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EFTA02735319

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• 'Filing # 101840557 E-Filed. 01/17/202012:23:06 PM 
IN THE CIRCUIT !COURT OF THE 
FIFTEENTH JUDICIAI, CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HQLDINOS, 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-CA4014681,X=C-MB 
Div.: AO 
FIRST AMENDED COM 4PLA),_,ILNT 
CA Florida Holdings, LLC, publisher o IlicalA Beach Post, for, its First Amended 
to 
1/4rney
Complaint against Dave Aronberg, the S for Palm Beach County, Florida, in his 
official capacity ("State Attorney"), . Bock, the Clerk of the Court for Palm Beach 
County, Florida, in her official a 9. ourt Clerk"), alleges as follows: 
JURISDICTION 
within the exclusive jurisdiction of the Circuit Court pursuant to 
Xi) and 86.011 et seq. 
PARTIES 
1. This is 
TS ,Fla. Stat. Secti '6.012 
0 The Palm Beach Post is a daily community newspaper published by Plaintiff:CA 
Florida.I1oldings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida. 
3. Defendant Dave .Aronberg is the duly elected State Atkiiney for the Fifteenth 
Judicial Circuit in and for Palm :Beach County, Florida, pursuant to Ha. Shat. Section 27.01 and 
has .authority in grand jury proceedings pursuant toPla. Stat. Section 27.04. He is sued herein in 
Party JOINT 
1000.a EV# 
DATEADMITTEO: 
Con No nal 
n CUITCOURT 
CAffirctIlfarD9IUM BEACH COUNTY, FL, J4EPH ABRUZZO, CLERK. 3.(27/2023 2:57:43 PM 
Joint Exhibit 
j - J09 
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his official capacity as his office is in possession and/or control of documents that are the subject 
of this action.
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. 
INTRODUCTION 
A A' 
5. In what is now widely if belatedly recognized as a colossal mis e of justice — 
which led to the further needless victimization of countless young girl n — a wealthy, C r)
politically connected, and powerful financier was not held accountab , nor even forced to 
confront, allegations of serious sex trafficking crimes. Whil that Jeffrey Epstein's 2008 
deal with the State of Florida was not consistent with ce gathered against him, what 
remains shrouded in mystery is how that eviden w resented — and the extent to which it was 
presented — to the grand jury that returned a ict nt far more limited in scope than expected 
./-===-
.7' ‘ 
8tyThrough this ac .0Yi, e ahn Beach Post seeks public access to the testimony, L 
minutes, and other evidence pr d in 2006 to the Palm Beach County grand jury empaneled 
during the first Epstein s apse investigation. Typically, access to such materials is limited, for 
example, in ord revent the flight of those whose indictment may be contemplated and their 
ability t r destroy evidence; to ensure jurors' candor in deliberations; and to protect an 
accuse s 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(I)(c). 
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. 
and deserved. 
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• 
To the contrary, transparency is required to promote public understanding of the criminal justice 
system and public confidence in the fair administration of justice. As detailed below, Epstein was 
accused of sexually abusing and trafficking dozens of women and girls in south Florida (among 
other locations) over a period of several years while exploiting his wealth and political connections 
to obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury 
proceedings will shed light on the extent to which those in our government entrusted-IVth the 
solemn responsibility of enforcing our criminal laws equally as to all citizens their duties 
in this instance. Justice will be furthered where it is either (I) demonstrated'th ein was treated 
like others accused of similar heinous crimes, or (2) as appears more I key/to be the case, those 
who chose to give Epstein favorable - "unusual," in the words own of Palm Beach Police 
Chief - treatment, are exposed and held accountable. From Wimited information is now in the 
public domain, the State Attomey's referral of Epsteiif s case to the grand jury — which would be > 
out of the ordinary for this type of case rise to a strong inference of favoritism and 
corresponding disregard for the right 
/ 
9 inor victims of Epstein's sex trafficking. Access to 
the grand jury materials will all theprutil c to determine whether the grand jury process, and the 
.(
secrecy that comes with it, was to further justice or, instead, operated to shield Epstein and 
his co-conspirators from e nsequences of their criminal activities. Accordingly, Fla. Stat. 
Section 905.27 ut zes the disclosure of Epstein's 2006 grand jury proceedings 
in the absence of such a statutory basis, this Court is empowered to order 
public sc osure pursuant to its inherent authority and supervisory powers over the grand jury. 
Indeed, courts throughout the country in the past several decades have ordered the disclosure of 
high-profile grand jury proceedings pursuant to their inherent authority where the public's interest 
in those proceedings has outweighed the general need for secrecy. This is particularly so where, 
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as here, many of the details of Epstein's criminal misdeeds have already been made available in 
the public domain through extensive news reporting by, among others, The Palm Beach Post; by 
the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves. 
9. In recognition of the sensitivity of the materials being sought, and in the interest of 
protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to 
copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach' County = , 
grand jury first being submitted to this Court for in camera review, where t be redacted, 
as appropriate, to protect those who deserve such protection. 
FACTUAL BACKGROUND 
10. The following facts were gathered, in large part, from documents obtained by The 
Palm Beach Post through various Florida Public Records Law requests, documents unsealed or 
publicly available in other related judicial proceedings, and information and documents in the 
public record.
A. First Epstein Sex Crimes investigation, Indictment, and Plea Agreement: 
200.5-2008. 
11. The investigation into Epstein's sex crimes began more than fourteen years ago, 
when a 14-year-old girl' tepmother reported to police in the Town of Palm Beach, Florida, that 
Epstein and othe ho wprked for him arranged for her to give Epstein a "massage." Epstein 
required th stlrp, exposed himself, and masturbated while touching her. The girl was paid 
$300. Ep~t@i1R4as 52 years old at the time. 
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 th s were 
expected to testify. The proceeding was postponed, however, due to meetinc re een the State 
Attorney's office and Epstein's prominent criminal defense lawyer n!!• .1 friend, Alan 
Dershowitz. 
15. Another grand jury was convened in April 2 'ow canceled the day before it was 
to begin receiving evidence. z1-k,
(1) Police Chief Reiter's Letter to the State Attorney. 
16. On May I, 2006, Town of(Pairtt Bach Police Chief Michael Reiter wrote a 
61; e1"personal and confidential" letter toA m Beach County State Attorney, Barry Krischer, 
stating: 
I must renew my pno rvation to you that I continue to find your office's 
treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to 
communicate in this manner, but my most recent telephone calls to you and those 
of the lead- detective to your assigned attorneys have been unanswered and 
messages remain unreturned. After giving this much thought and consideration, I 
must urge you to era mine 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 (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 gran n Palm 
Beach County 
19. In July 2006, after State Attorney Krischer presented tes C•  evidence from 
one victim, the grand jury returned an indictment on a sole count of • ',Lion of prostitution.
There is no mention in the indictment of the victim being a 
20. On information and belief, a second of st ictims was supposed to testify 
before the grand jury, but was unable to st attend b a of a school exam. \ 
a‘s ,21. No reasonable explanation h n provided as to why the numerous other known 
victims were not presented as witness daime victims to the grand jury convened in July 2006. 
Nor has any reasonable explan tton 
ct initially eager to investigate an _proSecute Epstein for his crimes, over time lost the desire to do 
trprovided as to why State Attorney Krischer, who was 
so. 
22. 
who tes • 
ormation and belief, during the grand jury appearance of the single victim 
State Attorney presented evidence that vilified the victim and attacked her 
credibila,yRcluding 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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• 
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 
Ai;minors" that were victims of Epstein's sexual predations. Based on evidence gathered the FBI, 
a 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. ever, at the 
request of Epstein's lawyers, the indictment was never presented to a feder 1 fy• 
25. Instead, then U.S. Attorney for the Southern District of lorida, exander Acosta, 
Vnegotiated a plea deal with Epstein's team of lawyers to gran nity to Epstein (along with 
four named co-conspirators and any unnamed potential c pt ors) from all federal criminal 
S26. Throughout the remainder oft rough the first half of 2008, Epstein's c ltr
lawyers and the U.S. Attorney continu otia g the plea arrangement. Upon information and 
belief, Epstein's lawyers insist h the victims not be notified, (2) the deal be kept 
confidential and under seal, a rand jury subpoenas (including one that had already been 
issued for Epstein's co 
7  
as) be withdrawn. it 40t.
27. O ne 30 2008, Epstein pled guilty to State charges: one count of solicitation of 
prostitutio e hunt of solicitation of prostitution with a minor under the age of 18. He was 
sente ce onths in jail, followed by a year of community control or house arrest, and was 
adjudicat 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 12 months, he was allowed to leave the jail on "work release" for up to 
12 hours a day, 6 days a week. His private driver provided his transportation to and korniicwork." 
ze—NI 
30. Epstein was released five months early. 
31. Upon information and belief, Epstein violated the terms:of his_probation, but was 
not prosecuted 
(4) The Crime Victims' Rights A5.1 Litigation. 
32. Epstein's victims only learned after the fact about his plea in State court and filed 
an emergency petition to force federal prosecutors toceimply with the Crime Victims' Rights Act 
/- \\ 
(18 U.S.C. § 3771, "CVRA"), which mandattieertainc*rights for crime victims, including the right 
to be informed about plea agreements inclitheyright to appear at sentencing. U.S. District Judge 
< 1/.. "), 
Kenneth A. Marra recently ruleditha e ral prosecutors violated the CVRA by failing to notify 
Epstein's victims before allowkhith to plead guilty to only the two State offenses. 
33. The pros s failure to keep the victims apprised, among other things, also 
contravenes th da Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001. 
34 owing publicity exposing the extraordinary leniency of the plea deal, dozens of 
Hscivil atril4i re 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." 
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36. Upon information and belief, during the course of the Town of Palm Beach and FBI 
investigations, Epstein retained private investigators to follow, harass, and photograph his victims 
and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated 
the case against Epstein.
37. Upon information and belief, Epstein's victims were threatened against c perating 
with law enforcement and told that they would be compensated only if they did not e te with 
law enforcement. 
B. Second Epstein Sex Crimes Investigation, Indictment. Si 
%1/4 142g charges. ra38. On July 6, 2019, Epstein was arrested on federal sex t
39. Upon information and belief, the United Stat 
allegations and charges stemmed, in part, from contin 
ent's investigation of new 
nvestigations into and reporting 
on the mishandling of the 2006 charges and the ' i its that followed \ 
40. In a July 8, 2019, letter to t era district court by the U.S. Attorney for the 
Southern District of New York, Epst cribed as "a serial sexual predator who preyed on 
dozens of minor girls over ape ." The letter emphasized that "the Government has real 
concerns — grounded in past ex ce with this defendant — that if allowed to remain out on bail, 
the defendant could atter t pressure and intimidate witnesses and potential witnesses in this 
case, including s and their families, and otherwise attempt to obstruct justice." It also 
described the res Its 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 pits nude." 
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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 ir&tiwi Trump 
administration, resigned from office. 
42. Epstein was denied bail and was placed into pretrial/detettio at the federal 
Metropolitan Correction Center in lower Manhattan 
43. On or about August 6, 2019, Florida Gov. Sadtis ordered a state criminal 
/ 
probe into the actions of the Palm Beach Sheriff andforr4ezAiate Attorney Krischer for their 
handling of the Epstein underage sex trafficking easeX\
44. On August 10, 2019, Epstein was found dead in his cell at the Metropolitan 
Correctional Center. His cause of d'IliM -determined to be suicide. 
C. The August 27, 20O.-SDhirilearine: Epstein's Victims Speak. 
45. On account of Ais,death, prosecutors sought to dismiss the indictment against 
Epstein, while maintaini they would continue to investigate his co-conspirators. 
46. nt States Senior District Judge Richard M. Berman ordered a hearing on 
August on the prosecutors' decision to dismiss the indictment and allowed victims to 
spec tt e caring 
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. 
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; 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 hearing that 
the court "is the institution that most people have confidence in, in these very troub 
49. At the August 27th hearing, the girls, now women, spoke abo "exploitation 
d*e to speak on [their) 
Cand coercion," and to the fact that many of them "were in very vulnerabl and in extreme 
11 
poverty, circumstances where [they] didn't have anyone on [their] 
behalf...." One victim lamented that "as a victim, [she] nev .ee what the agreement was 
or why the special treatment got approved" in the Fl ears earlier. Another noted how 
"completely different" the investigators leadin o 2019 federal indictment were from the 9\ 
prosecutors in the Florida case, both in then rea ent of her and their investigation of her 
/--- , 
victimization by 
Z 
Epstein. \---- 
'
50. A former feder Attendance at the August 27th hearing emphasized that -Cjb 
"transparency is one of the oveiTidi4 objectives in our criminal justice system." 
51. Nearly all t e victims expressed the conviction that the secrecy that shielded 
Epstein has ca islfriem "irreparable harm" and that an opportunity to address his criminal 
wrongd those of the individuals who enabled his sexual racketeering, would allow for 
at leaiticime 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 Reported Extensively On Epstein's 
Crimes For Nearly 15 Years. 
52. Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm 
Beach County and the Treasure Coast vicinity. 
53. The Palm Beach Post has been a Pulitzer Prize winner and noniinated as a finalist y, 
three other times. _7` \-- , -„..\1/4,  i) 
54. Beginning in 2004, The Palm Beach Post hace:atensively investigated and reported 
on the allegations against, the law enforcement in s ig ,c of, and the crimes committed by, 
ilfi ls „Epstein and his co-conspirators. The News p ortage has included publication of the 
following articles: 
• "The Man Who Had Eycyjiii Jeffrey Epstein Craved Big Homes, Elite Friends 
and Investi ators Say, Underage Girls.," published on August 14, 2006, reporting that: 
a local community college student, admitted in a sworn statement to 
police that "she had taken at least six girls to visit Epstein, all between the ages of 14 
and 16;" Palm Beach Police "interviewed five alleged victims and 17 witnesses;" 
"Dershowitz, the Harvard law professor, traveled to West Palm Beach with information 
about the girls," including social media discussions about "their use of alcohol and 
Eirijuana .," after meeting with Epstein's legal team, "prosecutors postponed their 
decision lo- take the case to a grand jury;" Palm Beach Police subsequently "received 
semplaints that two of the victims or their families had been harassed or threatened;" A
"*Iations between police and prosecutors were fraying" as the investigation continued; 
ditd "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 541 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 Jul 6, 2006, 
reporting that "Palm Beach police thought there was probable cause to Epstein 
with unlawful sex acts with a minor and lewd and lascivious molests Th rticle 
further reported that "Police Chief Michael Reiter was so angry ate Attorney 
Barry Krischer's handling of the case that he wrote a memo s g e county's 
top prosecutor disqualify himself," and identified a 20-year -record female 
source who said "she gave Epstein a massage in the nude, en blought him six girls, 
ages 14 to 16, for massage and sex-tinged sessions at his ho 
• "Police Say Lawyer Tried to Discredit Teenage rls" blished on July 29, 2006, 
reporting that "[flamed Harvard law profess Alan howitz met with the Palm 
Beach County State Attorney's Office and provided damaging information about 
teenage girls who say they gave his el' Palm Beach billionaire Jeffrey Epstein, 
sexually charged massages" and that " to  office said it presented the 
Epstein case to a county grand ju m h rather than directly charging Epstein 
because of concerns' about the gig's itch ity." 
• "Expert: Ignorance of Age nse In Sex Cases" published on August 5, 2006, 
reporting that "Mather fi arges, the state attorney's office presented the case 
to a county grand j r indicted Epstein last week on a single, less serious 
charge of felony of prostitution," and that "[t]he case raised eyebrows 
because the state a s office rarely, if ever, kicks such charges to a grand jury." 
• "Epstein C Female Accusers Liars" published on August 8, 2006, reporting 
that "[}state omey's spokesman would say only that the office refers cases to the 
when there are issues with the viability of the evidence or witnesses' 
Beach Chief Focus of Fire In Epstein Case" published on August 14, 2006, 
im porting that Chief Reiter "pressed for Epstein to be charged with the more serious 
crimes of sexual activity with minors" and "slammed State Attorney Bally 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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i 
• "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 Beecher 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 Tyc ublished on 
August 13 2008 reporting that "[d]uring his first month of confinem Epstein was 
visited by , who allegedly escorted victims "upon then at his Palm 
Beach waterfront home to an upstairs room, where she prepared the m ssa e table and 
provided the oils for their encounters" with Epstein, and (by 
i
, "a 
young woman whom Epstein purportedly described as his ugoslavian sex slave." 
• "Billionaire Sex Offender Leaves Jail Six Days a Work" published on July 
1, 2008, reporting that Epstein "is allowed to lm Beach County Stockade 
six days a week on a work-release program.., 
• "Women Want Epstein Sex Plea Deal ublished on June 10, 2009, reporting 
that attorneys for women suing Ep n ous courts "want his [non-prosecution] 
agreement [NPAJ with federal t unsealed" and were moving to unseal the 
agreement in Circuit Court of i h Judicial Circuit, and that "Epstein now faces 
at least a dozen civil laws eral and state courts filed by young women who 
said they had sex with ow are seeking damages." On that date, The Palm 
Beach Post moved to • en the matter for the purpose of obtaining public access 
to the NPA, which as o disclosed by this Court on June 25, 2009. 
• "Epstein's Secret Pa ith Feds Reveals 'Highly Unusual' Terms" published on 
September 1 , reporting that, owing to Epstein's non-prosecution agreement, 
"fede ro tors backed down and agreed to recall grand jury subpoenas if Epstein 
ilty to prostitution-related felonies in state court" and "also a not to plea 
f E stein's ssible co-conspirators: =MI Lesley 
" The article further reported that, according to an 
y representing three of Epstein's victims, "none of the 30 to 40 wom[e]n 
tified 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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• "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 Teen', Victims' 
Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge 
Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's 
teenage victims (under the Crime Victims' Rights Act] by failing to"\tpVeal they had 
dropped plans to prosecute the billionaire on dozens of federal char* in connection 
with the girls' claims that he paid them for sex at his Palm Bcackmanyiion." 
• "Epstein Indicted On Sex Charges/Pan-Time Palm Reacher Pleads Not Guilty to Sex 
Trafficking, Conspiracy Charges In Federal Court lrytvlanhattan" published on July 9, 
2019, reporting on Epstein's appearance in U.S. District Court for the Southern District 
of New York in which he "pleaded not guilty to/ciargesaceusing him of creating a vast 
network of girls as young as 14 that he exptjII <for is sexual pleasure at his homes 
in Palm Beach and Manhattan." A \ 
A true and correct copy of the above news ani,es -,N r the computerized format in which they 
are maintained in The Palm Beach Pose lect c archives or the news print edition in which 
originally published, is annexed her ibit 1. 
55. Since the filing fthe al Complaint in this matter, The Palm Beach Post - along 
with media worldwide 7 z  has con nued to report on Epstein's crimes and the ongoing official ci-_has 
proceedings resullog frofirthose crimes. result
2) The Palm Beach Post's Standing and the Public Interest. 
press has a constitutional right of access to criminal proceedings, see, e.g.,Oe 
Richinoi 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 
CA/Aronberg 7000131 
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Comm'r, Ala. Dept of Corr. v. Adva 
and "standing to question the v fi'di 
news is directly impaired or cu le(i ' 
c 
837 F.3d 753, 757-58 ( 
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.., 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme Court has recd, 
First Amendment offers protection to both speakers and those wishing to r 
Cr 
8
also Stephens v. Cry. of Albemarle, Va., 524 F.3d 485, 492 (4th Cir. 200 
has "standing to assert a right to receive speech" by "show[ing] that the exists a speaker willing 
that the 
h."); see 
that a plaintiff 
to convey the information to her") 
57. Because of the unique role performed by-we pre,ss as a "public surrogate" (=, 
426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about 
At 
criminal proceedings, proceedings, news organizations "pre‘sumptively have a right to access judicial records," 
Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019), 
order restricting publicity because its ability to gather 
426 So. 2d at 4; see also Carlson v. United States, 
2016) ("[a]s a member of the public, [the Reporters Committee] 
has standing to its] claim" to grand jury materials because such materials are "public records 
to whicb4h may seek access, even if that effort is ultimately unsuccessful"). 
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 (Ha. 2017); see also 
Zerilli v.IM, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press' function as a vital 
16 
CA/Aronberk000132 
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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 Reach 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 intended for 
the public benefit, and The Palm Beach Post seeks access on behalf of the pub! a. Stat. 
§ 905.27(1)(c). It is further express in Fla. Stat. § 905.27 that the legislature i for
rara 
 a court 
to be the party to make the determination of disclosure. Fla. Stat. § 905( 21( ther words, the 
legislature intended for recourse to the courts in considering and determining the propriety and 
scope of grand jury secrecy. 
E. The Court's Jurisdiction And Authority. 
(1) The Court's Supervision of the Grand Jury Process and Its 
Authority to Order Public Disclosure of the Epstein Evidence. 
60. The Florida Supreme Co it has noted that "in states such as Florida, where the 
grand jury is preserved, it is an im act t endage of the court which impanels it. At the same 
time it should not be forgotten hat the dge of that court is equally important and he is generally 
charged with the supervi n of the grand jury's activities .It is, therefore, of vital importance to 
maintain the digs and e integrity of both the grand jury and the presiding judge." State v. 
Clemons, 15O 2d`231, 233-34 (Fla 1963). 
apter 905 of the Florida Statutes governs the empanelment and conduct of 
Florid:4rand 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 
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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(1)(a)-(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 ("t-itisuict court 
has the inherent power to disclose [grand jury] materials in exceptional cir ces and . 
historic importance can be a sufficient reason when there is little counte ttilit'igngcl for secrecy"). 
64. The Florida Supreme Court has confirmed that grand ju t'crecy is not absolute 
and that any "potential harm to public officeholders" from disc( will be the product of their 
own conduct, and not the consequence of an unrestr d di of misguided citizens." Miami 
Herald Pub. Co. v. Marko, 352 So. 2d 518 (197il("The benefits to be derived from this 
•‘-‘7
extraordinary exercise in citizen participati the grand jury] would be severely limited if the 
fruits of that activity were not avails le blic on whose behalf it is undertaken. Implicit in 
the power of the grand jury to i ?esti veld expose official misconduct is the right of the people L k  ) 
to be informed of its findings. • public disclosure of grand jury findings inevitably entails the 
risk of reputational da ge, the legislature has ensured that any potential harm to public 
officeholders w I he product of their own conduct, and not the consequence of an unrestrained 
body ofrQl citizens."). 
(2) The Court's Jurisdiction To Declare Rights 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 
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as if fully set forth herein. 
66. Florida law specifically provides that a declaration may be sought from the Court 
conceming 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 be Ii administered 
and construed." Florida Stat. Section 86.101. 
COUNTS 
(Declaratory Relief - Florida Stat. Sections 816.01 f es seq.) 
.k/ 68. The allegations set forth in paragraphs 14throttgb47 are incorporated by reference 
fit 
69. This is an action for Declar4Reli f pursuant to Chapter 86, Florida Statutes, 
and other supplemental relief. )--,, 
70. The Pahn Beat t-fros tfully requests that the Court declare that pursuant to 
ts.Fla. Stat. Section 905.27(1), it eititled access to the testimony, minutes, and other evidence 
presented in 2006 to the tA  ut each County grand jury because such disclosure and access would 
be in the furthe of justice. Fla. Stat. § 905.27(1)(c). Because The Palm Beach Post is not 
seeking t e ma rials in connection with either a civil or criminal case, it seeks a declaration that 
the sco o 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 
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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 
l'istei irelief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith dispute e ‘ etween 
the parties. 
AS' 
73. Through this Complaint, The Palm Beach Post presently has ciable question 
concerning its rights to obtain the 2006 grand jury materials pursuant to Fla. Stat Section 905.27( I ) 
zr -S\ ,^i ill and the Court's inherent authority. 
74. A bona fide, actual, present, and practi or the declaration exists in that 
Defendants have denied to The Palm Beach P —God to the public at large — the grand jury 
materials sought to be disclosed. The relief s u fro the Court is therefore not merely the giving 
of legal advice or to answer hypothe ns. 
WHEREFORE, The P ost respectfully requests that the Court determine the 
rights and obligations of the pC 'e
B
ili:iy declaring that pursuant to Fla. Stat. Section 905.27(1)(c) 
and the Court's inheren ut ority, The Palm Beach Post may gain access to the testimony, 
minutes, and of er 'dente presented in 2006 to the Palm Beach County grand jury and use those 
material 'f rpose of informing the public. ÷ 
COUNT H 
YYY
 (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 
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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 in a manner 
that precluded his indictment for the serious crimes he committed, including sex trafficking and 
sexual assault. 
77. Pursuant to Florida Stat. Section 905.27, in order to furtheilystiee for Epstein's 
victims and the public, and to provide public disclosure to illuminatewhether Epstein received 
unreasonably lenient treatment based on the available evi,denerk,791 Palm Beach Post requests 
immediate access to the testimony, minutes, and othereviderwe presented in 2006 to the Palm 
Beach County grand jury. 
78. In a case of this magnitude a d t ortTnce where the accused is dead and so many 
of his crimes, as well as the identiti a es of his co-conspirators, and the identities of the 
victims have already been exp , t 7 for grand jury secrecy is no more. See United States 
v. Socony-Vacuum Oil Co., 3 . . 150, 234 (1940) ("[A]fter the grand jury's functions are 
ended, disclosure is whol p per where the ends ofjustice require it."). 
W HERD, The Palm Beach Past respectfully requests that this Court, pursuant to Fla. 
Stat. Se 7(1) and the Court's inherent authority, order the State Attorney and the Clerk 
of the Courto 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 
21 
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EFTA02735339

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 Fag 
Stephen A. Mendelsohn, Esq. 
5100 Town Center Circle, Suite 4 
Boca Raton, Florida 33486 
Telephone: ([Phone Redacted] O 
Facsimile: (561) 338-709 
By: /s/ Stephen A. Mendell 
STEPHEN A. 
Florida Bar No 
mendelsoh 
hasenh 
FLSe corn 
By: / elf Grvziel 
L J GRYGIEL 
m tted Pro Hac Vice) 
tate St., 6th Floor 
bany, New York 12207 
Telephone: ([Phone Redacted] 
Facsimile: ([Phone Redacted] 
grygielm®gtlaw.com 
By: /s/ Nina D. Bovaiian 
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®glaw.com 
22 
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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. 
/s/ Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
23 
CO 'S
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IT 1 
The Newspaper's Reportage on Jeffrey Epstein 
C)
CA/AronbeLQ-0Q0140 FILt110: PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
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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 1u112,2019 at 6:02 AM 
From the archives: `When Palm Beach detectives starte kin 
questions and teenage girls started talking, a wave o esistance 
followed, 
Bditor'sNote: This article appeared in The Palm Beach Post on A 
%Jeffrey Epstein's arrest iti Patin Beach County I a charge 6\ 
2(X$, three weeks after 
ahem ofprostitution. 
WINGED GARGOYLES guarded:the gate atje Is. Palm Beach mansion. Inside, 
hidden cameras trolled'two rooms, while th and went. 
:For the police detectives who sifted garbage outside. and kepi reeonis.cavisitors, it 
was the lair of a troubling target 
EpSteit, one of the mitt 11.1ft the country's mega-.rich, was known. as much for his 
secrecy as for his love of e things: magnificent hppaes,.priVate jets, beautiful women, te
friendships with th worl . e te. s ee
But at Palm o headquarters, he was becoming: known for something else: the 
regular ar nage girls he-hired to give:him massages and, police say, perform sexual 
favors 
Epstein was differenrfrom most sexual abuse suspects; he was far more powerful. He anuited 
among his friends' former President Bill.Clittot, Donald Trump and PrinceAndrew, along 
with some of the most prorninegr legal, scientific and business minds in the country.. 
When detectives started asking questions and teenage girls started talking, a wave of legal 
resistance, followed. 
1 
I 
I 
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1 
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•» NEW: Jeffrey Epstein: Lawyer said financier  had  sex with woman during work-
FeleaSq 
11Palm Beach,p0lice 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 h a; 
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert' 
In .a lengthy artide, headlinedithe Mystery of Ghislaine Maxwell's Seer e British 
Mail on Sunday tabloid laid out speculative stories that the tOcialite' au1. a CIA spook, a 
math. teacher,a concertpignist or a corporate headhunter: 
"But whatis the truth about him?' the newspaper wonde axwell, Epstein, is both 
flamboyant and intensely private; 
The media:frenzy did not begin in full until a dek t ii, er. lb September 2002, Epstein was 
tekflung into the limelight when he flew Clin dilttors Kevin Spacey and Chris Tucker to 
Africa.on his private let. 
Suddenly everyone wanted to 
publishedlengthY proilte.t. Th 
pstein was. New York magazine and Vanity Fair 
tit Post listed him as one of the city's theist:eligible 
*bachelors andbegan des ibing  its gossipcolumnsWith adjectivessuch gemysterious" 
'and.arectusivet 
Although Eiist t j no interviews, the. broad strokes of his past started to come into focus: 
Buildin asof extravagance 
He was bo blue-collar in 1953, the son of a New York City department employee, and 
raised in Brooklyn's. Coney Island neighborhood. Re left college without. a bachelor's degree 
but b'e'came a math teacher at the prestigious Dalton School. Manhattan, 
The story goes that the father of one of Epstein's studentsviaSSo impressed with the than that 
he puthim in touch with: a seniorpartner at•Bearr. Stearns; the ‘global investment bank and 
securities firm. 
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10.1976, Epstein:left Dalton fora job at Bear. Stearns,: By the early 1980s, he had started). 
Epstein and CO. That is when he began makinglis millions in earnest. 
Little is known or said about Epstein's businessexcept this: He manages money for the 
extremely wealthy. He is taidto handle:aacninta only:O1Si 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 apd a 
farmer Palm Beadier who is said to have been a mentorto Epstein. 
WO:hens:11d Epstein One of hitinciat lavish residences: a'magive &Mike doiniitatesa 
block on Manhattan's Upper. East Side. Itisteported to have, among.i res, closed, 
circuit television and a heated sidewalk to melt.a.w.artallen snow. 
bThat townhouse, thought to be the largest privatesesidence ' A c i anan, is only a piece of 
the extravagant world Epstein. built over tithe. 
In New Mexico; he constructed a 17,000-square- il &l nansion on a 10,000-acre ranch 
outside Santa Fe. Many believed.it to.be the I e in the state. 
1 
private island inthe Virgin Islands. 4
>> PHOTOS: The players in ey..SpAtehi saga ; - 
In Palm Beach, he bought a waterfront e o I Brillo Way. And he owns a 100-acre g ar,
Perhaps as remarkable As 'sh homes is his extensive network of friends and associates at 
the highest echeto fpo r. This includes not only socialites but also business tycoons, 
media moguls royalty and Nobel Prize-winning Scientists whose research he often 
lust. 11.  people collect art, he collects scientists; said Nowak, who directs the 
Program f r Evolutionary Dynamics. at Harvard University and was reportedly the recipientof 
a S30 million research donation from. Epstein. 
.EpStein is said to have befriended former Harvard President Laryy $nmm!ers,prominent law 
Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort 
Zuckerman. 
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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 rick wl 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 19505, when he paid tens of thousands of dollars to j him.at 
an intimate fund-raising dinner in PIIMBeach. But from all appearances they ome 
close friends until after Clinton left the Oval Office and moved to NewYor 
.Epstein has donated more than $100,006 toiDemocratiecandidates' including Jean 
Kerry's presidential bid, the reelection.tampaign of New Mexico GO sthartheh and the 
Senate bids of Joe Lieberman, Hillary Rodhatfi Clinton, Chri Dodd and Charles 
SChumer. 
Powerful friends and enemies 
A Vanity Fair profilefound cracks.in the ve teas life story. The1003 article said he 
left Bear Stearns in the wake of a:feder be a possible Seturitiesend:Exchange 
Commission. violation.. It also point Citibank once sued Itim for defaulting on a $20 
million loan. 
The article suggested that onedtthwtusiness inentors and previous employers was Steven 
Hoffenberg,, now' serving n terra after "bilking investors out:of more than $450 million 
in one of tbelarge . ernes in .American history? 
As he exam e4th, Epstein made enemies in disputes. both large and small., He sues:1111e 
man who.' : ' old limn his intiltimillidii-dollar Pala Beath hOthe over a dispute about:less 
than t1 in furnishings. 
A former Mend 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 hilt tiothilig. 
» Jeffrey Epsteip:tmocKprisoner who_ssfept, moppeli,floors42(fisial  says 
• 
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les a, bad. memory. I would rather not have ever ?net Jeffrey Epstein," said Michael Stroll; the 
retired forrner president of Electronics and Sega Corp. "Suffice* 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 aformerMs. Sweden and,a.Roipanian. 
model. 
"He's a lot of fun to be with," Donald Trump told New York.magazine in 2 t, t t is even said 
that he likes beautiful women as much as I do, and many of them are o ger side. No 
doubt about it, Jeffrey enjoys his social life? 
Investigation leads to Epstein 
c Although he wasnot:a frequenterof the.Palm Beach. • e 
A‘tvie 
, he made  presence felt. 
,*\in
Among his charitable donations, he gave S90,0.00 . e Beach.Police:Department and 
( ce \ck I-Cedes sat in his garage; alongside a -
.Palm Beach International Airport. Athome, a 
eady..Prom a window in his mansion, he could look. 
the West Palm Beach skyline. He seemed to be:a man. 
S100,000 to Ballet Florida: 
In Palm Beach, he lived in luxury. Thr 
Harley-DaVidson. His jet waited at 
private'chef and a small staff st 
out on the Intracoastal Wate 
who had everything. 
But extraordin ealtb c>rn fuel extraordinary desires. 
» Epstein eave ma for mansion in sex-trafficking case 
In March 20 a worried mother contacted Palm Beach police. She said another parent had 
overheard a conversation between their children. 
Now the mother was afraid her l4-year-Old daughter had been. molested,by a maxi on, the 
island. 
The phone call triggered an extensive investigation, one that would lead detectives to Epstein. 
but leave theiri frustrated. 
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Palm Beach police and the state attorney's office have declined to discuss fhecase..But a Palm 
Beach police report detailing the criminal probe offers awindow into whardetectives fated as 
they sought to close in on Epstein. 
Detectives interviewed the girl, who told them a friend had invited her tin rich man's house to 
perform a massage. She said thefriend.told her to say she was 1$ if asked; At the house, she 
said she was paid SSWalter stripping to her parities and massaging' the man while he 
masturbated. 
Police interview 5 alleged victims 
The investigation began, in Hill after the girl identified Epstein in a ph 
paid her. Police arranged for garbage trucks to set, aside Epstein's t 
through it. They set up a video-camera to record the comings 
monitored an airport hangar for signs of his private jes,ar 
They quickly learnecf that the woman who took the 
Palm Beach Coiriniiiiiity Coll 
statement at police headquarters, 
visit Epstein, all between the ages of IA 
During the drive back to her hots 
4c(1/40
trr Loxahatthee. In a Math 
fitted she had taken at least six girls to 
paid her for each visit, she said. 
man.who had 
ce could sift 
at his home.,They 
departures. 
girl to Epstein's house was: 
oIcl detectives, "I'm like a Heidi Pleiss." 
Police interviewed five alleged arid 17 witnesses, Their reportshows some of the girls 
said they.had been ins to have sex with another woman in front of Epstein, and one said 
she fiad direct intercourse him. 
In October 
looking 
found 
transcript. 
ed the Palm Beach mansion: They discovered photos of:naked, young-
as several of the girls had described in interviews. Hidden cameraswere 
age area'and inside a: cloCk on Epstein's desk, alongside :a ,girl's, high school 
Two of Epstein"sformer 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:chel cooked for them, Wqrkers gave 
them rides andlancied out hundreds of dollars ar atime. 
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One employee told detectives he was. told to send a.dozen roses to -one. teenage girl after .1 high ; 
school drama performance. Others weregiv.en rental can. One; according to polite:, received a 
$200 Christmas bongs. 
The cops moved to cement their case. But as they tried to tighten the noose, they encountered. 
other forces at work. 
In Orlando they interviewed a potsibletictitn who told them nothing. inappropriate ¢ad 
happenedbetween her:and Epstein. They asked her wheth:er she: had spoken to. ease. 
1 
1 
I 
She said yes, a private investigator had asked her the same questioris. 
Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart d 
When they subpoenaed one of Epstein's former employeest hetold e same thing. He 
ands private eye had.met.at a.restapra:nt:days earlier to go.o the mgt.would tell 
investigators. 
Detectives received :toniplaintstliatprivate eyes vi as polite officers. When they told 
Epstein's local attorney,. Guy Fronstin, he said gators worked for Roy Black, the 
highspowered,Miami lawyer who has defendC te Alves ofRush Limbaugh and William 
S ale'
Kennedy 
While the private eyes were. to •itallel investigation, Dershowitt, .dietiattard law 
professor, traveled to WettP. -with information- about the girls. From iheir own 
profiles on the popular b site ySpace.com, he obtiined copies of their discusSions about 
their use of alcohol and 
He took: his r h meeting with prosecutors in early 2006 *where he sought to cast 
doubt on e ns eliability, 
The, priybeyes had: dog up enough dirt on the girls to makeprosecutors skeptical. Not only 
did some of the girls have issues with drugs or alcohol but afro some had triniinal records and 
other troubles, Epstein's legal team claimed. And.at least one of them, they said, lied when she 
told police she was younger than I$ when she stsrted performing massages for Epstein. 
-After the meeting? prosecutors :po.s.tponed their decision to tamale case to a. grand jury:; 
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the'In  ollouting weeks, police receivedeor.nplaints. that two of the victirtis or their families had. 
been harassed Or threatened. Epsteitt'S legal team .ntaiiitainsthat its private investigators did 
.nothing illegal or unethicalduring 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-showt
according to EPSteith ittatity. 
"The embarrassment on the prosecutor's, face was evident whorl the. police (Ater : • r 
showed up for the meeting; attorney Jack Q0:illy:ger said. 
Later in April, Recarey walked into a prcise_cutor's.office at the state at. .. . ce and 
learned .the case Was taking an Unexpected turn, 
The prosecutor, Lanna Belohlavek, told.Recattythettate a Office had offered Epstein 
a plea deal that would not require: him to serve jail tinag felony conviction.. 
Recarey told her he disapproved of the plea offer. 
The deal never came to pass, however, \( S y
Future unclear after charge. 
Qn May-1,.the department ask to* rs' to approve Watitants to arrest Epstein on four 
counts ofunlawful sexualact* a:minor-and to charge his personalassistant, 
now 27, for heral role.in arranging.thevisits. Police .officials ilsowanted to 
charge Robtbni th Ifad bed Heidi.Fleisenvith.lew.d and lastiViotts acts. 
By then, the t was :frustrated with the way the state attorney's office had handled the 
case On ay the warrants were retwestetk, Palm Beach Police Chief Michael Reiter 
wrote a. tt r °State AttomerBarry Ki'ischer suggesting he disqualify:himself from the case if' 
he would of act. 
Two weeks later, Recarey was, told that prosecutors had decided .once again to take the case to 
the grand jury. 
I 
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It is notknownhow many of the girls testified before the grand jury: Buc Epstein's defense 
team said one girl who was subpoenaed - the Cafe who said she had sexii0 intercourse: With 
Epstein - never showed.up. 
The grand jury's indictmentwas 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; Epst 
charged With one count of felony solilitation of prostitution, Which carries a m 
of five years in prison; He was booked into the Palm Beach County Jail earlyJ Z3,
released hours. later. 
Epstein's legal teami'doesn't disputethat he had girls over for ma 
he said their claims that they had sexual encounters with him 1 creåfHfity.. 
"They are incapable of being believed," he said. "They h 
4 ,accusations of theft made: gainst them.by their emplo s. ‘ 
some of them." 
<S ,Wliat znre airis for Epstein is yet to be seen 
in was 
penalty 
erger said. But. 
records.. They had 
re: was evidence of drug use.by 
The Palm Beach Police Departmen the FBI to investigate the case. It also has 
returned the. $90,000 Epstein d 
lb New York, candidates for go'llet or and state attorney general have vowed to return å total 
of at least $60;000 in tam contributions from Epstein. Meanwhile, Epstein's powerful 
?S „bends have rem ' ed sileåt as tabloids and Internet blogs feast on the public details of the 
police investig • n. 
Goldbe ins Epstein's innocence but says the legal team has riot ruled out a future 
plea dea e insists. Epstein will emerge in the end with his reputation untarnished, 
"He will recover from this: he' said. 
Staffwriter Lerry and staff researchersBridget Bulger, Angelica Corter,,Amy Hanaway and 
Mink Mena contributtd to this story. 
[Email Redacted] 
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@AMarraPBPost 
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273 /278 - Tuesday, November 16, 2004 
Edition: FINAL 
Section:A SECTION 
Page: IA 
Source: By PAUL OWRRS Palm Beach Post.Staff. Writer 
Illustrationt PHOTO (C & 2 B&W)& MAP (B&W) 
Memo: Ran All editions. 
Dateline! WEST PALM BEACH 
TRUMP. SNAGS GOSMAN ESTATE FOR 541:MILLION 
When it came time 10,bid Monday for the palatial Paint. Beach digs of The 
Donald was not about to be trumped. 
"Nobody was going to outbid me," the brash developer-turned-TV- said from his 
New York office. 
Trump bested two other biddets With a $41.35 'Milian:Offer 43,000-Equare-focit, 
severvbeilroom estate on .6 oceanfront acres along the sto ees Row." 
But Trump, 58, proud possessorolMat-a-Lago; hat it• ye in the Gotman home at 
515 N. County Road. He wants to - what else? - set • e more money, 
The star of the niega-hit The Apprentiet said he ' Weep the site into a "Super 
hymn/ house" that would be the "finest anyw e nited States." He might build 
another house before flipping. the entire pa 
"I've known about thishouse for quite:so rump said. "It's probably the best piece 
of land in Florida d and probably the t notary real estate:" 
AltbotilTritrnp.taid he could su 
Lesly 
property into nine lots, Palm Beath Mais 
said zoning regul for onVtWo houses -.and maybe a third. 
said sheet not worried about 
"Hes been a very good pro o et- in the town of Palm Beach," she said. "He does his 
projects very well: He perfec must" 
Monday's auction took t U.S. Bankruptcy Court in West yawl Beach at part of 
Gosman's Chap; b play case. Proceeds from the. sale will go into escrow for eventual 
distribution to tors: 
The auctio, xactly.noon after Judge Steven dismissed an objection from 
an atio ting mohey manager. Jeffrey Epstein. The lawyer argued urisuccesAfidly 
that T of a qualified bidder because his contract stipulated that he would:not close 
on less title insurance was in place beforehand. 
Witla p listening via conference call, Epstein began the.biddingat $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 E.sptein bid against.each other until the price hit $38.8.5 
million. 
Puke then bid $59.1 Million, briefly.. raising the ire of Trump, who: elieved that Pulse had 
given up his right to bid.by passing the first time. 
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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 therightto buy 
the 29,000-square-toot home(a-typicalPalm 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:to 'd. Up a 
bit". Luzinski said. 
"The system worked," said Charles Tatelbaum3. a lawyer for creditor JPMor Bank. 
".In bankruptcy court, the idea is to get the most for creditors, and that's ed... 
The auction proved to beta bonanza for creditors, Luzinski said, noti highest offer 
former listing agent Sotheby's International Realty received was $:3 mil, othebY's won't 
receive a commission, he said. 
Pulte, 42, of Boca Raton, said he figured Trump wouldn't ba n Monday. 
"I got the feeling he. was willing to go a lot higher, and Id' to chase it," Pulte said. 
Pulte said Gosman asked him'beforethe auction wheth be willing to let hinastay 
in the mansionafter the closing until he decides why e e a to move. Trump and 
Luzinski said they havehad no such discussions 
Gosman, 75; had the house built after paying; ion for the. land in 1986. 
The former, health-care magnate declined i uests before and after the auction 
Monday. He was at the courthouse but le e auction took place.. 
The $41.35 million price tag eclipses 30 3 million sale of Lowell "Bud" Paxson's Palm 
Beach home and guest house but f91s the $45. million that Virginia home builder 
Dwight Scher paid for Ron Perel 00-square-foot estete,.Casa.Apava, a designated 
landmark. 
‘.Sharalso paid $18,6 million r a efront lot across the street from the plain:house, for a 
total of$63.6 million. Insiders Scher spent a total of $70 million for hisaiew property, 
making it the priciest resid -:,) sale in Ift,$. history; 
Gcisman once had fortu a teat Forbes magazine* estimated at$480 million. He 'voluntarily 
filed for Chapt banIcruptcy protection in 2001, listing assets of $250 million and 
liabilities of 'Ilion. 
'When a j clam Gosman .had to give up all of his exempt assets to creditors if he 
wanted o me under Chapter II, Gosman converted the-case to Chapter 7 liquidation. 
Last. . :;Bankruptcy Judge Larry Lessen.r.uled that Abe and. Lin °semen's marriage is 
invalid b "ause Florida law dcies.ndt recognize a Dominican ReptibliediVorce that Lin 
Colman tried to obtain, from another man, Michael Castre. 
Thedudgers decision was. a huge victory for creditors because it prevents Abe Gosman. from 
protecting assets by claiming joint ownership with his wife. Gosman's aisets 4which include 
an extensive collection of aftw.Orkstould total its much as $70 million and will be sold later. 
Without. Lessen's ruling, Luzinski wouldhave had &much harder time selling Gosnian's 
estate, said David.Cirno, special counsel for the trustee. 
"We would have been thwarted .. or at least substantially impaired;" Cimo said. 
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The trustee alleged during a weeklong trial in May that Gdaman fraudulently gave his. wife 
an ownership interest imhis home and other. belongings only to avoid losing them in 
bankruptcy. Gosman has. denied any wrongdoing, saying he 'made theproperty transfers in 
1999, well before he filed for bankruptcy,
Lessen is expected to rule in the next two. months whether Gosman made improper transfers, 
a decision thatwill affect how much money will be available to creditors.. 
Cimo acknowledged that Monday wasn't the best a. days for the. Gosmans but said they were 
willing to move forward, in part because the upkeep of the estatenow exceed's their means, 
"This is not a happy occasion. for. hem, but at leastwe're. moving to the next level," 'mo 
said. "That's Rot a house ymtwant to live in un1esSyou'rpmaking large timounts ney 
like Donald Trump." 
paul_owersepbpost.corri 
ccs 
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11/1112619 Indictment: Billionaire Solicited 3 Times • News • The Palm Beach Post - West Palm Beach, FL 
. Ih.., .... .e Palnr~ each ost REAL NEWS STARTS HERE I 
Indictment: Billionaire Solicited 3 Times Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 2, 2019 at:2:80 PM 
(EINTOR$ PIQTE: This story originally published in The Palm Beath Post on July 25, 
2a)6) 
Billionaire money manager and Palm Beach part-time resident Jeffte 
solicited.or procured prostitutes 'three or more times: between A d • ct. M 
of last year, according to an indiCtment charging him with fey ation of 
prostitution. 
Epstein, 53, was booked at the Palm.Beach County 5 a.m. Stuiday. He 
was released.on $3,000 bond. 
t\114Epstein's case is unutualin that stiSpett • - -tu 'on.johris7 are usually charged N e
Raiwith a misdemeanor,. and even a fel - &a  is. typically iriade in a criminal 
information - an alternative to ' di nt charging a person with the Al% my
commission of a crime. 
His attorney, Jack Qicil tge " , dined to discuss the charge: 
State attorney's o s olcesman. Mike:Edmondson also had little to says
'Gene ealcip , there is •a case that has'a number of different'aspects to It; 
Edm of a prostitution -related charge.being submitted to a grand jury. 
came aware of the case months ago. by Palm Beach police.* 
Pt utors and police worked together to being the case to the grand int% he 
said. 
3 
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-11/1112619 Indiament. 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-foothoni ith a 
pOol arid boat dock oti• the Intracoastal Waterway since 1990) ac 
property records. A man answering the door there Monday s 
wasn't home. A Cadillac Escalade registered bhp was parke e driVeway, 
which is flanked by two massive gargoyles, 
Epstein sued Property Appraiser Gary Rikglit; ntending that the 
assessment. of his home exceeded its fair mvket He dismissed his lawsuit 
in December 2002. 
A prOfile of Epstein in Vanity-F— e said he owns what are believed to 
be-the largest-private homes n - 51,000 square feet azid.in New 
Mexico - a 7,500-acre ra are in addition.to his.70-acre itlandin•the 
U.S. 'Virgin. Islands. and "craft. 
Epstein's friends a era, according to the magazine, include prominent. 
businessme  ,. cade ics and.scientists and famed. Harvard law prcifessor Alan. S ,
Dersho . 
@pbpost.com 
htlpsfirw/w.palmbeachpdslcorNnews/2008 02701/indietineht-billopaIresolld144-94999 
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t t1/1112019 After long probe, billionaire faces soholabonicharge • News • The.Palm Beach Post - West Palm Beach, FL 
The Palm. Beach O.g REAL NEWS STARTS HERE
After long probe, billionaire faces solicitation 
charge Posted Jill 27,2006 at int AM 
Updated 0O1,2019 et 3;11 PM 
(EDITOR'S NOTE: This stbry originalb, published itt The Palm Beach Post on MS 
2006) 
Palm Beach billionaire. Jeffrey Epstein,paid Shave underage g 
'women brought to. Ids homey where he received massages an soy times sex, 
according to ,ati investigation by..the.ralmBeach Policefru rtment. 
Palm Beach polite spent months sifting. through• hand watching his. 
Waterfront home and Faith BeithliiteitatiO to keep tabs his 
private jet. An indictment charging Epst unsealed Monday, charging 
•Mtn.with one count of felony sohtfita ntution. 
1 
I 
'Palm Beach police thought the able cause to charge Epstein with 
'unlawful sex acts with am d trid.lascivious. molestation. 
Police Chief Michael 17; s so angry with State Attorney Barryirischer'S 
handling:of the that he wrote a memo suggesting the county's top 
prosecutor dd quG elf. 
".I rums to examine the unusual coursethat your office's -handling of this 1 4 m ken and consider if good and sufficient reason exists to ;require your 1 
cation from the prosecution of these cases7Reiter wrote in a May I I 
i :meitio to Krischer: . ; I 
i
I While not commenting specifically on thetpstein caserMike EtiMondson, 
spokesman for the state attorney,.said his office.presents: cases other than 
murders to a grand  jury when there are questions about Wit:rids& credibility and 
their ability to testify. 
hitpsdAvenv.paimbeachpostoanthews/26060727/after•long-protte•bilhortaire4lees-sokiistionLdwp. 115 
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11/11/2019 After' Icing OA*, billionaire faces solicitation charge - News - The Paint Beath Post West Palm Beach. FL 
By the nature of their jobs, polite officers look at evideritefrom one-sided 
perspective,' .Edmondson said. "A prosecutor has to look at it in apnuch broader 
fashion,' weighing the veracity of witnesses and how they may fare under 
defense attorneys' questioning, he said. 
Epstein's attorney, ack Goldberger, said his client committed no crimes. 
"The reports andstatements 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 allegations 
wholly unsubstantiated:and not credible, and that's why his client was -1-AS 
Charged with sexual activity-with minors, he said. 
Goldberger said Epstein passed aliedetector test administere utable 
polygraph examiner in which he said he did notimow e minors. 
Also, a starch warrant served on Epstein's home fou dente to 
corroborate: he girls' allegations; Goldberger sal 
According to police documents:. 
-.A Palm BeathCormiinity.Colleg 
the nude, then brought him six t ag 4 to 16, for massage and sex-tinged Acc.,
sessions. at his home, 
ent id.she:gaVe Epstein-a massage in. 
- A 27-year-old woma ho rked as .Epstein's personal assistant also 
facilitated the liai ons p g the PBCC student to arrange for girls when 
Epstein was rpm wn. And she escorted the girls upstairs when they 
arrived, pytlng fre sheets on a massage table and placing massage oils nearby. 
- Pali sworn statements'from five allesed victims and 17Wittiesses. They 
at on three occasions, Epstein had sex with the girls. 
A nfoney manager for the ultra-rich, Epstein was •named one of New York's most 
eligible bachelors in 2003 by The New York Post, Be reportedly hobnobs with. 
the likes of former President Clinton, former Harvard UniversityPresident 
Summers and Donald Trump, andhas lavish homes in Manhattan, 
New Mexico and the-Virgin Islands. 
t t 
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tattirgriattftaria*****Oorning+rtr290A0?2.7.04w4onnitrn-tart-tttotaawitotiar*Oticak 
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11/i1/2010 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.Lieberman, Hillary Clinton, Dodd and Charles 
Schumer. 
Goldberger is one of five attorneys Ept 
subject of an investigation, Edmon saz fnong thenthers: Alan 
Dershowitz, the well-known Ha rofesso.r and author.; who is a friend 
of Epstein. Dershowitz could notched for comment. 
Police said the woman 
20, of Palm Beach' 
Wellington and. 
CollegeWh tslie 
phone 
To 
CO ASHA
rAS CICed Since he became the 
ed young girls forEpstein was 
on has worked at an Olive Garden restaurant in 
Was a journalism major at Palm Beach Community 
questioned by polite last October. She.has an unlisted 
d could not be reached. for comment. 
.she met Epstein wtien,atage- Vita friend asked her if she wouldlike 
e money giving him a massage. She said she was driven to his. five-
bedroom, 71/2 -bath hiamenn. the Intracoastal Waterway ; then *stoned upstairs. 
to a:bedroom with a Massage table and oils. Epstein and were both naked 
doting the massage, she said, but when he grabbed her bottocks,..shesaid.she 
dichetwent, to be touched. 
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.11/11/2019 Mac long probe,. billionaire faces solicitation charge- WWI.; Tlibealm Beach Post - West Palm Beach, FL 
Epstein said he'd pay her to bring him more girls - the.youngerthe 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;-:'I'm like a Heidi. 
Reiss,' police quoted her as' aying. The girlsktiew what to expect-When they 
were taken to Epstein's home, said. Give a tnattagt - maybe:naked -.and 
allow. some touching. 
Ong 4-year-old. girl took to meetEpstein led police to start 
investigation of him in March:2003. A relative of the girl called to 
thought the: child had recently engaged in_sex with •a.Palm Bea rl t egirl 
then. got into a. fight with. a classmate who accused.her of be stitute, and 
shecouldn't explain Why she had $300 in.her purse.. 
Thesirl gaye policethis account of her meeting ect)n: 
She accompanied and a second' gir 
.Febrtia.ry. 2005.. Once• there,. a woman 
girl to follow her upstairs to. a room 
photographs of naked women o E, a hot pink and 
i)  
table. "C r
She stripped to herbra ties and gave him a massage. 
l ecWillYEpstein gave the I -old $300 and:she and the.other. irls left, she said. She 
said Robs Old he that Epstein paid her $200' that day; 
s.house on a Sunday in 
was Epstein's assistant told the 
mural of a naked woman, several 
'sofa massage 
d similar stories. In most accounts, Epstein's personal assistant at 
rah =, now 27, escorted the as to Epstein's bedroom. 
iwhostmost recent known addressisia North Carolina,.bas 4ot been 
charged in. the case. 
Palm BeaCh:police often conducted surveillance of Epstein's home) and 'at Palm 
Beach International Aifpoitto get if hiS pi-if/ate jet Was tildte; to -they Would 
Icnow when he was in town. Police also arranged repeatedly-to receive his trash 
htlps://wm.palmbeschgost.com/newsl200.6072 7/aller-long-probtgagnolre-laces•solialanon-cnarge 
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• 11/112010 After long probe. billionaire faces solicitation charge - News • The Palen Beach Post - West Palm Beach, FL 
from Palm Beach sanitation workers, collecting papers with names 4nd phone 
numbers, sex toys and female hygiene prodtKIS• 
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 10:10 a.m. 
Only three months before the police department probe began, Epstein donate 
S90;000 to the department for the purchase of a firearms simulator, saidJ 
Strudgr, town finance director.: the purchase was never made. Them was 
returned to Epstein on Monday, slie said. 
CO 
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11/11/2019 Police say lawyer tried to discredit teenage girls - News Palrn Beach Daily News - Palm Beach, FL 
;Palm Beach Daily .News 
Police say lawyer tried to discredit teenage 
girls Posted Jul 29, 2006 at 17:01 AM 
Updated Oct 3, 2019 at 2:00 PM 
(EDITORS NOTE: TRU nary originally was published in The Palm Beach Po ly • 
2g 2066). 
AS" 
Famed Harvard laWprofessor Alan DershOwitz met with the P County. 
State Attorney's Office and provided damaginginformation.a out t enage girls 
who say they gave his client,.Palm.Beachhillionaireje gel!), sexually 
charged massages, according.to:police reports.. 
The reports also state that another Epstein a eed to a plea bargain that 
4.would have allowed Epstein to have no 4 . .; ord. His current attorney N e
denies this happened., 
And the documents also reveal 
private investigators aggre 
chased off visitors. 
her of at least one girl complained that 
wed his car,:phestographerthis.home and. 
Police also talked otiiebody Who said the was offered money if she refused to lioar
cooperate with the Beach Police Department probe of Epstein. 
Theist state said it presented the.:Epstein Case to a county'grand 
th rather than directly charging Epstein because. of concerns about 
credibility. The grandjury indicted Epstein, .53i On a single. count of 
felob solicitation ofprogfitutiort, which carries a maximum penaltyof 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 tate: 
helpsIMWOLISsimbeitchtiSynenconVartfclei20060729/NEWS/19091757 1 
I 
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11111/2019 Poke say lawyer tried to awe& teenage girls - News - Palm Beach Daily News •Pillre Bead% 
The case originally was. going to be presented to the. grand hiry i February, but 
Wit postponed after Dershowitz produced intontiation.gleaned h orn the Web,
site myspace.com showing some of the alleged victims commentinton alcohol 
and maAiltian.a ttse, according to the police report prepared by Detective 
Recarey. 
a 20-year-old Palm Beach woman who told police she 
recruited girls f6r Epstein, also is profiled on.tnyspace.corn. Her page includes 
photos of her and her friends, including one using the name "Pimpin' Made 
„who was. not charged in the case, is a potential prosecution with 
According to Recarey, prosecutor tanna Belohlavek offered Epste ys 
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, a g with 
Epstein, accepted the deal, in which Epstein wouldplead guil too e count of 
aggravated assault with intent to commit a felony; be p on_we year's' 
probation and have ho criminal record. The deal a or EPstbin to submit 
tea psychiatric and sekual evaluation and have. rvited.vitits with. 
minors, according . o Itecarey's report. The nwas made in connection. 
with only one of the five alleged vicpim e restates, 
Fronstin - who declined to corn i oii a case was subsequently fired and 
veteran defense attorney Ja r was hired. He denies there was any 
agreement by any of Eps ors to a plea deal. 
abtblUtelydid not l o a plea in this.casef he said. Neither Belohlavek 
nor a state .attom Icesirian Could be. reached for comment. 
The pate t arents of alleged victims who complained of being.harassed.by 
priva in sti ators provided license tag nutnbers of two of the. men.. Police 
to • ehicles were registered to a private eye in West Palm Beach and 
in Jupiter, according to Recareis report. 
"I have no knowledge ofictdefense.attorney Goldberger said. 
The report also says a Vernati 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; Itecarey's report says. Those 
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11111/2019 Police say laWyer tried to discredit teenage girls News • Palm Beach Daily News - Palm Beach, FL 
iThe chief himself has come tinder atta' b ps eiret laWyert and friends inclS 
TIr S ouNew York, where he has a home. ew Post quoted Epstein's,
prominent New York lawyer, G Le rt, as sayinghisclientwas indicted 
only 'because of the craclnes ice chief.' 
Reiter has declined.to c n the case.. 
Prosecutors have 
before tsaid ike F mo'ndson, spokesman for the' tate attorney's offite. "Thaes 
Whity6u ith a ate that falls into a gray area,' he: said. 
resented a sex-relatedcaselike Epstein's to &grand jury 
°they's office did notrecommend a particularcriminal charge on. 
indict Epstein, Edmondson said. The grand jury was presented with a. 
list . 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. "Ws away for theprosecutOes'offite t6 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: 
who did.tilk "will be dealt with: the woman said she was told. Phone records 
show the woman talked with the person who allegedlyintimidated 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 vyhether females came to his waterfroA 
home, but whether he knew their ;get. 
1 
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"He's neverdenied girls came, to the; ouse: Goldberger said, But he Mein 
was given a polygraph test, 'he .p.assed on knovileclge of age;' y said. 
Afterdie indictment against Epstein was unsealed this Po Ce. Chief Reiter 
referred the matter'to the FBI. 'We'Ve received th tid*E'te reviewing 
it,' said FBI spokeiWciman Judy Orihuela in M' { g iS e
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11111,2019 Police say lawyer toed to discredit teenage girls - News - Palm Beach Daily News - Pain Bela, Fl. 
Defense attorney Robert Gershman was a prosecutor for sixx years. "Those girls 
must have been.incredible or untrustsv.orthy, I dotift 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 hewas the 
subject of a criminal probe, Epstein hired .a phalanx of powerful attorneys such as 
Dershowitt and Lefcourt, who is a past president of the National Association of 
Criminal Defense Lawyers. 
Miami lawyer Ray Black -'wIMbecame nationally known when he sixA • Ih ;A
defended William Kennedy Smith on a rape charge in PAM Beach 
involved at. one point. 
Said defense attorney Sushauers-1 thimk.it's e public may 
get the: perception that with power, you:may be treat ently than the s 
average Joe? 
haperAWNepaInibiaeliclaitynews comianicle/20060729/NEWV190917573 
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The. Palm Beach. Post REAL NEWS STARTS NM 
Expert: Ignorance of age isn't 
defense in sex, cases Posted Aug 5, 2006 at 12:01 AM 
Updated, Opt 0, 2019 at, 1:38 PM 
(EDITOR'S NOTE: This story originally pubjishg(tin The 
Palm Beath. Poston Aug. .,2006) 
Even if Palm Beach money manager Jeffrey Epstein di 
know that, girls who police say.gayg him sexual mass 
his Intracoastal home were under the legal age, th 
wouldn't have exempted hint from criminal es A4c45 
sexual activity with, minors. 
ACC"Ignorance is not a valicfclefense o I1 ekle, a legal 
skills professor who was a r ecutor for nearly 
30 years, half of that tune in sex crimes against 
children. 
'Them is'no 
concerned; 
ment as far as the age is 
After a -month investigation, Palm Beach police said 
obable cause to charge Epstein, S3, with 
wful sex acts with a minor and lewd and lascivious 
OCA station. They contend that Epstein -.friend of the rich 
4 famous and financial patron of Democratic. Party 
organizations and candidates - committed those acts with 
five underage girls. 
In the past week, New York Attorney General and 
gubernatorial candidate Eliot Spitzer has returned about 
550,000 in campaign contribution's he received from 
Epstein, and Math ME, a candidate to replace Spitzer in 
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his current job, has returned. S10,000 to him because of the 
Palin Beach standal, the New York Daily News has 
reported. 
Rather than fileCharges, the state attorney's office-
presented, the case to a county grand jury, The panel 
indicted'Epstein last.week.on single, less.serious chargeof 
felonysolicitation of prostitution. 
The case raised eyebrows because the state attorney's office 
rarely, if ever, kicks such charges to a grand jury. And it 
increases the diffictilty ofprosettiting child sex abuse cases;,S .
especially when the defendant is enormously wealthy,a.0 can hire high-priced, top-tier lawyers. 
At least One of Epstein's alleged victims told 'ce' eV.,
shelvat underage when the two of them for 
massages and sexual activity. She was at the 
time'and said' Epstein asked her ut her high 
school, according to police re As ,
A girl who said she &let East en. she was 15 said he 
told her VA? 93.14 n hn. happened at his. house,. 
bad' things caul e police reports:state, 
Epstein's you leged victim was 14 when she says she 
gave hi massage that included some sexual activity. She 
is 9w e girl's .father says he doesn't know whether 
old Epstein her age. 
rdatighter has kept a lot .of What happened from me 
because ofSheer embarrassment," he said.. "But she very 
much looked 14. Any prudent.man would have had second 
thoughts about that.' 
Defense attomey.JacItGoldberger 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. 
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a 
"A prosecutor has to look at.it.in a much.broader fashidn, a 
state attorney's spokesman said last'week. 
Tf.re vesir 
NTIELLIGENT GRID Thlata 6111 
Epstein hired Harvard. law Professor Alan. tz 
when he became aware he was under a n, and 
Dershowitzgave prosecutors info t some of the 
alleged victims had *spoke of ' h and marijuana on 
a popular Web site, actor ' g:to in Beath.police 
report. 
Prosecutorstyp' 1 der two things in deciding 
'whether to c arge s ebody with sex-related offenses 
against min° ether there is sufficient evidence and 
whethe sLfl is a public interest:in doing so, Dekie said. 
o teens are in asexual relationship and the`:buy turns 
a b fore the girl, he could be chilled with a sex crime if 
e.sex continues. There would: be no public interest in 
pursuing that, Delde said. 
But where There is a large gap. ages and especially in 
cases of teachers with students - there is a public interettin 
prosecuting, h.e said. Likewise if the accused has a track 
record of sex with minors. 
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Still there is :a 'universal. constant in prosecuting these' 
cases, Dekle said.. Men whoiexploit underage Children fpr 
gel often carefully, choose their victims in ways that will 
minimize the risk to them, he said. 
Victims usually are from a lower socialstatus, and. they may 
suffer from psychological problems, badesaid, 
"Lots of child sexual abuse victims have been victimized by 
multiple people over a period of tithe. Then theltt of.abuse 
produces behavior in the victims .that further damages their. 
credibility.,  Examples include promiscumis:behaiiior and 
drug abuse. 
Some of the alleged victims:in the Epstein case returned t 
his home multiple times for the:massage sessions and the. 
1200 to $300 hetypit ally paid them pervisf "That would 
be a definite problem .forthe prosecutda jatdBettyResch, 
who prosecuted crimes against ch alm Beach. 
County' fOr Ai/eye:ars and now • tepractic.e intake 
Worth. 
"The victim becom pathetic to a jury, Resch said: 
"But she's.a victi a eless. She's aid.' 
Most men Gh with sex crimes against minors look 
norm Ide slid. A jury expecting to see a monster 
. And the victims' ages work.againSt them and:in 
r oldie defendant. in a trial, Dekle said.: 
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 cat" 
I 
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The Palm Beach Pok REAL NEWS STARTS HERE 
Epstein camp galls female accusers 
liars Posted Aug 8, 2006 at 12:.01 AM. 
Updated Oct 8,2019 at 3:35 PM 
(EDITOR'S NOTE: This story originally publish(d in The 
Palm Beach Pak dh Aug. 8, 2006) 
Attorneys and publicists for Palm. Beach financier Jeffre 
Epstein went:on the offensive Monday, contending 
teenage girls who have accused: Epstein of sexual 
Shenanigans at his waterfront home ire hart say g 
that the Palm Beach Police Department 
"There never was annex betwee and any 
underage WOmenrhis.lead at ac • Gtildberget, said 
from Idaho where he was with his family. 
ta eSintejn.dfd have yo n eornem his house to give 
him massages, 0 t . said. "Mr.. Epstein absolutely 
insisted anyb dy w e to his house be over theoge of 
18. How hey that, I don't know. The question is; did. 
anYthi occur. The law was net violated here.' 
ad no explanation as to why Epstein would-paygirls.or 
o en with ho massage training - is the illegetvictinit 
el was 'the case - $200 to 330() fortheir visits. 'The 
credibility of these witnesses has been seriously 
questioned;" Goldberger said. 
Epstein, 53, was indicted by ocounty grand jury lastmonth 
on a charge.of felony solicitation of prostitution. After-an 
1 I-month investigation that include.d sifting through 
Epsteitfs trash and surveilling his home, Palm Beach police 
concluded there was enough .evislence to charge him with
sexual activitywith minors. When the. grand juryindicted 
1 
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Epstein on the less serious chargei.Pol ice Chief Michael 
Reiter referred theicase 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 harinduded Paris 
Hilton and Jennifer - said on.Saturday that Epstein's 
camp was ready to get their story out.a
They did that Monday via Goldberger and a LOS Angela 
publicist for Miami criminal defense attorney Roy. Black, 
who also has represen'ted Epstein in the case. 
"We just, think there has been a distorted view of this 
irt the media presentedby the Palm Beach police.," 
Goldberger said. 
Reiter has consistently declined to cons egtd j6e case 
and did not respond to..1 request for m Monday. 
( S 4
Cr 
_ 
A S  i llair
A÷ .‘,..) 
The. implication that State Attorney Barry ICristher was 
easy on Epstein by presenting the case to a grand jury . 
rather than filing charges directly against him.is wrong, 
Goldberger said. 
1 
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The Palm Beach Police Department was 'happy and I 
ecstatic" that the panel was going to review the evidenCe. °I 
think what happened is they weren't happy with the. res ult. 
They decided to use the press to embarrass Mr. EpStein." 
But records show that Reiter wrote Krischer on May I 
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 prosetution of these 
cases! 
Rather than flat-.out decline to charge Epitein, ICrischer 
referred the case tothe grand jury. to `appease the chiefO 
Goldberger said. 
A state attorneys spokesman would say only t i t th_ fhee 
refers cases to the grand jury when there with the 
viability:of the evidence or witnesses' 
Both the state attorney and the concluded there 
was not sufficient evidence n had sex with 
minors, according to Gol t was just a childith 
performance by the Polite Department," 
Goldberger said 
The defense or eysaid one of the alleged victims who 
dame was a minor was in fact over the: age of 18. 
A they eged victim who was subpoenaed:to testify to 
t
so 
grand jury failed to do so. Epstein's accusers, he added, 
ve histories of drug. abuse and thefts. "These women are 
ars. We've established that! 
But why would they ill invent their stories about meeting 
Epstein rot sexual massages? 
1 don't:have an Answer is to'wharwas the motivation for 
these women to come forward and make these allegations," 
Goldberger said. 
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Newspapers' 
v4:49ncesig• 
• 
The Palm Beach Post (Seem Pam Beach, Florida) • 14 Aug 2006, MOn • Page 7 
Downbeats, on Nov 11. 2019 
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• 
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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 
(EDITORSTIOTE This story originally published in The Palm 
Reach Post March 13, XX) 
A federal probe or a plea deal could• explain the wait in 
Palm Beacher's solicitation cast 
Nearly eight months after Palm Beach tycoon 
Epstein was charged with felony solicitati stitution, 
there has been no discernible progres No. 
Witnesses deposed. No trial date , save:for 
routine court hearings reset anation. 
"Usually that would be urlcu Rsaid criminal defense 
attorney Glenn Mit no involvement in the 
case. 
)"As a generA C e t would be unusual for nothing to have 
happe " agreed Michael Dutko, a criminal defense ka me , ort Lauderdale: He represents:
Af2 Palm Beach, potentially a key witness in the 
O se
A routine hearing for Epstein was pulled frail:that:Mitt 
dodketlatt week and reSetfor May 16. The delays and 
inaction. could he: doeto a potential federal probe of Swain 
or because a plea dealt 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: 
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'Highly unusual'? is how Palm Beach Police Chief Michael 
Reiter described Ssate Attorney Barry krischer's handling 
of the cast in:a bluntly critical letter to Krischer last year 
before Epstein was indicted: 
Reiter Wetted the Witter -CO the•FBI to determine whether 
any federal laws had been violated. Epstein's allies 
countered by attacking the chief personally and 
professionally. 
Reiter% department investigated Epstein for 11 months. 
Paige sifted repeatedly through his trash and conductea 
surveillance on.his fivepbedro-om, 7 1/2gbath, 7;234-squ 
foot home on the Intratoattal Waterway. O 
Police said Epstein paid women and girls as y 
give him•erotic massages athis home. Pot ht there 
was probable cause to charge him wi sex acts 
withn minor and lewd and lascivious~l don.
Epstein responded by hiring4p oflawyers. One of 
them, Harvard law professor ay author Man Dershowitz, 
provided the state a ffice with infortnatiOn about 
alcohol and:Atari y some of the girls who said 
they were wi 
Prosect> en referred the case to the. grand jury rather 
file. arges directly against Epstein. 
st &attorneys deny he had sex with.underage 
e: lawyers say the.girls.' stories' are not credible. Bptif 'the 
court file is any indicatorv.they'vemadeno effort rollepoSe 
the girls. 
1 
Neither proseeptors, nor defense atto_rneystape.sought to 
question , said Dutko, her attorney. She 'recruited 
teenage gilt to visit Epstein for massages and sexual 
activity,. Palm Beach police. said, and presumably would be a 
key witness. 
• 
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Epstein 's attorney jack Goldberger did not return phorie 
messages: 
A source close, to the case *suggested iris languishing 
pending a decision by the FBI citi*lietherto refer itto. 
federal prosecutors. 
'We still have a:pending:case," FBI spokeswoman Judy• 
Orihuela said Monday. 
State Attorney Krischerdid not return a call for comment. 
His spokesman, Mike Edmondson, declined to say whether 
federal investigators. are:delaying;the Ep-stein case: But; hi 
added, "if another agency it looking at sbiliething,'W 
wouldn't want to step on their toes." 
Attorneys say inertia in a criminal case oft s to •a 
pending plea deal, 
"It would not:surprise the if som appened that's 
not reflected in the .court file such as an 
agreement that will be fo zed ter. 
Defense attorney 
sometimes put 
Witnesses, re esd g"documents and thelike -- because 
doing s creates more work for harried prosecutors who 
may bee ngryand not offer a plea deal. 
said defense attorneys 
conducting discovery -- deposing 
es defense lawyers, knowing that, will try and.do 
covery without taking depositions," said. Shiner, a former 
prosecutor for 13 years. 
Instead, they may conduct a belbw‘the-radar probe such as 
haVing aprivate investigator check out leads, he said, 
Shiner and others say'a pleadeal far 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. 
} 
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Edmondson, spokesman for State Attorney Krischer, said 
there is no plea offer and no .request for the prosecution to 
show its Cards. 
-pa my knoviledge, it's never happened before on a filed 
case; he said. 
Cos 
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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 S.UES:BILLIONAIRE INVESTOR, SAYS THEICHAD , SEX WHEN S WAS 16 
A billionaire investor, already facing jail in Palm Reach .County on charges of so erage 
prostitutes; is being sued by a young woman who says he had sex with her, w as 10 and had 
sought his:help becoming a model: 
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, say effrey .Epstein had 
the teen perform. a.sex act when she brought photographs of herself for view in his Upper 
East Side .mansion: sometime in 2900. 
Epstein,. 54, atrioney manager, told the teen he managed finan ctoria's Secret and "could get 
you into the catalog".ifshe were "nice" to him; court papers ..pens say being "nice" 
included massages and other favors. 
When the girl told,Bpstein, "I am 16 years old and just mo del," he replied, "Don't worry, I 
Won't tell anybody," court papers say. 
Epstein,. said by London's. Mail on Sunday to be. pttd of England's Prince Andrew, has been 
indicted in Paint Beach. on charges of solicitin prostitutes. That case. is pending: 
The girl visited Epstein "several times over [months and engaged in bizarre and unnatural 
sek acts" while she was a minor; the law 
Epstein "repeatedly requested that (th i with her I and 16-year-old girlfriends, 
Stating; !Genie by With your frieri )next time, Don't bring Sherrie (a mutual friend in her 
40s). I love .girlsyour age.' " 
The. yOutig Woman, nOW 23, kept til ing to.Epstein because. she has "mental issues;" said her 
lawyer; William I °moat. efused to elaborate, but court, papers say she was""disibled as a result 
of severe mental disease and 
Epstein's lawyer in York erald ketbourt; said, "The girthas admitted she js.insanet.btlt she can 
read a newspaper o lie the word 'rich."' 
Lefcourt also s sta e of limitations has•expired for the woman's ease criminally' and civilly, 
and will al t rta y be dismissed. 
. He refus menton.Epstein's Florida charges. 
Meanwhile, . niroch, 57, also acknowledged that his. Client was living with him and was M.thecentet 
of a $10 milli n lawsuit:he filed.last year against a neighbor who said he was having sex with: 
underage girls. That case is pending. 
"What she was d0ing at 22 is irrelevant to what happened to her w.hen.she: was 16i" Unroch said 
Wednesday. He went oil the say he hoped Epsteih.w601d agree to "dti right" by his blientand.reSolve 
the case otit of court. 
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The Palm Beath Post _ REAL NEWS SHIRTS HERE 
Palm Reacher pleads in sex ;mei Posled Jul 1, 2008 at 12:01 AM 
Updated Oct 3, 2019 at 1:47 PM 
(EDITOR'S NOTE; This story originally published in Th& 
Palm Beach. Post on fuly.l, 2008) 
Jeffrey Epstein will serve 1 1/2 years on teen solicitation 
t ic charges. 
He lives:in a Palm Eleach waterfront mansion and has kO 
company with the likes of President Clinton, Prink .) 
.Andrew and Donald Trump; but V ihvestine eriefftey 
Epstein will call the Palm Beach'Coun ' .for the 
nett I& months. 
jEpstein, 55) pleaded guilty MAta o felony solicitation of 
prostitution and procuri aft under the age of 18 for 
prostitution. After se oaths in jail, he will be 
under house acre r e . And. hewill have a lifelong.
obligation to a sex Offender: He must submit to 
an HIV test in hours, with the results being 
provid s victims or their parents. ? iv
( c mpart to the plea deal, federal investigators agreed to drop 
et • vestigation of Epstein; which they had takensto al i.an
d jury, two law enforcement sources said. 
Epstein was indicted two years ago after an 11-month 
investigation by Patin Beach ptiliCe. They received a 
complaint from a. relative of a.14-year-old girl who had 
given Epstein a naked massage at his five-bedroom, 7424-
square-foot, 8845 million Intracoastal home. 
Police concluded thartherc were several other girls brought 
in 2004 and 2005 to an upstairs room at the home for 
similar massages and sexual touching. 
• •• 
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The indictment charged:Epstein only with felony 
solicitation of .pmstinition. The state attorney's office later 
added the charge of procuring underagegirls for that 
purpose. 
Prosecutor Lannal3e1Ohlavelt said of tbcpleci tOOk into 
consideration the: lesigthithe trial would have been and 
witnesses havingto testify* about sometimes embarrassing 
.incidents. 
Epstein may have made a.serious mistake soon after he was 
charged. He rejected an offer to plead gniltyto one count of 
aggravateda.ssaultwithiptent to-commit a felony, 
according to police documents. 'HI would have god 
years' probation, had ho criminal secord and not b 
registered sex offender, the:documents Indic-
Epstein arrived in court Monday vn 
attorneys. He: wore a blue blazer, lue. jeans and 
and gray sneakers. Afte dge Deborah.Date 
Pucillo accepted the plea, was erprinted. Epstein 
then removed. his bl d s handcuffed for-the trip to 
jail while hfsattd di shield him from 
photographer 
When he eveiAta2ly is released-to house arrest,. Epstein.will 
have to e a.1..0 p.m, to '6 a.m.:curfew:Kanto 
pe ed contact with anyone wungerthan 18: and 
O1.e r own nor. possess pornographic or sexual materials 
at: are relevant to your deviant behavior/. theittdge said. 
+ 
Epstein will be allowed to leave home forwork. The New 
York-based money manager. told the judge he has formed 
the tot-for-p.mot.Floritla.Seience FollThclatIP.n. 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. 
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When he is release& from jail, there is a chance that Epitein 
will be forced tcrtriov.e. Self offendersare not allowed to live 
within 1.,000 feet of a school', parls.Or other areas where 
children may gather. No determination has been made as to 
whether Epstein's home compliet, but attorneys. said it 
likely does. 
Sea offenders also typicallyatistattend counseling sesslions. 
Belohlavek said that was waived for Epstein because his 
private psychiatrist is working' with him. The judge was 
skeptical but agreed to it. 
Epstein's legal woes don't end with MOnday's plea, The 
are four pending federal civil lawsuits. and one in s 
related to. his behavior. At least:one woman has su 
New York,. where.he owns a.$1,900-square- an 
mansion. 
"les validation of wharWoesa 
Miami .attomeyleffrey Henn 
victims in the federal 'Avis 
Ted LeopOld.represen 
state court. He sal 
add' "a few oth 
in 
attain 
I Caseti'said 
d represents the alleged 
aIm. Beach attorney 
ed victim in. a Civil suit in 
ates amending that lawsuit to 
'as well, 
In the crimin ate, police' went so far as to scow Epstein's 
trash a ticusurveillance at Palm Beach International 
here they watched for his private. jet to they 
know When.he was in town. They concluded that 
'paid girls $200 to $3.00 each after the massage 
sessions. 
"I'm like.a.Heidi. now 22, told Slice 
abouther efforts. in recruiting girts.for Epstein. 
Th'erewas probable cause to charge Epstein with unlawful 
sex acts with a Ennio,. arid lewd and lascivious molestation, 
police concluded. 
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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!graud jury 
rather than -directly charging him. 
Palm Beath Police Chief Michael Reiter wasfurimis 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 forind got a federal investigation. 
Epstein hired a phalanx of high-priced lawyers - Including 
Harvard law professor and author Alan Ders.1.19Writx - a 
public relations people who questionedReiter% go 
and the v,ictims' truthfulness. 
In addition to mansions in Palm Beach. an ttan, 
Epstein ownshomes in New Mexico. gin Islands, 
He's a ftettue-nttorittibittor to De- rty candidates-, 
lie also.donated $30 milliontgg ard n.2003. 
Former New York Gov. returned A 550,000 
campaign contribu pstein after his indictment, 
then resigned di mg:his own sex scandal. And the 
same Palm B Department that vigorously 
investigated returned his S90,000 donation for the 
parch rearms simulator. 
writer Eliot Kleinberg and forther.staffresearcher 
elle Quigley contributed to this story. 
t 
I 
. • 
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4 
The  Beach Post ,PalmREAL NEWS STARTS HERE 
Jeffrey Epstein: Scientist, 
stuntman, lstit slave' visit jailed 
tycoon 
• 
By LARRY / Palm Beach Post Staff Writer 
Petted Aug 13, 201 at 12:01 AM 
Updated Jul 16, 2019 at 4:54 PM 
Tycoon Jeffrey Epstein mingled with an eclectic MU of 
people, including beautiful young women, before he go 
into. trouble for paying: teenage:giils to give him s 
massages at his Paint Beach Mansion: 
Not Muth hat changed; even. thciugh.he • in a 
dorm at the Palm Beach County$lt 17-acre, 
967-bed stockade near-the fairgr. 
During his first menth.of t; Epstein was visited 
by the female assistant o, told polite, had escorted 
them. to the wpm. ton where theygave him 
naked massagec •ki
Also•treldting •' jail was .a youngwoman whom Epstein 
purpo scribed as his YugoslavianSeX Slate. 
wealthy financier 445:1 science word; also.has. been 
'sit d'by an expert on artificial intelligence, as well as a 
an 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 
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girls 3200 to.$300 in 2004 and 2005 for massages in hiS 
home. that sometimes included sexual touching, Palm Beach 
police said. 
His jail visitors injuly'lucluded: 
- 29, who some of the teen masseuses said 
phoned them when Epstein was in town and escorted them 
upon their arrivalat his:Palm Beach waterfront home town. 
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 
visitors iog. list.sa Manhattan home address.. 
Reached by telephone, she declined to discuss Epste' 
i
c 
- Nadia Marcirikova,- 23; whose family in av 
Epstein paid money to so that he could b • the 
United States to be his "sex slave;*tw iris tad 
police. One. girl told police that E cted 
Mareirikova and her to kiss a while he Wattled 
and masturbated. Another gaged in sex with. 
at Epste* j visited Epstein 
in jail four times.' e- lists her address as on the. 
Upper'East sidpp ar3hattan, not far from Epstein 's 
enormous a 
- Roge e  mp k, 62, founder of the Institute.fOr Learning 
ncest Northwestern University and au expert on 
al intelligence, paid. one visit to Epstein. Schank has 
tten numerous books owthat subject and has a doctorate 
degree from Yale Universityin linguistics. He'vms one of 19 
.people who applied to be president of Florida. Atlantic 
University in 2003. He became chief learning officer' at the 
online Trump University in 2005..Schanklisted his address 
as being in Stuart, and records show he also owns a,home 
in Lake Worth. 
I 
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Epstein has financed a number of scientists over the years, 
including Nobel Prize winners. He gave 830 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 -waked as a personal titter,. celebrity 
bodyguard and movie stuntman, according to -the leagues 
Web site. the •Nevaersey. resident visited. Epstein seven. 
times iti.july. 
Zinoviev, Sthank arid 
comme,nt, 
could not be tea 
Staff researcher Niels Heimeriks contribu s story:. 
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Teri fiarb.era, spokeswoman forthe Palm Beach 
Sheriffs'Office, confirmed that Epstein, 55) h 
work-release program since Oct. 10. 
Palm Beach Daily News 
Billionaire sex. offender "eaves 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 gpstein, 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. O 
"He works six days a week: Frid.ay. u ednesday 10 
a.m. to 10 p.m.: Barbera said vi He) works at his 
local West Palm Beach off ed on an active GPS 
system (he wears an ankl br Mr. Epstein hires a 
perm itdeputy, at h for his own security at his 
workplace autin he is outs 
Miami attorli fiey Herman represents siit young 
wome eye sued Epstein, claiming:be sexually abused. 
aim Beach home when they were minors. 
e an said he received a letter about the work-releaseO .
+ Ograra from the U.S. Attorney's Office within the pait 
few days. But Herman says Epstein haelbeen gut on,work-
release for several weeks beforelhe notification. 
"My clients expressed shockand disappointment," Herman 
said. "I find itincredible 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 
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arrangement is not unusual. 
lie goes to work every single day slid 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. 
04
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Palm Beach Post REAL NEWS STARTS HERE 
Woman want Epstein sex plea deal 
unsealed Posted Jul 1, 2008a112:01 AM 
Updated Oct Z 2019 at 223 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beath Pott June 10, 2009) 
Their attorneys will ask a judge to open Jeffrey Epstein's AS, 
records. 
When wealthy money manager Jeffrey Epstein of CH Beach pleaded guilty last year to proeurin 
prostitution, his case detoured around 
regarding the sealing of court documents.
At a plea conference on the 
lawyer and .a prosecutor 
that a deal Epstein h 
avoid cliarges s 
the hearing. 
Ands 
i t Flopriaima rulaes of. judicityalcoadmartinis.: mati,on, asuirweeplal baslicrules 
0
sealed,. 
thi.ngtkaacpoturttrQdmocurnpubleicnt.viheasw,beene or wesilail beso
require a judge to find a significant reason, to seal, such as 
protecting a trade secret dr a compelling gbvehtment 
interest. 
Yet no notification or reason occurred in Epsteiri!s case, 
according to court records. 
r 
tate rules 
es, a judge, a defense 
d of the bench and decided 
with federal prosecutors to 
ed, according to a transcript of 
t 
i 
• 
CA/Monberg-000187 
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Epstein's own attorneys,• in federal filings, have referred to 
his confidential deferred prosecution agreement with the 
U.S. attorney's office, struck in Septeniber 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, 
CatintyJudge Deborah Dale Pucillo. 
Epstein.now faces at least a dozerhcivil lawsuits in federal 
and state courts 'filed by young women who said they had 
sex with him and now are seeking dainages. 
Attorneys for some of those women want his agreemen 
with federal prosecutors unsealed and will ask Cir 
Jeffrey Colbath to do so today. 
It.is against public polity for these dettlft e have 
been sealed.and hidden• from public sc a member 
of tlieptiblic, E.\117..has a right to Ocuments 
unsealed"' wrote former Cirt e Berger) now in 
private practice and repres44ng of the women. 
The Palm Beach. s iviU ask Colbath to unseal the 
agreement..P tt Deanna.Shullmati will argue that 
the public ha i t to know the specifics of Epstein's OW 
Accor arious.media.accotints, Epstein movedin 
les that includecl:President Clinton, Donald Trump and 
Andrew. "International Moneyman of Mystery," 
ared a 2002 New York magazine profiltof Epstein.. 
Epstein, 50, is in. the Palm Beach Countratockade, serving 
an 1/1-month.sentenct.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 1.1 p.m., escorted by a 
deputy, said 'Palm Beach County. Sheriffs Office• 
spokeswoman Teri Barbera. 
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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. that 
Epstein. had entered a confidential agreement with 
attorney's office in which federal prosecutors 12r° 
pursuing charges against him if he pleaded state 
court. Putill0theii skid slieWatited te f the 
agreement filed in his case, and Gol e r c ncurred that 
hewantedit sealed. Belohlavek14kst off on it. 
The Florida Supreme Cot ias iessed "serious concern" 
and launched an all-o to sealing procedures 
across the state fo dia reports in 2006 of entire 
cases being sew disappearing from court records. 
"The public's tutional right of access to court records 
must re riviolate, and this court is fully committed to 
guar *ng.this right; justices wrote in their final report.. 
office on Tuesday referred any questions to 
oldberger, who declined to comment. Pucillo also has 
declined to comment. 
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The Palm Beach Pc•st REAL NEWS STARTS HERE 
Epstein secret pan with Feds 
reveals "highly mastiff" terms Posted Jun 10, 2009 at 12:01 AM 
Updated Oct 4, 2019 at9:23 AM 
(EDITOR'S NOTE: This story originally pubtisbe.d in lift 
Palm Beath Poston Septenibee 19, 21709) 
A secret non-prosecution agreement multimillionaire 
financier JeffreyEpstein struck with federal prose 
being called'ahighly unusual' by former federal pi-, rs 
and downright outrageous by attorneys now ese • rig 
young wornenwho:serviced him, 
AS2The deal reveals that the FBl and. S. orney's Office 
investigated hint for several fee - s, incluthil 
engaging minors iin CQMM e crimes are 
punishable by anywhe om years to life in prison. 
But federal prose) ked down and agreed to recall 
grand jury t poen Epstein pleaded guilty to 
prostitution- felonies in state.court; which he 
ultimat He received .arr 18-month jail sentence, of 
S eh h rued 13 months. 
C)he  .S. Attorney's Office ebb !agreed Mit to 601;040 of 
+ . pstein's possible co-conspirators: ==, 
In Lesley Grdff and Nadia .Martinkova. 
The deal was .negotiated in part by heavyweight New York 
criminal defense attorney Qerald Lefcourt, 
Unsealed on Friday after attorneys forsome of Epstein's 
victims and The Palm Beath Postsought its.release, it offers 
the firstpubliclook at the deal. Epstein's highfrpOWered legal 
counsel brokered on. his behalf. 
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Mark of Stuart, a former federal. prosecutor.,
described the. disparity in:potential sentences as Manual,:
but even more so :a priniiiion an attorney payment. 
The first draft of the agreement in September 1007 
required that Epstein pay an attorney --tapped by the 11,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 tithe 
AS,victims did not accept settlements.-- capped at S150,00O 
and instead pursued lawsuits. 
said it appears the government was 
balance the lesser sentence for Epstein:1i 
S150,000 for each victim. -I've never, 
like that in my life; he said. /es h' 
The deal does not say whe ., 
or totistilted before the d tl. - •5 ide. 
ring. 
ything 
s were contacted 
Attorney Brad dsJF.ort Lauderdale, who represents 
three of they, g. .en, believer that none of the 39 to 
40 woman d as victims in the federal investigation 
were tdldahead.bf time. said.his.elients received 
leeters m the U.S. Attorney's. Office months after the deal 
signed, assuring them Epstein would be prosecuted. 
'Never consulting thevictims is probably-the most 
outrageous aspect, of said. It taught them that 
someone with money can buy Iris 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 civillawsuits filed by the women, 
who are represented by a variety of attorneys. Jn many, the 
allegations are the same: that Epstein had a,predilection for 
teenage girls, identifiecipoor, vulnerable'ones and used 
1 
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other young women to lure them to his Palm Beach 
mansion. They walked away with between $200 and 
S11000. 
Forme'. titalit judge Bill Berger; also representing victims, 
called the agreementa "sweetheart deal." 
"Why was itso important for the government to make this 
dealt Berger asked. rhetorically: Ve have not yet had an 
honest explanation hyany public:official as to why itwas 
made .....:and why the victims were sold down the. river." 
Former federal prosecutor Ryon McCabe described the 
agreement is"very unorthodox:" Such agreements, h 
are. usually reserved for corporations, not individ 
/4 very, very rare. I've never seen or hear 
procedure that was setup here," said 
involvement in any Epstein iitigati 
o has no 
"He's essentially avoiding f ecutionbecausebe 
can afford to pay that e to help those victims 
review their cases..., rso has nOtnonoy,te couldn't 
be able to strike.4e3l, h is and avoid federal 
prosecution. 
The ba eal with federal prosecutors is all the more 
inwresei i light ciftlit legal powerhouses who have 
ed or. Epstein, including Harvard professor Alan 
O ee ... owitx and Bill Clinton investigator Kenneth Starr. 
+ . (court is a past president of theVational Association of 
-Criminal Defense Lawyers. 
Epstein'S local. defense attorney, ack Goldberger, issued a 
statement Friday saying he:had fought.the release of the 
sealed agreement to'protett 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 behind him. He is continuing:his:long-
standing history of science philanthropy." 
1 
i 
• 
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The investigation triggered tensions between police and 
prosecutors, with then-Palm I3each Chief Michael. Reqr 
saying is a May 2006 letter to then-State Attorney Bariy 
Krischer that the chief prosecutor should disqualify hiniselfi 
coMinue to find your qffice'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 ofwhat a 
many-million-dollar defense can accomplish,' Reiter told 
the Palm Beach. Daily News upon his retirement. 
46s 
CO S
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187 / 278 - Wednesday, January 27, 2010 
Edition: FINAL 
Section: LOCAL et BUSINESS 
Page: 3B. 
Source: By JANE MUSGRAVE Palm Beach P0st Staff Writer 
Dateline: WEST PALM BEACH 
JUDGE RULES EPSTEIN. ATTORNEYS CAN SUBPOENA ABORTION RECORDS 
In a decision that could spark a constitutional. showdown over privacy tights, g Tuesday gavelawyera representing multiMillionaire sex offender:Jeffrey- E the right to 
subpoena abortion records ftorinvotteri who are seeking millions in: the part-
tinte Palm Beach resident. 
Palm Beach County Circuit Judge. Donald Heide said the records c tild he p psteiii rebut 
the wornen's.claims that they suffered psychological ills after being id. give him
sexually-charged inessaget at his Paint Beach Marition.whe ere as young as 14. 
Hafele told Epstein's .attorneys they couldn't go on a fish' ion. The medical records, I he said, can't be.soughturitil the women are asked *he ave ever had an abortion, 
how many and. where. Further% be said, the records e madepublicand might not. ' 
be admissible during trial. 
But, he said, since the women cliim Epstein,, is r esponsible for their emotional 
distress, his attorneys can eicplete the. iinpa of a events. Medical records, Hafele said,
are a better source' f information than a rs memory. I Attorney Ltniis Silver, who tepriestrit Prat ential.Wornetes Health Center, a West Palm l 
! Beach clinic where abortions are. arced Hafelethathe was stepping on shaky 
constitutional grounds. . 1 "These records are protected: stitutional;right of privacy," he saidy.referring tothe
Florida Constitution.
After the hearing, Silvetcaid an ppeal Won't be necessary until. Epstein attorneys seek the 
.records. 
In another ruling e4ay,.Hafelealso said. hat videos from.depositions. in the state cases 
can't be releas bout a court order. The ruling. cameafter EpStein attorney Robert Critton 
complaine vi of Epstein being asked. whether'he had.an -"egg-shaped" penis 
beeline .Ocim sensation. It fiist.appeared on-The Palm. Beach Post Web site. 
Critton omey .Spencer Kuvin forreleasing it..Kuvin said it was public record. 
The began mounting after Epstein. agreed to plead guilty to two.state ;beiges: 
prowan minor for prostitution arid 'soliciting prostitution: He served. 13 months of an 18-
Mouth sentence As part of the deal brokered with fecler_al prosecutors, he agreed not to 
I, contest the accusations in the civil lawsuits. He can argue the women don't deserve the 
Millions they are seeking.
—[Email Redacted] 
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EFTA02735396

The Pihn each 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 et 10:51 AM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beath Post on March20, 2010) 
A purloined journal that is said to contain the 'faille. di 
"hundreds" of victims of convicted sex offender. Je 
Epstein could be used toreopen the investiga in 
multi-millionaire's appetite for teenage gi orney 
representing men of.the victims, said 
‘ New detailsabout dig contents o£ the journal were released 
this week when.Alfredo Ro who worked as a 
property manager fcirthe ath resident pleaded 
guilty to obstructio for lying to federal agents,
when asked if. reformation about.his former 
boss' crimin activi e later tried to. sell the journal he 
stole from Ep for $50,000 to an unidentified person, 
who afe uthotities, according to, court records.. 
art orthe plea agreement,. federal prosecutors said the 
urnal'contaiiis.infOrmatibri Material to the Epstein 
nvestigation, incjugling the names, of material witnesses 
aridadditional victims,' 
"Had the items been produced in response to the inquiries 
of state or federal authorities ... the materials would hate 
been presented to the federal grand jury," federal 
prosecutors wrote. 
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Instead, prosecutors short-circuited the grand jury 
investigation and. cut a deal with Epstein. They agreed hot 
to pursue federal charges ifhe didn't contest prostitution-
related felonies in state court. The. money:manager pleaded 
guilty injuly. 2008.to procuringa minor for prostitution. 
and soliCiting prostitution. He served .1.3 months of an. 18-
month sentence. 
Attorney Adam Horowitz, who represents seven of the 
roughly 18 Women who have filed civil suits:against 
Epstein, said the new information could trump the so-
called non-prosecution agreement. 
Tie multifaceted agreement, he said, deals only WI 
specific list.of victims that the U.S. Attorney's Offi 
about when it penned the deal in 2Ci071.1.fad al victims 
are listed in the journal Rodriguez stole, said, 
federal prosecutors could reopen the *ti on. \ 
It opens the door for further pis eutio he said. 
A 
knelt'
in additign.to.turping.a tit urnal to federal agents, 
Rodriguez told the is former boss was having 
sex with undera en he worked for him In 2004 
and 2005. H ad. s naked.giris, who looked likeminors,. 
in theppol o ins $8.6 million mansion. He had seen 
pornog, images of young girls on Epstein's computer, 
tdin o court records. 
°either Epstein's criminal defense attorney;:lack 
Goldberger, riot attorney Robert Ctittoni who represents 
Epstein in the civil lawsuits, couldbe reached. Federal 
prosecutors have consistently declined comment. 
The wording of the controversialegreement is unclear..lt 
sayafederalprosecutOrs would provide .Epstein's attorneys 
"with a. list ofindivicluals whom it has identified:as yictims," 
.Miami attorney Robert josefsberg was appointed to
t 
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EFTA02735398

represent any of the victims on the list who wanted to 
ti pursue Epstein in civil court As !Art 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 courtpapers to get the journal 
that Rodriguez stole. 'lt's another piece of evidence that 
shows our clients were at EpsteirA mansion,' he said. 
Rodriguez told'prosetutort he didn't turn over the jo 
when both.FBI and pain:II:leach polite zslted.for it 
he wanted money for it. He also said.he.was 
would make hito uclisappear.a.The infor • told 
investigators, was his "insurance poli 
Helaces a maximum 20'yezrs igjQnalten he is 
sentenced on June 18. 
jane_inusgtave@pb 
t 
CA/Aronbem-000197 
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EFTA02735399

r  ale Palm each Post REAL NEWS. STARTS HERE 
Epstein paidthree women $5.5 million to end underage-
sex lawsuits fly Jane:Mtiagraige 
Posted Ca 3, 2017 at 12:01 AM 
Updated Oct 4, 2017 at 12:46 AM 
:Ending years of speculation about how Muth Palm Beach billionaire Jeffs' in paid yOUng 
women whq claimed he used them as sertoys, court documents filed las wee show he shelled 
out $5.5 million to settle lawsuits with three of more than two dozen teens who sued'bim. 
N." 
Responding to requests from Epstein's attorneys in a compl = it that was spawned by the 
sex scandal, attorney said:the polititall 64-year-old tthivicted sex 
offender paid more than S 1, maim to each of the thgg. o Edwards represented. 
Identified in court papers only by their initial nyms ;because of the nature of the 
allegations.and their youthful.ages, L.M. d S million, E.W. $2 million and Jane Doe 
S2.5 million, said of the settl negotiated with Epstein to end the lawsuits. •ere—rgeie 
Jack Goldberger, one of Epste defense. attorneys, on Tuesday declined comment on 
the revelations, citing confide agreementrtharwere part of the settlements. For the 
.tame=, he decline say tv ether Epstein paid similar anti:aunts to settle roughly two 
dozen lawsuits filedJby of r Dung women against Epstein, claiming hepaid, them for sex Mr. revere. 
when some wereyoung as 14 years.old. 
Attorney la, who is representing was compelled to divulge 
the co ' 
, said his client+ 
I settlements to answer questions posed by'Epstein't• attorneys. "Brilliant move 
on their p ," he said. 
Even if Epstein's attorneys hadn'topened the door, Scarpla 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 a11.2 billion Ponzi scheme. 
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EFTA02735400

successful law firm by forging the names of federal judges and others to persuade 
had negotiated, settlements in lawsuits against high.profile people. Investors tol ‘ 
could get a cut of the cash. 
The revelations of the settlements came as part of an ongoing.lawstiitthat started as a dispute 
between Epstein and Rothstein, both billionaires. 
A year after Epstein in 200gpleadecl guilty to-solicitation of prostitution. and procuring a 
minor for prostitution, he sued Rothstein and claiming they trumped up the 
allegations bisexual indlestation to-perpetuate the Ponzi scheme. 
Rothstein was sentenced to 50 years in prison in 2010 after admitting hehad bulk his wildly 
stors he 
ey 
One of the high-profile people Rothstein used to lure investors was .ccording to a 
lawsuit Vest Palm Beach attorney Robert Critton filed on Epstein's According to the 
lawsuit, Rothstein told investors. Epstein, a money manager, had -Ned to settle, the lawsuits 
with the teens for S200 million — a claim Ctitton descri s "a complete fabrication." 
After Epstein dropped the lawsuit in 2012; Edwa t eJtlte tables on him. accused 
Epstein of filing thelawsuit malicitmilym p r representing the young women. 
Although was a partner in Rothst defunct firm, Scatolaclaiins Epstein had 
no evidence was involved in scheme. Federal prosecutors successfully 
charged other attorneys and mem firm, but was never implicated, Scarola 
said in the malicious prosecuti 
The revelations about th *hey Epstein paid to three of the young woman came last:week in 
documents filed four g uesday -in preparation far a Decernhertrial on the lawsuit. ? s ,
Attonry a addad Coleman) who represents. Epstein; on Tuesday sought a delay of the 
trial, itl p 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. 
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Pointing out Epsteip's enormous wealth aritthis private jet, Paint 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 front Epstein, to shore up her claims. 
Still,,Hatele.gave Coleman extra.time to respond to various motions that he will have to decide 
before the case goes to trial:. 
Despite Statolis insistence tha W. :nothing to .do with.Rothstein's P0 erne, 
Coleman. said theevidenceln_diCates Otherwise. Why else would he. try to de 
Tinton 
s 
wennoWn friends, such as now President Donald Trump, former Presi Hilton and 
illusionist David Copperfield, she asked. He used the celebrities as a d. 
'The Epstein cases were used to .fieece money and defraud inv said. 
Edward's:malicious prosecution case has been diffieultio ibecause both.Epstein and 
have refused to answer questions: As he di lawstiits;Epstein has invoked 
his.Fifth.Amendment right against Self-incritnin .questionedby Scarola... 
has claimed that much of the information Ep ' 'xi ng is protected by attorney-client c
privilege,. 
The malicious prosecution lawsuit 
against Epstein. Edwa 
the federal Crime Victims Righ 
Epstein. 
o hotly-contestedlawsuitsthat continue to pit 
suing the LILL attorney's office, claiming it violated 
when it 'negotiated a.nom-prosectition agreement with 
Only after fede secut rs agreed to drop their investigation of Epstein, did he agree to 
plead guiltyl thtion.charges in Palm Beach. County Circuit .Court, In federal court 
records, p claim one of the key reasons they agreed to drop their case was Epstein's 
agree tap lawsuits filed against him.by dozens of his underage victims, 
CA/Atonberci-000200 
FILED: PALM BEACH COUNTY, FL, ABRUZZO, CLERIC 3/27/2023 2:57:43 PM 
EFTA02735402

Palm Beach Daily News 
Judge rules Ms' agreement with 
Jeffrey Epstet pot violated teen 
victims' rights By Jane Musgrave 
Postated Sep 17, 2019 at 
ed Oct 8, 2019 
at1:62 PM 
2:31 PM 
(EDITOR'S NOTE: nig story originally published in The4•Assa\' 
4 
Upd
Palm Sega Post on ?Omar)! 4 2010) 
C) .'
Federal prosecutors violated the rights of Jeffrey E C tein's 
teenage victims by failing to reveal they had dropped plans 
to prosecute the billionaire on dozens :o 
connection with the girls' claims 
at hit Palm Beach mansion,.U:S 
Marra ruled on.Thursday. 
(sl yIna blistering 33-pa 
methodically de 
prosecutors t 
young worn 
they w as young as 14. e:l ir
arges in 
em for sex 
dge Kenneth 
ng arra. Meticulously and 
umerous steps federal, 
the agreement from. more than 40 
airn.Epstein paid them. for sex when. 
l :: goveroment'spent ontolclhours negotiating the 
and implications. ofthe NPA with Epstein's attorneys,. 
ant information was shared with the victims,7.Marra 
wroteet histead,:the victims weretold to.be.'patient! while 
the investigation proceeded." 
By then, it was too late. A deal had already been. ut 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 netted money manager 
who counts Presidents Donald Trump and Bill Clinton. 
among his friends. 
CA/Aronbegt-000201 
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EFTA02735403

Prosecutors failure to alert the young women about the 
deal violateC1 the Crime Victim? Rights Act, Marra ruled. 
-At a bare minimum the (act) respired the government; to 
inform (the young women) that it intended to enter i* an 
agreement not. o prosecute Epstein,? he. wrote. 
+ "We are.treading on virgin ground, to use what is prObably 
an inappropriate. phrase in this situation," he said. 
Still, Marra said he wasn't second-guessing prosecutors 
decision not to pursue Epstein on.federal.c.harges if he 
pleacletiguilty tominorstate prostitution charges. and 
agteed.to cOtripensate his victims for the trauma he-caused. 
"The court isnot:Whig that the decision not to prosecute 
was improper," Marra wrote: `The court is simply ruli 
that; under the facts of this case, there was a violation. 
the CVRA.".
U Further, he made no: decision.ahout wha dy 
should be. He gave prosecutors and a presenting 
the y.oungw0znert.15 days to inee ct oW to unravel 
the complex. legal.web that ging over Epstein 
and his young victims for i e a decade. 
The c.hances. an ac reached are slim, said 
attorneyfack St is representing the two Jane 
Does Who ct Ilan e prosecutors' actions, 
Furthe said, there is no road map to follow, The 
ly+ttsuit orney filed on behalf of the "MO 
entified young women., claiiningpintetutbil violated 
e edgral ant, is. unique, he 
Scarola said he and will ask that the non:-
prosecution agreement be thrown out:That would open 
the pnssibilitythat the long-shelved federal indictment 
could be dusted offend filed against rhe 66-yen -old • 
Epstein, who spends most of his time on .a private island he 
owns in thell..5. Virgin Islands. 
f 
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"I don't seethe government 'conceding to thatremedy,": 
Scarola admitted. Further, he said, it is likely:Epstein. will be 
allowed to weigh in.. Miami attorrity'Roy Slack years ago 
filed papers asking to intervene on Epstein's behalf. 
The U.S. Attorney's  Office said it wouldn't continent 
Marra's ruling. Neither Black .norNew.. York City attorney 
Jay Lefkowitz,who led efforts to. bury the federal 
indictment, responded to ernaile or phone tails for 
continent. WestPalm Beach attorney Jack Goldberger, who 
represents •Epetein,:ajw didn't respond. 
Scarola said it is likely Epstein 'S stamstudded legal team 
argue that Epstein fully complied with the .terms of 
agreement he made in 2007 with federal prosecut 
therefore the agreement can't beundone, 
'SIAs he promised,. Epstein pleaded gull : 8 w state 
charges of soliciting a minor'for p and soliciting 
prostitution. He served 18- mo an 18-month jail term 
in a vacant wing of the co de that he was allowed 
to leave 12 hours a da eek. 4 
Further, as ag settlements to the young women 
who sued h' e settlements were confidential, 
court records heinidthree women a total of $5.5 
turn, federal prosecutors held up their end of the 
;gain. 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. 
CA/Aronbem-000203 FILED: PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
EFTA02735405

Even if Marra agrees tb toss dutthemon-prosecution ! 
agreement, Scarola conceded that doesn't mean Epstein; will 
face federal charges. 
"The contact can be set asideAnd:the federal governmnt 
ari attempt to enter into the same ,agreetottehe 
Tacceptthe 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 ptosecuton May have had good teasbh not 
to pursue• Epstein. 'There pay be a reasonable explanation 
but we don't:know whatthatreason may have' been," h
said. 
In court papers) federal prosecutor's have said rat - Cri of 
the young women were• afraid to cross•tbe I, 
politically connected money'manager. refusedto 
testify against hint. 
In other cases; they said, tli hanged. their 'stories:: 
Jane Doe 2, who .is tryin non-prosecution 
agreement thrown y described Epstein as 'an 
awesome -man" osecutors she hoped "nothing 
happens` to e she later agreed to testify against 
Epstein„pr said they feared Epstein's attorneys 
would t r words to destroy her if she ever took the 
Ota,. however, said the yogrtg..W4M.414 comments didn't 
can she wasn't entitled to know about the prosecutors' 
plans to drop the charges. "mete is no dispute that:Epstein 
sexually abused Jane Doe 2 while she wan. minor? he 
wrote: 'Therefore, regardless of her:comments to the 
proSetutot, she was a -victim!' 
Before: he case is finally resolved, Scarola predicted that "a 
lot of people.are going to have to answer a lot of questions." 
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EFTA02735406

In his ruling, Marra detailed whatappeared 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 200Y breiktast meeting 
between Acosta, who.is now US. labor secretary;. and 
Lefkowitz shortly. after the non-prosecution•agreeinent was 
inked, 
After the meeting, Lefkowitz sent Acosta .a note than 
.him for "the -commitment you made to me duringo 
October 12 meetingin which you assured me that 
Office weuld not .., contaCtany of the Men 
individuals, potential witnesses, or pote 
and their respettiVe counsel in this 
Mutt quotedan equally pleas 
County State Attorney.Ba 
Attorney Villaf 
Epsteiti's Case. t 
reasontl won' .. CI
after the non ros • 
to en-Palm 5eaCh 
r sent to Assistant U.S. 
as the lead prosecutor in 
get this worked out for 
Ong," •Kriseher wrote, shortly 
ion agreement was signed. "After this 
itresol ettl wo love to. buy you a tupit Starbutks and 
have a c sation.' 
f the notes that were exchanged dealtwith 
osecutors' 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 tart we- have a conference call to discuss. 
what I may disclose to ... the girls regarding. the 
Agreement," she asked. 
CA/Aronbem-000205 FILED: PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
EFTA02735407

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. 
Ftirther;he noted, that when and his two young 
clients:asked.for information, they were repeatedly misled: 
"The.CRVA. was designed to ptOtettcrictirhe tight and 
ensure their involvement in the criminal justice process; 
Marra wrote. "When the government gives information to 
vittiint it Cubit& be misleading.' 
Ultimately; the terms of the non-protectition agree 
were revealed only after and attorneys fo 
press successfully sued to make them public. 
[Email Redacted] 
iS )@pbpeourts 
ONAtonberg-000206 
FILED: PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 
EFTA02735408

e 
761278 Tuesday; July 9, 20.19 
Edition: Final 
Section: A Section 
Page: 1A 
Source: By Jane Musgrave, The Palm Beach Post 
,Epstein indicted on sex charges 
Part-time Palm Beaches pleads not guilty to se 
trafficking, conspiracy charges in :frderal co 
Manhattan. 0 Dressed in a.blue prison jumpsuit, billionaire Jeffrey Epstein on Md ayjleadednot guilty 
to charges accusing hinTof creating a vast network olgirls as 
for his sexual pleasure. at his homes in Palm Beach.and 
The 66-year-old money manager's appearance ;in US. D t in New York City 
capped more than adetade of recriminations by young e. and their attomeys.who 
claimed Epstein used his money and political, influence tot ,old federal prosecution. 
N ti'Epstein's attorney Reid Weingarten dismissed e. .tcoffnt indictment on sex trafficking \ 
charges as "essentially a dower" of allegations t . . ded Epstein in tfie..Falm Beach 
County Tail for 13 Monthtnicirt than a decade ago 
:However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta Agreed to 
shelve a.53-page federal indictinen fter Epstein agreed to plead guilty to two state 
prostitution cherget; -prosecuto )cork indicated they aren't willing. to dettl..Apostalt 
nowil.S. labor secretary. 
"The alleged behavior ihock ijhe c gionce," New York City U.S. Attorney Geoffrey 
Berman said at a 
morning news contemn d while the charged conduct is 'from a number of years ago; it 
is still profoundly " i.po t omany. of the alleged victims, now young women. They 
deserve their court,. 
At a .detenti scheduled forMonday, Berman said he will ask a.federal judge to 
keep Epst until he is tried on charges of sex trafficking and conspiracy to 
commit i Epstein paid dozens of'young women to giVe him nude massages 
tha led to sex, he said.
Iftonvi of explOi ' zens of young Women, including many Palm Beach CoUntygirls 
who were•stodents at PaimBeach 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 protecutiom 
4 that he exploded 
CA/Aronbegt000207 
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EFTA02735409

"We think Ite's asignificant flight.ritk," Berman said of themati who ferried Britain's Prince 
Andrew, actor Kevin Spacey, famed Harvard lawprofessorAlartDersh0witz and former 
President Bill Clinton on his jet, dubbedthe.Lolita Express. 
Berman's hard-line stance was. welcomed by young womep who for years have. been told that 
Epsteincouldn'the touched because Acosta signed off on the nonprOtectitiOn agreement, 
promising not to charge Epstein in federal court. 
Former Palm Beach County resident Virginia Guiffre, wha has accused Epstein of turning. 
her into his sex slave and forcing her to have sex with others, includingaershowitz and, 
Prince Andrew, praised Berman.. He showed the case ig "being taken• in a Set-ions " she. 
told the Associated Pres&DershOwitz has vehemently denied Gates claims. 
New York prosecutors were able to ignOre the controversial nonprosecution a 
because it contained some significant.fine print, said former federal Judge Pelf ; who 
for years has foughtto get the agreement ihrown.Out. It saya.orily that ho101l  be 
filed.against Epstein in South Florida, he said. 
Berman agreed. "Thgt agreement only binds, by its terns, only bin the eft District of 
Florida," he said. "The Southern District of New Yorkis mot bound agreement and 
wasn't a signatory of it." 
That Means the sordid allegations that have been leveled for years are now part of 
a federal indictment, 
Contrary toEpstein'S claims, he.kneW the women w his homes. in New York and. 
Palm Beach. were minors because they old him tr a cording to the indietthent. 
Epstein preyed.owyoung girls because he kne "vulnerable to exploitation;" 
prosecutors added. 
As partOf a carefully. orchestrated sex f teiiTor his associates would call girls while 
he was in New York so they would labl or sex once he returned to Palm. Beach, the 
indictment says. The-employees.w d. They were identified only as. "Employee-I," 
"Employee-2'` and "Employee-3 
TOensure he had a steady.str oI dng girls, Epsteihwould turn some victims into 
recruiters.. He would pay the_ o b pg new girls to his home on El Brill0 Way along the 
Intracoastal Waterway 'n Palm ach or to his palatial townhouse on New York's Upper East 
Side. 
"This Allowed E in to ease artever-expanding web of new Victims," Bermansaid: 
In both New S' d Palm Beach, the lurid operation was similar. Unidentified employees. 
Of Epstein' d rt the teens into a room. They weretold to take off all or most of their 
cloth:es ingthe naketbillionaire massages, according to the indictment. 
".Epstein.  so typicallymastutbate during these encounters, ask victims tatouch him 
whi bated, and touch victims' genitals With,bia hands or with-sex %Ws?" the 
ifidictin t.says. 
As part of the criminal compilint,,prosecutors are asking thatEpstein be forced. to turn over 
his multhriillion-d011ar townhouse on East 71st Street. The complaint does not seek forfeiture 
of Epstein's house in Palm Beach: 
Whileheartened that Epstein how fadts serious criminal charges in New York, Cassell said 
he would continue to push a West Palm Beach-based federal fudge to throw out the 
nonprosectition agreement that Acosta. forgedwith Epstein's.star-studdeti legal team. 
CA/Aronbem7000208 
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'U.S. District JUdge:Kenenth Marta 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 taketo redress that wrong: 
Cassell. insisted Epstein should face charges in federal court in West Paint Beach. "Florida 
victims deserve justicein Florida said Cassell, who is. working on behalf ofEpstein's. 
Wain's: with attOrneya NM and Jack Sdaitla. 
.Silice it's likely Florida women will get: to testify against.Ep.stein_in New York, Scarola said. 
he's not focused on whether Epstein will face charges here. Instead,. he said he wan o know 
how and why the agreement was reached. 
"There's been no explanation as to hot* a deal like. this could have: been cut an 
federal government could have been involved in a conspiracy to violate feide ;" Scarola 
said of hit interest in continuing the legil battle. over the nonprosecution 
When Acosta. greed to drop the federal investigation, Epstein in 2008.pl ilty to two 
prostitution charges and.Served 13. Months of an 18-month sentence n a va t wing of the 
Palm Beach Countyjail.- a cell he' was. allowed to leave 12 hours a days a week. He 
was: also .fOrced to register as a sex offender and settle civil I more  30 young 
women filed against him. 
Rep. Lois Frankel, b-Weat:Palm Beach, said she. lgaintereat in finding out 
how the agreement tame label' am especially mo in why Epstein got the deal 
he. got;" Frankelsaid. "We need to know why he t., uch an easy sentence, 
'While she has asked. the House Oversight Co to investigate Acosta, Frankel said' he 
Is not sure that will happen, "It just seem t a travesty that this guy gotoffthe 
way he did and, without prejudging it, le h a roper tourt.case," Frankel said.. 
Former Palm Beach POlice Chief Mic was inflamed M2000 when then-State 
Attorney Barry Kriseherrefuse.d to. tein with serious crimes: Reiter look the 
'information his officers had ga dozens ofEpstein's victims to Acosta; believing 
he would prosecuteEpstein. 
Reiter said he was heartened t 1 years later, Epstein wilt -finally face justice. 
"Thankfully, U. S. Atto ey Be an and the other authorities in New York.have the good 
judgment to investigate secure Epstein in the waythat should have qccurredin 
Florida over a d e eiter said iftastatement. 
And, Scarola ere are signals that Berman's jnvestigatign is far from over. 
Bemtari dec wer questions about whether others, such as.Egsteires high-powered 
friends? o arged. He brushed off. questions, about. he,significance that the 
inv.estiga being handled by the Public Corruption Unit. 
on Saturday were arresting Epstein aboard his private jet at: the Teterboro 
Airport i ew Jersey. after returning: front Paris, other officers were searching his New-York 
City townhouse. Agents seized nude photos of yma% girls who appeared tabe,minora, 
Berman said.. 
He said: his focus was on finding more women who were exploited. and abused by Epstein. 
Turning to a poster,. detailingthe .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." 
I 
CA/Aronberg-000209 
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EFTA02735411

"If you believe you are a victim of this.man, JeffreyEpstein, we want to.haat from you," 
Berman said. A special number, 1.400-OALLFM,• will link victims of anthorities. 
Bill Sweeney, assistant director of the FBI's New York office, said after years of being 
ignored by federal agents, the victims' voico will be beard. 
"The Jeffrey Epstein matter is No. 1 on the major case list in the.country," Sweeney said. 
Tinning to address Epstein's victims directly, he said: "Your bravery may empower others to 
speak out against crimes against them." 
[Email Redacted] 
• • 
CA/Aronbera-000210 
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