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EFTA02732620

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Filing # 101840557 E-Filed 01/17/2020 12:23:06 PM 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
v . 
DAVE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
CASE NO.: 50-2019-CA-014681-XXXX-MB 
Div.: AG 
NOTICE OF FI 
Plaintiff, CA Florida Holdings, LLC, by and 
notice of filing the attached First Amended 
Dated: January 17, 2020 
Ac) 
• undersigned counsel, hereby gives 
pectfidly submitted, 
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] 
Facsimile: ([Phone Redacted] 
By /s/ Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
Florida Bar No. 849324 
mendelsohns gtlaw.com 
hasenh®gtlaw.com 
[Email Redacted] 
FILED: PALM BEACH COUNTY. FL. SHARON R BOCK. CLERK, 01/17/2020 12:23:06 PM 
EFTA02732620

I HEREBY CERTIFY that on this 1 
By: /s/ Michael .1 Grvgiel 
MICHAEL J GRYGIEL 
(Admitted Pro Hac Vice) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: ([Phone Redacted] 
Facsimile: ([Phone Redacted] 
grvgielmeetlaw.com 
By: /s/ Nina D. Bovajian 
NINA D. BOYAJIAN 
(Pro Hac Vice application pen •T-1
1840 Century Park East, Su': 
Los Angeles CA 90067 
Telephone: (310) 586 
Facsimile: (310) 586 
bo a"ian la •m 
riveraal tla 
CERTIFICATE (SERVICE 
d;NFJanuaty, 2020, a copy of the foregoing has 
been electronically filed with the Flori ortal for e-service on all parties of record herein. 
+6s 
/s/ Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
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EFTA02732621

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, CASE NO.: 50-2019-CA-014681-XX XX-MB 
Publisher of THE PALM BEACH POST, Div.: AG 
Plaintiff, 
v. 
DAVE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
FIRST AMENDED CSI
'CicCA Florida Holdings, LLC, publisher o eN Beach Post, for its First Amended \ 6
Complaint against Dave Aronberg, the S tto y for Palm Beach County, Florida, in his 
official capacity ("State Attorney"), R. Bock, the Clerk of the Court for Palm Beach 
C .)County, Florida, in her official '1c ourt Clerk"), alleges as follows: 
JURISDICTION 
rI. This is an to within the exclusive jurisdiction of the Circuit Court pursuant to 
Fla. Stat. Secti 2 (2Xa) and 86.011 et seq. 
2. 
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 
has authority in grand jury proceedings pursuant to Fla. Stat. Section 27.03. He is sued herein in 
EFTA02732622

his official capacity as his office is in possession and/or control 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 and/or 
control of documents that are the subject of this action. 
INTRODI1CT ION 
Alk 
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 to or, nor even forced to 
Wha Iconfront, allegations of serious sex trafficking crimes. • It that Jeffrey Epstein's 2008 
Sdeal with the State of Florida was not consistent w" Vdence gathered against him, what i rese
isremains shrouded in mystery is how that evid nted — and the extent to which it was et
presented - to the grand jury that return n in s ment far more limited in scope than expected 
and deserved. 
6. Through this ac 'on, T Palm Beach Post seeks public access to the testimony, 
minutes, and other evid ented in 2006 to the Palm Beach County grand jury empaneled 
during the first E sex use investigation. Typically, access to such materials is limited, for 
example, in p vent the flight of those whose indictment may be contemplated and their 
ability 1 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(1 Xc). 
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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EFTA02732623

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 Epste' grand jury 
proceedings will shed light on the extent to which those in our government enf with the 
solemn responsibility of enforcing our criminal laws equally as to all citize their duties 
in this instance. Justice will be furthered where it is either (1) demons 
like others accused of similar heinous crimes, or (2) as app 
who chose to give Epstein favorable — "unusual," in the Town of Palm Beach Police 
\s ,Chief — treatment, are exposed and held accountable o w t limited information is now in the 
public domain, the State Attorney's referral o i'ut case to the grand jury — which would be 
out of the ordinary for this type of c gt rise to a strong inference of favoritism and 
corresponding disregard for the ri t inor victims of Epstein's sex trafficking. Access to 
the grand jury materials will all w the ublic to determine whether the grand jury process, and the 
sed to further justice or, instead, operated to shield Epstein and secrecy that comes with i 
his co-conspiratq 
Section 905. 
+ ven 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, 
stein was treated 
y to be the case, those 
e consequences of their criminal activities. Accordingly, Fla. Stat. 
onzes the disclosure of Epstein's 2006 grand jury proceedings. 
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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 Pal h County 
grand jury first being submitted to this Court for in camera review, where be redacted, 0 
as appropriate, to protect those who deserve such protection. 
FACTUAL BACKGROUND
it10. The following facts were gathered, in larg documents obtained by The 
es ,Palm Beach Post through various Florida Public It requests, documents unsealed or i r
i rccpublicly available in other related judicial p in , and information and documents in the 
public record. 
A. First Epstein Sex Crinrgs lav intion, Indictment, and Plea Agreement: 
2005-2008. 
11. The investigatio Epstein's sex crimes began more than fourteen years ago, 
when a 14-year-old 'rl's prliother reported to police in the Town of Palm Beach, Florida, that 
Epstein and oft worked for him arranged for her to give Epstein a "massage." Epstein 
required t to 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 tms were 
expected to testify. The proceeding was postponed, however, due to meet een the State 
Attorney's office and Epstein's prominent criminal defense lawyeq z onal friend, Alan 
Dershowitz. 
c4)15. Another grand jury was convened in April 4,., anceled the day before it was 
i
i\
r
to begin receiving evidence. 
ts ,(I) Police Chief Reit e to the State Attorney. ( s ir 
16. On May I, 2006, Town Pa Beach Police Chief Michael Reiter wrote a 
"personal and confidential" letter n Im Beach County State Attorney, Barry Krischer, 
stating: 
I must renew m observation to you that I continue to find your office's 
treatment of the E to ] cases highly unusual. It is regrettable that I am forced to 
communic' in tin manner, but my most recent telephone calls to you and those 
of the tive to your assigned attorneys have been unanswered and 
mes es nain unreturned. After giving this much thought and consideration, I 
muk ou 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 
diIgpalification 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. 
18. 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 
Beach County. 
19. In July 2006, after State Attorney Krischer presented t Ond evidence from 
in Palm 
one victim, the grand jury returned an indictment on a sole coj f tation of prostitution. 
A 
There is no mention in the indictment of the victim being
20. On information and belief, a second to s victims was supposed to testify 
before the grand jury, but was unable to atten s f a school exam. 
21. No reasonable explanatio be rovided as to why the numerous other known 
victims were not presented as with es me victims to the grand jury convened in July 2006. 
Nor has any reasonable expla lion n provided as to why State Attorney Krischer, who was 
Ir yinitially eager to investig d prosecute Epstein for his crimes, over time lost the desire to do 
t so. 
22. On formation and belief, during the grand jury appearance of the single victim 
who t he 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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request of Epstein's lawyers, the indictment was never presented to a fed 
25. Instead, then U.S. Attorney for the Southern District o 
negotiated a plea deal with Epstein's team of lawyers to 
four named co-conspirators and any unnamed potentiais 
charges. 
(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 gath y the FBI, 
g ,a 53-page indictment was prepared by the U.S. Attorney's Office in June 200 owe er, at the 
jury. 
, Alexander Acosta, 
ity to Epstein (along with 
ors) from all federal criminal 
26. Throughout the remainder 7 d through the first half of 2008, Epstein's 
lawyers and the U.S. Attorney contin ting 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's 
27. 
prostituti 
sentencedhq, 18 months in jail, followed by a year of community control or house arrest, and was 
be withdrawn. 
0, 2008, Epstein pled guilty to State charges: one count of solicitation of 
count of solicitation of prostitution with a minor under the age of 18. He 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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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 I/2 months, he was allowed to leave the jail on "work release" for up to 
30. Epstein was released five months early. 
31. Upon information and belief, Epstein violated the to 
not prosecuted. 
12 hours a day, 6 days a week. His private driver provided his transportation to a "work." 
ACt' 
A i(4) The Crime Victims' Rights c L ) tion. 
0 robation, but was 
32. Epstein's victims only learned after t IN V  ut his plea in State court and filed 
an emergency petition to force federal prosec 
(18 U.S.C. § 3771, "CVRA"), which t.,* .e
to be informed about plea agreem e right to appear at sentencing. U.S. District Judge 
Kenneth A. Marra recently rul deral prosecutors violated the CVRA by failing to notify 
r vgEpstein's victims before ' him to plead guilty to only the two State offenses. 
33. T rosecu on's failure to keep the victims apprised, among other things, also 
contravenes d Constitution, Article I, § 16(b) and Ha. 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." 
ply with the Crime Victims' Rights Act 
in rights for crime victims, including the right 
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EFTA02732629

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 
die 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., S1iici : 19. 
38. On July 6, 2019, Epstein was arrested on federal ScIeing charges. 
39. Upon information and belief, the United S 
11 1/4; „allegations and charges stemmed, in part, from con u investigations into and reporting 
on the mishandling of the 2006 charges and th . s that followed. 
iirra40. In a July 8, 2019, letter e I district court by the U.S. Attorney for the 
Southern District of New York, E iw escribed as "a serial sexual predator who preyed on 
dozens of minor girls over a pe ." The letter emphasized that "the Government has real 
concerns — grounded in p ence with this defendant — that if allowed to remain out on bail, 
die defendant co attem to pressure and intimidate witnesses and potential witnesses in this 
case, inclucf rms and their families, and otherwise attempt to obstruct justice." It also 
descri esults 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." 
ent's investigation of new 
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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. IS 
42. Epstein was denied bail and was placed into pre 
Metropolitan Correction Center in lower Manhattan. 
Age t)43. On or about August 6, 2019, Florida Gov Santis ordered a state criminal 
Sip probe into the actions of the Palm Beach Sheriff State Attorney Krischer for their S ,
handling of the Epstein underage sex traffi i ? 
cki cc os
44. On August 10, 2019, E in found dead in his cell at the Metropolitan 
Correctional Center. His cause of t etermined to be suicide. 
C. The August 27, 201 D Hearing: Epstein's Victims Speak. 
%r ip, 45. On accou his death, prosecutors sought to dismiss the indictment against 
Epstein, while m ming at they would continue to investigate his co-conspirators. 
46. States Senior District Judge Richard M. Berman ordered a hearing on 
Augus 9, on the prosecutors' decision to dismiss the indictment and allowed victims to 
speak at the hearing. 
47. In the course of the hearing, more than two dozen victims delivered their personal 
stories of pain, 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. 
n at the federal 
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EFTA02732631

48. 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 
may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the earing that 
the court "is the institution that most people have confidence in, in these very tro .” 
49. At the August 27th hearing, the girls, now women, spoke a "exploitation 
and coercion," and to the fact that many of them "were in very vulnera a i c3 ns and in extreme 
poverty, circumstances where [they] didn't have anyone on ir e, to speak on [their] A4c 5,cit)behalf...." One victim lamented that "as a victim, [she] g see what the agreement was 
its ,or why the special treatment got approved" in the ' c years earlier. Another noted how 
8s
„ 
"completely different" the investigators lead' t 2019 federal indictment were from the te
prosecutors in the Florida case, both ' eirs atment of her and their investigation of her 
victimization by Epstein. 
50. A former fede udg in attendance at the August 27th hearing emphasized that 
"transparency is one of th ding objectives in our criminal justice system." 
51. N all o the victims expressed the conviction that the secrecy that shielded 
Epstein has them "irreparable harm" and that an opportunity to address his criminal 
wrong d those of the individuals who enabled his sexual racketeering, would allow for 
at least some measure of justice to be served after his death. Indeed, one victim stated: "Any efforts 
made to protect Epstein's name and legacy send a message to the victims that he wins and that he 
is untouchable." Another victim expressed fear that this is a world "where there are predators in 
power, a world where people can avoid justice if their pockets run deep enough." In short, the 
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"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. 
D. The Palm Beach Post's Standing and the Public Interest. 
(1) The Palm Beach Post Has Renorted Extensively On Ea 
Crimes For Nearly 15 Years. 
52. Plaintiff, The Palm Beach Post, is a community newspaper seri ad in Palm ijct 
Beach County and the Treasure Coast vicinity. 
e )53. The Palm Beach Post has been a Pulitzer Prize wine C and ominated as a finalist 
three other times. 
54. Beginning in 2004, The Palm Beach Pos 
on the allegations against, the law enforcement 
Epstein and his co-conspirators. The Ne 
following articles: 
0 
ively investigated and reported 
*ga lbn of, and the crimes committed by, 
ortage has included publication of the 
• "The Man Who Ha g: Jeffrey Epstein Craved Big Homes, Elite Friends 
and Investi tors Say, Und ge Girls.," published on August 14, 2006, reporting that: 
a localsommunity college student, admitted in a sworn statement to 
police that "sl d taken at least six girls to visit Epstein, all between the ages of 14 
h Police "interviewed five alleged victims and 17 witnesses;" 
th arvard law professor, traveled to West Palm Beach with information 
s," including social media discussions about "their use of alcohol and 
a;" after meeting with Epstein's legal team, "prosecutors postponed their 
to take the case to a grand jury;" Palm Beach Police subsequently "received 
aints that two of the victims or their families had been harassed or threatened;" 
lations between police and prosecutors were fraying" as the investigation continued; 
nd "one girl who was subpoenaed — the one who said she had sexual intercourse with 
Epstein — never showed up" to testify before the grand jury. 
• "Trump Snags Gosman Estate for $41 Million" published on November 16, 2004, 
reporting on the bidding war between Donald Trump and Jeffrey Epstein for the 
purchase of a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along 
the storied `Raider's Row' " in Palm Beach. 
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• "Indictment: Billionaire Solicited 3 Times" published on July 25, 2006, reporting that 
"Billionaire 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." 
• "After Long Probe, Billionaire Faces Solicitation Charge" published on J 26, 2006, 
reporting that "Palm Beach police thought there was probable cause t e Epstein 
with unlawful sex acts with a minor and lewd and lascivious moles e article 
further reported that "Police Chief Michael Reiter was so an wi State Attorney 
Barry ICrischer's handling of the case that he wrote a memo iggeiiti g the county's 
top prosecutor disqualify himself," and identified a 20-y 1 on-fhe-record female 
source who said "she gave Epstein a massage in the nud thenjbrought him six girls, 
ages 14 to 16, for massage and sex-tinged sessions a ' ho 
• "Police Say Lawyer Tried to Discredit Teena •ublished on July 29, 2006, 
reporting that "[flamed Harvard law prof howitz met with the Palm 
Beach County State Attorney's Office ed damaging information about 
teenage girls who say they gave his P Beach billionaire Jeffrey Epstein, 
sexually charged massages" and th h to attorney's office said it presented the 
Epstein case to a county grand • this onth rather than directly charging Epstein 
because of concerns about the ibility." 
• "Expert: Ignorance of A n efense In Sex Cases" published on August 5, 2006, 
reporting that "fflath t charges, the state attorney's office presented the case 
to a county grand j h "indicted Epstein last week on a single, less serious 
charge of felony so on of prostitution," and that "Mlle case raised eyebrows 
because the s attorney's office rarely, if ever, kicks such charges to a grand jury." 
• "Epstei amp Its Female Accusers Liars" published on August 8, 2006, reporting 
that " to attorney's spokesman would say only that the office refers cases to the 
ry hen there are issues with the viability of the evidence or witnesses' 
i i'lm• Beach Chief Focus of Fire In Epstein Case" published on August 14, 2006, 
porting that Chief Reiter "pressed for Epstein to be charged with the more serious 
crimes of sexual activity with minors" and "slammed State Attorney Barry Krischer in 
blunt language seldom used by one law enforcement official with another because of 
what he perceived as that office's mishandling of the case." 
• "Delays In Epstein Case Unusual, Lawyers Say" published on March 13, 2007, 
reporting that "[n]early eight months after Palm Beach tycoon Jeffrey Epstein was 
charged with felony solicitation of prostitution, there has been no discernible progress 
in his case." 
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• "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 
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 Ty puNished on 
August 13 2008 reporting that "[d]uring his first month of con t" Epstein was 
visited by who allegedly escorted victims "upon al at his Palm 
Beach waterfront home to an upstairs room, where she p 
provided the oils for their encounters" with Epstein, an 
assa e table and 
adia "a 
young woman whom Epstein purportedly described slavian sex slave." 
• "Billionaire Sex Offender Leaves Jail Six Da 
1, 2008, reporting that Epstein "is allowed t 
six days a week on a work-release pro 
• "Women Want Epstein Sex Plea Dea 
that attorneys for women suing 
agreement [NPA] with federal 
agreement in Circuit Court 
at least a dozen civil la 
said they had sex wit 
Beach Post moved t 
to the NPA, which 
• "Epstein's Sec
Septem 19, 
"fede 
PI 
r Work" published on July 
Palm Beach County Stockade 
' published on June 10, 2009, reporting 
arious courts "want his [non-prosecution] 
ors unsealed" and were moving to unseal the 
nth Judicial Circuit, and that "Epstein now faces 
ederal and state courts filed by young women who 
now are seeking damages." On that date, The Palm 
e in the matter for the purpose of obtaining public access 
ered disclosed by this Court on June 25, 2009. 
t With Feds Reveals `Highly Unusual' Terms" published on 
09, reporting that, owing to Epstein's non-prosecution agreement, 
secutors backed down and agreed to recall grand jury subpoenas if Epstein 
gu y to prostitution-related felonies in state court" and "also a not to 
y of E stein's ossible co-conspirators: Lesley , ,. The article further reported that, according to annd 
; %ig itna ey representing three of Epstein's victims, "none of the 30 to 40 wom[e]n 
entitled as victims in the federal investigation" were informed ahead of time about 
the NPA. 
• "Judge Rules Epstein Attorneys Can Subpoena Abortion Records" published on 
January 27, 2010, reporting that "a judge . . . gave lawyers representing multi-
millionaire sex offender Jeffrey Epstein the right to subpoena abortion records from 
women who are seeking millions in damages from the part-time Palm Beach resident." 
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EFTA02732635

• "Epstein 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." 
• "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated 
Rights" published on February 22, 2019, reporting on a ruling by U. 
Kenneth Marra that "Federal prosecutors violated the rights o 
teenage victims [under the Crime Victims' Rights Act] by fail' 
dropped plans to prosecute the billionaire on dozens of fede 
with the girls' claims that he paid them for sex at his Palm 
Tefn Victims' 
trict Judge 
y pstein's 
veal they had 
m connection 
ion." 
• "Epstein Indicted On Sex Charges/Part-Time Palm Beach&2Wads Not Guilty to Sex 
Trafficking, Conspiracy Charges In Federal Court a attan" published on July 9, 
2019, reporting on Epstein's appearance in U.S. ourt for the Southern District 
of New York in which he "pleaded not guilty accusing him of creating a vast 
network of girls as young as 14 that he e his sexual pleasure at his homes 
in Palm Beach and Manhattan." 
A true and correct copy of the above news 
are maintained in The Palm Beach Po 
originally published, is annexed 
er the computerized format in which they 
mc archives or the news print edition in which 
hibit 1. 
55. Since the filing itial Complaint in this matter, The Palm Beach Post— along 
with media worldwide — ntinued to report on Epstein's crimes and the ongoing official 
proceedings resulft m those crimes. 
(2) The Palm Beach Post's Standimz and tic l'uldic Interest. 
e press has a constitutional right of access to criminal proceedings, see, e.g., 
Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal 
proceedings. v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the integrity of the 
judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in 
proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Publ. 
15 
EFTA02732636

Co. v. , 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate" in 
matters concerning the closure of judicial proceedings). The press also has a First Amendment 
interest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer 
Council, 425 U.S. 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 rec that the 
First Amendment offers protection to both speakers and those wishing to t peech."); see 
ami
re) 
also Stephens v. Co'. ofAlbemarle, Va., 524 F.3d 485, 492 (4th Cir. 20 mg that a plaintiff 
has "standing to assert a right to receive speech" by "show[ing the exists a speaker willing 
to convey the information to her"). 
57. Because of the unique role perform 
426 So. 2d at 6-7) in protecting the right of 
I 
criminal proceedings, news organizatio resuAc ct ..,
Comm 'r, Ala. Dep't of Corr. v. A 
and "standing to question the v 
news is directly impaired 
837 F.3d 753, 75 
to whi 
ass as a "public surrogate" (=, 
interest in reporting information about 
ively have a right to access judicial records," 
!Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019), 
an order restricting publicity because its ability to gather 
iled."=, 426 So. 2d at 4; see also Carlson v. United States, 
tr. 2016) ("[a]s a member of the public, [the Reporters Committee] 
[its] claim" to grand jury materials because such materials are "public records 
lic may seek access, even if that effort is ultimately unsuccessful"). 
58. Here, the continued denial of access to information The Palm Beach Post seeks on 
behalf of its journalists and the public it serves "unquestionably constitutes irreparable injury." 
Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also 
Zerilli v.M, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press' function as a vital 
16 
EFTA02732637

source of information is weakened whenever the ability of journalists to gather information is 
impaired," as it is by Attorney General's refusal to disclose unredacted report and underlying grand 
jury materials). 
59. The Palm Beach Post has the right to maintain this private right of action because 
the furtherance of justice, an express legislative exception to grand jury secrecy, is ' tended for 
the public benefit, and The Palm Beach Post seeks access on behalf of the Fla. Stat. 4 
§ 905.27(1Xc). It is further express in Fla. Stat. § 905.27 that the legisla ' t d for a court 
to be the party to make the determination of disclosure. Fla. Stat. § 9 other words, the 
legislature intended for recourse to the courts in , considering ete ming the propriety and 
scope of grand jury secrecy. 
"S' )\, E. The Court's Jurisdiction And Authority.  t 1/4
(1) The Court's Sunervisiob-of the Grand Jury Process and Its 
Authority to Order Public Disclosure of the Epstein Evidence. 
...* 60. The Florida Supreme Cturt 14,s, noted that "in states such as Florida, where the 
\8 1-grand jury is preserved, it is an ppendage of the court which impanels it. At the same 
time it should not be forgotten judge of that court is equally important and he is generally 
tit' charged with the supervise o the grand jury's activities...It is, therefore, of vital importance to 
maintain the di the integrity of both the grand jury and the presiding judge." State v. 
Clemons, 231, 233-34 (Fla. 1963). 
6 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. 
62. Florida Stat. Section 905.27(1) provides that "the testimony of a witness examined 
before the grand jury . .. or other evidence received by it" may be disclosed "when required by a 
17 
EFTA02732638

Herald Pub. Co. v. Marko, 352 So. 2d 51 
court .. . for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by 
the witness before the court; (b) Determining whether the witness is guilty of perjury; or (c) 
Furthering justice." Fla. Stat. § 905.27(1Xa)-(c). 
63. Further, disclosure is appropriate pursuant to this Court's inherent authority over 
grand jury proceedings because of the exceptional public interest in this case and the compelling 
circumstances supporting transparency. Carlson v. United States, 837 F.3d at 766 trict court 
has the inherent power to disclose [grand jury] materials in exceptional ces and . . . 
historic importance can be a sufficient reason when there is little coun v i eed for secrecy"). 
64. The Florida Supreme Court has confirmed that d secrecy is not absolute A4Q 
tand that any "potential harm to public officeholders" fro cl "will be the product of their 
ll4, own conduct, and not the consequence of an un i dy of misguided citizens." Miami 
The benefits to be derived from this 
extraordinary exercise in citizen partici ' n [in e grand jury] would be severely limited if the 
fruits of that activity were not ava public on whose behalf it is undertaken. Implicit in 
the power of the grand jury to e and expose official misconduct is the right of the people 
to be informed of its find de public disclosure of grand jury findings inevitably entails the 
risk of reputatio e, the legislature has ensured that any potential harm to public 
officeholde the product of their own conduct, and not the consequence of an unrestrained 
body ed citizens."). 
(2) The Court's Jurisdiction To Declare Ri2lits And Construe 
Statutes. 
65. This Court has jurisdiction to declare rights, status, and other equitable or legal 
relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011. 
18 
EFTA02732639

66. Florida law specifically provides that a declaration may be sought from the Court 
concerning a petitioner's rights under a statute. Florida Stat. Section 86.021 ("Any person...whose 
rights, status, or other equitable or legal relations are affected by a statute, or any regulation made 
under statutory authority,...may have determined any question of construction or validity arising 
under such statute,...or any part thereof, and obtain a declaration of rights, status, or other equitable 
or legal relations thereunder."). 
67. The Court's exercise of its power to declare rights "is to 
and construed." Florida Stat. Section 86.101. 
COUNT I 
(Declaratory Relief - Florida Stat. Sec 
68. The allegations set forth in paragrap 8il,eac 
as if fully set forth herein. 
l et seq.) 
f 
administered 
67 are incorporated by reference 
69. This is an action for Dec for  elicf pursuant to Chapter 86, Florida Statutes, Dec
and other supplemental relief. 
70. The Palm Beac pectfully requests that the Court declare that pursuant to 
Fla. Stat. Section 905.27 s entitled access to the testimony, minutes, and other evidence 
presented in 200 Beach County grand jury because such disclosure and access would 
be in the fu e of justice. Fla. Stat. § 905.27(1Xc). Because The Palm Beach Post is not 
seekin aterials in connection with either a civil or criminal case, it seeks a declaration that 
the scope of its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2). 
71. The Palm Beach Post further seeks a declaration that disclosure of the testimony, 
minutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate 
19 
EFTA02732640

pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional 
public interest in this case and the compelling circumstances supporting transparency. 
72. The Palm Beach Post has sought from Defendants, but Defendants have refused to 
provide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach 
County grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint and the 
relief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith disput M between 
the parties. 
73. Through this Complaint, The Palm Beach Post presen Q ticiable question 
concerning its rights to obtain the 2006 grand jury materials purs to Fll . Stat. Section 905.27(1) 
and the Court's inherent authority. 
Sv „74. A bona fide, actual, present, and pr ctic for the declaration exists in that 
SDefendants have denied to The Palm Beach to the public at large — the grand jury 
materials sought to be disclosed. The reli ughSto m the Court is therefore not merely the giving 
of legal advice or to answer hypoth4cfl q tions. 
WHEREFORE, The P Post respectfully requests that the Court determine the 
rights and obligations of ties by declaring that pursuant to Fla. Stat. Section 905.27(lXc) 
and the Court's r t thority, The Palm Beach Post may gain access to the testimony, 
minutes, and ence presented in 2006 to the Palm Beach County grand jury and use those 
materittll e purpose of informing the public. 
COUNT H 
(Florida Stat. Section 905.27) 
75. The allegations set forth in paragraphs 1 through 74 are incorporated by reference 
as if fully set forth herein. 
20 
EFTA02732641

76. Based on information learned by The Palm Beach Post through its Florida Public 
Records Law requests, 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 jn a manner 
that precluded his indictment for the serious crimes he committed, including se eking and 
sexual assault. 
77. Pursuant to Florida Stat. Section 905.27, in order to Otice for Epstein's 
victims and the public, and to provide public disclosure to illjp a e ether Epstein received 
unreasonably lenient treatment based on the available e 
immediate access to the testimony, minutes, and o 
Beach County grand jury. 
78. In a case of this magnitudy Slt5d im rtance, where the accused is dead and so many 
of his crimes, as well as the identr limes of his co-conspirators, and the identities of the 
victims have already been exp e need for grand jury secrecy is no more. See United States 
v. Socony-Vacuum Oil U.S. 150, 234 (1940) ("[A]fler the grand jury's functions are 
ended, disclosure holly roper where the ends of justice require it.'). 
, The Palm Beach Post respectfully requests that this Court, pursuant to Fla. 
Stat. 55.27(1) and the Court's inherent authority, order the State Attorney and the Clerk 
of the Court to file with this Court copies of the testimony, minutes, and other evidence presented 
in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so 
that, following an in camera inspection, it can be made available to The Palm Beach Post and the 
e Palm Beach Post requests 
e presented in 2006 to the Palm 
21 
EFTA02732642

public on an expedited basis, and grant any other and further equitable or legal relief the Court 
deems just and proper. 
Dated: January 17, 2020 Respectfully submitted, 
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 
Boca Raton, Florida 33486 
Telephone: (561) 955-762 
Facsimile: (561) 338-7 
By: /s/ Stephen A. Mendel$b12n ) 
STEPHEN A. DELSOHN 
Florida Bar 49324 
mendelso .corn 
hasenh 
FLSAt aw.com 
By: 
8A 
elf Glutei 
C EL J GRYGIEL 
Slaw(5 Admitted Pro Hac Vice) 
4 State St., 6th Floor 
Albany, New York 12207 
Telephone: ([Phone Redacted] 
Facsimile: ([Phone Redacted] 
grygielm®gtlaw.com 
Is/Nina D. Boyajian 
NINA D. BOYAJIAN 
(Pro Hac Vice application pending) 
1840 Century Park East, Suite 1900 
Los Angeles CA 90067 
Telephone: (310) 586 -7700 
Facsimile: (310) 586 -7800 
boyajiann®gtlaw.com 
riveraal®gtlaw.com 
22 
EFTA02732643

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has 
been electronically filed with the Florida E-File Portal for e-service on all parties of record herein. 
Is/ Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN
CO S
23 
EFTA02732644

EXHIBIT 1 
The Newspaper's Reportage on Jeffrey Epstein 
EFTA02732645

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 Al'-pa 
From the archives: When Palm Beach detectives start i vsk ng 
questions and teenage girls started talking, a wave e f 1 resistance 
followed. 
Editor's Note: This article appeared in The Palm Beach Post o , 2006, three weeks after 
Jeffrey Epstein's arrest in Palm Beach County on a charge olicitation of prostitution. 
WINGED GARGOYLES guarded the gate at stein's Palm Beach mansion. Inside, 
hidden cameras trolled two rooms, while th 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 urge 
Epstein, one of the most sterious of the country's mega-rich, was known as much for his 
secrecy as for his love of fi ngs: magnificent homes, private jets, beautiful women, 
friendships with orld's elite. 
But at Palm p eie j I f lice headquarters, he was becoming known for something else: the 
\regular at teenage girls he 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. 
EFTA02732646

» 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 wo e was 
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robe 
In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Se 
Mail on Sunday tabloid laid out speculative stories that the socialit 
math teacher, a concert pianist or a corporate headhunter.-
," the British 
was a CIA spook, a 
"But what is the truth about him?" the newspaper won e Maxwell, Epstein is both 
The media frenzy did not begin in full until aidetle ter. In September 2002, Epstein was 
flung into the limelight when he flew CI' ton ay actors Kevin Spacey and Chris Tucker to 
Africa on his private jet. 
flamboyant and intensely private." 
Suddenly everyone wanted to ke::w Wh6 Epstein was. New York magazine and Vanity Fair 
published lengthy profiles. The New York Post listed him as one of the city's most eligible 
bachelors and began descr"ng him in its gossip columns with adjectives such as "mysterious" t 
and "reclusive." 
Although E s ve no interviews, the broad strokes of his past started to come into focus. 4 Building a li e of 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. 
EFTA02732647

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 
block on Manhattan's Upper East Side. It is reported to have, amon ' s t og, 
circuit television and a heated sidewalk to melt away fallen snow. 
at dominates a 
eatures, closed-
That townhouse, thought to be the largest private residence in Manhattan, is only a piece of 
the extravagant world Epstein built over time. 
illf nIn New Mexico, he constructed a 27,000-squars  p mansion on a 10,000-acre ranch 
outside Santa Fe. Many believed it to be the ,leak e in the state. 
In Palm Beach, he bought a waterfront houie_on El Brillo Way. And he owns a 100-acre 
private island in the Virgin Islands. 
» PHOTOS: The players in thtjeffrey Epstein saga 
Perhaps as remarkable as hi lavish homes is his extensive network of friends and associates at 
the highest echelons of power. This includes not only socialites but also business tycoons, 
media moguls oltcians, royalty and Nobel Prize-winning scientists whose research he often 
funds. 
"Just like other 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. 
EFTA02732648

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 in him at 
an intimate fund-raising dinner in Palm Beach. But from all appearances, the become 
close friends until after Clinton left the Oval Office and moved to New Y 
Epstein has donated more than $100,000 to Democratic candidates' paigns, including John 
Kerry's presidential bid, the reelection campaign of New Mexico Go and the 
Senate bids of Joe 
Schumer. 
Hillary Rodham Clinton, C 
Powerful friends and enemies 
A Vanity Fair profile found cracks in the ve 
left Bear Stearns in the wake of a fede 
Commission violation. It also poie ss)
million loan. 
The article suggested that 
Hoffenberg, now se 
in one of the lar 
As he amuse 
man who i 
r Dodd and Charles 
ofEpstein's life story. The 2003 article said he 
and a possible Securities and Exchange 
at Citibank once sued him for defaulting on a $20 
his business mentors and previous employers was Steven 
g a prison term after "bilking investors out of more than $450 million 
i schemes in American history." 
ealth, Epstein made enemies in disputes both large and small. He sued the 
90 sold him his multimillion -dollar Palm Beach home over a dispute about less 
than $16,000 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 
EFTA02732649

"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 R manian 
model. 
"He's a lot of fun to be with," Donald Trump told New York magazine in. "It is even said 
that he likes beautiful women as much as I do, and many of them areR he unger side. No 
doubt about it, Jeffrey enjoys his social life." 
Investigation leads to Epstein 
tilli riAlthough he was not a frequenter of the Palm Be 
\ 
a •• ne, he made his presence felt. 4 ,
Among his charitable donations, he gave $90,0 e alm Beach Police Department and 
$100,000 to Ballet Florida. 
In Palm Beach, he lived in luxury. Th e Mercedes sat in his garage, alongside a 
Harley-Davidson. His jet waited a at Palm Beach International Airport. At home, a 
private chef and a small staff sti e ready. From a window in his mansion, he could look 
out on the Intracoastal W term nd the West Palm Beach skyline. He seemed to be a man 
who had everything. 
But extraordinrye gfi  tthea can fuel extraordinary desires. 
» Epstein wants to leave jail for mansion in sex -trafficking case 
In March 2005, 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. 
EFTA02732650

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 
The investigation began in full after the girl identified Epstein in a pho e man who had 
paid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift 
through it. They set up a video camera to record the 
comingg 
oings 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 old girl to Epstein's house was 
a Palm Beach Community Coll t from Loxahatchee. In a sworn 
statement at police headquarters, 18, mitted she had taken at least six girls to 
visit Epstein, all between the ages of 14 16. pstein paid her for each visit, she said. 
, During the drive back to her ho told detectives, "I'm like a Heidi Fleiss." st viccr)
Police interviewed five alleged ms and 17 witnesses. Their report shows some of the girls 
said they had been instructed to have sex with another woman in front of Epstein, and one said 
she had direct intertcuse with him. 
In October, o • searched the Palm Beach mansion. They discovered photos of naked, % young-
looking ferns ) just as several of the girls had described in interviews. Hidden cameras were 
found in the garage 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. 
EFTA02732651

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,zone else. 
She said yes, a private investigator had asked her the same questions. 
» Jeffrey Epstein: Acosta, Krischer trade barbs over sweethe3Kt 
When they subpoenaed one of Epstein's former employees, he told them the same thing. He 
and a private eye had met at a restaurant days earlier to go over what the man would tell 
investigators. 
ASi IC)Detectives received complaints that private eyes NVC posing as police officers. When they told 
Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the 
high-powered Miami lawyer who has defe deSe likes of Rush Limbaugh and William 
Kennedy 
While the private eyes were corCictin a parallel investigation, Dershowitz, the Harvard law 
professor, traveled to West Palm Beach with information about the girls. From their own 
profiles on the popular Web site MySpace.com, he obtained copies of their discussions about 
their use of alcohol and marijuana. 
He took his research to a meeting with prosecutors in early 2006, where he sought to cast 
doubt on the teens' 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. 
EFTA02732652

The deal never came to pass, however. 
Future unclear after charge 
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. 
"The embarrassment on the prosecutor's face was evident when the police offissizever 
S
showed up for the meeting," attorney Jack Goldberger said. 
Later in April, Recarey walked into a prosecutor's office at the state .tt office and C ) 
learned the case was taking an unexpected turn. 
The prosecutor, Lanna Belohlavek, told Recarey the state attorneys 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 
\AS,
we a felony conviction. 
On May 1, the department asks ro ecutors to approve warrants to arrest Epstein on four 
counts of unlawful sexual *vip with a minor and to charge his personal assistant,7r 
, now 27, fclher alle ed role in arranging the visits. Police officials also wanted to 
charge the self-described Heidi Fleiss, with lewd and lascivious acts. 
By then, th Itartment was frustrated with the way the state attorney's office had handled the 
case. On t same day the warrants were requested, Palm Beach Police Chief Michael Reiter 
wrote a letter 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. 
EFTA02732653

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 • urn penalty 
of five years in prison. He was booked into the Palm Beach County Jail ear 23 nd 
released hours later. 
0 
Epstein's legal team "doesn't dispute that he had girls over for mas Idberger said. But 
he said their claims that they had sexual encounters with W cr bility. W
"They are incapable of being believed," he said. "They h ' 1 al records. They had 
accusations of theft made against them by their e plo ere was evidence of drug use by \ 
some of them." 
What remains for Epstein is yet to be se% 
ted( V2004. 
The Palm Beach Police Departme d the FBI to investigate the case. It also has 
returned the $90,000 Epstein d 
In New York, candidates 1Qlsrernor and state attorney general have vowed to return a total 
of at least $60,000 • pa gn contributions from Epstein. Meanwhile, Epstein's powerful 
friends have re ent as tabloids and Internet blogs feast on the public details of the 
police inves 
Goldberge ntains 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 Corte; Amy Hanaway and 
Melanie Mena contributed to this story. 
[Email Redacted] 
EFTA02732654

@AMarraPBPost 
TIHIF 
NTELLIGENT erai0 
ft'S 
EFTA02732655

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 
When it came time to bid Monday for the palatial Palm Beach digs of 
Donald was not about to be trumped. 
"Nobody was going to outbid me," the brash developer-turned-
New York office. 
Trump bested two other bidders with a $41.35 million offer or 43,000-square-foot, 
seven-bedroom estate on 6 oceanfront acres along the s der's Row." 
But Trump, 58, proud possessor of Mar-a-Lago, has o o live in the Gosman home at 
513 N. County Road. He wants to - what else? - s it d eke more money. 
The star of the mega-hit The Apprentice said s o redevelop the site into a "super 
luxury house" that would be the "finest an e United States." He might build 
another house before flipping the entire p 
"I've known about this house for quite 
of land in Florida - and probably 
Althouigrump said he could 
Lesly said zoning regul 
said she's not worried about T 
"He's been a very good 
projects very well. He's a 
Monday's auction k pl 
Gosman's Cha 
distribution 
The aucti 
an atto 
that T 
," Trump said. "It's probably the best piece 
for luxury real estate." 
w for only two houses - and maybe a third. 
e property into nine lots, Palm Beach Ma. 
plans. 
rty owner in the town of Palm Beach," she said. "He does his 
ctionist" 
at U.S. Bankruptcy Court in West Palm Beach as part of 
ankruptcy case. Proceeds from the sale will go into escrow for eventual 
ito 
t exactly noon after Judge Steven dismissed an objection from 
resenting money manager Jeffrey Epstein. The lawyer argued unsuccessfully 
as not a qualified bidder because his contract stipulated that he would not close 
on the sale unless 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. 
4, Alk 
Nnan, The 
ality said from his 
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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 ter i it up a 
bit," Luzinski said. 
"The system worked," said Charles Tatelbaum, a lawyer for creditor JPM. 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 $ mil ion. Sotheby's won't 
receive a commission, he said. 
Pulte, 42, of Boca Raton, said he figured Trump wouldn't Monday. 
"I got the feeling he was willing to go a lot higher, and t to chase it," Pulte said. 
Pulte said Gosman asked him before the auction wh uld be willing to let him stay 
in the mansion after the closing until he decides w is to move. Trump and 
Luzinski said they have had no such discussio man. 
Gosman, 75, had the house built after payin 1 lion for the land in 1986. 
The former health-care magnate declined requests before and after the auction 
Monday. He was at the courthouse busleft befo the auction took place. 
The $41.35 million price tag eclips the $30.35 million sale of Lowell "Bud" Paxson's Palm 
Beach home and guest house but port of the $45 million that Virginia home builder 
Dwight Schar paid for Ron Pe 6,000-square-foot estate, Casa Apava, a designated 
landmark. 
Schar also paid $18.6 m" ion for lakefront lot across the street from the main house, for a 
total of $63.6 million. In ay Schar spent a total of $70 million for his new property, 
making it the pricy tial sale in U.S. history. 
Gosman once ha a Pune that Forbes magazine estimated at $480 million. He voluntarily 
filed for Ch ptcy protection in 2001, listing assets of $250 million and 
liabilities c c million. 
When ed that Gosman had to give up all of his exempt assets to creditors if he 
wanted to organize under Chapter 11, Gosman converted the case to Chapter 7 liquidation. 
Last year, .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 Castre. 
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. 
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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 oney 
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) 
ti
Billionaire money manager and Palm Beach part-time resident JeffrecEM 
solicited or procured prostitutes three or more times between 2send Oct. 31 
of last year, according to an indictment charging him with lony solicitation of 
prostitution. 
Epstein, 53, was booked at the Palm Beach Co :45 a.m. Sunday. He 
was released on $3,000 bond. 
Epstein's case is unusual in that suspecreSko 'tution 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. 
His attorney, Jack Goldberger, declined to discuss the charge. 
State attorneys offic.e 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 'th a 
pool and a boat dock on the Intracoastal Waterway since 1990, n to 
property records. A man answering the door there Monday atd pstein 
wasn't home. A Cadillac Escalade registered to him was park i the driveway, 
which is flanked by two massive gargoyles. 
Epstein sued Property Appraiser Gary Nikolits in 2001, contending that the 
assessment of his home exceeded its fair market value. He dismissed his lawsuit 
in December 2002. 
A profile of Epstein in Vanity Fair magazine said he owns what are believed to 
be the largest private homes in Manhattan - 51,000 square feet - and in New 
Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the 
U.S. Virgin Islands and fleet of aircraft. 
Epstein's frie ds an dmirers, according to the magazine, include prominent 
businessme t, demics and scientists and famed Harvard law professor Alan 
Dersho 
larra 
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11/11/2019 After long 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 alisic6, 
20%) 
Palm Beach billionaire Jeffrey Epstein paid to have underage girls oung 
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 International Airport to keep tabs on his 
private jet. An indictment charging Ep ei1 53, was unsealed Monday, charging 
him with one count of felony solid of rostitution. 
A mtwePalm Beach police thought there ca probable 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 
matter has taken and consider if good and sufficient reason exists to require your 
disqualification from the prosecution of these cases: Reiter wrote in a May I 
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. 
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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 "one-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 credibility 
of the witnesses," Goldberger said. A county grand jury "found the allegggsnis -- 
,wholly unsubstantiated and not credible," and that's why his client w a t 
charged with sexual activity with minors, he said. 
Goldberger said Epstein passed a lie detector test administe d by reputable 
polygraph examiner in which he said he did not know  tr s were minors. 
Also, a search warrant served on Epstein's home f vidence to 
corroborate the girls' allegations, Goldberger sk . 
si‘ 
According to police documents: 
- A Palm Beach Community Coll 
the nude, then brought him s 
sessions at his home. 
( 41(student said she gave Epstein a massage in 
es 14 to 16, for massage and sex-tinged 
- A 27-year-old woman orked as Epstein's personal assistant also 
facilitated the liaisotiphoning the PBCC student to arrange for girls when 
Epstein was ming town. And she escorted the girls upstairs when they 
arrived,,p esh sheets on a massage table and placing massage oils nearby. 
- PoliceZtk isworn statements from five alleged victims and 17 witnesses. They 
contepd 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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11/1112019 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. 
Goldberger is one of five attorneys Ep 
subject of an investigation, Edmon 
Dershowitz, the well-known 
of Epstein. Dershowitz co 
tained since he became the 
*d. Among the others: Alan 
professor and author, who is a friend 
eached for comment. 
Police said the woman w listed young girls for Epstein was 
20, of Palm has worked at an Olive Garden restaurant in 
Wellington said e was a journalism major at Palm Beach Community 
College w r n was questioned by police last October. She has an unlisted 
phong r m r r and could not be reached for comment. 
said she met Epstein when, at age 17, a friend asked her if she would like 
to ma 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. 
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11/11f2019. After long probe, billionaire laces solicitation charge - News - The Palm Beach Post - 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. 
who has not been charged in the case, said she eventually brought six 
girls to Epstein who were paid $200 each time, said. "I'm 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 
thought the child had recently engaged in sex with a Palm Beath he girl 
then got into a fight with a classmate who accused her of behwirostitute, and 
she couldn't explain why she had $300 in her purse. 
The girl gave police this account of her meeti 
\She accompanied and a second girl M.pstein's house on a Sunday in 
February 2005. Once there, a woman she thought was Epstein's assistant told the 
girl to follow her upstairs to a room featuring a mural of a naked woman, several 
photographs of naked women'on a shelf, a hot pink and sofa and a massage 
table. / 
She stripped to her bra and panties and gave him a massage. 
Epstein gave. the 14-year-old $300 and she and the other girls left, she said. She 
said Robson told her that Epstein paid her $200 that day. 
Other_guictold similar stories. In most accounts, Epstein's personal assistant at 
then e, now 27, escorted the girls to Epstein's bedroom. 
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 
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11/112019 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 o ' y was N.,returned to Epstein on Monday, she said. 
https://www.palmbeachpost.cominews/20060727/after-long-probe-billionaire-faces-solicitation-charge 
CO 
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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 Beach Post on July 
29, 2006) 
Famed Harvard law professor Alan Dershowitz met with the Palm Beach County 
State Attorney's Office and provided damaging information 'about teenage girls 
who say they gave his client, Palm Beach billionaire pstein, sexually 
charged massages, according to police reports. 
hy,The reports also state that another EpsteinAtoS  greed to a plea bargain that 
would have allowed Epstein to have no criminal record. His current attorney 
? ic 
q r . ' And the documents also reveartha e father of at least one girl complained that 
private investigators aggtessivelyfollowed his car, photographed his home and il 
chased off visitors. 
denies this happened. 
Police also talked to somebody who said she was offered money if she refused to 7 cooperate with the Palm Beach Police Department probe of Epstein. 
The scate attdrney's office said it presented the Epstein case to a county grand 
jurythis 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. 
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11/11/2019 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' Made EZ." 
, who was not charged in the case, is a potential prosecution witnesS 
According to Recarey, prosecutor Lanna Belohlavek offered Eps 
Dershowitz and Guy Fronstin a plea deal in April. Fronstin 
eys 
ing with 
Epstein, accepted the deal, in which Epstein would plead gu one count of 
aggravated assault with intent to commit a felony, be placed on five years' 
probation and have no criminal record. The deal also called for Epstein to submit 
to a psychiatric and sexual evaluation and have no unsupervised visits with 
minors, according to Recarey's report. The plea bargain was made in connection 
with only one of the five alleged victims, the report states. 
Fronstin - who declined to comment on the case - was subsequently fired and 
veteran defense attorney Jack Goldberger was hired. He denies there was any 
agreement by any of Epstein, s attorneys to a plea deal. 
"We absolutely did not agree to a plea in this case," he said. Neither Belohlavek 
nor a state attorney's spokesman could be reached for comment. 
The pa nt p \ rents of alleged victims who complained of being harassed by 
private investigators provided license tag numbers of two of the men. Police 
found th-e 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 &suede 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 waterfrqnt, 
home, but whether he knew their ages. 
AS"He's never denied girls came to the house," Goldberger said. Bu pstein 
was given a polygraph test, "he passed on knowledge of age, e a rney said. 
After the indictment against Epstein was unsealed Police Chief Reiter 
referred the matter to the FBI. 'We've received et ' and we're reviewing e^
said FBI spokeswoman Judy Orihuela in Slut 
The chief himself has come under attack from Epstein's lawyers and friends in 
New York, where he has a home. The New York Post quoted Epstein's 
prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted 
only "because of the craziness of the police chief." 
Reiter has declined to comment on the case. 
Prosecutors have not/presented a sex-related case like Epstein's to a grand jury 
before, said Mike Edmondson, spokesman for the state attorney's office. "That's 
what you do with a case that falls into a gray area," he said. 
The state 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." 
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11/1112019 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. AL 
Miami lawyer Roy Black - who became nationally known when he s sft 
defended William Kennedy on a rape charge in Palm Bea as 
involved at one point. 
(1) Said defense attorney Suskauer: "I think it's unfortunate the public may 
get the perception that with power, you may be treated differently than the 
? S" 
average Joe." 
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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 mask 
his Intracoastal home were under the legal age, titlkie 
wouldn't have exempted him from criminal charges of 
sexual activity with minors. 
"Ignorance is not a valid defensenai Sfy Dekle, a legal 
skills professor who was a Lake City prosecutor for nearly 
30 years, half of that time specinzing in sex crimes against 
children. 
a 
O ul sex acts with a minor and lewd and lascivious 
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. 
"There is no knowledge element as far as the age is 
concerned," Dekle said. 
After an Iltmonth investigation, Palm Beach police said 
th'' 'was probable cause to charge Epstein, 53, with eist
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 
EFTA02732670

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. 
+ "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." 
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 case 
especially when the defendant is enormously wealthy aril
can hire high-priced, top-tier lawyers. 
At least one of Epstein's alleged victims tol ce he knew 
she was underage when the two of the d for 
massages and sexual activity. She wi 
Irk9
t s old at the 
time and said Epstein asked her cluestNs about her high 
school, according to police n ti Vc r
mg .,A girl who said she stein when she was 15 said he 
told her if she told anyb y what happened at his house, 
bad things co Id hapii,en, the police reports state. 
Epstein' oungest alleged victim was 14 when she says she 
gav him massage that included some sexual activity. She 
sh ol.ir
w 16. The girl's father says he doesn't know whether 
t d Epstein her age. 
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. 
EFTA02732671

"A prosecutor has to look at it in a much broader fashion," a 
state attorney's spokesman said last week. 
f a, 
NTELLTIGIEN7 GRID 
erciAtiiji tgoprip 
Epstein hired Harvard law Professor Alan ersh witz 
when he became aware he was under investigation, and 
Dershowitz gave prosecutors information that some of the 
alleged victims had spoke of using alcohol and marijuana on 
a popular Web site, according to a Palm Beach police 
report. 
Prosecutors typically consider two things in deciding 
whether to charge somebody with sex-related offenses 
against minors - whether there is sufficient evidence and 
wl~etlter there is a public interest in doing so, Dekle said. 
wo teens are in a sexual relationship and the boy turns 
+  
before the girl, he could be charged with a sex crime if 
the sex continues. There would be no public interest in
pursuing that, Dekle 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. 
► 3 
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Still there is a "universal constant" in prosecuting these 
cases, Dekle 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 me to 
his home multiple times for the massage se an the 
$200 to $300 he typically paid them per ist at would 
be a definite problem for the prosec o Betty Resch, 
who prosecuted crimes against children Palm Beach 
\ 
County for five years and n *typrivate practice in Lake his, 
Worth. 
"The victim becomesles sympathetic" to a jury, Resch said. 
"But she's a vigtiitit nerrtheless. She's a kid." 
Most m charged with sex crimes against minors look T he
nor al, said. A jury expecting to see a monster 
will. And the victims' ages work against them and in 
Oor of 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 -clad 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 Jeff 
II Epstein went on the offensive Monday, contending th 
teenage girls who have accused Epstein of sexual 1/4. ) 
shenanigans at his waterfront home are li saying 
sh." that the Palm Beach Police Departme 
Il tsy"There never was any sex betweedlp pstein and any 
underage women," his lead otneyjack Goldberger, said 
from Idaho where he wa tioning with his family. 
% PiEpstein did have yotpg men come to his house to give 
him massages, Goldberger said. "Mr. Epstein absolutely 
insisted anybody who came to his house be over the age of 
18. How he verified that, I don't know. The question is, did 
anything illegal occur. The law was not violated here." 
lir He had no explanation as to why Epstein would pay girls or 
-iwomen with no massage training - as the alleged victims 
said was the case - $200 to $300 for their 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 
EFTA02732674

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 
in the media presented by the Palm Beach police, 
Goldberger said. 
cReiter has consistently declined to com .,,a*, the case , 
and did not respond to a request comment Monday. q .,.
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. 
EFTA02732675

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
referred the case to the grand jury to "appease" the ch' 
Goldberger said. 
A state attorney's spokesman would say on 
refers cases to the grand jury when the 
viability of the evidence or witness 
Both the state attorney and 
was not sufficient eviden 
minors, according to 
performance by t 
Goldberger s 
cet office 
es with the 
d jury concluded there 
had sex with 
r. "It was just a childish 
each Police Department," 
The def e attorney said one of the alleged victims who 
daipted s e as a minor was in fact over the age of 18. 
er alleged victim who was subpoenaed to testify to 
Band jury failed to do so. Epstein's accusers, he added, 
ve histories of drug abuse and thefts. "These women are 
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. 
EFTA02732676

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EFTA02732677

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 tyco. ffr 
Epstein was charged with felony solicit ostitution, 
there has been no discernible progr case. No 
witnesses deposed. No trial date sett hmg, save for 
routine court hearings reset 'tirexplanation. e s e,
"Usually that would b usu , said criminal defense 
attorney Glenn e ho has no involvement in the 
case. 
"As a ge , ral rule, it would be unusual for nothing to have 
othappene a reed Michael Dutko, a criminal defense 
attorney in Fort Lauderdale. He represents 
of 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. 
EFTA02732678

"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. 
Police said Epstein paid women and girls as, rung as 14 to 
give him erotic massages at his home. Police thought there 
was probable cause to charge him with unlayirful sex acts 
with a minor and lewd and lascivious molestation. 
Epstein responded by hiring a phalanx of lawyers. One of 
them, Harvard law professor and author Alan Dershowitz, 
provided the state attorney's office with information about 
alcohol and marijuana use by some of the girls who said 
they were with Epstein. 
Pro ecutots then referred the case to the grand jury rather 
e charges directly against Epstein. 
0 tein'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. 
EFTA02732679

Epstein's attorney Jack Goldberger did not return phone 
messages. 
A source close 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 
added, "if another agency is looking at something, 
wouldn't want to step on their toes." 
Attorneys say inertia in a criminal case oft po is to a 
pending plea deal. 
"It would not surprise me if so as happened that's 
not reflected in the court file," sa utko, such as an 
agreement that will be forillized later. 
Defense attorney Marc Shiner said defense attorneys 
sometimes put toff overtly conducting discovery -- deposing 
witnesses, requesting documents and the like -- because 
doing so m ates more work for harried prosecutors who 
beco e angry and not offer a plea deal. 
etimes defense lawyers, knowing that, will try and do 
+ iscovery 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. 
EFTA02732680

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. 
Go 
EFTA02732681

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 . WAS 16 
A billionaire investor, already facing jail in Palm Beach County on charges of underage 
prostitutes, is being sued by a young woman who says he had sex with her vyhq was 16 and had 
sought his help becoming a model. 
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, sa finllltei'€r Jeffrey Epstein had 
the teen perform a sex act when she brought photographs of herself for review in his Upper 
East Side mansion sometime in 2000. 
Epstein, 54, a money manager, told the teen he managed fin ictoria's Secret and "could get 
you into the catalog" if she were "nice" to him, court pape 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 clo3,fi riend of England's Prince Andrew, has been 
indicted in Palm Beach on charges of solicit' e prostitutes. That case is pending. 
The girl visited Epstein "several times ov a 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 young e next time. Don't bring Sherrie (a mutual friend in her 
40s). I love girls your age.' " 
The young woman, now 23, f returning to Epstein because she has "mental issues," said her 
lawyer, William J. U • h. H hued to elaborate, but court papers say she was "disabled as a result 
of severe mental dise and d ect." 
Epstein's lawyer 
read a newspape 
Lefcourt also 
and will a 
He refused to c 
k, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can 
cognize the word 'rich.'" 
to of limitations has expired for the woman's case criminally and civilly, 
nly be dismissed. 
ment 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. 
EFTA02732682

The Palm Beach Post REAL NEWS STARTS HERE 
Palm Beacher pleads in sex case Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 3, 2019 at 1:47 PM 
(EDITORS NOTE: This story originally published in The 
Palm Beach Post on July 1, 20010 
Jeffrey Epstein will serve 1 1/2 years on teen solicitation 
charges. 
He lives in a Palm Beach waterfront mansion and 
company with the likes of President Clinton, Prin 
Andrew and Donald Trump, but investm er Jeffrey 
Epstein will call the Palm Beach Co for the 
next 18 months. 
Epstein, 55, pleaded guilty MbSlit felony solicitation of - tCy
prostitution and procuring a person under the age of 18 for 
prostitution. After g • 18 months in jail, he will be 
under house air ear. And he will have a lifelong 
obligation to ist r as a sex offender. He must submit to 
an HIV st wit in 48 hours, with the results being 
proyided i s victims or their parents. 
p31je of the plea deal, federal investigators agreed to drop 
+ th it 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. 
EFTA02732683

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. 
4Epstein may have made a serious mistake soon after he was ii, — 
charged. He rejected an offer to plead guilty to one count of 
aggravated assault with intent to commit a felony,
according to police documents. He would have goi ten to gl )
years' probation, had no criminal record and not n u 
registered sex offender, the documents in 
oc u three Epstein arrived in court Monday w' . . 
attorneys. He wore a blue blazer, blue rt, blue jeans and 
and gray sneakers. After Circuit Judge Deborah Dale 
Pucillo accepted the plea, hews fingerprinted. Epstein 
then removed his bl handcuffed for the trip to 
jail while his attot 9 tft to shield him from 
photographe 
tr# When h tually is released to house arrest, Epstein will 
h to o rye a 10 p.m. to 6 a.m. curfew, have no 
rvised contact with anyone younger than 18 and 
her own nor possess pornographic or sexual materials 
that 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. 
EFTA02732684

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. - k r 7
Epstein's legal woes don't end with Monday's plea. Tfter- -*,,\ 
are four pending federal civil lawsuits and one in t-ate`tourt 
related to his behavior. At least one woman has sued him in 
New York, where he owns a 51,000-squar fool Manhattan 
mansion. 
Si)e "It's validation of what we're sayiliAn civil cases," said 
Miami attorney Jeffrey He ttwho represents the alleged 
victims in the federal law i West Palm Beach attorney 
Ted Leopold represe leged victim in a civil suit in 
state court. He °pates amending that lawsuit to 
add "a few of r die s" as well. 
In the case, police went so far as to scour Epstein's 
t and a 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 
+ pstein 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. 
EFTA02732685

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. 
Alat\'' 
gaCt. 
Epstein hired a phalanx of high-priced lawyers - includin 
Harvard law professor and author Alan Dershowitz - 
public relations people who questioned Reiter's c 
and the victims' truthfulness.
In addition to mansions in Palm Beach attan, 
Epstein owns homes in New Met th irgin Islands. 
He's a frequent contributor to D cr 'c Party candidates. 
He also donated $30 milli° rd in 2003. 
Former New York G Got Spitzer returned a $50,000 
campaign contribution m Epstein after his indictment, 
then resigned this year during his own sex scandal. And the 
same Palm Beach Police Department that vigorously 
investig stein returned his $90,000 donation for the 
ptyfhase a firearms simulator. 
i .Quigley contributed to this story. 
writer Eliot Kleinberg and former staff researcher 
EFTA02732686

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 s xua 
massages at his Palm Beach mansion. 
Not much has changed, even though 
dorm at the Palm Beach County Sh, 
tit967-bed stockade near the fair\ 
During his first month of ent, Epstein was visited 
by the female assistan girls told police, had escorted 
them to the rootnic nsion where they gave him 
naked massag 
des in a 
ce's 17-acre, 
Also tre o the jail was a young woman whom Epstein 
Pu rt e described as his Yugoslavian sex slave. S i
ealthy financier and science wonk also has been 
4  ited by an expert on artificial intelligence, as well as a 
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 
EFTA02732687

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: 
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 
visitor's log. lists a Manhattan home address. 
Reached by telephone, she declined to discuss Ep 
23, whose family in Y avia 
Epstein paid money to so that he could to the 
United States to be his "sex slave: t7io e girls told 
1 
police. One girl told police that structed 
and her to kiss a ex while he watched 
and masturbated. Anothe s sh engaged in sex with 
at Epst $. visited Epstein 
in jail four time . She lists her address as on the 
Upper East si a of attan, not far from Epstein's 
enormous ap nt. 
ank, 62, founder of the Institute for Learning 
at Northwestern University and an expert on 
ficial intelligence, paid one visit to Epstein. Schank has + 
written 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's 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. 
EFTA02732688

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 contri is story. 
1 
EFTA02732689

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 
prostitution, is allowed to leave the Palm Beach County 
Stockade six days a week on a work -release program. 
Teri Barbera, spokeswoman for the Palm Beach Count 
Sheriffs Office, confirmed that Epstein, 55, has been the 
work -release program since Oct. 10. 
"He works six days a week: Friday through Wednesday 10 
a.m. to 10 p.m.," Barbera said via e-mail. "(He) works at his 
local West Palm Beach office, monitored on an active GPS 
system (he wears an ankle bracelet). Mr. Epstein hires a 
permit deputy, at his expense, for his own security at his 
workplace du • -1 diStime he is out: 
Miami attorney Jeffrey Herman represents six young 
wo en who've sued Epstein, claiming he sexually abused 
at his Palm Beach home when they were minors. 
Orman said he received a letter about the work-release 
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 
EFTA02732690

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 
offender. 
O 
C 
iS 4/)9
C 
? S' 
EFTA02732691

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 Epste* '0
records. 
When wealthy money manager Jeffrey Epsteing 
Beach pleaded guilty last year to procuring teens for 
prostitution, his case detoured around local and state rules 
regarding the sealing of court d eN. 9 ,
At a plea conference on Stharges, a judge, a defense djet 
lawyer and a prosecutor huddled at the bench and decided 
that a deal Epstein had struck with federal prosecutors to 
avoid charges should be sealed, according to a transcript of 
the hearing. 
And so it"Was. 
But Florida rules of judicial administration, as well as rules 
\ of the Palm Beach County court system, require public 
=== 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. 
EFTA02732692

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. 
Attorneys for some of those women want his agreement` 
with federal prosecutors unsealed and will ask Circuit Judge 
Jeffrey Colbath to do so today. 
"It is against public policy for these do t be have 
been sealed and hidden from public s a member 
of the public, E.W. has a right to have t e documents 
unsealed," wrote former Circuit Judge Bill Berger, now in 
private practice and represent ,  one of the women. 
The Palm Beac 
agreement. P 
will ask Colbath to unseal the 
they Deanna Shullman will argue that 
the publi as a right to know the specifics of Epstein's deal. ft v
ding o various media accounts, Epstein moved in 
at included President Clinton, Donald Trump and 
4  
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. 
EFTA02732693

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 wit 
attorney's office in which federal prosecutors bro e not 
pursuing charges against him if he pleade 1'indw p
court. Pucillo then said she wanted a seat c ‘ of the 
agreement filed in his case, and Gol r concurred that 
he wanted it sealed. Belohlave ed off on it. 
in state 
The Florida Supreme Courts expressed "serious concern" 
and launched an all-o inquiry into sealing procedures 
across the state fog;*inginedia reports in 2006 of entire 
1 -1‘" cases being se4iled an disappearing from court records. 
"The pubt4constitutional right of access to court records 
mktSt remain inviolate, and this court is fully committed to 
rding 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. 
EFTA02732694

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 prosecutors is 
being called "highly unusual" by former federal prosecutors 
and downright outrageous by attorneys n esenting 
young women who serviced him. 
\SS.The deal reveals that the FBI anckitc Attorney's Office 
investigated him for several federal crimes, including 
engaging minors in commercial sex. The crimes are 
punishable by anywhere from 1O years to life in prison. 
N./ But federal prosecutOrs,backed down and agreed to recall 
grand jury subpoenas if Epstein pleaded guilty to 
prostitution -related felonies in state court, which he 
ul *mately did. He received an 18-month jail sentence, of 
oAishh he served 13 months. 
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. 
EFTA02732695

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 t 
victims did not accept settlements -- capped at $150,0O 
and instead pursued lawsuits. 
csaid it appears the government was4vicng o 
balance the lesser sentence for Epstein with recovering 
$150,000 for each victim. "I've never] ever seen anything \\ \--,/ 
like that in my life," he said "les.higblanusual." 
. \ 
The deal does not say whether any victims were contacted 
or consulted before the deal was made. 
Attorney Brad,fidirard.stf Fort Lauderdale, who represents 
three of the young women, believes that none of the 30 to 
40 woman identified as victims in the federal investigation 
were told ahead of time. said his clients received 
iker ylit s from the U.S. Attorney's Office months after the deal 
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 
EFTA02732696

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 
made ... and why the victims were sold down the river! 
Former federal prosecutor Ryon McCabe described th 
agreement as "very unorthodox! Such agreements 
are usually reserved for corporations, not individ 
"It's very, very rare. I've never seen or h 
procedure that was set up here," said who has no 
involvement in any Epstein litig 
"He's essentially avoiding eralpdsecution because he 
can afford to pay that y la ers to help those victims 
review their cases. on has no money, he couldn't 
be able to st e this and avoid federal 
prosecution. 
The ba deal with federal prosecutors is all the more 
in light of the legal powerhouses who have 
O
rk for Epstein, including Harvard professor Alan 
+ rshowitz and Bill Clinton investigator Kenneth Stan. 
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." 
EFTA02732697

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 th ief 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 
many-million -dollar defense can accomplish," Reiter told 
the Palm Beach Daily News upon his retirement. 
EFTA02732698

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 
1 JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS 
In a decision that could spark a constitutional showdown over privacy righ I 
Tuesday gave lawyers representing multimillionaire sex offender Jeffrey n the right to . 
subpoena abortion records from women who are seeking millions in t m the part-
time Palm Beach resident 
Palm Beach County Circuit Judge Donald Hafele said the records uld elp Epstein rebut
the women's claims that they suffered psychological ills after ng to give him
sexually-charged massages at his Palm Beach mansion w were as young as 14. i 
1 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 reco o t be made public and might not ; 
be admissible during trial.
But, he said, since the women claim Epste s responsible for their emotional I 
distress, his attorneys can explore the 
imps
o er events. Medical records, Hafele said, 1
are a better source of information thanAtiperson memory. ; 
Attorney Louis Silver, who represe thePresidential Women's Health Center, a West Palm 
Beach clinic where abortions ali, warned Hafele that he was stepping on shaky
constitutional grounds. I 
"These records are protected b nstitutional right of privacy," he said, refening to the
Florida Constitution.
After the hearing, Silver appeal won't be necessary until Epstein attorneys seek the . 
records. • 
In another rulin esday, Hafele also said that videos from depositions in the state cases 
can't be rele' th a court order. The ruling came after Epstein attorney Robert Critton • complain t a ideo of Epstein being asked whether he had an "egg-shaped" penis
becam .e.com sensation. It first appeared on The Palm Beach Post Web site. i 
Critton b ed 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. 
—[Email Redacted] 
1 
.1 
EFTA02732699

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 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on March 20, 2010) 
A purloined journal that is said to contain the names, O 
"hundreds" of victims of convicted sex offenderit 
Epstein could be used to reopen the invest into the 
multi-millionaire's appetite for teenage4irL ttorney 
representing seven of the victims s 
New details about the conte s ournal were released t
this week when Alfredo , who worked as a 
property manager for the Palm Reach resident, pleaded 
guilty to obstruction of justice for lying to federal agents 
when asked if he had any information about his former 
boss' criminal activity. He later tried to sell the journal he 
stole from EpINI for $50,000 to an unidentified person, 
alerted authorities, according to court records. 
part of the plea agreement, federal prosecutors said the 
urnal "contains information material to the Epstein 
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. 
EFTA02732700

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. 
1 
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. 
The multifaceted agreement, he said, deals only 
specific list of victims that the U.S. Attorney's Oi ew 
about when it penned the deal in 2007. If al victims 
are listed in the journal Rodriguez sto tz said 
federal prosecutors could reopen ation. 
1/4„"It opens the door for furth s 'on," he said. ? s ,
In addition to 
turning'
 journal to federal agents, 
Rodriguez told  his former boss was having 
sex with unde en he worked for him in 2004 
and 2005. He en naked girls, who looked like minors, 
in the p pstein's $8.6 million mansion. He had seen 
pcyttogra is images of young girls on Epstein's computer, 
g to court records. 
+ Neither Epstein's criminal defense attorney, Jack 
Goldberger, nor attorney Robert Critton, 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 
EFTA02732701

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. 
Rodriguez told prosecutors he didn't turn over thejo 
when both FBI and Palm Beach police asked for i eca 
he wanted money for it. He also said he wa a 'd Epstein 
would make him "disappear." The inforniata e told 
investigators, was his "insurance po 
He faces a maximum 20 year when he is 
sentenced on June 18. 
jane_musgrave@p 
@pbpcourts 
• 
EFTA02732702

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 Jeffrey E1  paid young 
women who claimed he used them as sex toys, court documents filed last week show he shelled 
out $5.5 million to settle lawsuits with three of more than two dot's who sued him. 
Responding to requests from Epstein's attorneys in a com uit that was spawned by the 
sex scandal, attorney said the political cted 64-year-old convicted sex 
offender paid more than $1 million to each of thekliireecymen represented. 
Identified in court papers only by their initi donyms because of the nature of the 
allegations and their youthful ages, L.M, was p $I million, E.W. $2 million and Jane Doe 
$2.5 million, said of the se m8S he negotiated with Epstein to end the lawsuits. 
Jack Goldberger, one of Epstel al defense attorneys, on Tuesday declined comment on 
the revelations, citing confidenna agreements that were pan of the settlements. For the 
same reason, he declined t ay whether Epstein paid similar amounts to settle roughly two 
dozen lawsuits file oth young women against Epstein, claiming he paid them for sex 
when some w gas 14 years old. 
Attorne rola, who is representing , said his client was compelled to divulge 
the confidential 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 him undermine Epstein's claims that 
"ginned up" the allegations to help his former law partner, imprisoned and disbarred 
Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme. 
EFTA02732703

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 it vectors he 
rftohad negotiated settlements in lawsuits against high-profile people. Investo tdTh they 
could get a cut of the cash. 
O One of the high-profile people Rothstein used to lure investors wa pst in, according to a 
lawsuit West Palm Beach attorney Robert Critton filed on E alf. According to the 
lawsuit, Rothstein told investors Epstein, a money mana to settle the lawsuits 
with the teens for $200 million — a claim Critton des a complete fabrication." 
After Epstein dropped the lawsuit in 2012 rned the tables on him. accused 
Epstein of filing the lawsuit maliciously to for representing the young women. 
Although 
no evidence 
was a partner in Ro in's ow defunct firm, Scarola claims Epstein had 
was involved 'Kt e nzi scheme. Federal prosecutors successfully 
charged other attorneys and me ter 
said in the malicious prosecutio uit. 
The revelations about thel iZry Epstein paid to three of the young woman came last week in 
documents filed for"Nafing Tuesday in preparation for a December trial on the lawsuit. 
e firm, but was never implicated, Scarola 
Attorney To'kja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the 
trial, in part, because she claimed she has been unable to talk to her client since his estate on his 
private island in the U.S. Virgin Islands was devastated last month by Hurricane Irma. "I've had 
no ability to communicate with Mr. Epstein," she said. 
EFTA02732704

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 P cheme, 
Coleman said the evidence indicates otherwise. Why else would he try to demo 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 t'a said. c 
"The Epstein cases were used to fleece money and defraud 
ins 
s," s e said. 
Edward's malicious prosecution case has been difficult fdCb& s because both Epstein and 
M.  have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked 
his Fifth Amendment right against self-incrimination when questioned by Scarola. 
has claimed that much of the information Epstein is seeking is protected by attorney -client 
privilege. 
The malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit 
ME against Epstein. Edwards also is suing the U.S. attorney's office, claiming it violated 
- the federal Crime Victims Rights Act when it negotiated a non -prosecution agreement with 
Epstein. 
Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to 
plead guilty to two piostitution charges in Palm Beach County Circuit Court. In federal court 
records, p-rojecutors claim one of the key reasons they agreed to drop their case was Epstein's 
agreement to settle lawsuits filed against him by dozens of his underage victims. 
EFTA02732705

Falco :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 
Updated Oct 8, 2019 at 12:31 PM 
'S e(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on February 22, 2019) 
CEINFederal prosecutors violated the rights of Jeffrey 
teenage victims by failing to reveal they 
to prosecute the billionaire on dozen 
connection with the girls' claims 
at his Palm Beach mansion, U tri 
Marra ruled on Thursday., ? s‘ 
\./ 
In a blistering 33-p 
methodically de 
prosecutors t 
young vomen 
the wer 
ped plans 
eral charges in 
id them for sex 
Judge Kenneth 
g, Marra meticulously and 
numerous steps federal 
de the agreement from more than 40 
o claim Epstein paid them for sex when 
oung as 14. 
the government spent untold hours negotiating the 
+ to s and implications of the NPA with Epstein's attorneys, 
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. 
EFTA02732706

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. 
eS e"The court is not ruling that the decision not to prosecut 
was improper," Marra wrote. "The court is simply rut 
that, under the facts of this case, there was a viol 
the CVRA." 
, k isFurther, he made no decision about w edy 
should be. He gave prosecutors an tt representing 
C; 
the young women 15 days to m° de how to unravel 
the complex legal web that anging over Epstein 
and his young victims fo an a decade. 
1 
€ 
€ 
€ 
The chances an a I be reached are slim, said 
attorney Jack ca o o is representing the two Jane 
Does who ch d the prosecutors' actions. 
er, l e sraid, there is no road map to follow. The 
attorney filed on behalf of the two 
dentified young women, daiming prosecutors violated 
e e 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- s 
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. 
EFTA02732707

"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. 
I 
E I 
g 
; I 
S 
i 
Scarola said it is likely Epstein's star-studded legal tea 1 g 
argue that Epstein fully complied with the terms fa
he made in 2007 with federal prosecuted 
therefore the agreement can't be undone. , 
As he promised, Epstein pleaded g e 2008 to state 
charges of soliciting a minor fo on and soliciting 
prostitution. He served 13 an 18-month jail term 
in a vacant wing of the co ockade that he was allowed 
to leave 12 hours a ys week. 
Further, as ag aid settlements to the young women 
who sued him. e the settlements were confidential, 
court re how he paid three women a total of $5.5 
r. turn, federal prosecutors held up their end of the 
rgain. 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. 
1 
EFTA02732708

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," lie 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 explanatio 
but we don't know what that reason may have been," 
said. 
( 1) In court papers, federal prosecutors have s t many of 
the young women were afraid to cross ful, 
politically connected money manager a siMply refused to 
testify against him. 
In other cases, they said, the women changed their stories. 
Jane Doe 2, who is trying to have the non-prosecution 
agreement thrown out, initially described Epstein as "an 
awesome ma "and told prosecutors she hoped "nothing nc
happens" to hi_ While she later agreed to testify against 
Epstein, utors said they feared Epstein's attorneys 
d us er words to destroy her if she ever took the 
stand. 
+Marra, 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." 
EFTA02732709

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 
inked. 
.77-7I 7 
After the meeting, Lefkowitz sent Acosta a note thankftig 
him for "the commitment you made to me during our _21
October 12 meeting in which you assured me thatyour 
Office would not ... contact any of the ide 
individuals, potential witnesses, or po claimants 
and their respective counsel in thi 
Marra quoted an equally ple then -Palm Beach 
County State Attorney B  cher sent to Assistant U.S. 
Attorney Vill was the lead prosecutor in 
Epstein's case. uld get this worked out for 
reasons I wo ting," Krischer wrote, shortly 
after the non -p cution agreement was signed. "After this 
is resolved I would love to buy you a cup at Starbucks and 
ly a conversation." 
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. 
EFTA02732710

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 Aft,
victims it cannot be misleading." 
Ultimately, the terms of the non-prosecution agre 
were revealed only after and attorneys f 1/41.0'
press successfully sued to make them publ' 
[Email Redacted]
"S )
@pbpcourts 
EFTA02732711

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 
Part-time Palm Beadier pleads not guilty to 
trafficking, conspiracy charges in federal c 
Manhattan 
Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on 
to charges accusing him of creating a vast network of girls ps y 
for his sexual pleasure at his homes in Palm Beach and Ranh 
The 66-year-old money manager's appearance in U.S. 
capped more than a decade of recriminations by y 
claimed Epstein used his money and political i 
Epstein's attorney Reid Weingarten dismisse 
charges as "essentially a do-over" of alleg 
County Jail for 13 months more than a 
However, unlike in 2007 when then;
shelve a 53-page federal indictm 
prostitution charges, prosecute, 
now U.S. labor secretary. 
"The alleged behavior shocks 
Berman said at a 
morning news con 
is still profoundl 
deserve their 
At a deten 
keep Este 
commit 
o. 
rids U.S. Attorney Alex Acosta agreed to 
in agreed to plead guilty to two state 
ork indicated they aren't willing to deal. Acosta is 
pleaded not guilty 
as 14 that he exploited 
trick LFourt in New York City 
omen and their attorneys who 
avoid federal prosecution. 
unt indictment on sex trafficking 
ended Epstein in the Palm Beach 
nscience," New York City U.S. Attorney Geoffrey 
And while the charged conduct is from a number of years ago, it 
rtant to many of the alleged victims, now young women. They 
g scheduled for Monday, Berman said he will ask a federal judge to 
d bars until he is tried on charges of sex trafficking and conspiracy to 
eking. Epstein paid dozens of young women to give him nude massages 
that, for m t, led to sex, he said. 
If convicted of exploitislozens of young women, including many Palm Beach County girls 
who were students at =I 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. 
EFTA02732712

"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 Guiffre's claims. 
New York prosecutors were able to ignore the controversial nonprosecutio tt nt 
because it contained some significant fine print, said former federal Judie 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 b Southern District of 
Florida," he said. "The Southern District of New York is not min at agreement and 
wasn't a signatory of it." 
That means the sordid allegations that have been leveleOE in 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 t ,
Palm Beach were minors because they told h' g , according to the indictment. 
Epstein preyed on young girls because he ere "vulnerable to exploitation," 
prosecutors added. 
As part of a carefully orchestrated sex Ep 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-1," 
"Employee-2" and "Employ 
To ensure he had a steady str o oung girls, Epstein would turn some victims into 
recruiters. He would pay hem to ring new girls to his home on El Brillo Way along the 
Beach or to his palatial townhouse on New York's Upper East Intracoastal Waterway in 
Side. 
"This allowed 
In both New 
of Epstei 
cloth 
"Epstein 
while he m 
to create an ever-expanding web of new victims," Berman said. 
alm Beach, the lurid operation was similar. Unidentified employees 
cort the teens into a room. They were told to take off all or most of their 
ving the naked billionaire massages, according to the indictment. 
ould also typically masturbate during these encounters, ask victims to touch him 
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. 
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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 Floridi,tidCassell, 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 was 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 
federal government could have been involved in a conspiracy to violate f e law," Scarola 
said of his interest in continuing the legal battle over the nonprosecutio ent. 
When Acosta agreed to drop the federal investigation, Epstein in 2 guilty to two 
prostitution charges and served 13 months of an 18-month senten m a avant wing of the 
Palm Beach County Jail - a cell he was allowed to leave 12 h , six days a week. He 
was also forced to register as a sex offender and settle civi more than 30 young 
women filed against him. 
U.S. Rep. Lois Frankel, D-West Palm Beach, said s carola's interest in finding out 
how the agreement came to be."I am especially 
m' 
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 investigate Acosta, Frankel said she 
is not sure that will happen. "It just seems it as a travesty that this guy got off the 
way he did and, without pre-judging i ha a proper court case," Frankel said. 
Former Palm Beach Police Chief ter was inflamed in 2006 when then-State 
Attorney Barry Krischer refused pstein with serious crimes. Reiter took the 
information his officers had m dozens of Epstein's victims to Acosta, believing 
he would prosecute Epstein. 
Reiter said he was hearteped 
"Thankfully, U. S. Attom 
judgment to inves e an 
Florida over a d 
And, Scarola 
Berman d 
friends 
investigat 
While agents 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." 
t. 
3 years later, Epstein will finally face justice. 
an and the other authorities in New York have the good 
prosecute Epstein in the way that should have occurred in 
o," Reiter said in a statement. 
are signals that Berman's investigation is far from over. 
answer questions about whether others, such as Epstein's high-powered 
be charged. He brushed off questions about the significance that the 
was being handled by the Public Corruption Unit. 
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"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-CALLFBI, 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] 
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