EFTA02732405

Extracted Text #

*"" CASE NUMBER: 502019CA014681XXMMB Div: AG **** 
Filing # 98869063 E-Filed 11/14/2019 11:06:37 AM 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, CASE NO.: 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
v. 
Palm Beach County, Florida; SHARON R. O AS
DAVE ARONBERG, as State Attorney of 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
COMPL \9 CC
CA Florida Holdings, LLC, publisher m Beach Post, for its Complaint against 
Dave Aronberg, the State Attorney for P Bea County, Florida, in his official capacity ("State 
Attorney"), and Sharon R. Bock, 
official capacity ("Court Cle 
1. ThS " ' an action within the exclusive jurisdiction of the Circuit Court pursuant to 
er f the Court for Palm Beach County, Florida, in her 
as follows: 
JURISDICTION 
Fla. Stat. SeO6. 2(2)(a). 
PARTIES 
The Palm Beach Post is a daily community newspaper published by Plaintiff CA 
Florida Holdings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida. 
3. Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth 
Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and 
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/14/2019 11:06:37 AM 
EFTA02732405

has authority in grand jury proceedings pursuant to Fla. Stat. section 27.03. He is sued herein in 
his official capacity as his office is in possession of documents that are the subject of this action. 
4. Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach 
County, Florida. She is sued herein in her official capacity as her office is in possession of 
documents that are the subject of this action. 
INTRODUCTION 
5. In what is now widely if belatedly recognized as a colossal e of justice — 
which led to the further needless victimization of countless young gi en — a wealthy, 
politically connected, and powerful financier was not held a ta or, nor even forced to 
confront, allegations of serious sex trafficking crimes. ' 1 a that Jeffrey Epstein's 2008 
ISts .,deal with the State of Florida was not consistent w'  gathered against him, what 
remains shrouded in mystery is how that evide resented — and the extent to which it was 
presented — to the grand jury that retumydin in ent far more limited in scope than expected 
and deserved. 
6. Through this ac on, 7jlt1 Palm Beach Post seeks public access to the testimony, 
a iminutes, and other evide ksented in 2006 to the Palm Beach County grand jury empaneled 
during the first E 
example, in 
ability 
in sex use investigation. Typically, access to such materials is limited, for 
pfevent the flight of those whose indictment may be contemplated and their 
al or destroy evidence; to ensure jurors' candor in deliberations; and to protect an 
accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law 
expressly authorizes the disclosure of grand jury proceedings under certain circumstances, 
including, as here, in the furtherance of justice. Fla. Stat. § 905.27(1Xc). 
7. It can no longer credibly be maintained that continued blanket secrecy over the 
proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law. 
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To the contrary, transparency is required to promote public understanding of the criminal justice 
system and public confidence in the fair administration of justice. As detailed below, Epstein was 
accused of sexually abusing and trafficking dozens of women and girls in south Florida (among 
other locations) over a period of several years while exploiting his wealth and political connections 
to obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury 
proceedings will shed light on the extent to which those in our government entrustelid with the 
,,
solemn responsibility of enforcing our criminal laws equally as to all citize lii,lpd their duties ( 
in this instance. Justice will be furthered where it is either (I) demons [list pstein was treated 
like others accused of similar heinous crimes, or (2) as appea re tiltely to be the case, those 
who chose to give Epstein favorable — "unusual," in the Town of Palm Beach Police 
Chief— treatment, are exposed and held accountable Fro w t limited information is now in the 1
Snpublic domain, the State Attorney's referral to ury — which would be out of the ordinary( ri
for this type of case — gives rise to a st infe ce of favoritism and corresponding disregard „c ....,
for the rights of the minor victims E t s sex trafficking. Access to the grand jury materials 
will allow the public to detenn ther the grand jury process, and the secrecy that comes with 
r,it, was used to further jus instead, operated to shield Epstein and his co-conspirators from 
the consequences heir c minal activities. Accordingly, Fla. Stat. Section 905.27 authorizes the 
disclosure o
\
f 's 2006 grand jury proceedings. 
t •••• Even in the absence of such a statutory basis, this Court is empowered to order 
public disclosure pursuant to its inherent authority and supervisory powers over the grand jury. 
Indeed, courts throughout the country in the past several decades have ordered the disclosure of 
high-profile grand jury proceedings pursuant to their inherent authority where the public's interest 
in those proceedings has outweighed the general need for secrecy. This is particularly so where, 
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as here, many of the details of Epstein's criminal misdeeds have already been made available in 
the public domain through extensive news reporting by, among others, The Palm Beach Post; by 
the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves. 
9. In recognition of the sensitivity of the materials being sought, and in the interest of 
protecting any victims who wish to remain anonymous, The Palm Beach Post has no bjection to 
copies of the testimony, minutes, and other evidence presented in 2006 to the PalnPllr h County 
grand jury first being submitted to this Court for in camera review, where be redacted, 
C5as appropriate, to protect those who deserve such protection. 
FACTUAL BACKGRO 
10. The following facts were gathered, in 1 e alyfrom documents obtained by 
The Palm Beach Post through various Florida 
Pubi 
w requests, documents unsealed tgs
M.,or publicly available in other related judicial and information and documents in the 
public record. 
A. First Epstein Sex Crimes l g>stig ion, Indictment, and Plea Agreement: 
2005- 2008. 
11. The investigatio Epstein's sex crimes began more than fourteen years ago, 
when a I4-year-old irl's other reported to police in the Town of Palm Beach, Florida, that 
Epstein and of worked for him arranged for her to give Epstein a "massage." Epstein 
required the gt trip, exposed himself, and masturbated while touching her. The girl was paid 
$300. Ep n was 52 years old at the time. 
12. Following this initial report in 2005, the Town of Palm Beach Police, and later, in 
2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and 
seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with 
disturbingly similar details, with each of the other victims. 
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13. Both the victim/witness interviews, as well as evidence retrieved following a search 
of Epstein's home, showed that some of the girls involved were under the age of 18. The police 
search of Epstein's residence also found two hidden cameras and, throughout the house, large 
numbers of nude photos of girls, including victims whom the police had not interviewed in the 
course of their investigation. 
14. In March 2006, a State grand jury was scheduled at which all of ms were 
expected to testify. The proceeding was postponed, however, due to meet een the State 
Attorney's office and Epstein's prominent criminal defense la onal friend, Alan 
Dershowitz. 
15. Another grand jury was convened in April 2 anceled the day before it was 
itt \
to begin receiving evidence. 
ts ,(1) Police Chief Reit to the State Attorney. ( s t i y 
16. On May 1, 2006, Town Pa Beach Police Chief Michael Reiter wrote a ,, ....., 
"personal and confidential" letter, tin elm Beach County State Attorney, Barry Krischer, 
stating: 
I must renew mye 
treatment of the E 
communi 
of the 
messaves 
d 
observation to you that I continue to find your office's 
te ] cases highly unusual. It is regrettable that I am forced to 
in thisrmanner, but my most recent telephone calls to you and those 
ective to your assigned attorneys have been unanswered and 
main unreturned. After giving this much thought and consideration, 
you to examine the unusual course that your office's handling of this 
as taken and consider if good and sufficient reason exists to require your 
alification from the prosecution of these cases. (Emphasis supplied) 
17. Chief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach 
Police Department's probable cause affidavits charging Epstein and two of his assistants with 
multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested 
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that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges 
against him, which would be public. 
(2) The July 2006 State Grand Jury Presentation. 
IS. Instead, State Attorney Krischer elected to refer the case to a grand jury, which is 
mandatory for capital cases but rarely used for all other crimes. According to an official 
spokesperson, this was the first time that a sex crimes case was presented to a 
'Se 
Beach County. 
19. In July 2006, after State Attorney Krischer presented C,in d evidence from 
in Palm 
one victim, the grand jury returned an indictment on a sole co of tation of prostitution. <)
There is no mention in the indictment of the victim being 'n 
20. On information and belief, a second s victims was supposed to testify 
before the grand jury, but was unable to atten f a school exam. 
21. No reasonable explanatio 
victims were not presented as with 
Nor has any reasonable expl 
provided as to why the numerous other known 
me victims to the grand jury convened in July 2006. 
provided as to why State Attorney Krischer, who was 
initially eager to investig rd prosecute Epstein for his crimes, over time lost the desire to do 
so. 
22. On formation and belief, during the grand jury appearance of the single victim 
who te e State Attorney presented evidence that vilified the victim and attacked her 
credibility, including soliciting testimony regarding underage drinking and questionable personal 
behavior that was unrelated to the charges against Epstein. Further upon information and belief, 
this information was initially brought to the attention of the State Attorney's office by Epstein's 
defense counsel. 
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(3) The FBI's Investigation and Epstein's Non-Prosecution 
Agreement With Federal Authorities. 
23. On information and belief, following the deficient July 2006 indictment, and with 
Chief Reiter's encouragement, the FBI began its own investigation of Epstein. 
24. Records unsealed in 2015 revealed that the FBI compiled reports on "34 confirmed 
;minors" that were victims of Epstein's sexual predations. Based on evidence gathe y the FBI, 
a 53-page indictment was prepared by the U.S. Attorney's Office in June 200, owe er, at the 
Itorequest of Epstein's lawyers, the indictment was never presented to a fed - . !.., (jury. 
25. Instead, then U.S. Attorney for the Southern District o lori , Alexander Acosta, 
negotiated a plea deal with Epstein's team of lawyers to nity to Epstein (along with 
four named co-conspirators and any unnamed potentia ns 'rotors) from all federal criminal 
charges. 
26. Throughout the remainder 7 ltd through the first half of 2008, Epstein's 
lawyers and the U.S. Attorney contin Ling the plea arrangement. Upon information and 
belief, Epstein's lawyers insis ) the victims not be notified, (2) the deal be kept 
confidential and under seal, and I grand jury subpoenas (including one that had already been 
issued for Epstein'sjomp rs be withdrawn. 
27. 0, 2008, Epstein pled guilty to State charges: one count of solicitation of 
prostituti count of solicitation of prostitution with a minor under the age of 18. He was 
senten 18 months in jail, followed by a year of community control or house arrest, and was 
adjudicated as a convicted sex offender required to register twice a year in Florida. 
28. The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to 
receive immunity from federal sex-trafficking charges that could have sent him to prison for life. 
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30. Epstein was released five months early. 
31. Upon information and belief, Epstein violated the t 
not prosecuted. 
C)tst(4) The Crime Victims' Righ L Lion. 
%32. Epstein's victims only learned after t a ut his plea in State court and filed 
%an emergency petition to force federal prosecu ply with the Crime Victims' Rights Act 
(18 U.S.C. § 3771, "CVRA"), which m es in rights for crime victims, including the right 
to be informed about plea agreem a right to appear at sentencing. U.S. District Judge 
Kenneth A. Marra recently rules deral prosecutors violated the CVRA by failing to notify 
Epstein's victims before "n him to plead guilty to only the two State offenses. 
33. rosecu on's failure to keep the victims apprised, among other things, also 
contravenes da Constitution, Article I, § 16(b) and Fla. Stat. § 960.001. 
ollowing publicity exposing the extraordinary leniency of the plea deal, dozens of 
civil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court. 
35. In 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense) 
sex offender in New York, a lifelong designation. In 2011, the New York County District 
Attorney's office unsuccessfully sought to lower his registration to low-risk "level one." 
On information and belief, based on public records, former State Attorney Krischer communicated 
with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers. 
29. Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for 
which he was convicted. Instead, he was placed in a private wing of the Palm Beach County 
Stockade, where, after 3 1/2 months, he was allowed to leave the jail on "work releas " for up to 
12 hours a day, 6 days a week. His private driver provided his transportation toACt-anti S4 "work." 
Qrobation, but was 
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36. Upon information and belief, during the course of the Town of Palm Beach and FBI 
investigations, Epstein retained private investigators to follow, harass, and photograph his victims 
and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated 
the case against Epstein. 
37. Upon information and belief, Epstein's victims were threatened against cooperating 
with law enforcement and told that they would be compensated only if they did no rate with 
law enforcement. 
B. Second Epstein Sex Crimes Investigation, Indictment, Suicide: 201---)
38. On July 6, 2019, Epstein was arrested on federal triStragding charges. 
39. Upon information and belief, the United S g ent's investigation of new 
S investigations into and reporting 
-tc
ii ts
on the mishandling of the 2006 charges and th t
i
s that followed. 
40. In a July 8, 2019, letter 1 district court by the U.S. Attorney for the 
Southern District of New York, Ep escribed as "a serial sexual predator who preyed on 
dozens of minor girls over a ." The letter emphasized that "the Government has real 
concerns — grounded in p ence with this defendant- that if allowed to remain out on bail, 
the defendant co to pressure and intimidate witnesses and potential witnesses in this 
case, includi and their families, and otherwise attempt to obstruct justice." It also 
descri ults of the FBI's search of Epstein's Manhattan townhouse: evidence of sex 
trafficking in the form of "hundreds — and perhaps thousands — of sexually suggestive photographs 
of fully- or partially-nude females," including underage females. In a locked safe, compact discs 
were found with handwritten labels including the descriptions: "Young [Name] + [Name]," "Misc 
nudes 1," and "Girl pies nude." 
allegations and charges stemmed, in part, from con 
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41. On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's 
office for the Southern District of New York charged Epstein with sex trafficking and conspiracy 
to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were 
brought into Epstein's mansions for sexual encounters. A few days later, owing to public outcry 
over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida, 
Alexander Acosta, who by then was serving as U.S. Secretary of Labor e Trump 
administration, resigned from office. S" 
42. Epstein was denied bail and was placed into pre On at the federal 
Metropolitan Correction Center in lower Manhattan. 
43. On August 10, 2019, Epstein was foun is cell at the Metropolitan 
Correctional Center. His cause of death was detenn uicide. 
C. The August 27. 2019, SDNY Hearin s Victims Sneak. 
44. On account of his death os rs sought to dismiss the indictment against 
Epstein, while maintaining that the 1 ntinue to investigate his co-conspirators. 
45. United States for strict Judge Richard M. Berman ordered a hearing on 
August 27, 2019, on the utors' decision to dismiss the indictment and allowed victims to 
speak at the heart 
46. course of the hearing, more than two dozen victims delivered their personal 
stories frustration, and sexual abuse at the hands of Epstein. Several victims spoke of 
violent rape by Epstein. Many more victims were present in the courtroom but did not testify. 
47. While some questioned the reasoning behind the court's decision to give the victims 
voice after Epstein's death, District Judge Berman noted that "a public hearing is [the] preferred 
vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings 
promote transparency and they provide the court with insights and information which the court 
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may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that 
the court "is the institution that most people have confidence in, in these very troubled times." 
48. At the August 27th hearing, the girls, now women, spoke about their "exploitation 
and coercion," and to the fact that many of them "were in very vulnerable situations and in extreme 
poverty, circumstances where [they] didn't have anyone on [their] side, to spea on [their] 
behalf...." One victim lamented that "as a victim, [she] never got to see what th ent was 
or why the special treatment got approved" in the Florida case years jearl's er noted how ci m i
"completely different" the investigators leading to the 2019 federa m t were from the 
prosecutors in the Florida case, both in their treatment of d ir investigation of her 
victimization by Epstein. 
its . ,49. A former federal judge in attendan gust 27th hearing emphasized that 
"transparency is one of the overriding objectiv  C riminal justice system." 
e
iSs „
50. Nearly all of the victims the conviction that the secrecy that shielded 
Epstein has caused them "irrep and that an opportunity to address his criminal 
wrongdoings, and those of the divi als who enabled his sexual racketeering, would allow for 
at least some measure ofj • be served after his death. Indeed, one victim stated: "Any efforts 
made to protect m's n me and legacy send a message to the victims that he wins and that he 
is untouchab o er victim expressed fear that this is a world "where there are predators in 
power, where people can avoid justice if their pockets run deep enough." In short, the 
"unusual" treatment Epstein received in Florida in 2006 based on his wealth, social status, and 
connections severely eroded the public's faith in the integrity and impartiality of the criminal 
justice system. 
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D. The Paint Beach Post' Landing and the Public Interest. 
51. Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm 
Beach County and the Treasure Coast vicinity. 
52. The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist 
three other times. 
4 .,53. Beginning in 2004, The Palm Beach Post has extensively investiga d reported 
on the allegations against, the law enforcement investigation of, and the • committed by, 
Epstein and his co-conspirators. The Newspaper's reportage has 
following articles: 
blication of the 
• "The Man Who Had Everything: Jeffrey Ep ykd Big Homes, Elite Friends 
and Investi ators Say, Underage Girls.," pu August 14, 2006, reporting that: 
a local community colle s e , admitted in a sworn statement to 
police that "she had taken at least six yr tt Epstein, all between the ages of 14 
and 16;" Palm Beach Police "int a we alleged victims and 17 witnesses;" 
"Dershowitz, the Harvard law p or, eled to West Palm Beach with information 
about the girls," including s m discussions about "their use of alcohol and 
marijuana;" after meetin tein's legal team, "prosecutors postponed their 
decision to take the d jury;" Palm Beach Police subsequently "received 
complaints that two ms or their families had been harassed or threatened;" 
"relations between lice prosecutors were fraying" as the investigation continued; 
and "one girl who 6poenaed — the one who said she had sexual intercourse with 
Epstein — nev wed up" to testify before the grand jury. 
• "Trum nags osman Estate for $41 Million" published on November 16, 2004, 
repo ii g the bidding war between Donald Trump and Jeffrey Epstein for the 
a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along 
`Raider's Row" in Palm Beach. 
• "Indictment: Billionaire Solicited 3 Times" published on July 25, 2006, reporting that 
illionaire money manager and Palm Beach part-time resident Jeffrey Epstein 
solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 of last 
year, according to an indictment charging him with felony solicitation of prostitution." 
The article further reported that "Epstein's case is unusual in that suspected prostitution 
johns are usually charged with a misdemeanor, and even a felony charge is typically 
made in a criminal information — an alternative to an indictment charging a person with 
the commission of a crime." 
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• "After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006, 
reporting that "Palm Beach police thought there was probable cause to charge Epstein 
with unlawful sex acts with a minor and lewd and lascivious molestation." The article 
further reported that "Police Chief Michael Reiter was so angry with State Attorney 
Barry Krischer's handling of the case that he wrote a memo suggesting the county's 
top prosecutor disqualify himself," and identified a 20-year-old on-the-record female 
source who said "she gave Epstein a massage in the nude, then brought him six girls, 
ages 14 to 16, for massage and sex-tinged sessions at his home." 
• "Police Say Lawyer Tried to Discredit Teenage Girls" published on JuSi 29, 2006, 
reporting that "[flamed Harvard law professor Alan Dershowitz metiwitli the Palm 
Beach County State Attorney's Office and provided damaging infonnation about 
teenage girls who say they gave his client, Palm Beach bill' e iteffrey Epstein, 
sexually charged massages" and that "[t]he state attorney's o presented the 
Epstein case to a county grand jury this month rather the charging Epstein 
because of concerns about the girls' credibility." 
• "Expert: Ignorance of Age Isn't Defense In Sex 
reporting that "[lather than file charges, the 
to a county grand jury" which "indicted E 
charge of felony solicitation of prostitu • 
because the state attorney's office rare 
• "Epstein Camp Calls Female A 
that "[a] state attorney's spok 
grand jury when there are 
credibility." 
ublished on August 5, 2006, 
y's office presented the case 
week on a single, less serious 
that "[t]he case raised eyebrows 
icks such charges to a grand jury." 
"published on August 8, 2006, reporting 
uld say only that the office refers cases to the 
vith the viability of the evidence or witnesses' 
• "Palm Beach Chief Fire In Epstein Case" published on August 14, 2006, 
reporting that Chie i "pressed for Epstein to be charged with the more serious 
crimes of sex activity with minors" and "slammed State Attorney Barry Krischer in 
blunt language used by one law enforcement official with another because of 
what he as that office's mishandling of the case." 
I pstein Case Unusual, Lawyers Say" published on March 13, 2007, 
that "[n]early eight months after Palm Beach tycoon Jeffrey Epstein was 
with felony solicitation of prostitution, there has been no discernible progress 
case." 
• "Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published 
on October 18, 2007, reporting on a lawsuit brought in New York State court against 
Epstein "by a young woman who says he had sex with her when she was 16 and had 
sought his help becoming a model." 
• "Palm Beacher Pleads In Sex Case" published on July 1, 2008, reporting that "Epstein, 
55, pleaded guilty ... to felony solicitation of prostitution and procuring a person under 
the age of 18 for prostitution," resulting in "a lifelong obligation to register as a sex 
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offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their 
investigation of Epstein, which they had taken to a grand jury." 
• "Jeffrey Epstein: Scientist, Stuntman, `Sex Slave' Visit Jailed Tycoon" published on 
August 13 2008reporting that "[d]uring his first month of confinement" Epstein was 
visited by who allegedly escorted victims "upon their arrival at his Palm 
Beach waterfront home to an upstairs room, where she prepared the massa e table and 
provided the oils for their encounters" with Epstein, and by "a 
young woman whom Epstein purportedly described as his Yugoslavian sex slave." 
• "Billionaire Sex Offender Leaves Jail Six Days a Week For Work" p ed on July 
1, 2008, reporting that Epstein "is allowed to leave the Palm Beacflun ockade 
six days a week on a work-release program." 
• "Women Want Epstein Sex Plea Deal Unsealed" published , 2009, reporting 
that attorneys for women suing Epstein in various courts ant his [non-prosecution] 
agreement [NPA] with federal prosecutors unsealed" and • moving to unseal the 
agreement in Circuit Court of the Fifteenth Judicial and that "Epstein now faces 
at least a dozen civil lawsuits in federal and s filed by young women who 
said they had sex with him and now are se ges." On that date, The Palm 
Beach Post moved to intervene in the ma urpose of obtaining public access 
to the NPA, which was ordered disclos ourt on June 25, 2009. 
• "Epstein's Secret Pact With F `Highly Unusual' Terms" published on 
September 19, 2009, reportin at, ing to Epstein's non-prosecution agreement, 
"federal prosecutors back agreed to recall grand jury subpoenas if Epstein 
charge any of Epstein' co-conspirators: , Lesley ==, 
ed felonies in state court" and "also a not to pleaded guilty to prosti 
Groff and Nadia rcink ." The article further reported that, according to an 
attorney representin th e of Epstein's victims, "none of the 30 to 40 wom[e]n 
identified as rns in the federal investigation" were informed ahead of time about 
the NPA. 
• "Judg les Epstein Attorneys Can Subpoena Abortion Records" published on 
J 2 2010, reporting that "a judge ... gave lawyers representing multi-
sex offender Jeffrey Epstein the right to subpoena abortion records from 
4pstei re 
who are seeking millions in damages from the part-time Palm Beach resident." 
• n Journal's Findings Could Resurrect Abuse Case" published on March 20, 
2010, reporting that "[a] purloined journal that is said to contain the names of 
`hundreds' of victims of convicted sex offender Jeffrey Epstein could be used to reopen 
the investigation into the multi-millionaire's appetite for teenage girls." 
• "Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits" published 
on October 4, 2017, reporting that, according to court documents, Epstein "shelled out 
$5.5 million to settle lawsuits with three of more than two dozen teens who sued him." 
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EFTA02732418

• "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims' 
Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge 
Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's 
teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had 
dropped plans to prosecute the billionaire on dozens of federal charges in connection 
with the girls' claims that he paid them for sex at his Palm Beach mansion." 
• "Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex 
Trafficking, Conspiracy Charges In Federal Court In Manhattan" published on July 9, 
2019, reporting on Epstein's appearance in U.S. District Court for the So 
of New York in which he "pleaded not guilty to charges accusing him 
network of girls as young as 14 that he exploited for his sexual pl 
in Palm Beach and Manhattan." 
A true and correct copy of the above news articles, in either the compu 
are maintained in The Palm Beach Post's electronic archives o 
originally published, is annexed hereto as Exhibit 1. 
54. The press has a constitutional right 
m District 
ting a vast 
at s homes 
at in which they 
print edition in which 
o criminal proceedings, see, e.g., 
Richmond Newspapers, Inc. v. Virginia, 448 573 (1980), including pre-trial criminal 
proceedings. v. Graddick, 696 d 1 1 th Cir. 1983). Indeed, "the integrity of the 
judicial process, which public sc sed to safeguard, is just as much at issue in 
proceedings of this kind [pre- did poytlErial] as at trial." Id. at 801; see also Miami Herald Publ. 
Co. v. M, 426 So. 2d m 7 la. 1982) (identifying the news media as a "public surrogate" in ttp 
matters concemin e do of judicial proceedings). The press also has a First Amendment 
interest in i ormation from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer 
Counc 748, 756-57 (1976) ("Where a speaker exists . . . the protection afforded [by 
the First Amendment] is to the communication, to its source and to its recipients both."); Pittman 
v. M, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme Court has recognized that the 
First Amendment offers protection to both speakers and those wishing to receive speech."); see 
also Stephens v. Cty. of Albemarle, Va., 524 F.3d 485, 492 (4th Cir. 2008) (providing that a plaintiff 
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has "standing to assert a right to receive speech" by "show[ing] that there exists a speaker willing 
to convey the information to her"). 
55. Because of the unique role performed by the press as a "public surrogate" (M, 
426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about 
criminal proceedings, news organizations "presumptively have a right to access judici 1 records," 
Comm 'r, Ala. Dept of Corr. v. Advance Local Media, LLC, 918 F.3d 1161, 1166 r. 2019), 
and "standing to question the validity of an order restricting publicity beca b'lity to gather 
news is directly impaired or curtailed." M, 426 So. 2d at 4; see a o v. United States, 
837 F.3d 753, 757-58 (7th Cir. 2016) ("[a]s a member of the c 'c, Reporters Committee] k) 
to which the public may seek access, even if that e i h at 
bthas standing to assert [its] claim" to grand jury materials e materials are "public records
unsuccessful"). /4t14k 
56. Here, the continued denial of a ormation The Palm Beach Post seeks on 
behalf of its journalists and the public it-serves questionably constitutes irreparable injury." 
•ape 
Gainesville Woman Care, LLC v. t orida, 210 So. 3d 1243, 1263 (Fla. 2017); see also 
Zerilli v. M,  656 F.2d 705, .C. Cir. 1981) (noting that "the press' function as a vital 
source of information is fined whenever the ability of journalists to gather information is 
!orhic , mimpaired," as it is tto y General's refusal to disclose unredacted report and underlying grand 
jury material° 
Thiff\miE.  rt's Supervision of the Grand Jury Process and Its Authority to Order 
Pubjic Disclosure of the Epstein Evidence. 
57. The Florida Supreme Court has noted that "in states such as Florida, where the 
grand jury is preserved, it is an important appendage of the court which impanels it. At the same 
time it should not be forgotten that the judge of that court is equally important and he is generally 
charged with the supervision of the grand jury's activities...It is, therefore, of vital importance to 
16 
EFTA02732420

maintain the dignity and the integrity of both the grand jury and the presiding judge." State v. 
Clemons, 150 So. 2d 231, 233-34 (Fla. 1963). 
58. Chapter 905 of the Florida Statutes governs the empanelment and conduct of 
Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury 
about its legal duties. Fla. Stat. § 905.18. 
59. Florida Stat. Section 905.27(1) provides that "the testimony of a wA* examined 
ASreqbefore the grand jury ... or other evidence received by it" may be disclos uired by a 
court ... for the purpose of: (a) Ascertaining whether it is consistent stimony given by 
the witness before the court; (b) Determining whether the W i ilty of perjury; or (c) 
Furthering justice." Fla. Stat. § 905.27(1)(a)-(c). 
c it60. Further, disclosure is appropriate p a is Court's inherent authority over e
41/2„grand jury proceedings because of the except' a u • interest in this case and the compelling ? c ir
circumstances supporting transparency. 
has the inherent power to disclo 
historic importance can be a su 
on United States, 837 F.3d at 766 ("a district court 
ry] materials in exceptional circumstances and ... 
reason when there is little countervailing need for secrecy"). 
COUNT I 
(Florida Stat. Section 905.27) 
61., on information learned by The Palm Beach Post through its Florida Public 
uests, law enforcement sources with direct knowledge of the grand jury evidence 
and proceedings, judicial documents obtained from independent but related court proceedings, and 
documents otherwise available in the public record, the State Attorney for Palm Beach County 
presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner 
17 
EFTA02732421

that precluded his indictment for the serious crimes he committed, including sex trafficking and 
sexual assault. 
62. Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's 
victims and the public, and to provide public disclosure to illuminate whether Epstein received 
unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests 
immediate public access to the testimony, minutes, and other evidence presented 6 to the 
Palm Beach County grand jury. In a case of this magnitude and importan the accused is 
dead and so many of his crimes, as well as the identities and crimes o sc spirators, and the 
identities of the victims have already been exposed, the need a7urY secrecy is no more. 
See United States v. Socony-Vacuum Oil Co., 310 U.S. 15 0) ("[A]fter the grand jury's 
All yfunctions are ended, disclosure is wholly proper wh 
s, 
of justice require it."). i 
WHEREFORE, The Palm Beach Post \e s ti
Stat. Section 905.27(1) and the Court's • nt thority, order the State Attorney and the Clerk % 
of the Court to file with this Court the testimony, minutes, and other evidence presented 
in 2006 to the Palm Beach Co ty d jury during the first Epstein sex abuse investigation so 
bas 
that, following 
an 
an in cam * ection, it can be made available to The Palm Beach Post and the 
TS ,public on ex ed bas s, and grant any other and further equitable or legal relief the Court 
deems just a 
requests that this Court, pursuant to Fla. 
18 
EFTA02732422

Dated: November 14, 2019 Respectfully submitted, 
c 
ACTIVE 45678709v3 
By: 
GREENBERG TRAURIG, P.A. 
Attorneys for CA Florida Holdings. LLC, 
Publisher of The Palm Beach Post 
Stephen A. Mendelsohn, Esq. 
5100 Town Center Circle, Suite 400 
Boca Raton, Florida 33486 
Telephone: ([Phone Redacted] 
/s/ Stephen A. Mendelsohn 
Facsimile: ([Phone Redacted] 
STEPHEN A. MENDELS 
Florida Bar No. 849324 
mendelsohns@gtlaw.c 
[Email Redacted] 
FLService®gt1 
By: /s/ Micha 
MIC GIEL 
(Pro application forthcoming) 
5 & L, 6th Floor 
ew York 12207 
one: ([Phone Redacted] 
simile: ([Phone Redacted] 
gielmegtlaw.com 
Y: /s/ Vincent H. Chic& 
VINCENT H. CHIEFFO 
(Pro Hac Vice application forthcoming) 
1840 Century Park East, Suite 1900 
Los Angeles CA 90067 
Telephone: ([Phone Redacted] 
Facsimile: ([Phone Redacted] 
chieffov®gtlaw.com 
[Email Redacted] 
By: /s/ Nina D. Boyajian 
NINA D. BOYAJIAN 
(Pro Hac Vice application forthcoming) 
1840 Century Park East, Suite 1900 
Los Angeles CA 90067 
Telephone: ([Phone Redacted] 
Facsimile: ([Phone Redacted] 
boyajiann®gtlaw.com 
riveraal®gtlaw.com 
19 
EFTA02732423

EXHIBIT 1 
The Newspaper's Reportage on Jeffrey Epstein 
EFTA02732424

The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 1 of 10 
The Palm Beach Post REAL NEWS STARTS HERE 
The Man Who Had Everything: Jeffrey Epstein craved big 
homes, elite friends and underage girls 
By Andrew Marra
Posted Jul 17, 2019 at 6:02 AM 
From the archives: When Palm Beach detectives start sking 
questions and teenage girls started talking, a wave f resistance 
followed. 
Editor's Note: This article appeared in The Palm Beach Post on 2006, three weeks after 
Jeffrey Epstein's arrest in Palm Beach County on a charge ykolicitation of prostitution. 
f‘ nWINGED GARGOYLES guarded the gate at Je e Sipstein's Palm Beach mansion. Inside, 
hidden cameras trolled two rooms, while the ' Is e and went. 
For the police detectives who sifted e garbage outside and kept records of visitors, it 
was the lair of a troubling targeC )
Epstein, one of the most mysteri of the country's mega-rich, was known as much for his 
secrecy as for his love of fine things: magnificent homes, private jets, beautiful women, 
friendships with teisrld's elite. 
0 3But at Palm B ch lice headquarters, he was becoming known for something else: the 
regular arrival of teenage girls lie hired to give him massages and, police say, perform sexual 
favors. 
Epstein was different from most sexual abuse suspects; he was far more powerful. He counted 
among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along 
with some of the most prominent legal, scientific and business minds in the country. 
When detectives started asking questions and teenage girls started talking, a wave of legal 
resistance followed. 
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 2 of 10 
» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work -
release 
If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough. 
Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends 
quietly, always in the background as he navigated New York high society. 
When he first attracted notice in the early 1990s, it was on account of the wom VMS 
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robe 
In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Se the British 
Mail on Sunday tabloid laid out speculative stories that the socialit a CIA spook, a 
math teacher, a concert pianist or a corporate headhunter. 
"But what is the truth about him?" the newspaper won 
The media frenzy did not begin in full until a er. In September 2002, Epstein was 
flung into the limelight when he flew C • t 
Africa on his private jet. 
flamboyant and intensely private." 
Suddenly everyone wanted to 
published lengthy profiles. The 
bachelors and began desc 
and "reclusive." 
e Maxwell, Epstein is both 
actors Kevin Spacey and Chris Tucker to 
Epstein was. New York magazine and Vanity Fair 
ork Post listed him as one of the city's most eligible 
in its gossip columns with adjectives such as "mysterious" 
Although Ep ve no interviews, the broad strokes of his past started to come into focus. 
Building f extravagance 
He was born blue-collar in 1953, the son of a New York City department employee, and 
raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree 
but became a math teacher at the prestigious Dalton School in Manhattan. 
The story goes that the father of one of Epstein's students was so impressed with the man that 
he put him in touch with a senior partner at Bear Stearns, the global investment bank and 
securities firm. 
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 3 of 10 
In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J. 
Epstein and Co. That is when he began making his millions in earnest. 
Little is known or said about Epstein's business except this: He manages money for the 
extremely wealthy. He is said to handle accounts only of $1 billion or greater. 
It has been estimated he has roughly 15 clients, but their identities are the subject of only 
speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a 
former Palm Beacher who is said to have been a mentor to Epstein. 
Wexner sold Epstein one of his most lavish residences: a massive townh at dominates a 
block on Manhattan's Upper East Side. It is reported to have, among • eatures, closed-
circuit
c 
television and a heated sidewalk to melt away fallen snow. 
That townhouse, thought to be the largest private ' Manhattan, is only a piece of residencefic x
"Cl ')
the extravagant world Epstein built over time. 
\In New Mexico, he constructed a 27,000-square- ill p mansion on a 10,000-acre ranch 
outside Santa Fe. Many believed it to be the 
In Palm Beach, he bought a waterfron 
private island in the Virgin Islan 
e in the state. 
El Brillo Way. And he owns a 100-acre 
» PHOTOS: The players in tkJsffrey Epstein saga 
Perhaps as remarkab as hl la •sh homes is his extensive network of friends and associates at 
the highest echel power. This includes not only socialites but also business tycoons, 
media moguls s, royalty and Nobel Prize-winning scientists whose research he often 
funds. 
lust like o r people collect art, he collects scientists; said Nowak, who directs the 
Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of 
a $30 million research donation from Epstein. 
Epstein is said to have befriended former Harvard President Larry Summers, prominent law 
Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mon 
Zuckerman. 
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 4 of 10 
And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely 
photographed. 
"The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials 
and tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article. 
Epstein's friendship with Clinton has attracted the most attention. 
Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at 
an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become 
close friends until after Clinton left the Oval Office and moved to New York. 
Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John 
Kerry's presidential bid, the reelection campaign of New Mexico G . Bill and the 
Senate bids of Joe Hillary Rodham Clinton, Ch r Dodd and Charles 
Schumer. 
Powerful friends and enemies 
A Vanity Fair profile found cracks in the v of Epstein's life story. The 2003 article said he 
left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange 
Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20 
million loan. 
The article suggested thatt of his business mentors and previous employers was Steven 
Hoffenberg, now se ng a nson term after "bilking investors out of more than $450 million 
in one of the Iarg Pouzi schemes in American history." 
As he amasse his wealth, Epstein made enemies in disputes both large and small. He sued the -7=== 
man who in 1990 sold him his multimillion -dollar Palm Beach home over a dispute about less 
than 516,000 in furnishings. 
A former friend claimed Epstein backed out of a promise to reimburse him hundreds of 
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein 
owed him nothing. 
» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says 
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 5 of 10 
"It's a bad memory. I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the 
retired former president of Electronics and Sega Corp. "Suffice it to say I have 
nothing good to say about him.' 
Among the characteristics most attributed to Epstein is a penchant for women. 
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York 
and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian 
model. 
'He's a lot of fun to be with,' Donald Trump told New York magazine in 
that he likes beautiful women as much as I do, and many of them arec 
doubt about it, Jeffrey enjoys his social life." 
Investigation leads to Epstein 
Although he was not a frequenter of the Palm Beac 
Among his charitable donations, he gave $90, 
$100,000 to Ballet Florida. 
A 
It is even said 
Unger side. No 
ne, he made his presence felt. 
Beach Police Department and 
In Palm Beach, he lived in luxury. ercedes sat in his garage, alongside a 
Harley-Davidson. His jet waited t at Palm Beach International Airport. At home, a 
private chef and a small staff st d at ready. From a window in his mansion, he could look 
out on the Intracoastal Waterwa d the West Palm Beach skyline. He seemed to be a man 
who had everything. 
But extraordin can fuel extraordinary desires. 
» Epstein o leave jail for mansion in sex -trafficking  case 
In March 2 5, a worried mother contacted Palm Beach police. She said another parent had 
overheard a conversation between their children. 
Now the mother was afraid her 14-year-old daughter had been molested by a man on the 
island. 
The phone call triggered an extensive investigation, one that would lead detectives to Epstein 
but leave them frustrated. 
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 6 of 10 
Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm 
Beach police report detailing the criminal probe offers a window into what detectives faced as 
they sought to close in on Epstein. 
Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to 
perform a massage. She said the friend told her to say she was 18 if asked. At the house, she 
said she was paid $300 after stripping to her panties and massaging the man while he 
masturbated. 
Police interview 5 alleged victims „opAak 
Ne The investigation began in full after the girl identified Epstein in a p e man who had 
paid her. Police arranged for garbage trucks to set aside Epstein's h s police could sift 
through it. They set up a video camera to record the coming omgs at his home. They 
monitored an airport hangar for signs of his private jet's d departures. 
They quickly learned that the woman who took th 4 old girl to Epstein's house was 
a Palm Beach Community Colle s e t from Loxahatchee. In a sworn 
statement at police headquarters, 18, nutted she had taken at least six girls to 
visit Epstein, all between the ages of 14, 16. stein paid her for each visit, she said. 
During the drive back to her ho n told detectives, "I'm like a Heidi Fleiss." 
Police interviewed five alleged v1lt4ths and 17 witnesses. Their report shows some of the girls 
said they had been instru have sex with another woman in front of Epstein, and one said 
she had direct intesdQurse th him. 
In October, arched the Palm Beach mansion. They discovered photos of naked, young-
looking just as several of the girls had described in interviews. Hidden cameras were 
found in th arage area and inside a clock on Epstein's desk, alongside a girl's high school 
transcript. 
Two of Epstein's former employees told investigators that young-looking girls showed up to 
perform massages two or three times a day when Epstein was in town. 
They said the girls were permitted many indulgences. A chef cooked for them. Workers gave 
them rides and handed out hundreds of dollars at a time. 
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 7 of 10 
One employee told detectives he was told to send a dozen roses to one teenage girl after a high 
school drama performance. Others were given rental cars. One, according to police, received a 
$200 Christmas bonus. 
The cops moved to cement their case. But as they tried to tighten the noose, they encountered 
other forces at work. 
In Orlando they interviewed a possible victim who told them nothing inappropriate had 
happened between her and Epstein. They asked her whether she had spoken to n one else. 
She said yes, a private investigator had asked her the same questions. 
» Jeffrey Epstein: Acosta, Krischer trade barbs over sweeth 
When they subpoenaed one of Epstein's former employees, he Id l rf the same thing. He 
and a private eye had met at a restaurant days earlier to go c what the man would tell 
investigators. 
Detectives received complaints that private eyes  14 )to g as police officers. When they told 
Epstein's local attorney, Guy Fronstin, he t e stigators worked for Roy Black, the 
high-powered Miami lawyer who has d d e likes of Rush Limbaugh and William e ct ..„
Kennedy =. 
While the private eyes were co du a parallel investigation, Dershowitz, the Harvard law 
professor, traveled to West Palm ach with information about the girls. From their own 
profiles on the popular MySpace.com, he obtained copies of their discussions about 
their use of alcoho uana. 
He took his to a meeting with prosecutors in early 2006, where he sought to cast 
doubt o ns reliability. 
The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only 
did some of the girls have issues with drugs or alcohol but also some had criminal records and 
other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she 
told police she was younger than 18 when she started performing massages for Epstein. 
After the meeting, prosecutors postponed their decision to take the case to a grand jury. 
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 8 of 10 
In the following weeks, police received complaints that two of the victims or their families had 
been harassed or threatened. Epstein's legal team maintains that its private investigators did 
nothing illegal or unethical during their research. 
By then, relations between police and prosecutors were fraying. At a key meeting with 
prosecutors and the defense, Detective Recarey, the lead investigator, was a no-show, 
according to Epstein's attorney. 
nevershowed 
embarrassment on the prosecutor's face was evident when the police officer ver 
showed up for the meeting: attorney Jack Goldberger said. 
Later in April, Recarey walked into a prosecutor's office at the state ac s)
learned the case was taking an unexpected turn. 
AS' office and 
The prosecutor, Lanna Belohlavek, told Recarey the state at ne s office had offered Epstein 
a plea deal that would not require him to serve jail tim 
Recarey told her he disapproved of the plea offe 
."S„
(S .,The deal never came to pass, however. 
Future unclear after charge 
e a felony conviction. 
On May 1, the department ask ecutors to approve warrants to arrest Epstein on four 
counts of unlawful sexual vity with a minor and to charge his personal assistant, 
IM , now 27, for r all a role in arranging the visits. Police officials also wanted to 
charge M, th s -described Heidi Fleiss, with lewd and lascivious acts. 
QBy then, th ent was frustrated with the way the state attorney's office had handled the 
case. O e day the warrants were requested, Palm Beach Police Chief Michael Reiter 
wrote a lett to State Attorney Barry Krischer suggesting he disqualify himself from the case if 
he would not act. 
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to 
the grand jury. 
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and under... Page 9 of 10 
It is not known how many of the girls testified before the grand jury. But Epstein's defense 
team said one girl who was subpoenaed - the one who said she had sexual intercourse with 
Epstein - never showed up. 
The grand jury's indictment was handed down in July. It was not the one the police 
department had wanted. 
Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was 
charged with one count of felony solicitation of prostitution, which carries a m .4 I. tun penalty 
of five years in prison. He was booked into the Palm Beach County Jail earlyo; 23 ild 
released hours later. 
Epstein's legal team 'doesn't dispute that he had girls over for mass ldberger said. But 
he said their claims that they had sexual encounters with him cre ility. 
"They are incapable of being believed," he said. "They 
accusations of theft made against them by their em 
some of them? 
What remains for Epstein is yet to be 
The Palm Beach Police Departme 3Lnifthe FBI to investigate the case. It also has 
al records. They had 
ere was evidence of drug use by 
returned the $90,000 Epstein d 2004. 
In New York, candidates 
of at least $60,000 i p n contributions from Epstein. Meanwhile, Epstein's powerful 
friends have rem dent as tabloids and Internet blogs feast on the public details of the 
police inves 
ovemor and state attorney general have vowed to return a total 
Goldberge =tains Epstein's innocence but says the legal team has not ruled out a future 
plea deal. He insists Epstein will emerge in the end with his reputation untarnished. 
"He will recover from this," he said. 
Staff writer Larry and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and 
Melanie Mena contributed to this story. 
[Email Redacted]
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The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and und... Page 10 of 10 
@AMarraPBPost 
frlHIFF 1l irk: r 
rTEILLIGEN7 GNP ykinwArailau 4„,k, 
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273 / 278 - Tuesday, November 16, 2004 
Edition: FINAL 
Section: A SECTION 
Page: 1A 
Source: By PAUL OWERS Palm Beach Post Staff Writer 
Illustration: PHOTO (C & 2 B&W) & MAP (B&W) 
Memo: Ran all editions. 
Dateline: WEST PALM BEACH 
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION 
ASWhen it came time to bid Monday for the palatial Palm Beach digs of oit an, The 
Donald was not about to be trumped. 
"Nobody was going to outbid me," the brash developer-turned-TV4persopality said from his 
New York office. 
Trump bested two other bidders with a $41.35 million offe 43,000-square-foot, 
seven-bedroom estate on 6 oceanfront acres along the st der's Row." 
But Trump, 58, proud possessor of Mar-a-Lago, has live in the Gosman home at 
513 N. County Road. He wants to - what else? - s5144 ake more money. 
The star of the mega-hit The Apprentice said hi intends redevelop the site into a "super 
luxury house" that would be the "finest anyvykere lake United States." He might build 
another house before flipping the entire pckekage. 
"I've known about this house for quiteAsome time," Trump said. "It's probably the best piece 
of land in Florida - and probably th ountry - for luxury real estate." 
Althoutirump said he could s 
Lesly said zoning regal 
c the property into nine lots, Palm Beach Mayor
Lesly  for only two houses - and maybe a third. 
said she's not worried about plans. 
"He's been a very good 'ropert er in the town of Palm Beach," she said. "He does his 
projects very well. He's tionist." 
Monday's auction k pl at U.S. Bankruptcy Court in West Palm Beach as part of 
Gosman's Chapt anlcruptcy case. Proceeds from the sale will go into escrow for eventual 
distribution t Ito 
The aucti at exactly noon after Judge Steven dismissed an objection from 
an atto enting money manager Jeffrey Epstein. The lawyer argued unsuccessfully 
that Tru was not a qualified bidder because his contract stipulated that he would not close 
on the sale less title insurance was in place beforehand. 
With Trump listening via conference call, Epstein began the bidding at $37.25 million -
$250,000 higher than Trump's initial offer. 
Mark Pulte, son of the founder of home-building giant Pulte Homes, passed when his turn 
came, letting lawyers for Trump and Esptein bid against each other until the price hit $38.85 
million. 
Pulte then bid $39.1 million, briefly raising the ire of Trump, who believed that Pulte had 
given up his right to bid by passing the first time. 
EFTA02732435

But allowed the offer to stand, and Pulte and Trump went back and forth until 
Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at 
$38.6 million. 
closed the bidding 10 minutes after it started, leaving Trump with the right to buy 
the 29,000-square-foot home (a typical Palm Beach County single-family house is about 
2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service 
quarters. 
The closing could take place within a week but probably won't happen until next month. 
Trustee Joe Luzinski and creditors said they were pleased with the outcome. 
"We knew we were dealing with some substantial people . .. who were going t b it up a 
bit," Luzinski said. 
"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMo Chase Bank. 
"In bankruptcy court, the idea is to get the most for creditors, and that' pened." 
The auction proved to be a bonanza for creditors, Luzinski said, no e highest offer 
former listing agent Sotheby's International Realty received was $ ion. Sotheby's won't 
receive a commission, he said. 
Pulte, 42, of Boca Raton, said he figured Trump wouldn't wn Monday. 
"I got the feeling he was willing to go a lot higher, and i i t to chase it," Pulte said. 
Pulte said Gosman asked him before the auction whe uld be willing to let him stay 
in the mansion after the closing until he decides w r e nts to move. Trump and 
Luzinski said they have had no such discussion G man. 
Gosman, 75, had the house built after payin 'Ilion for the land in 1986. 
The former health-care magnate declined ie requests before and after the auction 
Monday. He was at the courthouse but be the auction took place. 
The $41.35 million price tag eclips t 5 million sale of Lowell "Bud" Paxson's Palm 
Beach home and guest house but of the $45 million that Virginia home builder 
Dwight Schar paid for Ron Peptin i 6,000-square-foot estate, Casa Apava, a designated 
landmark. 
Schar also paid $18.6 
total of $63.6 million. 
making it the pricipet resi 
Gosman once h 
filed for Cha 
liabilities of 
When • 
wanted 
••lion 'lakefront lot across the street from the main house, for a 
y Schar spent a total of $70 million for his new property, 
ial sale in U.S. history. 
ortune that Forbes magazine estimated at $480 million. He voluntarily 
1 l%nkruptcy protection in 2001, listing assets of $250 million and 
million. 
ed that Gosman had to give up all of his exempt assets to creditors if he 
organize under Chapter 11, Gosman converted the case to Chapter 7 liquidation. 
Last year, F1.S. Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is 
invalid because Florida law does not recognize a Dominican Republic divorce that Lin 
Gosman tried to obtain from another man, Michael Castrc. 
The judge's decision was a huge victory for creditors because it prevents Abe Gosman from 
protecting assets by claiming joint ownership with his wife. Gosman's assets, which include 
an extensive collection of artwork, could total as much as $70 million and will be sold later. 
Without Lessen's ruling, Luzinski would have had a much harder time selling Gosman's 
estate, said David Cimo, special counsel for the trustee. 
"We would have been thwarted ... or at least substantially impaired," Cimo said. 
EFTA02732436

The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife 
an ownership interest in his home and other belongings only to avoid losing them in 
bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in 
1999, well before he filed for bankruptcy. 
Lessen is expected to rule in the next two months whether Gosman made improper transfers, 
a decision that will affect how much money will be available to creditors. 
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were 
willing to move forward, in part because the upkeep of the estate now exceeds their means. 
"This is not a happy occasion for them, but at least we're moving to the next level ' Cimo 
said. "That's not a house you want to live in unless you're making large amoun o money 
like Donald Trump." 
[Email Redacted] 
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11/11/2019 Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West Palm Beach, FL 
The Palm Beach Post REAL NEWS STARTS HERE 
Indictment: Billionaire Solicited 3 Times Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 2, 2019 at 2:30 PM 
(EDITORS NOTE: This story originally published in The Palm Beach Post on July 25, 
2006) 
Billionaire money manager and Palm Beach part-time resident Jeffrey EpMI 
solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 
of last year, according to an indictment charging him with felony solicitation of 
prostitution. 
'49 ntEpstein, 53, was booked at the Palm Beach Cou ' a .45 a.m. Sunday. He 
was released on $3,000 bond. 
Epstein's case is unusual in that susp tution johns are usually charged 
with a misdemeanor, and even a fel n arge is typically made in a criminal 
information - an alternative to, an jUdictment charging a person with the 
\ commission of a crime. \,./ 
His attorney, Jack Goldberger, declined to discuss the charge. 
State attorney's office spokesman Mike Edmondson also had little to say. 
"Generally speaking, there is a case that has a number of different aspects to it," 
Edmondson said of a prostitution -related charge being submitted to a grand jury. 
"We-first became aware of the case months ago by Palm Beach police." 
Prosecutors and police worked together to bring the case to the grand jury, he 
said. 
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11/11/2019 Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West Palm Beach, FL 
Palm Beach police confirmed that and said the department will release a report 
today regarding its investigation. 
Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot h a 
pool and a boat dock on the Intracoastal Waterway since 1990 to 
property records. A man answering the door there Monday pstein 
wasn't home. A Cadillac Escalade registered to him was ark the driveway, 
which is flanked by two massive gargoyles. 
Epstein sued Property Appraiser Gary Nikoli contending that the 
assessment of his home exceeded its fair v e. He dismissed his lawsuit 
in December 2002. 
A profile of Epstein in Vanity F a ne said he owns what are believed to 
be the largest private home ttan - 51,000 square feet - and in New 
Mexico - a 7,500-acre ch. are in addition to his 70-acre island in the 
U.S. Virgin Islands and aircraft. 
Epstein's f i ant dmirers, according to the magazine, include prominent 
businessm demics and scientists and famed Harvard law professor Alan 
Dersh 
[Email Redacted] 
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11/11/2019 After tong probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL 
The Palm Beach Post REAL NEWS STARTS HERE 
After long probe, billionaire faces solicitation 
charge Posted Jul 27, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 3:11 PM 
(EDITOR'S NOTE: This story originally published in The Palm Beach Post on fuly 26, 
2006) 
Palm Beach billionaire Jeffrey Epstein paid to have underage girlsv254oung 
women brought to his home, where he received massages and sometimes sex, 
according to an investigation by the Palm Beach Police Department. 
Palm Beach police spent months sifting through Epstein's trash and watching his 
waterfront home and Palm Beach Internati fi /tort to keep tabs on his 
private jet. An indictment charging Eps was unsealed Monday, charging 
him with one count of felony solicit of rostitution. 
Palm Beach police thought there c obable cause to charge Epstein with 
unlawful sex acts with a minor and lewd and lascivious molestation. 
Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's 
handling of the case that he wrote a memo suggesting the county's top 
prosecutor disqualify himself. 
"I must urge you to examine the unusual course that your office's handling of this 
mattet)aas taken and consider if good and sufficient reason exists to require your 
disqualification from the prosecution of these cases," Reiter wrote in a May 1 
memo to Krischer. 
While not commenting specifically on the Epstein case, Mike Edmondson, 
spokesman for the state attorney, said his office presents cases other than 
murders to a grand jury when there are questions about witnesses' credibility and 
their ability to testify. 
https://vAmpalmbeachpost.com/news/20060727/alter-long-probe-billionaire•faces-solicitation-charge 115 
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11/11/2019 After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL 
By the nature of their jobs, police officers look at evidence from a none-sided 
perspective," Edmondson said. "A prosecutor has to look at it in a much broader 
fashion," weighing the veracity of witnesses and how they may fare under 
defense attorneys' questioning, he said. 
Epstein's attorney, Jack Goldberger, said his client committed no crimes. 
"The reports and statements in question refer to false accusations that were not 
charged because the Palm Beach County state attorney questioned the credi ility 
of the witnesses," Goldberger said. A county grand jury "found the alleg *o s 
wholly unsubstantiated and not credible," and that's why his client 
charged with sexual activity with minors, he said. 
Goldberger said Epstein passed a lie detector test administe 
polygraph examiner in which he said he did not know 
Also, a search warrant served on Epstein's home f 
corroborate the girls allegations, Goldberger s\ 
According to police documents: 
- A Palm Beach Community Coll 
the nude, then brought him s 
sessions at his home. 
Cdv- A 27-year-old woman orked as Epstein's personal assistant also 
facilitated the liais oning the PBCC student to arrange for girls when 
Epstein was mg town. And she escorted the girls upstairs when they 
arrived, esh sheets on a massage table and placing massage oils nearby. (45 
0 by reputable 
ere minors. 
-dente to 
t said she gave Epstein a massage in 
s 14 to 16, for massage and sex-tinged 
sworn statements from five alleged victims and 17 witnesses. They 
contend that on three occasions, Epstein had sex with the girls. 
A money manager for the ultra-rich, Epstein was named one of New York's most 
eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with 
the likes of former President Clinton, former Harvard University President 
Summers and Donald Trump, and has lavish homes in Manhattan, 
New Mexico and the Virgin Islands. 
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11/11/2019 After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL 
He has contributed tens of thousands of dollars to Democratic Party candidates 
and organizations, including Sen. John Kerry's presidential bid, and the Senate 
campaigns of Joe Hillary Clinton, Dodd and Charles 
Schumer. 
CO SA
/;</ 94:)
Goldberger is one of five attorneys Eps h etained since he became the 
subject of an investigation, Edmon o d Among the others: Alan 
Dershowitz, the well-known H d I professor and author, who is a friend 
of Epstein. Dershowitz couj4 a >t eached for comment. 
Police said the woman ted young girls for Epstein was 
20, of Palm h. has worked at an Olive Garden restaurant in 
Wellington sai he was a journalism major at Palm Beach Community 
College n e was questioned by police last October. She has an unlisted 
phone r and could not be reached for comment. 
o o d she met Epstein when, at age 17, a friend asked her if she would like 
tom e money giving him a massage. She said she was driven to his five-
bedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs 
to a bedroom with a massage table and oils. Epstein and were both naked 
during the massage, she said, but when he grabbed her buttocks, she said she 
didn't want to be touched. 
hapaThmwpalmbeachpost.com/news/20060727/after-long-rxobe-billionalre-faces-solicitation-charge 3/5 
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11/112019 After long probe, billionaire faces solicitation charge - News - The Palm Beach Poet - West Palm Beach, FL 
Epstein said he'd pay her to bring him more girls - the younger the better, 
told police. When she tried once to bring a 23-year-old woman to him, 
Epstein said she was too old, said. 
M, who has not been charged in the case, said she eventually brought six 
girls to Epstein who were paid $200 each time, said. arm like a Heidi 
Fleiss," police quoted her as saying. The girls knew what to expect when they 
were taken to Epstein's home, said. Give a massage - maybe naked - and 
allow some touching. 
One 14-year-old girl took to meet Epstein led police to start 
investigation of him in March 2005. A relative of the girl called t s 
thought the child had recently engaged in sex with a Palm B n I he girl 
then got into a fight with a classmate who accused her of beg rostitute, and 
she couldn't explain why she had $300 in her purse. 
c4pThe girl gave police this account of her meetin tein: , \,, 
and a second gis ts, ps ein's house on a Sunday in She accompanied 
att iFebruary 2005. Once there, a wom e ght was Epstein's assistant told the 
girl to follow her upstairs to a ro fea ng a mural of a naked woman, several 
rphotographs of naked wome n ef, a hot pink and sofa and a massage 
table. 
She stripped to he bra an anticses and gave him a massage. st
Epstein gav e 14- ar-old $300 and she and the other girls left, she said. She 
said Ro to er that Epstein paid her $200 that day. 0
old similar stories. In most accounts, Epstein's personal assistant at 
now 27, escorted the girls to Epstein's bedroom. 
M , whose most recent known address is in North Carolina, has not been 
charged in the case. 
Palm Beach police often conducted surveillance of Epstein's home, and at Palm 
Beach International Airport to see if his private jet was there, so they would 
know when he was in town. Police also arranged repeatedly to receive his trash 
haps/Nnvw.palmbeachpost.com/news/20060727/after-long-probe-balionalre-faces-solidtation-charge 4/5 
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11 /1112019 After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL 
from Palm Beach sanitation workers, collecting papers with names and phone 
numbers, sex toys and female hygiene products. 
One note stated that a female could not come over at 7 p.m. because of soccer. 
Another said a girl had to work Sunday - "Monday after school?" And still 
another note contained the work hours of a girl, saying she leaves school at 11:30 
a.m. and would come over the next day at 10:30 a.m. 
Only three months before the police department probe began, Epstein donated 
$90,000 to the department for the purchase of a firearms simulator, said Jane 
Struder, town finance director. The purchase was never made. The money was 
returned to Epstein on Monday, she said. 
C
O\
httpsINAvw.palmbeachpost.comMews/20060727/after-long-probe-billionalre-faces-soNdtation-eharge 515 
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11/11/2019 Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL 
Palm Beach Daily News 
Police say lawyer tried to discredit teenage 
girls Posted Jul 29, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 2:00 PM 
(EDITOR'S NOTE: This story originally was published in The Palm Beath Nun July 
29, 2006) 
Famed Harvard law professor Alan Dershowitz met with the Palm Belch County 
State Attorney's Office and provided damaging information t teenage girls 
who say they gave his client, Palm Beach billionaire JVE pstein, sexually 
charged massages, according to police reports. 
S )  owThe reports also state that another Epstein at, greed  to a plea bargain that 
would have allowed Epstein to have no fly record. His current attorney 
denies this happened. 
And the documents also reveal th father of at least one girl complained that 
private investigators aggressively followed his car, photographed his home and 
chased off visitors. 
Police also talked to somebody who said she was offered money if she refused to 
cooperate with the Palm Beach Police Department probe of Epstein. 
The state attorney's office said it presented the Epstein case to a county grand 
jury this month rather than directly charging Epstein because of concerns about 
the girls' credibility. The grand jury indicted Epstein, 53, on a single count of 
felony solicitation of prostitution, which carries a maximum penalty of five years 
in prison. 
Police believed there was probable cause to charge Epstein with the more serious 
crimes of unlawful sex acts with a minor and lewd and lascivious molestation. 
Police Chief Michael Reiter was so angry that he wrote State Attorney Barry 
Krischer a memo in May suggesting he disqualify himself from the case. 
httpsJNnwe.palmbeachdailynews.com/artlde/20060729/NEW$/190917573 1/4 
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[Phone Redacted] Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL 
The case originally was going to be presented to the grand jury in February, but 
was postponed after Dershowitz produced information gleaned from the Web 
site myspace.com showing some of the alleged victims commenting on alcohol 
and marijuana use, according to the police report prepared by Detective 
Recarey. 
a 20-year-old Palm Beach woman who told police she 
recruited girls for Epstein, also is profiled on myspace.com. Her page includes 
photos of her and her friends, including one using the name "Pimpin' Made1EZ." 
who was not charged in the case, is a potential prosecution witness 
According to Recarey, prosecutor Lanna Belohlavek offered Eps eys 
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, fie speaking with 
Epstein, accepted the deal, in which Epstein would plead gu to one count of 
aggravated assault with intent to commit a felony, bezta on five years' 
probation and have no criminal record. The deal alb for Epstein to submit 
to a psychiatric and sexual evaluation and hav o pervised visits with 
minors, according to Recarey's report. The plea b gain was made in connection 
with only one of the five alleged victims, the report states. 
Fronstin - who declined to co 
veteran defense attorney Ja 
agreement by any of Ep eat s 
S on the case - was subsequently fired and 
ldberger was hired. He denies there was any 
Orneys to a plea deal. 
"We absolutely did agree to a plea in this case," he said. Neither Belohlavek 
nor a state attorneyspokesman could be reached for comment.
The pa n p ents of alleged victims who complained of being harassed by 
privitk gators provided license tag numbers of two of the men. Police 
foirinte vehicles were registered to a private eye in West Palm Beach and 
another in Jupiter, according to Recarey's report. 
"I have no knowledge of it," defense attorney Goldberger said. 
The report also says a woman connected to the Epstein case was contacted by 
somebody who was still in touch with Epstein. That person told her she would 
be compensated if she didn't cooperate with police, Recarey's report says. Those 
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11/11/2019 Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL 
who did talk "will be dealt with," the woman said she was told. Phone records 
show the woman talked with the person who allegedly intimidated her around 
the time she said, Recarey reported. 
Phone records also show that the person said to have made the threat then 
placed a call to Epstein's personal assistant, who in turn called a New York 
corporation affiliated with Epstein, the report states. 
The issue in the Epstein case is not whether females came to his waterfront', 
home, but whether he knew their ages. 
\\\ 
"He's never denied girls came to the house," Goldberger said. But whepr Epstein 
was given a polygraph test, "he passed on knowledge of age," the attorney said. 
After the indictment against Epstein was unsealed tit' Police Chief Reiter 
referred the matter to the FBI. "We've received and we're reviewing 
it," said FBI spokeswoman Judy Orihuela in 
The chief himself has come under atta lawyers and friends in 
New York, where he has a home. T e w ork Post quoted Epstein's 
prominent New York lawyer, Ge.iaLtl Lefcourt, as saying his client was indicted 
only "because of the crazines the\—  police chief." 
Reiter has declined to coltme.ht on the case. 
Prosecutors have n pt E sented a sex-related case like Epstein's to a grand jury 
before, said e Edmondson, spokesman for the state attorney's office. "That's 
what y a case that falls into a gray area," he said. 
Th-rst  attorney's office did not recommend a particular criminal charge on 
which to indict Epstein, Edmondson said. The grand jury was presented with a 
list of charges from highest to lowest, then deliberated with the prosecutor out of 
the room, he said. 
"People are surprised at the grand jury proceeding," West Palm Beach defense 
attorney Richard Tendler said. "It's a way for the prosecutor's office to not take 
the full responsibility for not filing the (charge), and not doing what the Palm 
Beach Police Department wanted. I think something fell apart with those 
underage witnesses." 
httpsiniiww.palmbeachdailynews.comfarticle/20060729/NEWS/190912023 3/4 
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11/11/2019 Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL 
Defense attorney Robert Gershman was a prosecutor for six years. "Those girls 
must have been incredible or untrustworthy, I don't know," he said. 
Other attorneys said Epstein's case raises the issue of whether wealthy, connected 
defendants like Epstein - whose friends include former President Clinton and 
Donald Trump - are treated differently from others. Once he knew he was the 
subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as 
Dershowitz and Lefcourt, who is a past president of the National Association of 
Criminal Defense Lawyers. 
Miami lawyer Roy Black - who became nationally known when he s 
defended William Kennedy on a rape charge in Palm Bea 
involved at one point. 
Said defense attorney Suskauer: aI think it's the public may 
get the perception that with power, you may be tryst rently than the 
average Joe." 
https.//www palmbeachdailynews.com/article/20060729/NEWS/190917573 4/4 
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The Palm Beach Post REAL NEWS STARTS HERE 
Expert: Ignorance of age isn't 
defense in sex cases Posted Aug 5, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 1:38 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on Aug. 5, 2006) 
Even if Palm Beach money manager Jeffrey Epstein di 
know that girls who police say gave him sexual m 
his Intracoastal home were under the legal age, 
wouldn't have exempted him from crimin es of 
sexual activity with minors. c 
"Ignorance is not a valid defense Delde, a legal 
skills professor who was a L rosecutor for nearly 
30 years, half of that tim t'ali g in sex crimes against 
'4C1clirillar
children. 
element as far as the age is `There is no 
concerned," d. 
A.fter an %ttl!bnth investigation, Palm Beach police said 
robable cause to charge Epstein, 53, with 
sex acts with a minor and lewd and lascivious 
F. lestation. They contend that Epstein - friend of the rich 
and famous and financial patron of Democratic Party 
organizations and candidates - committed those acts with 
five underage girls. 
In the past week, New York Attorney General and 
gubernatorial candidate Eliot Spitzer has returned about 
$50,000 in campaign contributions he received from 
Epstein, and Mark a candidate to replace Spitzer in 
EFTA02732449

his current job, has returned 510,000 to him because of the 
Palm Beach scandal, the New York Daily News has 
reported. 
Rather than file charges, the state attorney's office 
presented the case to a county grand jury. The panel 
indicted Epstein last week on a single, less serious charge of 
felony solicitation of prostitution. 
The case raised eyebrows because the state attorney's office 
rarely, if ever, kicks such charges to a grand jury. And it 
increases the difficulty of prosecuting child sex abuse ca 
especially when the defendant is enormously wealthy
can hire high-priced, top-tier lawyers. 
At least one of Epstein's alleged victims tol *cc new 
she was underage when the two of the d for 
massages and sexual activity. She w e old at the 
time 
Ns 
me and said Epstein asked her ti about her high 
school, according to police r 
A girl who said she met Bpste when she was 15 said he 
told her if she told ,CnybodyWhat happened at his house, 
bad things co appen, the police reports state. 
Epstein' ungest alleged victim was 14 when she says she 
gay him m ge that induded some sexual activity. She 
16. The girl's father says he doesn't know whether 
d Epstein her age. 
A
"My daughter has kept a lot of what happened from me 
because of sheer embarrassment," he said. "But she very 
much looked 14. Any prudent man would have had second 
thoughts about that." 
Defense attorney Jack Goldberger maintains that not only 
did Epstein pass a polygraph test showing he did not know 
the girls were minors, but their stories weren't credible. 
The state attorney's office also implied that their credibility 
was an issue when it decided not to charge Epstein directly, 
but instead give the case to the grand jury. 
EFTA02732450

"A prosecutor has to look at it in a much broader fashion: a 
state attorney's spokesman said last week. 
1.11r5 cl::. r 
likTEILLIG EN7 OR 
LEARN MORE ) 
Epstein hired Harvard law Professor witz 
when he became aware he was unde tion, and 
Dershowitz gave prosecutors inf at some of the 
alleged victims had spoke of • hol and marijuana on 
a popular Web site, accor to alm Beach police 
report. 
Prosecutors cphsider two things in deciding 
whether to cli g Jomebody with sex-related offenses 
against • ors - whether there is sufficient evidence and 
whedter ere is a public interest in doing so, Delde said. 
before the girl, he could be charged with a sex crime if 
eens are in a sexual relationship and the boy turns 
+ the sex continues. There would be no public interest in 
pursuing that, Delde said. 
But where there is a large gap in ages - and especially in 
cases of teachers with students - there is a public interest in 
prosecuting, he said. Likewise if the accused has a track 
record of sex with minors. 
EFTA02732451

Still there is a "universal constant" in prosecuting these 
cases, DeIde said. Men who exploit underage children for 
sex often carefully choose their victims in ways that will 
minimize the risk to them, he said. 
Victims usually are from a lower social status, and they may 
suffer from psychological problems, Dekle said. 
"Lots of child sexual abuse victims have been victimized by 
multiple people over a period of time. Then the act of abuse 
produces behavior in the victims that further damages their 
credibility." Examples include promiscuous behavior and
drug abuse. 
Some of the alleged victims in the Epstein case re rnO to 
his home multiple times for the massage ses 
$200 to $300 he typically paid them per at would 
be a definite problem for the prosec etty Resch, 
who prosecuted crimes against Palm Beach 
County for five years and ng . 'vate practice in Lake 
Worth. 
"The victim beco 
"But she's a vi 
pathetic" to a jury, Resch said. 
heless. She's a kid." 
Most machargge with sex crimes against minors look 
said. A jury expecting to see a monster 
And the victims' ages work against them and in 
Oor f the defendant in a trial, Dekle said. 
+ If a child and an adult tell different stories and both swear 
they're telling the truth, adult jurors are more likely to 
believe the adult, Dekle said. 
"You have all these things working against you in a child 
sex abuse case. Prosecutors normally try to be very careful 
in filing those cases because they know what they're getting 
into. There is no such thing as an iron-dad child sexual 
abuse case." 
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The Palm Beach Post REAL NEWS STARTS HERE 
Epstein camp calls female accusers 
liars Posted Aug 8, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 3:35 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on Aug. 8, 2006) 
Attorneys and publicists for Palm Beach financier Je 
Epstein went on the offensive Monday, contendin 
teenage girls who have accused Epstein of sexual 
shenanigans at his waterfront home are li 
S 
saying 3; 
that the Palm Beach Police Departmen " h." 
'"There never was any sex betw e St pstein and any 
underage women," his lead a ack Goldberger, said 
from Idaho where he wa do g with his family. 
Epstein did have y en come to his house to give 
him massages er said. "Mr. Epstein absolutely 
insisted anyb w o came to his house be over the age of 
18. Ho verified that, I don't know. The question is, did 
anything egal occur. The law was not violated here." 
h no explanation as to why Epstein would pay girls or 
the alleged victims 
said was the cnasnemaSs2s0a0getotr$3. 00ingfo-rastheir visits. "The 
credibility of these witnesses has been seriously 
questioned," Goldberger said. 
Epstein, 53, was indicted by a county grand jury last month 
on a charge of felony solicitation of prostitution. After an 
11-month investigation that included sifting through 
Epstein's trash and surveilling his home, Palm Beach police 
concluded there was enough evidence to charge him with 
sexual activity with minors. When the grand jury indicted 
EFTA02732453

Epstein on the less serious charge, Police Chief Michael 
Reiter referred the case to the FBI to determine whether 
there were federal law violations. 
After a spate of stories about the case last week, New York 
publicist Dan Klores - whose client list has included Paris 
Hilton and Jennifer - said on Saturday that Epstein's 
camp was ready "to get their story out." 
They did that Monday via Goldberger and a Los Angeles 
publicist for Miami criminal defense attorney Roy Black, 
who also has represented Epstein in the case. 
"We just think there has been a distorted view of 'st 
in the media presented by the Palm Beach police, '% J 
Goldberger said. 
Reiter has consistently declined to co c ) the case 
and did not respond to a request comment Monday. 
(s\ 
+o 
The implication that State Attorney Barry Krischer was 
easy on Epstein by presenting the case to a grand jury 
rather than filing charges directly against him is wrong, 
Goldberger said. 
EFTA02732454

The Palm Beach Police Department was "happy and 
ecstatic" that the panel was going to review the evidence. I 
think what happened is they weren't happy with the result. 
They decided to use the press to embarrass Mr. Epstein." 
But records show that Reiter wrote Krischer on May 1 -
well before the case went to the grand jury - suggesting that 
Krischer 'consider if good and sufficient reason exists to 
require your disqualification from the prosecution of these 
cases." 
Rather than flat-out decline to charge Epstein, Krischer Ae Alial\" 
referred the case to the grand jury to "appease" the chi , 
Goldberger said. 
A state attorney's spokesman would say onl t office 
refers cases to the grand jury when ther s with the 
viability of the evidence or witnesse ' s ,
Both the state attorney and fry concluded there 
was not sufficient eviden at Lein had sex with 
minors, according to ber r. "It was just a childish 
performance by tVP ch Police Department," 
Goldberger s 
The def attorney said one of the alleged victims who 
cl ed a minor was in fact over the age of 18. 
eged victim who was subpoenaed to testify to 
C e histories of drug abuse and thefts. "These women are 
gXand jury failed to do so. Epstein's accusers, he added, 
+ liars. We've established that." 
But why would they all invent their stories about meeting 
Epstein for sexual massages? 
"I don't have an answer as to what was the motivation for 
these women to come forward and make these allegations," 
Goldberger said. 
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aft ,Reiter focus of fire in Epstein case 
Clipped By: 
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SP!. Apr 22. 2 ,31 
Nerisiiapers—
EFTA02732456

The Palm Beach Post REAL NEWS STARTS HERE 
Delays in Epstein case unusual, 
lawyers say Posted Mar 13, 2007 at 12:01 AM 
Updated Oct 3, 2019 at 3:48 PM 
(EDITORS NOTE: This story originally published in The Palm 
Beach Post March 13, 2007) 
A federal probe or a plea deal could explain the wait i 
Palm Beacher's solicitation case. 
Nearly eight months after Palm Beach tycoo ffr 
Epstein was charged with felony solicita ostitution, 
there has been no discernible progre u s e. No 
witnesses deposed. No trial date t g, save for 
routine court hearings reset lanation. 
"Usually that would b usual" said criminal defense I t ii
attorney Glenn M. e c w o has no involvement in the 
case. 
"As a general rttlg,, it would be unusual for nothing to have 
happene y agreed Michael Dutko, a criminal defense 
attorney in Fort Lauderdale. He represents 
20, of 
case. 
Palm Beach, potentially a key witness in the 
A routine hearing for Epstein was pulled from the court 
docket last week and reset for May 16. The delays and 
inaction could be due to a potential federal probe of Epstein 
or because a plea deal is in the works, attorneys say. 
Unusual is the word that best describes everything about 
the case against Epstein, 54, an enigmatic money manager 
in New York City who counts Bill Clinton and Donald 
Trump among his friends. 
EFTA02732457

"Highly unusual" is how Palm Beach Police Chief Michael 
Reiter described State Attorney Barry Krischer's handling 
of the case in a bluntly critical letter to Krischer last year 
before Epstein was indicted. 
Reiter referred the matter to the FBI to determine whether 
any federal laws had been violated. Epstein's allies 
countered by attacking the chief personally and 
professionally. 
Reiter's department investigated Epstein for 11 months. 
Police sifted repeatedly through his trash and conducted 
surveillance on his five-bedroom, 7 1/2 -bath, 7,234-s 
foot home on the Intracoastal Waterway. 
C)Police said Epstein paid women and girls as young as 1 4 to 7  , 
give him erotic massages at his home. PolickthoUght there 
was probable cause to charge him witfituirawful sex acts 
- \ \i/ with a minor and lewd and lascivious molestation. 
4\ \ 
Epstein responded by hiring a phalanx of lawyers. One of 
them, Harvard law professor and author Alan Dershowitz, 
provided the state attorneys office with information about 
alcohol and m rirjuaissise by some of the girls who said 
they were wit p,Skein. 
Prosecutbfs t en referred the case to the grand jury rather 
than file charges directly against Epstein. 
Epstein's attorneys deny he had sex with underage girls. 
The lawyers say the girls' stories are not credible. But if the 
court file is any indicator, they've made no effort to depose 
the girls. 
Neither prosecutors nor defense attorneys have sought to 
question , said Dutko, her attorney. She recruited 
teenage girls to visit Epstein for massages and sexual 
activity, Palm Beach police said, and presumably would be a 
key witness. 
EFTA02732458

Epstein's attorney Jack Goldberger did not return phone 
messages. 
A source dose to the case suggested it is languishing 
pending a decision by the FBI on whether to refer it to 
federal prosecutors. 
"We still have a pending case," FBI spokeswoman Judy 
Orihuela said Monday. 
State Attorney Krischer did not return a call for comment. 
His spokesman, Mike Edmondson, declined to say whether 
federal investigators are delaying the Epstein case. But,Jhf : 
added, "if another agency is looking at something, e )) 
wouldn't want to step on their toes." 
Attorneys say inertia in a criminal case o 
pending plea deal. 
ts to a 
"It would not surprise me if so as happened that's 
not reflected in the court utko, such as an 
agreement that will be later. 
Defense attorne ner said defense attorneys 
sometimes p off y conducting discovery -- deposing 
witnesses, req g documents and the like -- because 
doing so more work for harried prosecutors who 
e angry and not offer a plea deal. 
metimes defense lawyers, knowing that, will try and do 
+discovery without taking depositions,' said Shiner, a former 
prosecutor for 13 years. 
Instead, they may conduct a below-the-radar probe such as 
having a private investigator check out leads, he said. 
Shiner and others say a plea deal for Epstein probably 
would result in pretrial intervention, in which a defendant 
may be ordered to undergo a psychological evaluation, 
counseling or other conditions in return for dropping the 
charge. 
EFTA02732459

Edmondson, spokesman for State Attorney Krischer, said 
there is no plea offer and no request for the prosecution to 
show its cards. 
"To my knowledge, it's never happened before on a filed 
case," he said. 
EFTA02732460

252 / 278 - Thursday, October 18, 2007 
Edition: FINAL 
Section: LOCAL 
Page: 5B 
Source: The Associated Press 
Illustration: PHOTO (B&W) 
Memo: Ran all editions. 
Dateline: NEW YORK 
WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN Sfl WAS 16 
A billionaire investor, already facing jail in Palm Beach County on charges of tinglfnderage 
prostitutes, is being sued by a young woman who says he had sex with her was 16 and had 
sought his help becoming a model. 
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, sa s nbei6r Jeffrey Epstein had 
the teen perform a sex act when she brought photographs of herself fo review in his Upper 
East Side mansion sometime in 2000. 
Epstein, 54, a money manager, told the teen he managed final or ictoria's Secret and "could get 
you into the catalog" if she were "nice" to him, court pape a papers say being "nice" 
included massages and other favors. 
When the girl told Epstein, "I am 16 years old and j odel," he replied, "Don't worry, I 
won't tell anybody," court papers say. 
Epstein, said by London's Mail on Sunday to clo iend of England's Prince Andrew, has been 
indicted in Palm Beach on charges of solicitin ge prostitutes. That case is pending. 
The girl visited Epstein "several times ov se ral months and engaged in bizarre and unnatural 
sex acts" while she was a minor, the la 
Epstein "repeatedly requested that turn with her 14-, 15-, and 16-year-old girlfriends, 
stating, 'Come by with your frien yours a next time. Don't bring Sherrie (a mutual friend in her 
40s). I love girls your age.' " 
The young woman, now 23, returning to Epstein because she has "mental issues," said her 
lawyer, William J. Unroch. sed to elaborate, but court papers say she was "disabled as a result 
of severe mental dis and d ect." 
Epstein's lawyer i' irk, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can 
read a newspa c gnize the word 'rich.'" 
Lefcourt also tatute of limitations has expired for the woman's case criminally and civilly, 
and will al inly be dismissed. 
He refused to ent on Epstein's Florida charges. 
Meanwhile, Unroch, 57, also acknowledged that his client was living with him and was at the center 
of a $10 million lawsuit he filed last year against a neighbor who said he was having sex with 
underage girls. That case is pending. 
"What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said 
Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve 
the case out of court. 
EFTA02732461

The Palm Beach Post REAL NEWS STARTS HERE 
Palm Beadier pleads in sex case Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 3, 2019 at 1 A7 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on July 1, 2008) 
Jeffrey Epstein will serve 1 1/2 years on teen solicitation A, 
charges. 
He lives in a Palm Beach waterfront mansion and CS S
company with the likes of President Clinton, 
Andrew and Donald Trump, but investor er Jeffrey 
Epstein will call the Palm Beach Co e for the 
next 18 months. 
Epstein, 55, pleaded guilty felony solicitation of 
prostitution and procurin a rs n under the age of 18 for 
prostitution. Afters months in jail, he will be 
under house arr ar. And he will have a lifelong 
obligation to egist r a sex offender. He must submit to 
an HIV test wi 48 hours, with the results being 
provide victims or their parents. 
of the plea deal, federal investigators agreed to drop 
r investigation of Epstein, which they had taken to a 
+ grand jury, two law enforcement sources said. 
Epstein was indicted two years ago after an 11-month 
investigation by Palm Beach police. They received a 
complaint from a relative of a 14-year-old girl who had 
given Epstein a naked massage at his five-bedroom, 7,234-
square-foot, $8.5 million Intracoastal home. 
Police concluded that there were several other girls brought 
in 2004 and 2005 to an upstairs room at the home for 
similar massages and sexual touching. 
EFTA02732462

The indictment charged Epstein only with felony 
solicitation of prostitution. The state attorney's office later 
added the charge of procuring underage girls for that 
purpose. 
Prosecutor Lanna Belohlavek said of the plea: "I took into 
consideration the length the trial would have been and 
witnesses having to testify" about sometimes embarrassing 
incidents. 
Epstein may have made a serious mistake soon after he was 
charged. He rejected an offer to plead guilty to one count 
aggravated assault with intent to commit a felony, 
according to police documents. He would have go 
years probation, had no criminal record and not 
registered sex offender, the documents in••*VI 
Epstein arrived in court Monday a three 
attorneys. He wore a blue blazer e , blue jeans and 
and gray sneakers. A t Judge Deborah Dale 
Pucillo accepted the plea, e s gerprinted. Epstein 
then removed his b as handcuffed for the trip to 
jail while his att d to shield him from 
photographe 
When ritually is released to house arrest, Epstein will 
hays to o erve a 10 p.m. to 6 a.m. curfew, have no 
ervised contact with anyone younger than 18 and 
ther own nor possess pornographic or sexual materials 
at are relevant to your deviant behavior," the judge said. 
Epstein will be allowed to leave home for work. The New 
York-based money manager told the judge he has formed 
the not-for-profit Florida Science Foundation to finance 
scientific research. "I'm there every day," Epstein said. 
The foundation was incorporated in November. Epstein 
said he already has awarded money to Harvard and MIT. 
EFTA02732463

When he is released from jail, there is a chance that Epstein 
will be forced to move. Sex offenders are not allowed to live 
within 1,000 feet of a school, park or other areas where 
children may gather. No determination has been made as to 
whether Epstein's home complies, but attorneys said it 
likely does. 
Sex offenders also typically must attend counseling sessions. 
Belohlavek said that was waived for Epstein because his 
private psychiatrist is working with him. The judge was 
skeptical but agreed to it. 
Epstein's legal woes don't end with Monday's plea. Th 
are four pending federal civil lawsuits and one in 
related to his behavior. At least one woman has s 
New York, where he owns a 51,000-squar 
mansion. 
"Ies validation of what we're sa 
Miami attorney Jeffrey He 
victims in the federal lavr
Ted Leopold represenCso 
anhattan 
civil cases," said 
represents the alleged 
W a Palm Beach attorney 
eged victim in a civil suit in 
state court. He•   • anticipates amending that lawsuit to 
add "a few other clie as well. 
In the c ' al case, police went so far as to scour Epstein's 
an 
MT" 
d nduct surveillance at Palm Beach International 
, where they watched for his private jet so they 
uld know when he was in town. They concluded that 
+ Epstein paid girls $200 to $300 each after the massage 
sessions. 
"I'm like a Heidi Fleiss," , now 22, told police 
about her efforts in recruiting girls for Epstein. 
There was probable cause to charge Epstein with unlawful 
sex acts with a minor and lewd and lascivious molestation, 
police concluded. 
EFTA02732464

The state attorney's office said questions about the girls' 
credibility led it to take the unprecedented step of 
presenting the evidence against Epstein to a grand jury, 
rather than directly charging him. 
Palm Beach Police Chief Michael Reiter was furious with 
State Attorney Barry Krischer, saying in a May 2006 letter 
that the prosecutor should disqualify himself. "I continue to 
find your office's treatment of these cases highly unusual," 
he wrote. He then asked for and got a federal investigation. 
Al cEpstein hired a phalanx of high-priced lawyers - includin 
Harvard law professor and author Alan Dershowitz - 
public relations people who questioned Reiter's cC 
and the victims' truthfulness. 
In addition to mansions in Palm Beach attan, 
Epstein owns homes in New Mai 1 irgin Islands. 
He's a frequent contributor to D arty candidates. 
He also donated $30 million in 2003. 
Former New York G tzer returned a $50,000 
campaign contrib n Epstein after his indictment, 
then resigned uring his own sex scandal. And the 
same Palm Be lice Department that vigorously 
investig stein returned his $90,000 donation for the 
p a firearms simulator. 
Qs Quigley contributed to this story. 
ff "ter Eliot Kleinberg and former staff researcher 
+ 
EFTA02732465

The Palm Beach Post REAL NEWS STARTS HERE 
Jeffrey Epstein: Scientist, 
stuntman, `sex slave' visit jailed 
tycoon By LARRY / Palm Beach Post Staff Writer 
Posted Aug 13, 2008 at 12:01 AM 
Updated Jul 16, 2019 at 4:54 PM 
Tycoon Jeffrey Epstein mingled with an eclectic mix of 
people, including beautiful young women, before he 
into trouble for paying teenage girls to give him 
massages at his Palm Beach mansion. 
Not much has changed, even though h des in a 
dorm at the Palm Beach County Sh ce's 17-acre, 
967-bed stockade near the Tai 
During his first month of efient, Epstein was visited 
by the female assis o t s told police, had escorted 
them to the roo nsion where they gave him 
naked massa 
Also tre to the jail was a young woman whom Epstein 
rt escribed as his Yugoslavian sex slave. 
elted by an expert on artificial intelligence, as well as a 
e ealthy financier and science wonk also has been 
+ man who is a mixed martial arts aficionado and sometime 
movie stuntman. 
The only other people to visit him at the jail, according to 
records, are a Island man and an individual who 
listed Epstein's Palm Beach address as his own. 
Epstein, 55, pleaded guilty on June 30 to two prostitution-
related charges and was sentenced to 18 months in jail, 
followed by a year of house arrest. Epstein paid teenage 
EFTA02732466

girls $200 to $300 in 2004 and 2005 for massages in his 
home that sometimes included sexual touching, Palm Beach 
police said. 
His jail visitors in July included: 
a= 29, who some of the teen masseuses said 
phoned them when Epstein was in town and escorted them 
upon their arrival at his Palm Beach waterfront home to an 
upstairs room, where she prepared the massage table and 
provided the oils for their encounters with him. 
visited Epstein three times in July, according to a jail 4,4 1
visitor's log. lists a Manhattan home address. 
Reached by telephone, she declined to discuss Eps 0 
vi
C )
- 23, whose family in Y a
Epstein paid money to so that he could to the 
United States to be his "sex slave," girls told 
police. One girl told police that s u tructed 
and her to kiss sex while he watched 
and masturbated. Moth sh engaged in sex with 
at Epste g• visited Epstein 
in jail four times . She lists her address as on the 
Upper East si a of attan, not far from Epstein's 
enormous ap t. 
ank, 62, founder of the Institute for Learning 
s at Northwestern University and an expert on 
ficial intelligence, paid one visit to Epstein. Schank has 
+ itten numerous books on that subject and has a doctorate 
degree from Yale University in linguistics. He was one of 19 
people who applied to be president of Florida Atlantic 
University in 2003. He became "chief learning officer" at the 
online Trump University in 2005. Schank listed his address 
as being in Stuart, and records show he also owns a home 
in Lake Worth. 
EFTA02732467

Epstein has financed a number of scientists over the years, 
including Nobel Prize winners. He gave $30 million to 
Harvard University in 2003. In November, he formed the 
not-for-profit Florida Science Foundation, which he said 
finances scientific research. 
- Igor Zinoviev, a Russian mixed martial arts fighter, who 
coaches a Chicago team in the International Fight League. 
He also has worked as a personal trainer, celebrity 
bodyguard and movie stuntman, according to the league's 
Web site. The New Jersey resident visited Epstein seven 
times in July. 
Zinoviev, Schank and 
comment. 
could not be reach 
Staff researcher Niels Heimeriks cont ribt is story. 
EFTA02732468

Palm Beach Daily News 
Billionaire sex offender leaves jail 
six days a week for work 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 4, 2019 at 9:27 AM 
Palm Beach billionaire Jeffrey Epstein, who's serving 18 
months in jail for soliciting an underage girl for 
AS, 
prostitution, is allowed to leave the Palm Beach County 
Stockade six days a week on a work-release program. O 
Teri Barbera, spokeswoman for the Palm Beach 
Sheriffs Office, confirmed that Epstein, 55,Acie 
work-release program since Oct. 10. 
the 
"He works six days a week Frida ednesday 10 
a.m. to 10 p.m.," Barbera said a "(He) works at his 
local West Palm Beach o m • ored on an active GPS 
system (he wears an 
permit deputy, at 
workplace du 
et). Mr. Epstein hires a 
se, for his own security at his 
he is out." 
Miami orney effrey Herman represents six young 
wo en o e sued Epstein, claiming he sexually abused 
at his Palm Beach home when they were minors. 
an said he received a letter about the work-release 
-4÷ program from the U.S. Attorney's Office within the past 
few days. But Herman says Epstein had been out on work-
release for several weeks before the notification. 
"My clients expressed shock and disappointment," Herman 
said. "I find it incredible that he's on work-release in the 
community and my clients aren't notified of this and we get 
this letter weeks after the fact." 
Jack Goldberger, Epstein's criminal attorney, said the 
EFTA02732469

arrangement is not unusual. 
"He goes to work every single day and goes back to jail at 
night, just like everybody else (in the program)," 
Goldberger said. 
Epstein pleaded guilty June 30 to two felony counts: 
soliciting prostitution and procuring a person under 18 for 
prostitution. As part of the plea agreement, Epstein must 
serve one year of house arrest and register as a lifelong sex 
Ctoffender. 
EFTA02732470

The Palm Beach Post REAL NEWS STARTS HERE 
Women want Epstein sex plea deal 
unsealed Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 2, 2019 at 2:23 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post June 10, 2009) 
Their attorneys will ask a judge to open Jeffrey Epsteb( AS,m) 
records. 
1 
When wealthy money manager Jeffrey Epst of aim 
Beach pleaded guilty last year to procure or 
prostitution, his case detoured aro d state rules 
regarding the sealing of court do 
At a plea conference on tate rges, a judge, a defense 
lawyer and a prosecut ud at the bench and decided 
that a deal Epste d with federal prosecutors to 
avoid charges sealed, according to a transcript of C )
the hearing. 
And so i 
rida rules of judicial administration, as well as rules 
e Palm Beach County court system, require public 
A÷. notification that a court document has been or will be 
sealed, meaning kept from public view. The rules also 
require a judge to find a significant reason to seal, such as 
protecting a trade secret or a compelling government 
interest. 
Yet no notification or reason occurred in Epstein's case, 
according to court records. 
EFTA02732471

Epstein's own attorneys, in federal filings, have referred to 
his confidential deferred prosecution agreement with the 
U.S. attorney's office, struck in September 2007, as 
'unprecedented" and "highly unusual." And it was "a 
significant inducement" for Epstein to accept the state's 
deal, observed the state judge who accepted his plea, 
County Judge Deborah Dale Pucillo. 
Epstein now faces at least a dozen civil lawsuits in federal 
and state courts filed by young women who said they had 
sex with him and now are seeking damages. 
40, Ast\' 
Attorneys for some of those women want his agreem N with federal prosecutors unsealed and will ask Cir 't C .)
Jeffrey Colbath to do so today. 
'It is against public policy for these doc be have 
been sealed and hidden from public y s a member 
of the public, E.W. has a right to documents 
unsealed," wrote former Cir u Bill Berger, now in 
private practice and repr e g ne of the women. 
The Palm Bea will ask Colbath to unseal the 
agreement. P ey Deanna Shullman will argue that 
the pub has a nght to know the specifics of Epstein's deal. 
various media accounts, Epstein moved in 
at included President Clinton, Donald Trump and 
ce Andrew. "International Moneyman of Mystery," 
+ declared a 2002 New York magazine profile of Epstein. 
Epstein, 56, is in the Palm Beach County Stockade, serving 
an 18-month sentence after pleading guilty nearly a year 
ago to felony solicitation of prostitution and procuring 
teenagers for prostitution. 
He is allowed out from 7 a.m. to 11 p.m., escorted by a 
deputy, said Palm Beach County Sheriffs Office 
spokeswoman Teri Barbera. 
EFTA02732472

During a Palm Beach Police Department investigation, five 
victims and 17 witnesses gave statements. They told of 
young women brought by his assistants to Epstein's 
mansion on El Brillo Way for massages and sexual activity, 
and then being paid afterward. 
At Epstein's plea conference last year, his attorney, Jack 
Goldberger, and then-Assistant State Attorney Lanna 
Belohlavek approached Pucillo in a sidebar conference. 
Pucillo, who had left the bench nine years earlier, was 
filling in temporarily as a senior judge. 
According to a transcript, Goldberger told Pucillo tha 
Epstein had entered a confidential agreement wi 
attorney's office in which federal prosecutors bro of 
pursuing charges against him if he pleade in state 
court. Pucillo then said she wanted as of the 
agreement filed in his case, and Go oncurred that 
he wanted it sealed. Belohlavek ed off on it. 
The Florida Supreme Co e>Fpressed "serious concern" 
and launched an all- • into sealing procedures 
across the state f edia reports in 2006 of entire 
cases being se sappearing from court records. 
"The pu constitutional right of access to court records 
myet rem inviolate, and this court is fully committed to 
ding this right," justices wrote in their final report. 
+ stein's office on Tuesday referred any questions to 
Goldberger, who declined to comment. Pucillo also has 
declined to comment. 
EFTA02732473

The Palm Beach Post REAL NEWS STARTS HERE 
Epstein secret pact with Feds 
reveals "highly unusual" terms Posted Jun 10, 2009 at 12:01 AM 
Updated Oct 4, 2019 at 9:23 AM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on September 19, 2009) 
A secret non-prosecution agreement multimillionaire 
financier Jeffrey Epstein struck with federal pros 
being called `highly unusual" by former federal p ec on 
and downright outrageous by attorneys noyiljesenting 
young women who serviced him. 
1S1,The deal reveals that the FBI an e 8 ttorney's Office 
investigated him for several es, including 
engaging minors in com e s The crimes are 
punishable by anyw 0 years to life in prison. 
But federal pr asked down and agreed to recall 
grand jury su oe if Epstein pleaded guilty to 
prostitu • -related felonies in state court, which he 
ul atel di . 
ti t
He received an 18-month jail sentence, of 
h he served 13 months. 
ar....\O e U.S. Attorney's Office also agreed not to charge any of 
— Epstein's possible co-conspirators: 
, Lesley Groff and 
The deal was negotiated in part by heavyweight New York 
criminal defense attorney Gerald Lefcourt. 
Unsealed on Friday after attorneys for some of Epstein's 
victims and The Palm Beach Post sought its release, it offers 
the first public look at the deal Epstein's high-powered legal 
counsel brokered on his behalf. 
EFTA02732474

Mark of Stuart, a former federal prosecutor, 
described the disparity in potential sentences as unusual, 
but even more so a provision on attorney payment. 
The first draft of the agreement in September 2007 
required that Epstein pay an attorney -- tapped by the U.S. 
Attorney's Office and approved by Epstein -- to represent 
some of the victims. That attorney is prominent Miami 
lawyer Bob Josefsberg. 
But an addendum to the agreement signed the following 
month struck Epstein's duty to pay Josefsberg if he and thsc ,
victims did not accept settlements -- capped at $150, 
and instead pursued lawsuits. 
said it appears the government w c 
balance the lesser sentence for Epstein ering 
$150,000 for each victim. "I've neve eJe anything 
„tlike that in my life," he said. "It's sual." 
&oviThe deal does not say wh r 'ctims were contacted 
or consulted before vor made. 
Attorney Brad Fort Lauderdale, who represents 
three of the y tmg men, believes that none of the 30 to 
40 woni elen ed as victims in the federal investigation 
were tolate4d of time. said his clients received 
from the U.S. Attorney's Office months after the deal 
Os s gned, assuring them Epstein would be prosecuted. 
"Never consulting the victims is probably the most 
outrageous aspect of it," said. "It taught them that 
someone with money can buy his way out of anything. It's 
outrageous and embarrassing for United States Attorney's 
Office and the State Attorney's Office." 
Epstein now faces many civil lawsuits filed by the women, 
who are represented by a variety of attorneys. In many, the 
allegations are the same: that Epstein had a predilection for 
teenage girls, identified poor, vulnerable ones and used 
EFTA02732475

other young women to lure them to his Palm Beach 
mansion. They walked away with between $200 and 
$1,000. 
Former Circuit Judge Bill Berger, also representing victims, 
called the agreement a "sweetheart deal." 
"Why was it so important for the government to make this 
deal?" Berger asked rhetorically. "We have not yet had an 
honest explanation by any public official as to why it was 
4, 44 1
made ... and why the victims were sold down the river." 6 k
Former federal prosecutor Ryon McCabe described the 
agreement as "very unorthodox." Such agreements, C )
are usually reserved for corporations, not individ als. 
"It's very, very rare. I've never seen or he 
procedure that was set up here," said ho has no 
involvement in any Epstein litiga 
"He's essentially avoiding f rd ecution because he 
can afford to pay that en to help those victims 
review their cases. on has no money, he couldn't 
be able to strik this and avoid federal 
prosecution. 
The ba deal with federal prosecutors is all the more 
i rs(s pbdestin in light of the legal powerhouses who have 
or for Epstein, including Harvard professor Alan 
howitz and Bill Clinton investigator Kenneth Starr. 
+ Lefcourt is a past president of the National Association of 
Criminal Defense Lawyers. 
Epstein's local defense attorney, Jack Goldberger, issued a 
statement Friday saying he had fought the release of the 
sealed agreement to protect the third parties named there. 
"Mr. Epstein has fully abided by all of its terms and 
conditions. He is looking forward to putting this difficult 
period in his life behind him. He is continuing his long-
standing history of science philanthropy." 
EFTA02732476

The investigation triggered tensions between police and 
prosecutors, with then -Palm Beach Chief Michael Reiter 
saying in a May 2006 letter to then -State Attorney Barry 
Krischer that the chief prosecutor should disqualify himself. 
"I continue to find your office's treatment of these cases 
highly unusual," Reiter wrote. He then asked for and got 
the federal investigation that ended in the sealed deal. 
"The Jeffrey Epstein matter was an experience of what a 
.4many-million -dollar defense can accomplish," Reiter told 4
the Palm Beach Daily News upon his retirement. 
CO 
EFTA02732477

187 / 278 - Wednesday, January 27, 2010 
Edition: FINAL 
Section: LOCAL & BUSINESS 
Page: 3B 
Source: By JANE MUSGRAVE Palm Beach Post Staff Writer 
Dateline: WEST PALM BEACH 
JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS 
In a decision that could spark a constitutional showdown over privacy rights 
Tuesday gave lawyers representing multimillionaire sex offender Jeffrey the right to 
subpoena abortion records from women who are seeking millions in m the part-
time Palm Beach resident. 
Palm Beach County Circuit Judge Donald Hafele said the records ould e p Epstein rebut 
the women's claims that they suffered psychological ills after ing to give him 
sexually-charged massages at his Palm Beach mansion wh= were as young as 14. 
Hafele told Epstein's attorneys they couldn't go on a fis ition. The medical records, 
he said, can't be sought until the women are asked w have ever had an abortion, 
how many and where. Further, he said, the record be made public and might not 
be admissible during trial. 
But, he said, since the women claim Epstein s responsible for their emotional 
distress, his attorneys can explore the im f o events. Medical records, Hafele said, 
are a better source of information than memory. 
Attorney Louis Silver, who represe idential Women's Health Center, a West Palm 
Beach clinic where abortions are , warned Hafele that he was stepping on shaky 
constitutional grounds. 
"These records are protected onstitutional right of privacy," he said, referring to the 
Florida Constitution. 
After the hearing, Silver appeal won't be necessary until Epstein attorneys seek the 
records. 
In another ruling e • ay, Hafele also said that videos from depositions in the state cases 
can't be rel 'th t a court order. The ruling came after Epstein attorney Robert Critton 
complain ideo of Epstein being asked whether he had an "egg-shaped" penis 
becam ' . -.com sensation. It first appeared on The Palm Beach Post Web site. 
Critton me attorney Spencer Kuvin for releasing it. Kuvin said it was public record. 
The civil s Its began mounting after Epstein agreed to plead guilty to two state charges: 
procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18-
month sentence. As part of the deal brokered with federal prosecutors, he agreed not to 
contest the accusations in the civil lawsuits. He can argue the women don't deserve the 
millions they are seeking. 
—jane musgrave®pbpost.com 
EFTA02732478

The Palm Beach Post REAL NEWS STARTS HERE 
Epstein Journal's Findings Could 
Resurrect Case By Jane Musgrave 
Posted Sep 17, 2019 at 12:01 AM 
Updated Oct 1, 2019 at 10:51 AM 
4, 464k 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on March 20, 2010)
OA purloined journal that is said to contain the nams, 
"hundreds" of victims of convicted sex offender J .efey) 
Epstein could be used to reopen the invests tion iitt the 
multi-millionaire's appetite for teenage,gir njttorney 
representing seven of the victims sa 
New details about the conten journal were released 
this week when Alfredo gu , who worked as a 
property manager for Pal each resident, pleaded 
guilty to obstru ice for lying to federal agents 
when asked if information about his former 
boss' criminal . He later tried to sell the journal he 
stole fro for $50,000 to an unidentified person, 
alert authorities, according to court records. 
O paftof the plea. agreement,.  
material th 
federal prosecutors .said the 
a "contains 
investigation, including the names of material witnesses 
and additional victims." 
"Had the items been produced in response to the inquiries 
of state or federal authorities ... the materials would have 
been presented to the federal grand jury," federal 
prosecutors wrote. 
EFTA02732479

Instead, prosecutors short-circuited the grand jury 
investigation and cut a deal with Epstein. They agreed not 
to pursue federal charges if he didn't contest prostitution-
related felonies in state court. The money manager pleaded 
guilty in July 2008 to procuring a minor for prostitution 
and soliciting prostitution. He served 13 months of an 18-
month sentence. 
Attorney Adam Horowitz, who represents seven of the 
roughly 18 women who have filed civil suits against 
Epstein, said the new information could trump the so-
called non-prosecution agreement. 0A 
The multifaceted agreement, he said, deals only '0rO 
specific list of victims that the U.S. Attorney's O e k ew 
about when it penned the deal in 2007. If al victims 
are listed in the journal Rodriguez stol said 
federal prosecutors could reopen t ation. 
"It opens the door for furth solution," he said. 
In addition to turnin oumal to federal agents, 
Rodriguez told th w his former boss was having 
sex with unde hen he worked for him in 2004 
and 2005. He n naked girls, who looked like minors, 
in the p Epstein's S8.6 million mansion. He had seen 
po ogra is images of young girls on Epstein's computer, 
g to court records. 
+ Neither Epstein's criminal defense attorney, Jack 
Goldberger, nor attorney Robert Craton, who represents 
Epstein in the civil lawsuits, could be reached. Federal 
prosecutors have consistently declined comment. 
The wording of the controversial agreement is unclear. It 
says federal prosecutors would provide Epstein's attorneys 
"with a list of individuals whom it has identified as victims! 
Miami attorney Robert Josefsberg was appointed to 
EFTA02732480

represent any of the victims on the list who wanted to 
pursue Epstein in civil court. As part of the agreement, 
Epstein is to pay for Josefsberg to represent the women. 
Some of the women, most identified as Jane Doe in 
lawsuits, had already hired attorneys to represent them. 
Some have since settled their suits with Epstein, although 
terms were not disclosed. 
Horowitz said he has filed court papers to get the journal 
that Rodriguez stole. It's another piece of evidence that 
shows our clients were at Epstein's mansion," he said. AS_ 
Rodriguez told prosecutors he didn't turn over the 
and 
'cri
when both FBI  Palm Beach police asked for i beca e 
he wanted money for it. He also said he was 'd 
would make him "disappear." The info e told 4 
investigators, was his "insurance po
*He faces a maximum 20 years  n hen he is 
sentenced on June 18.
jane_musgrave@p 
@pbpcourts C 
r gN('S  IC illair
‘...) 
EFTA02732481

Epstein paid three women $5.5 million to end underage-sex lawsuits - News - The Palm B... Page 1 of 3 
The Palm Beach Post REAL NEWS STARTS HERE 
Epstein paid three women $5.5 million to end underage-
sex lawsuits By Jane Musgrave 
Posted Oct 3, 2017 at 12:01 AM 
Updated Oct 4, 2017 at 12:46 AM 
Ending years of speculation about how much Palm Beach billionaire in paid young 
women who claimed he used them as sex toys, court documents fil w show he shelled 
out $5.5 million to settle lawsuits with three of more than two dozM teeits who sued him. 
Responding to requests from Epstein's attorneys in a com 
sex scandal, attorney said the politi 
offender paid more than  Si million to each of the 
uit that was spawned by the 
ed 64-year-old convicted sex 
represented. 
Identified in court papers only by their initi orddonyms because of the nature of the 
allegations and their youthful ages, L.M p $1 million, E.W. $2 million and Jane Doe 
$2.5 million, said of the se m e negotiated with Epstein to end the lawsuits. 
Jack Goldberger, one of Epstein s crimi al defense attorneys, on Tuesday declined comment on 
the revelations, citing confidentiality agreements that were part of the settlements. For the 
same reason, he declined toeay whether Epstein paid similar amounts to settle roughly two 
dozen lawsuits fil otheryoung women against Epstein, claiming he paid them for sex 
when some w g as 14 years old. 
Attornr ola, who is representing said his client was compelled to divulge 
the confiden 'al settlements to answer questions posed by Epstein's attorneys. "Brilliant move 
on their part," he said. 
Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have 
likely come out. He says the information will help hint undermine Epstein's claims that 
"glinted up" the allegations to help his former law partner, imprisoned and disbarred 
Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme. 
https://www.palmbeachpost.com/news/crime-law/epnpaid-three-women-million-end... 11/11/2019 
EFTA02732482

Epstein paid three women $5.5 million to end underage-sex lawsuits - News - The Palm B... Page 2 of 3 
The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute 
between Epstein and Rothstein, both billionaires. 
A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a 
minor for prostitution, he sued Rothstein and claiming they trumped up the 
allegations of sexual molestation to perpetuate the Ponzi scheme. 
Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly 
successful law firm by forging the names of federal judges and others to persua vestors he 
had negotiated settlements in lawsuits against high-profile people. Investorc e t they j ,
could get a cut of the cash. 
One of the high-profile people Rothstein used to lure investors w Epst m, according to a 
lawsuit West Palm Beach attorney Robert Critton filed on E . 's alf. According to the 
lawsuit, Rothstein told investors Epstein, a money man reed to settle the lawsuits 
with the teens for $200 million — a claim Critton des complete fabrication." 
After Epstein dropped the lawsuit in 2012, Ed med the tables on him. accused 
Epstein of filing the lawsuit maliciously to • h lljm77for representing the young women. 
Although was a partner in Ro s ow defunct firm, Scarola claims Epstein had 
no evidence was involved jd qie nzi scheme. Federal prosecutors successfully 
charged other attorneys and me 
said in the malicious prosecutio uit. 
The revelations abou 
documents filed f 
was never implicated, Scarola 
the f(ott y Epstein paid to three of the young woman came last week in 
earmg Tuesday in preparation for a December trial on the lawsuit. 
Attorney ja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the 
trial, in part, • e she claimed she has been unable to talk to her client since his estate on his 
private island in u U.S. Virgin Islands was devastated last month by Hurricane Irma. "I've had 
no ability to co cate with Mr. Epstein," she said. 
haps://www.palmbeachpost.com/news/crime-law/epnpaid-three-women-million-end... 11/11/2019 
EFTA02732483

Epstein paid three women $5.5 million to end underage-sex lawsuits - News - The Palm B... Page 3 of 3 
Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge 
Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those 
victimized by the storm that hammered the Caribbean and roared through South Florida, he 
said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims. 
Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide 
before the case goes to trial. 
Despite Scarola's insistence that had nothing to do with Rothstein's Pg scheme, 
Coleman said the evidence indicates otherwise. Why else would he try to d Ep ein's 
well-known friends, such as now President Donald Trump, former Pre • Clinton and 
illusionist David Copperfield, she asked. He used the celebrities as a said. 
'The Epstein cases were used to fleece money and defraud in c) rs, e said. 
Edward's malicious prosecution case has been difficult des because both Epstein and 
have refused to answer questions. As he L~jjr, t vil lawsuits, Epstein has invoked 
his Fifth Amendment right against self-incrim* ti when questioned by Scarola. 
has claimed that much of the information F m eeking is protected by attorney-client 
privilege. 
lil cious prosecutio 
against Epstein. 
the federal Crime Victi 
Epstein. 
( euOnly after fed os S ton agreed to drop their investigation of Epstein, did he agree to 
plead gull o o rostitution charges in Palm Beach County Circuit Court. In federal court 
records, ton claim one of the key reasons they agreed to drop their case was Epstein's 
agreement t settle lawsuits filed against him by dozens of his underage victims. 
ale'e two hotly-contested lawsuits that continue to pit 
is suing the U.S. attorney's office, claiming it violated 
when it negotiated a non-prosecution agreement with 
haps://www.palmbeachpostcom/news/crime-law/epnpaid-three-women-million-end... 11/11/2019 
EFTA02732484

Palm Beach Daily News 
Judge rules feds' agreement with 
Jeffrey Epstein pact violated teen 
victims' rights By Jane Musgrave 
Posted Sep 17, 2019 at 4:02 PM 
(EDITOR'S NOTE: This story originally published in The 'A l
Updated Oct 8, 2019 at 12:31 PM 
Palm Beach Post on February 22, 2019) 
0 
Federal prosecutors violated the rights of Jeffrey steites l
victims by failing to reveal they h dropped plans 041/400
t itito prosecute the billionaire on dozens e 'charges in 
at his Palm Beach mansion, U. . • ' Judge Kenneth 
Als ,connection with the girls' claims t e ' them for sex 
Marra ruled on Thursday. 
Att 
S 
In a blistering 33-pa , Marra meticulously and 
methodically de umerous steps federal 
prosecutors t ok to e the agreement from more than 40 
young women 6 claim Epstein paid them for sex when 
they weryoung as 14. 
4 1e the government spent untold hours negotiating the 
s and implications of the NPA with Epstein's attorneys, 
7\ scant information was shared with the victims: Marra 
, wrote. "Instead, the victims were told to be 'patient while 
the investigation proceeded." 
By then, it was too late. A deal had already been cut with 
then -South Florida U.S. Attorney Alex Acosta and Epstein's 
attorneys to shelve a 52-page federal indictment against 
Epstein, a former math teacher turned money manager 
who counts Presidents Donald Trump and Bill Clinton 
among his friends. 
EFTA02732485

Prosecutors' failure to alert the young women about the 
deal violated the Crime Victims' Rights Act, Marra ruled. 
"At a bare minimum the (act) required the government to 
inform (the young women) that it intended to enter into an 
agreement not to prosecute Epstein," he wrote. 
Still, Marra said he wasn't second-guessing prosecutors' 
decision not to pursue Epstein on federal charges if he 
pleaded guilty to minor state prostitution charges and 
agreed to compensate his victims for the trauma he caused. 
"The court is not ruling that the decision not to prosecute 
was improper," Marra wrote. "The court is simply 
that, under the facts of this case, there was a viola •C )
the CVRA." 
Further, he made no decision about wh edy 
should be. He gave prosecutors and h presenting 
the young women 15 days to m • e how to unravel 
the complex legal web that anging over Epstein 
and his young victims for tuitu a decade. 
The chances an a~C e reached are slim, said 
attorney Jack o is representing the two Jane 
Does who ch n the prosecutors' actions. 
d, there is no road map to follow. The 
omey filed on behalf of the two 
tified young women, claiming prosecutors violated 
federal act, is unique, he said. 
"We are treading on virgin ground, to use what is probably 
an inappropriate phrase in this situation," he said. 
Scarola said he and will ask that the non-
prosecution agreement be thrown out. That would open 
the possibility that the long-shelved federal indictment 
could be dusted off and filed against the 66-year-old 
Epstein, who spends most of his time on a private island he 
owns in the U.S. Virgin Islands. 
EFTA02732486

"I don't see the government conceding to that remedy," 
Scarola admitted. Further, he said, it is likely Epstein will be 
allowed to weigh in. Miami attorney Roy Black years ago 
filed papers asking to intervene on Epstein's behalf. 
The U.S. Attorney's Office said it wouldn't comment on 
Marra's ruling. Neither Black nor New York City attorney 
Jay Lefkowitz, who led efforts to bury the federal 
indictment, responded to emails or phone calls for 
comment. West Palm Beach attorney Jack Goldberger, who A 
represents Epstein, also didn't respond. 
Scarola said it is likely Epstein's star-studded legal teagr I S
argue that Epstein fully complied with the terms 
agreement he made in 2007 with federal prosecu 
therefore the agreement can't be undone. 
As he promised, Epstein pleaded gu u 2008 to state 
charges of soliciting a minor for r n on and soliciting 
prostitution. He served 13 s 18-month jail term 
in a vacant wing of the c st de that he was allowed 
to leave 12 hours a d ys week. 
Further, as a 
who sued hi 
id settlements to the young women 
e the settlements were confidential, 
court re4show he paid three women a total of $5.5 
n. 
Orrge rn, federal prosecutors held up their end of the 
ain. Their investigation ceased. 
Having done all that prosecutors asked of him, Scarola said 
Epstein will make a simple argument: 'You can't turn 
around and deprive me of the benefits I bargained for." 
However, Scarola said, using Marra's ruling, he will counter 
that the contract Epstein signed was illegal and therefore 
unenforceable. 
EFTA02732487

Even if Marra agrees to toss out the non-prosecution 
agreement, Scarola conceded that doesn't mean Epstein will 
face federal charges. 
"The contract can be set aside and the federal government 
can attempt to enter into the same agreement," he said. 
"Except the spotlight of public attention will be on them 
and the 40 victims will be able to explain to the court why 
this sweetheart deal should not be approved." 
Scarola said that prosecutors may have had good reason not 
to pursue Epstein. "There may be a reasonable explanation( 
but we don't know what that reason may have been," O 
said. 
In court papers, federal prosecutors have s CSy of 
the young women were afraid to crossZo l
politically connected money manag ly refused to \ 
testify against him. 
In other cases, they said 
Jane Doe 2, who is 
agreement throw"!, 
awesome ma niland to,prosecutors she hoped "nothing 
happens" to him. While she later agreed to testify against 
Epstein, ecutors said they feared Epstein's attorneys 
wgald u er words to destroy her if she ever took the 
stand. 
SCIS:o changed their stories. 
e the non-prosecution 
ally described Epstein as "an 
Oarra, however, said the young woman's comments didn't + 
mean she wasn't entitled to know about the prosecutors 
plans to drop the charges. "There is no dispute that Epstein 
sexually abused Jane Doe 2 while she was a minor," he 
wrote. "Therefore, regardless of her comments to the 
prosecutor, she was a victim." 
Before the case is finally resolved, Scarola predicted that "a 
lot of people are going to have to answer a lot of questions." 
EFTA02732488

In his ruling, Marra detailed what appeared to be a cozy 
relationship between Acosta, his line prosecutors and 
Epstein's team of lawyers. His phalanx of lawyers included 
noted Harvard law professor Alan Dershowitz and Kenneth 
Starr, the former U.S. solicitor general whose investigation 
led to the impeachment of President Clinton. 
Marra describes an October 2007 breakfast meeting 
between Acosta, who is now U.S. labor secretary, and 
Lefkowitz shortly after the non-prosecution agreement was A 
inked. 
After the meeting, Lefkowitz sent Acosta a note th •O AS, anI 
him for 'the commitment you made to me duringtbr 
October 12 meeting in which you assured me that you0 
Office would not ... contact any of the identified 
individuals, potential witnesses, or po -Nyil claimants 
and their respective counsel in this tt s t) 
Marra quoted an equally ple then-Palm Beach 
County State Attorney B er sent to Assistant U.S. 
Attorney Vill o was the lead prosecutor in 
Epstein's case. d get this worked out for 
reasons I wo put "ring," Krischer wrote, shortly 
after the non- ution agreement was signed. "After this 
is resolv uld love to buy you a cup at Starbucks and 
a co ersation." 
y of the notes that were exchanged dealt with 
+ prosecutors and Epstein's lawyers' shared desire to keep the 
deal secret from Epstein's accusers. In a September email, 
Villafana asked Lefkowitz for guidance about what she 
should reveal. "And can we have a conference call to discuss 
what I may disclose to ... the girls regarding the 
Agreement," she asked. 
EFTA02732489

Such cooperation between prosecutors and defense 
attorneys is unusual, Marra said. "It was a deviation from 
the government's standard practice to negotiate with 
defense counsel about the extent of crime victim 
notifications," he wrote. 
Further, he noted, that when and his two young 
clients asked for information, they were repeatedly misled. 
"The CRVA was designed to protect victims right and 
ensure their involvement in the criminal justice process,"
Marra wrote. "When the government gives information to 
victims it cannot be misleading." 
Ultimately, the terms of the non-prosecution agr 
were revealed only after and attorneys 
31press successfully sued to make them pub1 • 
[Email Redacted] 
I'S 
)9 
@pbpcourts 
EFTA02732490

76 / 278 - Tuesday, July 9, 2019 
Edition: Final 
Section: A Section 
Page: 1A 
Source: By Jane Musgrave, The Palm Beach Post 
Epstein indicted on sex charges 
trafficking, conspiracy charges in federal co44i 
Part-time Palm Beacher pleads not guilty to s 
Manhattan 0 
Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on M> pleaded not guilty 
to charges accusing him of creating a vast network of girls "-young as 14 that he exploited 
for his sexual pleasure at his homes in Palm Beach and nhattan. 
The 66-year-old money manager's appearance in U.S. s is Court in New York City 
capped more than a decade of recriminations by yo and their attorneys who 
claimed Epstein used his money and political in e e void federal prosecution. 
Epstein's attorney Reid Weingarten dismissed -count indictment on sex trafficking 
charges as "essentially a do-over" of allege ended Epstein in the Palm Beach 
County Jail for 13 months more than a 
However, unlike in 2007 when then- nda U.S. Attorney Alex Acosta agreed to 
shelve a 53-page federal indictment agreed to plead guilty to two state 
prostitution charges, prosecutopwt eye ork indicated they aren't willing to deal. Acosta is 
now U.S. labor secretary. 
"The alleged behavior shocks nscience," New York City U.S. Attorney Geoffrey 
Berman said at a 
morning news conf renc d while the charged conduct is from a number of years ago, it 
is still profound! t to many of the alleged victims, now young women. They 
deserve their 
At a detenti ng scheduled for Monday, Berman said he will ask a federal judge to 
keep Eps d bars until he is tried on charges of sex trafficking and conspiracy to 
comm fficldng. Epstein paid dozens of young women to give him nude massages 
that, form t, led to sex, he said. 
If convicted of explolgacipzens of young women, including many Palm Beach County girls 
who were students at Palm Beach High School, Epstein faces a maximum 45-year 
prison sentence. 
Citing Epstein's enormous wealth, his homes in New York, Palm Beach, the U.S. Virgin 
Islands, New Mexico and Paris and his ownership of two jets, Berman said there are few 
conditions that could keep Epstein from fleeing to a foreign country to evade prosecution. 
EFTA02732491

"We think he's a significant flight risk," Berman said of the man who ferried Britain's Prince 
Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former 
President Bill Clinton on his jet, dubbed the Lolita Express. 
Berman's hard-line stance was welcomed by young women who for years have been told that 
Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement, 
promising not to charge Epstein in federal court. 
Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning 
her into his sex slave and forcing her to have sex with others, including Dershowitz and 
Prince Andrew, praised Berman. He showed the case is "being taken in a serious ay," she 
told the Associated Press. Dershowitz has vehemently denied Guiffie's claims. 
New York prosecutors were able to ignore the controversial nonprosecution 
because it contained some significant fine print, said former federal Judge Cassell, who 
for years has fought to get the agreement thrown out. It says only that could be 
filed against Epstein in South Florida, he said. 
Berman agreed. "That agreement only binds, by its terms, only bi th outhern District of 
Florida," he said. "The Southern District of New York is not at agreement and 
wasn't a signatory of it." 
That means the sordid allegations that have been levele for years are now part of 
a federal indictment. 
Contrary to Epstein's claims, he knew the women to his homes in New York and 
Palm Beach were minors because they told him t eieag , according to the indictment. 
Epstein preyed on young girls because he w tis ,vere "vulnerable to exploitation," 
prosecutors added. 
As part of a carefully orchestrated sex in or his associates would call girls while 
he was in New York so they would e for sex once he returned to Palm Beach, the 
indictment says. The employees ed. They were identified only as "Employee-I," 
"Employee-2" and "Employe 
To ensure he had a steady s o oung girls, Epstein would turn some victims into 
recruiters. He would pa them t ring new girls to his home on El Brillo Way along the 
Intracoastal Waterway i lgrBeach or to his palatial townhouse on New York's Upper East 
Side. 
"This allowed E to create an ever-expanding web of new victims," Berman said. 
In both New an alm Beach, the lurid operation was similar. Unidentified employees 
of Epstei escort the teens into a room. They were told to take off all or most of their 
clothes ng the naked billionaire massages, according to the indictment. 
"Epstein ou also typically masturbate during these encounters, ask victims to touch him 
while he m turbated, and touch victims' genitals with his hands or with sex toys," the 
indictment says. 
As part of the criminal complaint, prosecutors arc asking that Epstein be forced to turn over 
his multimillion-dollar townhouse on East 71st Street. The complaint does not seek forfeiture 
of Epstein's house in Palm Beach. 
While heartened that Epstein now faces serious criminal charges in New York, Cassell said 
he would continue to push a West Palm Beach-based federal judge to throw out the 
nonprosecution agreement that Acosta forged with Epstein's star-studded legal team. 
EFTA02732492

U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime 
Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked. 
Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight 
Monday, explaining what action Marra should take to redress that wrong. 
Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida 
victims deserve justice in Florida" said Cassell, who is working on behalf of Epstein's 
victims with attorneys and Jack Scarola. 
Since it's likely Florida women will get to testify against Epstein in New York, Scarola said 
he's not focused on whether Epstein will face charges here. Instead, he said he waits to know 
how and why the agreement was reached. 
"There's been no explanation as to how a deal like this could have been cut ho e 
federal government could have been involved in a conspiracy to violate fe law, Scarola 
said of his interest in continuing the legal battle over the nonprosecutio nt. 
When Acosta agreed to drop the federal investigation, Epstein in 2 d guilty to two 
prostitution charges and served 13 months of an 18-month senten rn a acant wing of the 
Palm Beach County Jail - a cell he was allowed to leave 12 ho rs a , six days a week. He 
was also forced to register as a sex offender and settle civi s more than 30 young 
women filed against him. 
U.S. Rep. Lois Frankel, D-West Palm Beach, said sh • la's interest in finding out 
how the agreement came to be."I am especially m e ed in why Epstein got the deal 
he got," Frankel said. "We need to know why n such an easy sentence. 
While she has asked the House Oversight o investigate Acosta, Frankel said she 
is not sure that will happen. "It just seems a it as a travesty that this guy got off the 
way he did and, without pre-judging it 's ha a proper court case," Frankel said. 
Former Palm Beach Police Chief er was inflamed in 2006 when then-State 
Attorney Barry ICrischer refused pstein with serious crimes. Reiter took the 
information his officers had g m dozens of Epstein's victims to Acosta, believing 
he would prosecute Epstein. 
Reiter said he was heart ned tha years later, Epstein will finally face justice. 
"Thankfully, U. S. Atto rman and the other authorities in New York have the good 
judgment to invest to a • prosecute Epstein in the way that should have occurred in 
Florida over a de ago,' Reiter said in a statement. 
And, Scarol th are signals that Berman's investigation is far from over. 
Berman d answer questions about whether others, such as Epstein's high-powered 
friend; charged. He brushed off questions about the significance that the 
investig tk:in was being handled by the Public Corruption Unit. 
While agedt on Saturday were arresting Epstein aboard his private jet at the Teterboro 
Airport in New Jersey after returning from Paris, other officers were searching his New York 
City townhouse. Agents seized nude photos of young girls who appeared to be minors, 
Berman said. 
He said his focus was on finding more women who were exploited and abused by Epstein. 
Turning to a poster, detailing the charges that had been filed against Epstein, he pointed a 
finger at a photo of the convicted sex offender who was once described as "a man of 
mystery." 
EFTA02732493

"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you," 
Berman said. A special number, 1-800-CALLFB1, will link victims of authorities. 
Bill Sweeney, assistant director of the FBI's New York office, said after years of being 
ignored by federal agents, the victims' voices will be heard. 
"The Jeffrey Epstein matter is No. 1 on the major case list in the country," Sweeney said. 
Turning to address Epstein's victims directly, he said: "Your bravery may empower others to 
speak out against crimes against them." 
[Email Redacted] 
EFTA02732494