEACH, FLORIDA 33401-5014

• beard Certified Criminal Trial Lawyer
(561) 471-1000
Fax (561) 558-0793
E-mall: SalnickLaw@aolcom
Fuchislaw O bellsoath net
Fbertisch ebellsouth ince

• Member of Colorado, District of Columbia
and New York Bars

Jennifer L. Shand
Certified Legal Assistant

MEMO

DATE:

JANUARY 11, 2006

FROM:

MICHAEL SALNTCK

TO:

Daliah Weiss

RE:

Investigation Re: Jeffrey Epstein
Our Client: Janusz Banasiak

This shall confirm the rescheduling of the meeting with my client until Tuesday, January
17, 2006 at 11:00 a.m. at your office. In one of our conversations earlier this morning, you
indicated that you would be inclined to issue him a subpoena. I would please ask that you
fax a copy of that subpoena to my office prior to our meeting.
Thank you for your attention to this matter.
Wit

• dest regards,

Michae Salnick

07/26/17

Page 59 of 131

Public Records Request No.: 17-295

 4

FROM

FAX NO. :5618024121

Jai

.1 2006 12:28PM P1

LAW OFFICE OF GUY P. FRONSTIN
515 N. FLAGLER DRIVE, SUITE 300 PAVILION
WEST PALM BEACH, FL 33401
(561) 447-4011 * (561) 802-4121 (Fax)

*TIME SENSITIVE MATERIAL*
*PLEASE DELIVER IMMEDIATELY*
FAX COVER SHEET

TO:

Lanna Belohlavek, ASA

RE:

Jeff Epstein

DATE:

January 11, 2006

FROM:

Guy P. Fronstin, Esq.

NUMBER OF PAGES INCLUDING COVER SHEET: 2
Please see attached letter.

THANK YOU FOR YOUR ASSISTANCE IN THIS MATTER.

THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND
EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. if thereader of this message is not the
intended recipient or the employee or agent responsible for delivery of the message to the intended
recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us immediately by
telephone, and return the original message to us at the above address.

07/26/17

Page 60 of 131

Public Records Request No.: 17-295

 FAX NO. :5618024121

FROM :

1. 11 2006 12:28PM P2

LAW OFFICE OF GUY FRONSTIN
515 N. FLAGLER DRIVE, SUITE 300 PAVILION
WEST PALM BEACH, FL 33401
(561) 447-4011 * (561) 802-4121 (Fax)

SENT VIA FACSIMILE TRANSMISSION

January 11, 2006

Lanna Belohlavek
Assistant State Attorney
Office of the State Attorney
401 N. Dixie Highway
West Palm Beach, FL 33401
Re:

Jeff Epstein
Third Party Attorney Fee Payment

Dear Ms. Belohlavek:
As you know I represent Mr. Jeff Epstein. Mr. Epstein's house manager,
Yanush Banasiak, was asked to speak with your office regarding the matter
that I represent Mr. Epstein on. In anticipation of Mr. Banasiak's meeting
with your office he decided to retain legal counsel. Yesterday, he met with
and retained, attorney Michael Salnick, who will be attending Mr.
Banasiak's statement in your office today at 1:30 p.m.
Since your questioning of Mr. Banasiak concerns information that he may
have that arises out of his employment with Mr. Epstein, Mr. Epstein will be
paying Mr. Banasiak's attorneys fees. I felt it important to notify you of this
third party attorney fee payment structure and confirm that you have no
objection. Mr. Epstein would like to wire the payment for Mr. Salnick's
representation to Mr. Salnick as soon as possible. Therefore, I would
appreciate your getting back to me today on this issue.
Very truly yours,

Guy P. Fron ,

sq

GPFImw
cc: Daliah Weiss
Michael Salnick

07/26/17

Page 61 of 131

Public Records Request No.: 17-295

 FAX NO. :5618024121

FROM :

,.n. 11 2006 12: 31PM P1

LAW OFFICE OF GUY P. FRONSTIN
515 N. FLAGLER DRIVE, SUITE 300 PAVILION
WEST PALM BEACH, FL 33401
(561) 447-4011 * (561) 802-4121 (Fax)

*TIME SENSITIVE MATERIAL*
*PLEASE DELIVER IMMEDIATELY*
FAX COVER SHEET

TO:

Daliah Weiss, ASA

RE:

Jeff Epstein

DATE:

January 11, 2006

FROM:

Guy P. Fronstin, Esq.

NUMBER OF PAGES INCLUDING COVER SHEET: 2
Please see attached letter.

THANK YOU FOR YOUR ASSISTANCE IN THIS MATTER.

THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRMLEGED, CONFIDENTIAL AND
EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the
intended recipient or the employee or agent responsible for delivery of the message to the intended
recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us immediately by
telephone, and return the original message to us at the above address.

07/26/17

Page 62 of 131

Public Records Request No.: 17-295

 bhUll

FAX NO. :5618024121

J,

11 2006 12:32PM P2

LAW OFFICE OF GUY FRONSTIN
515 N. FLAGLER DRIVE, SUITE 300 PAVILION
WEST PALM BEACH, FL 33401
(561) 447-4011 * (561) 802-4121 (Fax)
SENT VIA FACSIMILE TRANSMISSION

January 11, 2006

Lanna Belohlavek
Assistant State Attorney
Office of the State Attorney
401 N. Dixie Highway
West Palm Beach, FL 33401
Re:

Jeff Epstein
Third Party Attorney Fee Payment

Dear Ms. Belohlavek:
As you know I represent Mr. Jeff Epstein. Mr. Epstein's house manager,
Yanush Banasiak, was asked to speak with your office regarding the matter
that I represent Mr. Epstein on. In anticipation of Mr. Banasiak's meeting
with your office he decided to retain legal counsel. Yesterday, he met with
and retained, attorney Michael Salnick, who will be attending Mr.
Banasiak's statement in your office today at 1:30 p.m.
Since your questioning of Mr. Banasiak concerns information that he may
have that arises out of his employment with Mr. Epstein, Mr. Epstein will be
paying Mr. Banasiak's attorneys fees. I felt it important to notify you of this
third party attorney fee payment structure and confirm that you have no
objection. Mr. Epstein would like to wire the payment for Mr. Salnick's
representation to Mr. Salnick as soon as possible. Therefore, I would
appreciate your getting back to me today on this issue.
Very truly yours,

Guy P. Fron
GPF/mw
cc: Daliah Weiss
Michael Salnick

07/26/17

Page 63 of 131

Public Records Request No.: 17-295

 IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
vs.

NOTICE OF DEPOSITION

JEFFREY EPSTEIN,
Defendant.

TO:

Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401

RECEIVED B y
MAR 2 6 2008
COUNTY ro

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Cri.mtaliVocedure that on
April 2, 2008 beginning at the hour of 1:30 P.M., at the Palm Beach County Courthouse, 4 th
Floor. 205 North Dixie Highway, West Palm Beach. Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
HALEY ROBSON
COURTNEY WILDE &
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for
such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue,
Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 25' day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
We Palm Beach, Florida 33401
(5 ) 65 -8310
f (56 83 1:691

J
Fl
07/26/17

A. GOLi BERGER, ESQUIRE
da Bar No. 262013

Page 64 of 131

Public Records Request No.: 17-295

 /r, _CIRCUIT COURT OF THE FIFTEENTH
JUDI IMF, CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FtOkIDAt.
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
NOTICE OF DEPOSITION

vs.
JEFFREY EPSTEIN,
Defendant.

TO:

Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on
March 24, 2008 beginning at the hour of 1:30 P.M., at the Palm Beach County Courthouse, 4th
Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
COURTNEY WILDE,
BRITANNY BEALE,
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for
such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue,
Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 17th day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
Wes Palm B ch, Florida 33401
(56 65 -83 f.
fax 56 jI 83. V.91

A. GOLDBERGER, ESQUIRE
JA
Fl ida Bar No. 262013
07/26/17

Page 65 of 131

Public Records Request No.: 17-295

 ATTERBURY GOLDBERGER
RICHARDSON & WEISS, P.A.

A

R KKK

250 Australian Avenue South, One Clearlake Centre
• 1400, West Palm Beach, FL 33401

State Attorney's Office
Circuit Court Division
401 North Dixie Highway
West Palm Beach, FL 33401
33401+4209

07/26/17

C07.41

Page 66 of 131

Public Records Request No.: 17-295

 FAX NO. 581835[4891

MAR-19-2008 WED 10:49 AM

P. 01/01

IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
vs.

NOTICE OF DEPOSITION

JEFFREY EPSTEIN,
Defendant.

TO:

Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on
March 24. 2008 beginning at the hour of 1:30 P.M., at the Palm Beach County Courthouse, 4th
Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
COURTNEY WILDE,
ITANNY BEALE,
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for
such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue,
Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 17' day of March, 2008.
Al 1ERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
Wes Palm B h, Florida 33401
(56 65
fa 56 i 83, ,:,91
A. GOLDBERGER. ESQUIRE
FIT da Bar No. 262013
07/26/17

Page 67 of 131

Public Records Request No.: 17-295

 P. 01/01

FAX NO. 5618358691

MAR-25-2008 TUE 11:46 AM

LCUNY\°"VC-7--rIN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
vs.

NOTICE OF DEPOSITION

JEFFREY EPSTEIN,
Defendant.

TO:

Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on
April 2, 2008 beginning at the hour of 1:30 P.M., at the Palm Beach County Courthouse, el'
Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
HALEY ROBSON
COURTNEY WILDE
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for
such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue,
Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 25th day of March, 2008.
ATTERBURY, GOLDBERGER. & WEISS, P.A.
250 Australian Avenue South, Suite 1400
We Palm Beach, Florida 33401
(5 ) 65 -83 10
691

J
Fl
07/26/17

A GOL BERGER, ESQUIRE
da Bar No. 262013

Page 68 of 131

Public Records Request No.: 17-295

 JAN-29-2008 TUE 10:50 AM

FAX NO, 561.13:691

P. 01/01
La
1/CIF

IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
vs.

NOTICE OF DEPOSITION

JEFFREY EPSTEIN,
Defendant.

TO:

Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on
February 6, 2008 beginning at the hour of 9:30 A.M., at the Palm Beach County Courthouse. 4'h
Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
Wit:

9:30 A.M.
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such
other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERI1FY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee(s) by mail this 29'h day of January, 2008.
IERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
West Palm each, Florida 33401
(56 659-• 00 /
1
fa 561)

J C 7A. OLDBERGER, ESQUIRE
ori a Bar No. 262013

07/26/17

Page 69 of 131

Public Records Request No.: 17-295

 IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
NOTJC,E OF DEPOSITION

vs.
JEFFREY EPSTEIN,
Defendant.

TO:

Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on
April 11, 2008 beginning at the hour of J 0:00 A.M. at the Palm Beach County Courthouse, 4th
Floor, 205 North Dixie Tlighway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
•• I

•—• •—• •

sz—adk

.....••••••••••

Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such
other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue, Suite
340, Coconut Grove, Florida 33133 and Jeffrey M. Herman, Esquire, 18205 Biscayne Boulevard,
Suite 2218, Miami, Florida, 33160 by via fax & mail this 20''' day of March, 2008.
ATTERBURY, GOLDBERGER & WEISS, P.A.
250 Australian Avenue South, Suite 1400
We Palm Beach, Florida 33401
(56:' 659-8300
fa 56 835-8691

JAI A.

07/26/17

10/10

Page 70 of 131

16995E8195 'ON XVJ

LDBERGER, ESQUIRE
o 262013
Public Records Request No.: 17-295

WV 95:01 NOW 8002-pe-du

 FEB-08-2008 FRI 03:55 PM

FAX NO, 5618'k8691

P. 01/01

IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
vs.

NOTICE OF DEPOSITION
(Time change only pursuant to the request of Theodore ), Leopold, Esquire)

JEFFREY EPSTEIN,
Defendant.

TO:

Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on
February 20, 2008 beginning at the hour of 2:00 P.M., at the Palm Beach County Courthouse,
4"' Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
2:00 P.M.
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such
other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee, Thedore J. Leopold, Esquire, 2925 PGA Boulevard, Suite
200, Palm Beach Gardens, Florida 33410 and Jeffrey Herman, Esquire, 18205 Biscayne Boulcvaryl,
Suite 2218, Miami, Florida, 33160 by via fax & mail this 8th day of February, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, Florida 33401
(561) 659- 300
f. (5 1) 5 86
1
►s

A. GOLDBERGER, ESQUIRE
Fl lri.da Bar No. 262013
07/26/17

Page 71 of 131

Public Records Request No.: 17-295

 s.

IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
NOTICE OF DEPOSITION

vs.

(Time change only pursuant to the request of Theodore J. Leopold, Esquire)

JEFFREY EPSTEIN,
Defendant.

TO:

Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on
February 20, 2008 beginning at the hour of 2:00 P.M., at the Palm Beach County Courthouse,
46 Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
2:00 P.M.
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such
other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee, Thedore J. Leopold, Esquire, 2925 PGA Boulevard, Suite
200, Palm Beach Gardens, Florida 33410 and Jeffrey Herman, Esquire, 18205 Biscayne Boulevard,
Suite 2218, Miami, Florida, 33160 by via fax & mail this 86 day of February, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, Florida 33401
(561) 659- 300
fa (511) 5-86

07/26/17

J
A. GOLDBERGER, ESQUIRE
Page
72
of 131
Public Records Request No.: 17-295
Fl rida Bar
No. 262013

 nwl

i“ca aciudi

FL 53401
affr
ar
IDT '4.410 $0.410 $0410
.410 IIMETER

ATTERBURY GOLDBERGER WEISS,

Ult 1:L8 Od 08

One Clearlake Centre, Suite 1400
250 Australian Avenue South West Palm Beach, FL 33401

fr

5843979

NCL FEB 11 Br.t 8 S8
Office of the State Attorney
Lanna Belohlavek, Esquire
410 North Dixie Highway
West Palm Beach, Florida 33401

3340i$42i0 CO21

4

07/26/17

111111111111111111111111111111111111111111111111111111411111n

Page 73 of 131

Public Records Request No.: 17-295

 IN THE CIRCUIT COURT OFT HE
15111 JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY
FLORIDA
JANE DOE, by and through
JANE DVS MOTHER as parent and natured
gnat Wan.

CASE NO:

Plaiatiffs.
fa.

JEFFREY EPSTEIN, HALEY ROBSON.
and SARAH KELLEN,
Defendants.

COMPLAINT
PlandifF4, JANE DOE, by and through JAM DOE'S MOTHER as patent and natural
guardian of JANE DOE. brings this Complaint wind Defendaeds JEFFREY EPSTEIN,
HALEY ROBSON. and SARAH KELLEN. and 3!:ale:; 1.3110111:
Parties, Jurisdiction and Venue
lane lice is a Callen and grfickau of the State of 3 Wilda She is a minor under the age o
IS yews
2. Jane Doe Does Mother bongs this action by and through hex Mother who is patent and
natural guardian of Jane Doe
3 Ihis Complaint is brought under fictitious name= to protect the identity of the ,.tium
Planuirt bztause tIu Complanit mates amisenve allegations of sexual ass-ault and abuse upon a
Maar

4

DefesaJard kffrey Epstem is a citizen asidresident of the State of New York

5

Mandan Haley Robwa is a c rtu and iesidem of Palm Beach County, I' londa

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 0

Defendant Sarah Kellen is a amen and resident of the,Staadot New.Torg
Itus v. as action for dating at exact of Fifteen llossand Dollars tS1:t 030 cicbttt ;:t

sitemst and rods
8

Vet9.,7 is proper m this COWL under ',MIMI 4 7 011 Honda Statutes, because the mist t of

action twilight herein accrued in Palm Beach County, Flattla and one or more Defendants
Paha Beach County. Ronda
Factual Ahognuows
9

At all televant times, Defendant Jefhey Epstein was an adult male. Epstein n a financier and

ri-ertalltea Went:
0r,
lee:

money nnaspeee sine a secret clientele limited exclustvely to billionswes. lie is a man of etemenclaiu
wealth, power aid influence He mardams his principal bone in New Tort and also owns resits:noes
Si New Mexico. St Thomas a-st Palm Beach Flonda The allegations herein coucesn Epittesis
condna wink a his lasull l912le NI Palm Beach
10 Upcs:Infounatou and betief, Epstein has a seanal pieta-mice and olitittinOtt the 911119:4

lie cuelPed an a Plan scheme, andfot euttryerse m witch he gamed aCess to is:wittily economically
disadvantaged minor gals in his hour, sexually aciutted these gills ce corned or anempsec to

i

gaga them to engage in picatuntson, and Den gave them stoney her or stow MS lane Doe. Des
14 yea s ok1. fen into Epsteuis trap and LeC4nit one of leis vaunts
II_ Upon tnfolirialion and belief, Jeffrey Epstein canted out Um schemeenterptile and assaulted
Vats m Honda, New Yost and on his plink' island, known as Little St. James, m St. Thomas
12 An integral player m Epstetn's Honda schnue'elacipnse way Sash Kellen. an assistant of
Epstein's Boon New Test New Tint aid Haley Robson a Palm Beach Conamuuty (.:allege student
nom Losatiannee, Florida They fttlUlltd girls oda-usably to give a wealthy was a 111913^,4„it em
mammy odinpensztice in Ins Palm Beadi mansion. Utelti Epitein's planretiltlpfiSe. M9. Robson
was coreacted dmetly befoge or soon alley Epstein way a le* Palm Beal residence. Epstein KeCca

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 or someone on Weil behalf directed sits_ Rotoort to thing one or more trilder*e guts to the ressice.
Mt Robscw upon ittilataidlOa and belief teacloth sought ou eronoreacally disolvessaged

undcrege Fuji bola Losaliatchee and sunounding

NM

who nould tea enticed by the Toomey nett*

offered lye-LI:catty irird to 530 pal .nias .-,ge session - and ate note perceived as leas In.tly to
COlapiaM to ailtitOlttte-5 01 have aeddsolity if aneg3110/13 OflatyMpta cctuhael were made. TM; T.,!.;ti art

unpanant denier* orEpnean's plonemeignive
13 Epsteins p4n. !thong, andior enterpase reflected a panieultor pattern and method Upon
serval at Epaesn's mansion :it. Robeen would alltatalte tale Vaatta to Steals Kellett frAnIVI
a3511tald. lain gathered the gars pCM1123 alfaMMOIL Malabar her 112111t and telephone number.

Ms. Kellen would then bring the gun up a Meg of stairs to a bedroom that contained a massage table
in addition to other finsitstimis. There were photographs of node women lining the stairway hall and
w the bedroom Ms. Kellen n ouid then leave the girl alone in this wont whaeupon Epstein would
MCI wearute only a towel lie would then :more ins towel. lay dawn naked on the tnassage noble,

and direct the girl to remove her clothes. tie (Tea would pet-Kinn one or more lewd. lascivious and
sexual acts. including masturbalson, touching the girl's v*itia with a vibrator, or digitally penetrating
the Furs roma and coerce or ;tempt to con cc Metro( to engage in lewd acts ram pioniumon

14. Cancroid With the foregoing plan scheme, stdof enterpitte, Ms. Robson relaulled lane
Dot to give Epstein a ata.=Sagt for 1110tIttaly companenan Ms Robson brought lase Doe to
Epstein; mansiors inn Palm Beads Jane was untoducod to Sarah Kellen who led her up the Matti of
tuns to the MOM with the massage table Ms. Mien set tip the inessve table and had out me:Agg
MI5

and told lane Do: tine Epstein would be in shortly. aid than left tlw room. Jane Doe was 'Corte in

the room when Epattm saved, k:pstein told her to semi-; hes clothes and HA the room. When
Epstein returned he was wearing only a towel He removed his towel. and laid down on his
stomach on the giggsage table. Epstein again told Jane Doe to remove her dollies. In shock. fen

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 and nepidasion. lane Doe complied, ismos-mg hex Maus except rot her paUlle5 and bra Shortly
after starting to rub Epstettia bad., EpsWin told lane Doe to sit on ho back lane Doe. ow of feat
and trepidation Contplied. After a period of tune Epstein got up horn the table and went betund
the does lot seven' uniustes Jane Doe beard loud noises and moans and believes that Epstein
was mastunialmg. Thereafter Epstein, naked, returned to the massage. table and laid face up on
the table Epstein than told Jane Doe to continue with the massage and told het to sit on top of
him Out of tear and trepidation she complied. As lane Doe tubbed Epatettia chess Epstein
began to use a vibrator on Jane Doe's xagina. Thereafter Epstein began to digu ally stimulate and
attempt to penetrate fank,Prse:s. vagina. Al this same time, Epstein was mastoids-Xing Upon
reaching orgasm, Epstein got up from the M2432,1% table and told Jane Doe to write down her
name and phone number and then left the room
li lag Doe was then attic to get Messed. leave the mom and go back down the stair and
Into the kitchen EDStein. Robson and Kellen were waning for lane Doe Epstein paid Jane Doe
3300 Ms Robson 'a-as pad 5200 by Epstein foi bunging Sant to him. Ms. Robson b10104 .1331e
Dot home.

16 As a result of this encounter with Epstein. the 14-yeas old lane Doe experienced
confannn. shame, htrttubatton, embaaassinent and the :Loault acid het hfe two a downw ard

apical
COUNT I
Sexual Amid( against Defendant Epstein
1 Plaintiff Sane Doe, by and thiough her Mother, as parent and manial guardian, reprgst

ieautathada Indent,
I lefts
0', FY* Was

and reanilt 3 dangTap315 1 through 16 above
10 De Uncial:A Epsiem factiously assauhed Jane Doe sexually in or about 2i)O,

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 19 This seXUal assault was it violation of Chaplet 800 of the Florida Statutes. %Ouch
tecoginisei 3. a chute the lewd and lascivious acts committed by Epstein upon lane Doe.
20. As a direct and psoximate result of EyAkin's axiaull on hue Doe the has ;gifted and
will continue to Sulky sevete and pettlianeol IlaWitatic nom-3. toCludtng mental psychological
and emotional damages.
WHEREPOKE. plaintiff Jane Doe. by and tluougti her Mother., as paten and netutal
guardian. 6cloand3 judgment against llama= krney Eptileitt rot consprnaatOry clasnaf
coal. aUarocy'S fees. and such other and ftutbes relief as this Cotut deems lux and popes
FUrther. PI muff !turves the fight to amend this Complaint to add a claim roe punitive damages
pursuant to Florida Law.

COUNT II
Civil Conspiracy ogidula Defendants Epstein, Robson and Kellen
21. Plantar lane Doe bi and through lin Mollie: a parent and natu.il guardian. a-p: a;

f ...made& Wont:
tot,
f*ga tne.

and rtallert3 pasaittap16 1 through 16 above
22.1Tefroulants Epstellt. Rotr3on and Kellen complied to subject Jane Dcte to the resod
assault of De Tendait Epstein
23 Each of the Dekrulants commuted an ovra act in pm-mance of this consult:icy.
Defendant Robson used false pretenses to lure lane Dc: to the home of Defendant Epstein so
tha Ewen. could sexually assault lane Doe, Defendant Kellen delivered Low Doe to Defendant
Epstem's tiediOnen so that Epstein could sexually aisault Jane Doc. and Defendant Epstein
actually committed sexual assault agatim lane Doc

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 24. As a direct and proximate result of Defendants' civil conspiracy. Jane Doe has suffered
and will continue to suffer severe and permanent oaurrizic injuries. including mental,
psychological and efROLICCIal damages.
WHEREFORE. Plaint R' Jane Dot. by and through her Monier, as vaunt and natural
guardian demands judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah
Kellen for compensatory damages. costs. attorney's frets. and such other and higher relief as this
Court deems ptst and proper. Further, Plaintiff reserves the right to amend Dos Complaint to add
a claim for punitive damages pursuant to Honda Law

[-Mtn Ill
Intentional Innis Min of Emotional Distress against Defendant Epzein
25 rlar4aff Jane Doe, by and thromilr her htsdres a putts and nzural ouardian. reptsts.

- iadasorttork Wu*
La% V. First Ina,

and realleges paragrapIr i through 16 antscr
26 Epsteins conduct was rut =anal en reckless
2-1. Epsteins conduct was outrageous. going beyond all bounds of decency
28 Epstems conduct caused severe emotional dispels not only to Jane line. Epstein knew
of had reason to know that his nutritional sod outrageous conduct would cause emononal trauma
and damage to lane Doc,and her mother
29. As a direct and proximate result of Epnein's intentional or reckless conduct, lane Doe
well continue to aurrei severe mental anguish and pan.
WHEREFORE, Plandtfl hat Doc. by and through La Mother as petal and natural
guardian, demands, and lane Doe's Mother indivictuallN, demand judgment against Defendants
Jeffrey Epstein. Haley Robson. and Sarah Kellen for compensatory damages. costs, attorney's
fee:, and such other and further relief as this Court deems tun and proper Further. Plaintiff

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 rescnir; the right to amend this Complaint to add a chum for puruttve dan pc; pormu
Honda Law.
COUNT IV
Civil Remedy for Violation of Florida Statute Section 772.103 against
Defendants Epstein, Robson aad Kellen

30 ilioiff Jane floe, by and through her Mother.:s patent and nowal guardian.. opals.

j•Iti 0'. Fait 0.10

and reallegetPalaSraphs I through 16 above.
31. Defendants participated in an enterprise, or coospired or endeavored to so participate,
Duough a pattern otenimnal activity in violation of Florida Statute section 772.103i 31.(4)
Deititnards nlaged in this palteto of criminal activity by togaigna mat least two or the
fulloning incidents of criminal activity with the same or similar intents. results accomplices.
VICIIMS. and methods of commission wnhot a 5 year period
P,Or Ullng s persimmon. or causing to be prostituted am person wins sr under

the aft of IS yeses in VIOLZOOSI of Floods Statute section 796 03,
b. Soliciting, inducing, entiong. or punning another to commit prostrumon.
lewdness, or assignation in violation of Florida Statute section 796.07P1(fi, or
aiding, abetting of participating In soda acts in notation of Florida Statute section
796.97(2)(4
Knowingly retooling. enticing. !albedo'?, ltamporting, provieung, or obtaining
by any means a person. knowing that force, fraud. or coercion will be used to
cause that person to engage in plOgitUt1011 in violation of Florida Statute section
7015.946 or
Cl Fooling, compelling, or coercing anodic. to become a prostitute in violaion Of
Fianna Stamm section 796,04

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 33 Under Defendants' plan. schemr and entt [mire. Delbndant Epstein pad Delindant.

47—
ricsirettidi iniuro
Fist I"'

Robson to repeatedly fond and bong him tutilmage erns, who weer dein-and to Epstein by
Defndant Rabson and Kellen. in order for Epstein to soma[, induce, coerce. entice, compel
font such gals to engage to acs of prostitution andrnt lewdness
34 ilaninff lane Doe wan the menu' of Defendants' plan. scheme and rnierpilSC Defendant
Robson toe...Elam Doe to Nineties home under the rename that lone Doc wear be paid to give
Epstein a manage. Defendant Kellen delivered Jane Doe to a mom with a massage labia and
told that EpArin would be in shoddy. lane Due was alone in Lbe room when Epstein alined.
Epstein told ha to remove her clothes aid left the mom When Epstein returned he was %vexing
only a towel lie =Moved his towel and laid down on lus stomach on the massage table Epsom
again told lane Doc remove he; clothes In shock, fen and trepidation, lane Doe complied,
removing her clothes except for her panties and bra Shortly after starting to rub Epstein' 5 back.
Epstein told brio Doe IL ail on ho back. Jane Doe. cm of feat and nepsdation, complied. Alias a
period of Wilt Epstein got up from the table and went behind the door. For sesetat tumbles Jane
Doe head loud noises and moans and believes that Epstein was MaSturbuiug Thereafter
Epstein, naked. ieninmd to the massage table and Ind face up on the table. Epstein then told
lane Doe to continue with the massage and told lies to ad on top of him Out of fro and
trepidation. .he complied. As Jane Doe rubbed Epsicuas chest, Epstein began to Use a vibrator
on Jane Does vagina. Thereafter; Epstein began to digitally stimulate and aftempt to penetrate
inn Does vagna At this saute time, with his other hand, Epstein was otanurbatum

pan

reaching Orgasm, Epstein pot np from the massage table and told lane Doe to inar down het
name and phone number and then led the loom

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 - 35 lane Doe was then able to get dressed. leave the room and go back down the sou: :not
into the kitchen. Epstein Robson and Kellen were waiting for lane Doe. Epstein paid lane Poe
S300 Ms Robson WAS paid 5200 by Epdein for bringno lane Doe to hint. Ms Robson tiimight

Jane Doe home
%THEREFORE. Plaintiff Jane Doe by and through het Mother, as parent and nranal
guardian. demands judgment against Defendants Jeffrey Epstein. flaky Robson. and Sarah
Kellen for eneflpelltnlOry damages, treble damages wider Florida Statute section 772.104. cows
and 2110111er s S fees under Florida Statute section 772 101. and such °dim and Rather rehear dus

Court deertii Just arid prows nuttier. Plaintiff revives the tight to amend dm Complann to add
a dant fo punitive Multaetl pal5112111 to Florida Law

JURY TRIAL DEMAND
PlaanniSS demand a jury Ind in Our action

Dated. March

. 2008

Respectfully nitututted.
ItICX1-LEOPOLla,P A

3925 PGA. Ned.. S4106200
Palm Reath Ondern, FL 13410
Pince 541404-6300
Fae 361-097-23M

Ely .
THEODORE J. LEOPOLD
Florida Sat No.: 705808

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  5.2157?. 



gag/NAM

07/26/17 Page 83 of 131 Public Records Request No.: 17-295

Page 2

1 APPEARANCES:
2
3
4

On behalf of the State:
DALIAH H. WEISS, Esquire
ASSISTANT STATE ATTORNEY
401 North Dixie Highway
West Palm Beach, Florida 33401
561.355.7100

5
6
7
8

On behalf of the Witness:
DONNIE MURRELL, Esquire
L.D. MURRELL, P.A.
400 Executive Center Drive
Suite 201
West Palm Beach, Florida 33409
561.686.2700

9
10
11

ALSO PRESENT:
DETECTIVE JOE RECAREY
Palm Beach Police Department

12
13
14
15
16
17
18
19
20
21
22
23
24
25

3. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
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 Page 3

INDEX

1
2
3

PAGE:

WITNESS:
JUAN P. ALESSI
EXAMINATION BY DET. RECAREY

4

4
5

NO

EXHIBITS

MARKED

6
7
8
9

,

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION

561.835.9738
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 Page 4

Sworn statement taken before Susan

1
2

Shelling, Registered Professional Reporter and Notary

3

Public in and for the State of Florida at Large, in the

4

above cause.
- - -

5
6

Thereupon,

7

JUAN P. ALESSI,

8

having been first duly sworn or affirmed, was examined

9

and stated as follows:
MR. MURRELL: I just want to repeat that

10
11

we're here under the State investigative subpoena

12

that was served on Mr. Alessi, although it was

13

dated for, I believe, Wednesday or something.

14

This is Monday the 21st, and we are here by

15

agreement.
EXAMINATION

16
17
18

BY DET. RECAREY:
Q.

Mr. Alessi, I'm Detective Joe Recarey with

19

the Palm Beach P.D. As I explained to you on the

20

telephone, I am conducting an investigation on a former

21

employer of yours.
I just spoke with your wife and she told me

22
23
24
25

you guys worked for Mr. Epstein for eight years?
A.

Yes, she did work for eight years. I

worked longer. I was there before my wife came.

CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
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 Page 5

1

Q.

Before your wife came.

2

A.

I started full-time with him on January 1,

3

1991, and we both left December 31, 2002. So I worked

4

eleven years exactly. Prior to that, prior to working

5

full-time for him, I worked part-time for him, on-and-off

6

basis.

7

Q.

What were your responsibilities?

8

A.

In the full-time basis, I started as a

9 houseman, and I became a major domo and butler and
10 everything else, driver, and did everything. We both did
11 all the chores in the house, but I was in charge of the
12 house. I was above my wife and above the cleaning crew,
13 the gardners, pool people. So I was house manager, major
14

domo.
Q.

You would have been the go-to guy for the

17

A.

Yes. And the one who would get the blame.

18

Q.

We are talking about Jeffrey Epstein?

19

A.

Of course.

20

Q.

Do you remember the address of the house?

21

A.

558 El Brillo.

22

Q.

Was it in the beginning of the street --

23

A.

At the end of the street, on the left-hand

Q.

We're talking about the same house.

15
16

24
25

house?

side.

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1
2

Q.

During the time that he was here, you

prepared the house, did all the chores.

3

Did you do any of the cleaning?
A.

4

Sometimes. Many times. I did -- last two

5

or three years the work was so much that we have to

6

hire

7

week or once a week, then it was twice a week. Depends

8

upon his schedule, because he did not allow anybody at

9

the house except us when he was in town. So when he was

we hire a clean-up crew that they came twice a

10

in town, it was just us doing the cleaning and the

11

cooking, the driving, shopping, everything else.

12
13
14

Q.

Did you stay on property in the guest

A.

Yes and no. We had an apartment right

house?

15

across the bridge. We had an apartment in Tower 1515 on

16

Flagler, and we had an apartment at the house.

17

Q.

Why would you stay at the house, then?

18

A.

We stay at the house mostly when he was

19

there. When he was not in town, we went home. We went

20

to our apartment. When he was there, it was -- the job

21

was just too much to go home 9 o'clock, 10 o'clock and

22

come back 5 o'clock in the morning. We would just stay

23

and sleep and get up and work.

24
25

Q.

When he was in town, did he receive a lot

of guests at the house?

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girlfriend. She was our immediate superior.

2

Q.

Did he have girls come over to give

3 massages?
4

A.

Yes.

5

Q.

How many massages would he have in a day?

6

A.

Sometimes one, sometimes two, three.

7

Q.

Was it the same girl that would come back

8

to do the massages?

9

A.

Yeah, yeah. Not the same girl -- I mean

10 during eleven years, I probably saw a hundred, two
11

hundred different massage therapists.

12

Q.

Did they seem young to you?

13

A.

No, sir. Mostly no. We saw one or two

14

young ones in the last year. Before that, it was all

15

adults.

16

Q.

During your last year when you were working

17 with him, what do you mean that they looked young? Did
18
19
20

they look like they were still in high school?
A.

I remember one girl was young. We never

asked how old she was. It was not in my job.

21

Q.

Right. I understand.

22

A.

But I imagine she was 16, 17. In my

23

judgment, she was 16, 17.

24

Q.

Where would these massages take place?

25

A.

All the time it was in his room. Sometimes

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it was in the balcony of his quarters. His room has a

2

wraparound balcony facing the pool. So the massages were

3

in the balcony outside in the sun, or inside in his

4

bathroom or her bathroom.

5

Q.

Would you set up the room for the massages?

6

A.

Many times. Yes, he will tell me, Set up

7 the room inside my bathroom or in the bedroom or in
8

Elaine's bathroom, or outside on the balcony. And I

9 would go and set up or my wife would go and set up the
10

table.
We had a table in every room of the house,

11
12

the massage tables, for the different guests. Because

13

not only he got massages, all the other guests got

14

massages too. So we have a table -- massage table in

15

basically every room, guest room.

16

Q.

The girls that would come over to do

17 massages, they would massage him first or massage guests?
18

A.

Different times. There were -- mostly they

19 was his massage. Mostly he would get massages.
20

Q.

Would Ms. Maxwell be in the room with him

21 while he was getting the massage?
22

A.

We don't know. Apparently we saw her going

23

upstairs, because it was -- when they went upstairs, they

24

closed -- his quarters, it had a double door, so it was a

25

door on top of the stairs -- I don't know if you've been

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in the house -- and then there's another door going into

2

his room. So it was a long corridor. So everything was

3

closed and nobody saw anything.

4

Q.

Would you clean up after?

5

A.

Once in a while, yes, I did. Most of the

6
7
8
9

times I did. I did the cleanup.
Q.

Did it appear as if there was going to be

more than one massage going on in the room?
A.

More than one massage? I don't know. It

10 was massages. There was massages, because it was a hot
11

oil, and it was -- you know this vibrator, the neck

12

vibrators with the long handles. And towels, a lot of

13

towels. We used a lot of towels in the house. Used like

14

maybe 40, 50 towels a day, because every time he go in

15

into the pool, it was two or three towels. Everything

16 had to be cleaned up. I went most of the time to pick up
17
18
19
20

the room and get it ready.
Q.

Did it ever appear to you that more went on

in the room other than a massage?
A.

I just imagine. I never saw anything. But

21

I imagine there was more than

I never saw anything

22

because it was closed doors. It was never done outside.

23

Q.

Based on the cleanup?

24

A.

Based on the cleanup -- at the end, I

25

cannot say there was. At the end, it was a few times

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that the bed was undone. You know, we make the beds

2 three or four times a day. And sometimes we went to
3

clean up the massage to put it back, the massage table,

4

to pick up the towels, but the bed was undone again. So

5

either he took a nap or he went for a nap, I don't know.

6

Q.

Or something else occurred?

7

A.

Or something else. I cannot.

8

Q.

Did the girls, would they bring their own

9

stuff or they would use his stuff?
A.

10
11

No. We had everything. We had gallons of

stuff, different stuff.

12

Q.

Different massage oils?

13

A.

Different, all kinds.

14

Q.

Different massagers?

15

A.

Different stuff.

1

They would buy all over the world different

16
17

types of -- for different --

18
19
20
21

Q.

Did any of these massagers look like sex

A.

At the end, at the last year that we were

toys?

there they had like sex toys, some of them. I can say

22 maybe three or four occasions that I saw in the sink,
23

they were left out on the sink, and just --

24

Q.

Where would he keep these massagers?

25

A.

When I was there, we keep all the stuff in

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a basket inside Ms. Maxwell's closet. It was a big

2

basket, about this round (indicating), with a cover on

3

it. And we used to pick up from the towel and just dump

4

it in there. That's it. That's the standard we went

5

through.
Q.

What sink would you find those massagers

8

A.

Mostly in his sink, in his bathroom sink.

9

Q.

His bathroom sink?

6
7

in?

Was Ms. Maxwell still his girlfriend at

10
11

that time?

12

A.

Oh, yeah.

13

Q.

Still his girlfriend that you know of right

A.

Yeah. We left, she was still his

14
15
16

now?

girlfriend. I don't know now, but she was still there.

17

Q.

Why did you leave at the end?

18

A.

It was a hard job. It was an incredible

19

hard job. So demanding. Hours were terrible, from

20

5 o'clock in the morning to 10 o'clock at night.

21

Constantly on your feet.
I got very sick. My health went down the

22
23

drain. I was diagnosed with cancer, polycythemia, a kind

24

of blood cancer, and we had to leave. It was just too

25 much for me.

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1

Q.

Sounds like a lot.

2

A.

Yeah. For me and my wife, we both left.

3

Q.

It was very demanding when he was here in

5

A.

It was terrible. Bad job. Pay was good,

6

but we had enough.

7

Q.

4

town?

I know you guys had a falling out a couple

8

of years ago; I guess you weren't working with him

9

anymore. This would have been in 2003. You guys had a

10

falling out, remember?

11

A.

Yeah, we settled that.

12

Q.

That was settled?

13

A.

That was settled with him between us.

14

Q.

Was that --

15

A.

It was an amicable -- it was an agreement,

16 mutual agreement. It was a mistake on my part.
17

Q.

Are there any questions you have of me?

18

A.

No. I told you the truth.
We just imagined things that could have

19
20

happened. I used to talk to my wife all day, working and

21

under that environment. But we didn't know for sure what

22

was going on.
We never heard anything. We never heard a

23
24
25

complaint, or a girl crying.

Q.

Would these massage girls, especially

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towards the end, would they come alone or would they come

2

with other people?

3

A.

Mostly they would come alone. It was one

4

girl, one of the young girls, the one I can't think of

5

it, she would bring somebody else. She'd bring other

6

girls. But I didn't even know the names.

7

Q.

All of them would go downstairs?

8

A.

Yes.

9

Q.

Or would one stay downstairs?

10

A.

Most of the times when that girl came, it

11

was at night. So after dinner -- after dinner, they went

12 to the movies. And by the time they went to the movies,
13 we clean up right away and tried to get out of there.
14

And that was about 8, 9 o'clock at night.
After, when they come back, I don't know

15

16 what happened. Our quarters were a different -- I don't
17

know if you've been in the house, but our quarters were

18

separate.

19

Q.

It's separate.

20

A.

Separate. Before -- that building is new.

21

They build the building in 2001.

22

Q.

The guest quarters?

23

A.

Yeah, the guest quarters.
Before, we had an apartment upstairs.

24
25

Q.

They have the laundry and a little office

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2
3

and the bedroom?
A.

Yes. That was 2001. Before that, we had

an apartment upstairs in their house, in the main house.
In the little rooms upstairs across from

4

Q.

5

his master bedroom?

6

A.

Right.

7

Q.

Was there ever any photographs that you can

8
9
10

recall around the house?
A.

Girls, girls' photographs and guests'

photographs, yes.

11

Q.

Were they dressed or were they naked?

12

A.

Most of them were dressed. It was a lot of

13

entertainment in the pool, around the pool area. But

14

most of them were dressed.

15
16
17

Q.

When was the last time you spoke with

Mr. Epstein?
A.

The last time I spoke with Mr. Epstein was

18

about a week ago, when you left me the card. I got

19

scared because of that fallout that we had, and I thought

20

it was a consequence of that. And I called and says,

21

Jeffrey, what's going on, what's happening? Because I

22

thought it was an investigation against me on his part.

23

Q.

I'm sorry if I gave you that impression.

24

A.

That's why I called him. That's the only

25

reason that I called.

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Before I even spoke to you.

1
2

Q.

Just when you found the card?

3

A.

When I find the card, I get scared. I

4

said, What's going on now? Why are you bothering me now

5

in my house?

6

That's why I called him.

7

He said, John, there is an investigation

8

going on. I have nothing to talk to you. That's it.

9

I said, Okay.

10

Q.

He didn't give you any information as to --

11

A.

No, not a word.

12

Q.

Has anybody else contacted you from

13

Mr. Epstein or his organization, his assistants, his

14

attorney?

15

A.

No, no, no.

16

Q.

Anyone that works for his attorney?

17

A.

For his attorney? Yes. For his attorney,

18 the present attorney? Yes. That was an investigator
19

that it was investigated on his side, I can't remember

20 his name, but I understand it was from Roy Black's
21

office. That was his attorney. And he -- this

22

investigator basically asked me the same questions,

23 exactly the same questions: What did I know, what did I
24
25

know.
Q

When did this happen?

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1
2

A.

This happened about ten days ago -- about a

week ago, ten days ago. I'm not sure what date.

3

Q.

Was his investigator's name --

4

A.

It's the date after I contacted you.

5

Q.

-- Paul, first name Paul?

6

A.

Paul, Paul, yes.
You have the last name?

7
8

Q.

No.

9

A.

He asked me exactly the same questions.

10

Q.

Did he offer you any money?

11

A.

Absolutely not. I would not take it.

12

Q.

Did he tell you not to speak to me?

13

A.

No. He says -- no, he told me not to speak

14

to you. He didn't say that to me. He says, It's your

15

choice. You make that decision.
And he says, If you hire a lawyer, you make

16
17

that decision.
And we feel that was important for us. I

18
19

don't want to be involved with this thing. I'm out of

20

the job three years ago, and that's why we hired

21

Mr. Murrell. He suggested that.

22

Q.

Did he ask you if anybody else has been

23

contacted?

24

A.

No.

25

Q.

Did he tell you that to call him back after

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our meeting?

2

A.

No, no.

3

Q.

Were you to have any contact with him at

4
5

any time after our meeting?
A.

If I will have a contact? I have no reason

6

for it. I have no reason to call Jeffrey or anybody

7

else. This is over, I hope.

8
9

Well, Mr. Alessi, this is basically an

Q.

ongoing investigation, so obviously anything that we

10

discuss hopefully will stay between us. Because it is

11

still ongoing, I wouldn't want this out until the

12

investigation is complete.

13
14
15
16
17

A.

don't know it.
Q.

20
21
22
23
24
25

He contacted you after you called

Mr. Epstein?
A.

Yes.
When I call him and I said, Jeffrey, what's

18
19

It's not going anywhere. Even my kids

going on?
He said, John, I don't know what's going
on. There's an investigation against me.
So then I said, Whew, thank God. I don't
know what's happening.
And then he says, I have an investigator
that is investigating, the same thing the police
isaChossuaikii.110.11iftialiMItameo,

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department is doing. He's going to contact you.

2

And that was the end of it.

3

I think his name was Paul. I only met him

4

for about fifteen minutes, ten minutes.

5

Q.

You met at your house?

6

A.

No, no. I don't want him at my house. We

7

met at Carrabas restaurant, but it was not open, so we

8

met outside Carrabas. It took about ten minutes.

9
10

Q.

Going back to the items that were found in

the sink, can you describe any of those massagers?
A.

11

I only saw two things: It was a big,

I think a vibrator. Big (indicating). And it was

12

big

13

a long -- I hate to -- I'm sorry. It was a long dick, I

14

think. Rubber thing. And there was a thing you used it

15

in the back, the vibrator in the back.

16

Q.

What color?

17

A.

We always had those. Not those toys.

18

Vibrators, we have different types, one for the neck, one

19

for the back. You know the one that has a battery and

20

they move, with balls on it, vibrator. That's it.

21

That's what I find there. I never find anything else.

22

Those two things.

23

Q.

24
25

Do you remember any names of the girls that

might have come over for massages?
A.

Yes. I remember some of them. From the

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beginning? From the end?

2

Q.

As many as you can remember.

3

A.

As many as I can remember.

4

Q.

I know it's been a while.

5

A.

It was Jody. It was Donna. And it was --

6

it was Virginia. It was -- how many? Virginia, Lana.

7

It was also a young girl, but she was not a

8

massage therapist. She came to the house as a friend, I

9

think. I don't think she was a massage therapist. Her

10

name was -- as a matter of fact, she's in a soap opera

11

now, she's a star. Just give me a minute.

12

Nadya Jorlin, J-0-R-L-I-N.

13

There also were men masseuses.

14

Q.

There were men too?

15

A.

There were men. A few. Not that many. A

16

few. I can't remember.
Allison. There was an Allison. There was

17
18

a Dina. I think every name -- girls' names. In

19

eleven years, I cannot remember.

20

Q.

That's fine.

21

A.

There were girls coming and going. There

22 were girls traveling with him as massage therapists.
23 They would travel with him all over the world, because he
24

was in the plane, he got massages on the plane,

25 because -- I know because I used to supply the oils and
-...

J

..114

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the towels for the plane.

2

Q.

Would you clean his plane too?

3

A.

No, no.

4

Q.

Did you ever travel with him anywhere?

5

A.

No, no.

6

Q.

When he went to New York or Arizona or his

7
8
9

private island?
A.

I've been on his island. I've been as a

guest, as a vacation. We just took vacations, and I went

10 to his island in the Caribbean. And I've been in New
11

Mexico. I've been at his house in London. But not as a

12

worker, just vacation.

13

Q.

As a vacation?

14

A.

Uh-huh.
We went to New Mexico for -- it was kind of

15

16 a symposium about how to clean homes. It was this lady
17

who make -- teach all the house people, housemen, and

18

they invited us to Santa Fe, New Mexico, to teach us how

19

to clean homes. That was kind of stupid.

20

Q.

How he wanted it to be cleaned?

21

A.

Yes. We didn't get that much.

22

Q.

Can you think of anything that I haven't

23 asked you that might be relevant to this?
24

A.

I can't think of anything. Basically it's

25 the same questions that the other investigator asked me.

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1

Exactly the same.
I wish I could give you more names.

2
3

Allison --

4

Q.

I'm not going to ask you to do that because

5

I know it's been a long time. I can't think of stuff I

6

did last week.

7

A.

It's been a long time.

8

Q.

If by any chance you are contacted again by

9 his investigator again for any more questions or anything
10 or any packages that he may deliver to you
11

A.

They have to go to Mr. Murrell.

12

Q.

I was going to say, have him contact your

13
14
15

attorney.
MR. MURRELL: Packages? Are we expecting a
delivery of something?

16

DET. RECAREY: No. I'm just saying --

17

MR. MURRELL: Okay. Just making sure there

18
19
20

wasn't something I didn't know about.
DET. RECAREY: I.e., gifts, et cetera.
That kind of thing.

21

THE WITNESS: No.

22

DET. RECAREY: I would appreciate a phone

23
24
25

call just to give me a heads up.
THE WITNESS: I do not intend to contact
him at all.

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DET. RECAREY:

2

And that's it.

3

(Thereupon, the sworn statement was

4
5

Okay.

I appreciate it.

concluded at 1:05 p.m.)
-

-

-

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

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1 THE STATE OF FLORIDA,
2 COUNTY OF PALM BEACH.
3
4
I, the undersigned authority, certify that Juan

5
6

P. Alessi personally appeared before me and was duly

7

sworn.

8
9
10

WITNESS my hand and official seal this 5th day
of December, 2005.

11
12
13
14
15
16

/Susan Shefing, RPR
Notary Pu.lic - State of Florida
My Commission No. DD 098441
My Commission expires 3/7/2006

17
18

_"ffuw9e.
ires Moth 7, 2006
Bonded Ms
ithmtle ilonedngCo.lue,

19
20
21
22
23
24
25

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1

CERTIFICATE

2
The State Of Florida,
3 County Of Palm Beach.
4

5
6
7
8
9
10
11

I, Susan Shelling, Registered Professional
Reporter and Notary Public in and for the State of
Florida at Large, do hereby certify that Juan P. Alessi
was by me first duly sworn to testify the whole truth;
that I was authorized to and did report said sworn
statement in stenotype; and that the foregoing pages,
numbered from 1 to 24, inclusive, are a true and correct
transcription of my shorthand notes of said sworn
statement.
I further certify that said sworn statement
was taken at the time and place hereinabove set forth and
that the taking of said sworn statement was commenced and
completed as hereinabove set out.

12
13
14

I further certify that I am not an attorney or
counsel of any of the parties, nor am I a relative or
employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
action.

15
16
17
18

The foregoing certification of this transcript
does not apply to any reproduction of the same by any
means unless under the direct control and/or direction of
the certifying reporter.
IN WITNESS WHEREOF,
and seal this 5th day of D

have he
r, 200

t my hand

19
20
21
22

S san S rOr ling/ Notary. Public
n and or the State of Florida
My Commission No. DD 098441
My Commission Expires 3/7/2006

23
24
25

J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
07/26/17

Page 106 of 131

Public Records Request No.: 17-295

 Page 27

A
Absolutely 18:11
action 26:14,14
Adam 8:11
address 5:20
adults 9:15
affirmed 4:8
ago 6:5 14:8 16:18
18:1,2,2,20
agreement 4:15
14:15,16
Alessi 1:6 3:2 4:7
4:12,18 19:8
25:6 26:6
Allison 21:17,17
23:3
allow 7:8
amicable 14:15
and/or 26:16
Annie 8:20
anybody 7:8
17:12 18:22
19:6
anymore 14:9
apartment 7:14
7:15,16,20
15:24 16:3
Apparently 10:22
appear 11:7,18
APPEARANCES
2:1
appeared 25:6
apply 26:16
appreciate 23:22
24:1
area 16:13
Arizona 22:6
arrangements
6:24
asked 9:20 17:22
18:9 22:23,25
assistant 2:3 8:5
8:18,19,22
assistants 8:3,4
17:13
Associates 1:24
attorney 2:3
17:14,16,17,17
17:18,21 23:13
26:12,13
authority 25:5

authorized 26:7
B
B 3:5
back 7:22 9:7
12:3 15:15
18:25 20:9,15
20:15,19
Bad 14:5
balcony 10:1,2,3
10:8
balls 20:20
Based 11:23,24
basically 6:7 8:24
10:15 17:22
19:8 22:24
basis 5:6,8
basket 13:1,2
bathroom 10:4,4
10:7,8 13:8,9
battery 20:19
Beach 1:1,4,11
2:4,8,11 4:19
25:2 26:3
bed 12:1,4
bedroom 10:7
16:1,5
beds 12:1
beginning 5:22
21:1
behalf 2:2,5
believe 4:13
big 13:1 20:11,12
20:12
Black's 17:20
blame 5:17
blood 13:24
boss 6:14 8:25
bothering 17:4
bridge 7:15
Brill° 5:21
bring 12:8 15:5,5
build 15:21
building 15:20,21
butler 5:9
buy 12:16
C

C 26:1,1
cal118:25 19:6,18
23:23
called 16:20,24,25

17:6 19:15
cancer 13:23,24
card 16:18 17:2,3
Caribbean 22:10
Carrabas 20:7,8
cause 4:4
Center 2:7
certification
26:15
certify 25:5 26:6
26:10,12
certifying 26:17
cetera 23:19
chance 23:8
charge 5:11
chef 8:7,7,13,15
chef's 8:9
choice 18:15
chores 5:11 7:2
clean 11:4 12:3
15:13 22:2,16
22:19
cleaned 11:16
22:20
cleaning 5:12 7:3
7:10
cleanup 11:6,23
11:24
clean-up 7:6
closed 10:24 11:3
11:22
closet 13:1
color 20:16
come 6:21 7:22
8:17,17 9:2,7
10:16 15:1,1,3
15:15 20:24
coming 6:22
21:21
commenced 26:11
Commission
25:15,16 26:22
26:22
complaint 14:24
complete 19:12
completed 26:11
concluded 24:4
conducting 4:20
connected 26:13
consequence
16:20

Consor 1:24
Constantly 13:21
contact 19:3,5
20:1 23:12,24
contacted 17:12
18:4,23 19:15
23:8
control 26:16
cooking 7:11
correct 6:19 26:8
corridor 11:2
counsel 26:13,13
County 1:1 25:2
26:3
couple 14:7
course 5:19
cover 13:2
crew 5:12 7:6
crying 14:24
D
D 3:1,5
DALIAH 2:2
date 18:2,4
dated 4:13
day 9:5 11:14
12:2 14:20 25:9
26:18
days 18:1,2
DD 25:15 26:22
deal 6:8,14
December 5:3
25:10 26:18
decision 18:15,17
deliver 23:10
delivery 23:15
demanding 13:19
14:3
department 2:11
20:1
Depends 7:7
describe 20:10
DET 3:3 4:17
23:16,19,22
24:1
Detective 2:11
4:18
diagnosed 13:23
dick 20:13
Didier 8:13
different 9:11
10:12,18 12:11

12:12,13,14,15
12:16,17 15:16
20:18
Dina 21:18
dinner 15:11,11
direct 26:16
direction 26:16
directly 6:8,15
discuss 19:10
Dixie 1:10 2:3
doing 7:10 20:1
domo 5:9,14
Donna 21:5
DONNIE 2:6
door 10:24,25
11:1
doors 11:22
double 10:24
downstairs 15:7,9
drain 13:23
dressed 16:11,12
16:14
Drive 2:7
driver 5:10
driving 7:11
duly 4:8 25:6 26:6
dump 13:3
E
E 3:1,5,5 26:1,1
eight 4:23,24
either 12:5
El 5:21
Elaine 6:17
Elaine's 10:8
eleven 5:4 6:21
9:10 21:19
employee 26:13
employer 4:21
English 8:15,20
entertainment
16:13
environment
14:21
Epstein 4:23 5:18
6:9 16:16,17
17:13 19:16
especially 14:25
Esquire 2:2,6
et 23:19
exactly 5:4 17:23
18:9 23:1

J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
07/26/17

Page 107 of 131

Public Records Request No.: 17-295

 Page 28

EXAMINATION girls 9:2 10:16
12:8 14:25 15:4
3:3 4:16
15:6 16:9,9
examined 4:8
20:23 21:18,21
Executive 2:7
21:22
expecting 23:14
give 9:2 17:10
expires 25:16
21:11 23:2,23
26:22
go 7:21 8:17,17
explained 4:19
10:9,9 11:14
F
15:7 23:11
F 26:1
God 19:22
facing 10:2
going 6:7 10:22
fact 21:10
11:1,7,8 14:22
falling 14:7,10
16:21 17:4,8
fallout 16:19
19:13,19,20
Fe 22:18
20:1,9 21:21
feel 18:18
23:4,12
feet 13:21
good 14:5
fifteen 20:4
gourmet 8:7
financially 26:14 go-to 5:15
find 13:6 17:3
guess 14:8
20:21,21
guest 7:12 10:15
fine 21:20
15:22,23 22:9
first 4:8 10:17
guests 7:25 8:1,2
18:5 26:6
10:12,13,17
Flagler 7:16
16:9
Florida 1:1,11,23 guy 5:15
2:4,8 4:3 25:1
guys 4:23 14:7,9
25:15 26:2,6,21
H
fly 8:19
H 2:2 3:5
follows 4:9
foregoing 26:7,15 hand 25:9 26:18
handles 11:12
former 4:20
happen 17:25
forth 26:10
happened 14:20
found 17:2 20:9
15:16 18:1
four 12:2,22
happening 16:21
French 8:13
19:23
friend 21:8
hard 13:18,19
full-time 5:2,5,8
further 26:10,12 hate 20:13
heads 23:23
G
health 13:22
gallons 12:10
heard 14:23,23
gardners 5:13
hereinabove
getting 10:21
26:10,11
gifts 23:19
hereunto 26:18
girl 8:20 9:7,9,19 high 9:18
14:24 15:4,10
Highway 1:10 2:3
21:7
hire 7:6,6 18:16
girlfriend 6:10,18 hired 18:20
8:25 9:1 13:10
home 7:19,21
13:13,16
homes 6:12 22:16

22:19
hope 19:7
hopefully 19:10
hot 11:10
Hours 13:19
house 5:11,12,13
5:16,20,25 6:24
7:2,9,13,16,17
7:18,25 10:11
11:1,13 15:17
16:3,3,8 17:5
20:5,6 21:8
22:11,17
households 6:11
houseman 5:9
housemen 22:17
hundred 9:10,11

look 9:18 12:18
looked 9:17
J
lot 7:24 8:21
January 5:2
11:12,13 14:1
Jeffrey 5:18 16:21
16:12
19:6,18
L.D 2:6
job 7:20 9:20
M
13:18,19 14:5
M 3:5
18:20
main 16:3
Jody 21:5
major 5:9,13
Joe 2:11 4:18
making 23:17
John 17:7 19:20
manager 5:13
Jorlin 21:12
6:11,11
Juan 1:6 3:2 4:7
massage 9:11
25:5 26:6
10:12,14,17,17
judgment 9:23
10:19,21 11:8,9
J-O-R-L-I-N
21:12
11:19 12:3,3,12
I
14:25 21:8,9,22
K
imagine 9:22
massagers 12:14
K 3:5
11:20,21
12:18,24 13:6
keep 12:24,25
imagined 14:19
20:10
kids 19:13
immediate 9:1
massages 9:3,5,8
important 18:18 kind 13:23 22:15
9:24 10:2,5,13
22:19 23:20
10:14,17,19
impression 16:23
kinds 12:13
inclusive 26:8
11:10,10 20:24
know 8:11,14
incredible 13:18
21:24
10:22,25 11:9
indicating 13:2
masseuses 21:13
11:11 12:1,5
20:12
master 16:5
13:13,16 14:7
inform 6:22
matter 21:10
14:21 15:6,15
information
Maxwell 6:17,18
15:17 17:23,24
17:10
8:22 10:20
19:14,20,23
inside 10:3,7 13:1
13:10
20:19 21:4,25
Maxwell's 13:1
intend 23:24
23:5,18
interested 26:14
mean 9:9,17
investigated
means 26:16
L
17:19
meeting 19:1,4
lady 22:16
men 21:13,14,15
investigating
Lana
21:6
met 20:3,5,7,8
19:25
investigation 1:4 Large 4:3 26:6
Mexico 22:11,15
4:20 16:22 17:7 laundry 15:25
22:18
lawyer 18:16
19:9,12,21
minute 21:11
investigative 4:11 leave 13:17,24
minutes 20:4,4,8
investigator 17:18 left 5:3 6:5 12:23 mistake 14:16
13:15 14:2
17:22 19:24
Monday 1:8 4:14
16:18
22:25 23:9
money 18:10
left-hand 5:23
investigator's
morning 7:22
little 15:25 16:4
18:3
13:20
London 22:11
invited 22:18
move 20:20
long 11:2,12
movies 15:12,12
involved 18:19
20:13,13 23:5,7 Murrell 2:6,6
island 22:7,8,10
longer 4:25
items 20:9
4:10 18:21
I.e 23:19

J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
07/26/17

Page 108 of 131

Public Records Request No.: 17-295

 Page 29
23:11,14,17
mutual 14:16
N
N 1:10 3:1,5
Nadya 21:12
naked 16:11
name 8:9,14
17:20 18:3,5,7
20:3 21:10,18
names 15:6 20:23
21:18 23:2
nap 12:5,5
neck 11:11 20:18
never 8:2 9:19
11:20,21,22
14:23,23 20:21
new 8:12 15:20
22:6,10,15,18
night 13:20 15:11
15:14
North 2:3
Notary 1:23 4:2
25:15 26:5,21
notes 26:8
November 1:8
number 6:2
numbered 26:8
0
0 3:5
obviously 19:9
occasions 12:22
occurred 12:6
offer 18:10
office 15:25 17:21
official 25:9
Oh 13:12
oil 11:11
oils 12:12 21:25
Okay 17:9 23:17
24:1
old 9:20
once 7:7 11:5
ones 9:14
ongoing 19:9,11
on-and-off 5:5
open 20:7
opera 21:10
organization
17:13
outside 10:3,8

P-E-R-R-Y 8:11
11:22 20:8
o'clock 7:21,21,22 P.A 2:6
13:20,20 15:14 P.D 4:19
p.m 1:9,9 24:4
P
Q
P 1:6 3:2 4:7 25:6
quarters 10:1,24
26:6
15:16,17,22,23
packages 23:10
questions 6:7
23:14
PAGE 3:2
14:17 17:22,23
pages 26:7
18:9 22:25 23:9
Palm 1:1,4,11 2:4 quickly 8:16
2:8,11 4:19 25:2 quite 8:10
26:3
R
part 14:16 16:22
R3:5
26:1
parties 26:13
ready 6:24 11:17
party 26:13
reason 16:25 19:5
part-time 5:5
19:6
Paul 18:5,5,6,6
recall 16:8
20:3
Recarey 2:11 3:3
Pay 14:5
4:17,18 23:16
people 5:13 15:2
23:19,22 24:1
22:17
receive 7:24
Perry 8:11
Registered 4:2
personal 8:19,21
26:5
personally 25:6
phone 1:25 23:22 relative 26:13
relevant 22:23
phonetic 8:14
photographs 16:7 remember 5:20
8:9 9:19 14:10
16:9,10
17:19 20:23,25
pick 11:16 12:4
21:2,3,16,19
13:3
repeat 4:10
place 9:24 26:10
report 26:7
plane 21:24,24
Reported 1:21
22:1,2
police 2:11 19:25 reporter 4:2 26:5
26:17
polycythemia
Reporting 1:24
13:23
reproduction
pool 5:13 10:2
26:16
11:15 16:13,13
responsibilities
prepared 7:2
5:7
present 2:10
restaurant 20:7
17:18
right 6:13,23,25
prior 5:4,4
7:14 9:21 13:13
private 22:7
15:13
16:6
probably 9:10
room
9:25
10:1,5
Professional 4:2
10:7,11,15,15
26:5
10:20 11:2,8,17
property 7:12
11:19
Public 1:23 4:3
rooms 16:4
25:15 26:5,21
round 13:2
put 12:3

24:3 26:7,9,10
26:11
stay 7:12,17,18,22
8:7 15:9 19:10
S
stenotype 26:7
S 3:5
street 5:22,23
Santa 22:18
stuff 12:9,9,11,11
saw 9:10,13 10:22
12:15,25 23:5
11:3,20,21
stupid 22:19
12:22 20:11
subpoena 4:11
saying 23:16
suggested 18:21
says 16:20 18:13 Suite 2:7
18:14,16 19:24 sun 10:3
scared 16:19 17:3 superior 9:1
schedule 7:8
supply 21:25
school 9:18
sure 14:21 18:2
seal 25:9 26:18
23:17
separate 15:18,19 Susan 1:22 4:1
15:20
25:14 26:5,21
served 4:12
sworn 1:6 4:1,8
set 10:5,6,9,9
24:3 25:7 26:6,7
26:10,11,18
26:8,10,11
settled 14:11,12
symposium 22:16
14:13
T
sex 12:18,21
Shelling 1:22 4:2 T 3:5 26:1,1
table 10:10,11,14
25:14 26:5,21
10:14 12:3
She'd 15:5
tables 10:12
shopping 7:11
take 9:24 18:11
shorthand 26:8
taken 4:1 26:10
sick 13:22
talk 14:20 17:8
side 5:24 17:19
sink 12:22,23 13:6 talking 5:18,25
Taylor 8:20
13:8,8,9 20:10
teach 22:17,18
sir 9:13
telephone 4:20
sleep 7:23
te1110:6 18:12,25
soap 21:10
ten 18:1,2 20:4,8
somebody 15:5
sorry 16:23 20:13 terrible 13:19
14:5
Sounds 14:1
testify 26:6
speak 18:12,13
spoke 4:22 16:15 thank 19:22
therapist 21:8,9
16:17 17:1
therapists 9:11
stairs 10:25
21:22
standard 13:4
thing 18:19 19:25
star 21:11
20:14,14 23:20
started 5:2,8
State 1:1,23 2:2,3 things 14:19
20:11,22
4:3,11 25:1,15
think 8:11 15:4
26:2,5,21
20:3,12,14 21:9
stated 4:9
21:9,18 22:22
statement 1:6 4:1
Roy 17:20
RPR 1:22 25:14
Rubber 20:14

J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
07/26/17

Page 109 of 131

Public Records Request No.: 17-295

 Page 30

22:24 23:5
thought 16:19,22
three 6:5 7:5 9:6
11:15 12:2,22
18:20
time 6:6,8 7:1 8:6
8:22,23 9:25
11:14,16 13:11
15:12 16:15,17
19:4 23:5,7
26:10
times 7:4 10:6,18
11:6,25 12:2
15:10
told 4:22 14:18
18:13
top 10:25
towel 13:3
towels 11:12,13
11:13,14,15
12:4 22:1
Tower 7:15
town 7:9,10,19,24
14:4
toys 12:19,21
20:17
transcript 26:15
transcription 1:24
26:8
travel 8:5,8,21
21:23 22:4
traveled 8:23
traveling 21:22
tried 15:13
true 26:8
truth 14:18 26:6
twice 7:6,7
two 7:4 8:6 9:6,10
9:13 11:15
20:11,22
types 12:17 20:18
U
Uh-huh 22:14
Um-hum 6:20
undersigned 25:5
understand 6:6
9:21 17:20
undone 12:1,4
upstairs 10:23,23
15:24 16:3,4
use 12:9

V
vacation 22:9,12
22:13
vacations 22:9
vibrator 11:11
20:12,15,20
vibrators 11:12
20:18
Virginia 21:6,6
want 4:10 18:19
19:11 20:6
wanted 22:20
wasn't 23:18
Wednesday 4:13
week 7:7,7,7
16:18 18:2 23:6
WEISS 2:2
went 7:19,19 8:16
10:23 11:16,18
12:2,5 13:4,22
15:11,12 22:6,9
22:15
weren't 14:8
West 1:11 2:4,8
we're 4:11 5:25
WHEREOF
26:18
Whew 19:22
wife 4:22,25 5:1
5:12 6:2 10:9
14:2,20
wish 23:2
Witness 2:5 3:2
23:21,24 25:9
26:18
word 17:11
work 4:24 7:5,23
worked 4:23,25
5:3,5
worker 22:12
working 5:4 9:16
14:8,20
works 17:16
world 6:12 12:16
21:23
wouldn't 19:11
wraparound 10:2
X

X 3:1,5

400 2:7
401 1:10 2:3

yeah 6:1 9:9,9
13:12,15 14:2
14:11 15:23
year 8:4 9:14,16
12:20
years 4:23,24 5:4
6:5,21 7:5 8:6
9:10 14:8 18:20
21:19
York 8:12 22:6
young 9:12,14,17
9:19 15:4 21:7

5
5 7:22 13:20
5th 25:9 26:18
50 11:14
558 5:21 6:3,3
561.355.7100 2:4
561.686.2700 2:8
561.835.9738 1:25

0
098441 25:15
26:22

8
8 15:14
9
9 7:21 15:14

1
15:2 26:8
1:05 1:9 24:4
10 7:21 13:20
12:25 1:9
1515 7:15
16 9:22,23
17 9:22,23
1991 5:3
2
2001 15:21 16:2
2002 5:3
2003 14:9
2005 1:8 25:10
26:18
201 2:7
21 1:8
21st 4:14
24 26:8
3
3/7/2006 25:16
26:22
315:3
33401 1:11 2:4
33409 2:8
358 6:3,4
4
4 3:3
40 11:14

J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
07/26/17

Page 110 of 131

Public Records Request No.: 17-295

  -- 

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9-21-03] DAY 

07/26/17- Page 111 of 131 Public Records Request No.: 17-295

 

        

     

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07/26/17

Page 116 of 131

Public Records Request No.: 17-295

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Jeffrey E. Epstein

07/26/17

Page 117 of 131

Public Records Request No.: 17-295

  

Jeffrey E. Epstem
07/26/17 Page 118 of 131 Public Records Request No.: 17-295



 

Alberto,

I received your short letter with great disappointment. Unfortunately, today, I cannot
accept your "resignation". I'm sorry, but it is not that simple to abandon a "family member", no

snarler how frustrating or good-looking he may be.
limy appreciation for both you and your talent has not been adequately expressed as you
41114
: i Win not spoken directly, I apologise.

I OMR attire )470 have forgotten. but you bed Initially aseared me that the island project
W duet tor £au Christmas. I have Ogee 111 ai beth gracious and generous in forgiving
1111411000 Alfpad by. You and I liarre„Iihrit.a. a unique understanding.

w ► 1110un eater mint leossid be completely the end of July, when in fact, for
allitlher 4v dims or sill inseam Pa* rules for side tables in the living room, has
Imams gps, Illookoirokos
"opposed to give, but eve:Anti! today, I have not been told

*hi maul east Ina gsage
14111041 t 1 a yaar right to take on only jobs iuu went. If Is both unfair, Unfriendly and
ispradholkiliallga gayly leave a job undoes its lie middle. This is not your way. I don't believe
psis vmuid tree a fro Mollify dint *ids the same tresiagant.
..- •
I would hope &myna urn seeneurkkr the big home Wand project. As you know, we

loalekt suety

otlitil*INId bar Iticurrod great expense to get permits and
Nil use dimes nut so move forward, I think at a minimum, my

1611fAll 8611 int ION %the flak of disrepair ha whids it currently sits and should be brought
posabie
— IfJean. who I have great respect for, does pot want to
he is only an employee and as I have my total re 7on tp not with Jean
Cabinet Pinto, the obligation falls on you personally.

1°43 1133°wit iS.4111"

are aware, I was told repeatedly that you would call me upon re
botkvisit and finish the project. You and I have more of a friendship
07/26/17

Page 119 of 131

Public Records Request No.: 17-295

       
  

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Page 1 or

FedEx I Ship Manager I Label 7071254 9,070 ,

From: Origin ID: (212)750-9895
Cecifia Steen
JEFFREY E. EPSTEIN
457 MADISON AVENUE
4TH FLOOR
NEW YORK, NY 10022

Fecias

&pees:

REF: mail
k

A
SHIP TO: (561)832-0232

Jeffrey Epstein

Sip Date:19SEP05
Actual Wgt: 2 LB
system#11513884nNET2200
Account: S .741,:*

511•131540/13

BILIAINDER
414

111111111 11111 I
NI
De ivery Add ess Ba Dodo AU

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358 El Brillo Way

Palm Beach, FL 33480
TUE

PRIORITY OVERNIGHT

TRK#

7 917 3254 9070

33480

-FL-US

Deliver By:
20SEP05

FORM
0201

FLL •

AA

XH LNAA

RES

Shipping Label: Your shipment is complete
1. Use the 'Print' feature from your browser to send this page to your laser or inkjet printer.
2. Fold the printed page along the horizontal line.
3. Place label in shipping pouch and affix it to your shipment so that the barcode portion of the label can be readjnd scanned.
Warning: Use only the printed original label kir shipping. Using a photocOpy of this label for shipping purposes is fraudulent
and could result in additional billing charges, along with the cancellation of your FedEx account number.
Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com. FedEx will not
be responsible for any claim in excess of $100 per package, whether the result of loss, damage, delay, non-delivery. misdelivery, or misinformation.
unless you declare a higher value, pay an additional charge, document your actual loss and file a timely claim. Limitations found in the current FedEx
Service Guide apply. Your right to recover from FedEx for any loss, including intrinsic value of the package, loss of sales, income interest, profit,
attorney's fees, costs, and other forms of damage whether direct, incidental, consequential, or special is limited to the greater of $100 or the
authorized declared value. Recovery cannot exceed actual documented loss. Maximum for items of extraordinary value is $500, e.g. jewelry,
precious metals, negotiable instruments and other items listed in our Service Guide. Written claims must be filed within strict time limits, see current
FedEx Service Guide.
-

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07/26/17
..YWW•fecipv

Page 121 of 131

Public Records Request No.: 17-295
L-i/11,-1?

a A nYtAiaUr.

  

- .f'm Pub'ic RecordSRedw

 

Alberto,
I received your short letter with-great disappointment. Unfortunately, today, I cannot
accept your "resignation". I'm sorry, but it is not that simple to abandon a "family member", no
matter how frustrating or good-looking he may be.
If my appreciation for both you and your talent has not been adequately expressed as you
and I have not spoken directly, I apologize.
I am sure you have forgotten, but you had initially assured me that the island project
would be done for last Christmas. I have always been both gracious and generous in forgiving
the dates that have slipped by. You and I have,l.thotelt, a unique understanding.
Jean, who assured me the project would be completely the end of July, when in fact, for
example, till this day there are still wooden puking crates I or lido tables in the living room, has
yet to contact me. FuruM4re acme supposed to arrive, but even until today, I have not been told
what and when to expect the balance.
Alberto, it is your right to take on only jobs you want. It is both unfair, unfriendly and
unprofessicittlf to simply leave a job undone in the middle. This is not your way. I don't believe
that you would treat a less friendly client with the same disregard.
I would hope that you will reconsider the big house Island project. As you know, we
have bought many things for the interior and have incurred great expense to get permits and
drawings in a Moroccan style, but if you choose not to move forward, I think at a minimum, my
house shotild not be left in the state of disrepair in which it currently sits and should be brought
to completion as soon as possible. If Jean, who I have great respect for, does not want to
complete it as I believe he is only an employee and as I have my total relationship not with Jean,
but with Cabinet Pinto, the obligation falls on you personally. This is only right, you know it is.
As you are aware, I was told repeatedly that you would call me upon return from your vacation
and both visit and finish the project. You and I have more of a friendship than my receiving, in a

07/26/17

Page 123 of 131

Public Records Request No.: 17-295

 frankly iteriehti way, Only a letter and not even the phone call I was repeatedly promised.
(However; I intki• you don't like tension) Please call me at your earliest convenience.
I repait your friend

4 .44 41 /94"3‘

r.f

I
:0

07/26/17

Page 124 of 131

Public Records Request No.: 17-295

  

Jeffrey E. Epstein

 

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Public Records Request No.: 17-295

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PLEASE CALL '7

CAME To SEE YOU WILL CALL AGAIN

To Il?
RETURNED mun CALL SPECIAL ATTENTION

MESSAGE

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07/26/17 Page 131 of 131 Public Records Request No.: 17-295