Court Records
Filing # 132529617 E-Filed 0412021 10:20:22 AM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC,
Publisher of THE PALM BEACH POST,
Plaintiff
v. CASE NO.: 2019-CA-0146$I
DIVISION: AG
DAVE ARONBERG, as State Attorney of
Palm Beach County, Florida; SHARON R.
BOCK, as Clerk and Comptroller of Palm
Beach County, Florida.
Defendants.
Th
AMENDED MEMORANDUM OF LAW EN SUPPORT OF DEFENDANT DAVE
ARONBERG'S AMENDED MOTION FOR ATTORNEYS' FEES
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, (the
"State Attorney"), by and through counsel below, hereby submits the following Amended
Memorandum of Law in Support of his Amended Motion for Attorneys' Fees, as follows:
TIMELINE & BACKGROUND
I. On November I 9, Plaintiff filed a Complaint against the State Attorney and
Clerk seeking to create n private right of action under Fla. Stat. § 905.27, in the interest of
"furthering justice", to compel disclosure of the testimony, minutes, and other evidence presented
in 2006 to dep Beach County grand jury, as to Jeffrey Epstein, (the "Requested Materials").
2. On November 26, 2019, the State Attorney and his office received an engagement
letter and attorney-client contract from the undersigned, which was later executed. Pef.Ex.A-2).
Party JOINT
IDu. J29 EVti.j21 ,• rim 9/1122721
Joint Exhibit
J29 • 2
CA/Aronberg-001133 ABRUZIO CLERK I
UIT COURT
FILED: PALM BEACH COUNTY, Ft., OSEPH ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735689
[Deftx.Ar5, p. 12].
3. On December 6, 2019, the State Attorney filed his Motion to Dismiss, which put
Plaintiff on notice that "Defendant Aronberg is not in custody or control of the (Requested
Materials] and is therefore not a proper party to this action." [Def.Ex.A-3].
4. On January (7,2020; Plaintiff filed its First Amended Cisniplaint, which in addition
to its original claim under § 905.27 FIa. Stat.i.("Count II"), added a Claim for DeelaittO Relief,
("Count 1"), that sought an order declaring that.* State Attorney and the Cler e and
release the'Requested Materials. [DelEx.A-4].
An )5. On January 24, 2020, the State Attorney filed an t 1 of the First
Amended. Complaint and a Motion to Dismiss 'Count EJ, which a ' p Plaintiff than:
Defendant Alt:berg and the Office of the State Atto - Fijiemith Judicial
Circuit are not in custody or control of the reco herein, and therefore
Defendant Aronberg is not a proper parry io th fact, Defendant, Sharon
R. Rock as Clerk and Comptroller of P e, h nay, Florida, admits that it
is the custodian in possession of the clo; hat are the subject of this action.
( S
6. On June 3, 2020; C arx held a hearing on the State Attorney's and
Clerk's Motions to Dismiss C f.Ex.A-6].
7. On June 8, 202 , Court entered its Order Granting Defendants' Motions to
Dismiss Count I) o Plai First Amended Complaint with Prejudice, leaving only Plaintiffs
Count seeki toty relief. [Def:Ex.A-7].
ediatety thereafter, Plaintiff was served with a demand, pursuant to § 57.105
Fla. St to voluntarily dismiss/withdraw the First Amended Complaint and the claim's against
the State Attorney, along with a Motion for Attorneys' Fees ("§ 57:105 Demand"). [Del.ExA,8].
2
CAthitifire301 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735690
•
9. In serving his § 57.105 Demand, the State Attorney properly put Plaintiff on notice
that he would seek sanctions by filing the § 57.105 Motion for Attorneys' Fees if Plaintiff failed
to dismiss the remainder of the First Amended Complaint within 21 days.
10. On June 23, 2020, Plaintiff's counsel sent a response to the § 57.105 Demand
refusing to withdraw the remainder of the First Amended Complaint. [DetEx.A-9].
II. After receiving Plaintiff's response and waiting the requisite "21 days:after service
of the motion," the State Attorney's § 57.105 Motion for Attorneys' Fees was_fuled With the Court
on July 1, 2020, ("First Motion for Attorneys' Fees"). [DelEx.A-10].
12. On August. 18, 2020, the State Attorney filed his Motion for Summary Judgment,
[DelEx.A-11], which includes an Affidavit made by the State Attorney. [Def.Ex.A-121.
13. On October 21, 2020, Plaintiff filed its Notice. of Dropping the State Attorney,
pursuant to Rule 1.250(b), Fla.R.Civ.P. [DelEx.Ar 13].
14. On November 9, 2020, the State Attorney filed his Amended Motion for Attorneys'
Fees, ("Amended Motion"), pursuant to § 57105, Fla.. Stat., seeking attorneys' fees in the amount
of S19,975.00, plus a multiplier -Of 2. [Def.Ex.A-I 4].
I. LEGAL STANDARD
As follows, Florid Statutes § 57.105(1) authorizes awards of attorneys' fees as sanctions:
I
'i-
1 Upon the court's initiative or motion of any party, the court shall atvwd a
nabie attorney's fee, including prejudgment interest, to be paid to the
prevailing party in equal amounts by the losing party and the losing party's attorney
on any claim or defense at any time during a civil proceeding or action in which
the court finds that the losing party or the losing party's attorney knew or should
have known that a claim or defense when initially presented to the court or at any
time before trial:
(a) Was not supported by the material facts necessary to establish the
claim or defense; or
(b) Would not be supported by the application of then-existing law to
those material facts.
3
cAtAropmpl ALitaa M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735691
•
"Section 57.105 does not require a finding of frivolousness to justify sanctions, but only a
finding that the claim lacked a basis in fact or law" and "does not require a party to show complete
absence of a justiciable issue of fact or law." County Conservation Alliance v.
County, 73 So. 3d 856, 865 (Fla. 1st DCA 2011) (finding that "Courts are not at liberty to disregard
the legislative Mandate that courts shall impose sanctions in cases without foundation in material
fact or law. The word "shall" in § 57.105, Fla. Stat., evidences the legislative intent to a
mandator) penalty to discourage baseless claims, by placing a price tag on_losilig parties who
engage in these activities. Section 57.105 expressly states courts "shall"' assess attorney's fees for
bringing, or failing to dismiss, baseless claims or defenses.").
In deterMinirig an award of sanctions under § 57105, the SI court's findings "must be
based on substantial competent evidence" and the trial court "lutist make an inquiry into what the
losing party knew or should have known during-the fact-establishment process, both before and
after the suit was filed." See Trust Mong., LLC c. Ferlanti, 193 So. 3d 997 (Fla. 4th DCA 2016).
II. THE STATE ATTORNEY'S AMENDED MOTION IS NEITHER IN VIOLATION
OF THE 2I -DAY SAFE HARBOR PROVISION IN FLA. STAT. § 57.105(4), NOR
WAS THE AMENDED MOTION MOOT UPON FILING.
"Section 57.105(4), Florida Statutes creates an opportunity to avoid the sanction of
attorney's fees by c tine period for withdrawal or amendment of meritless allegations and
claims." Day' son, 268 So. 3d 762, 769 (Fla. 4th DCA 2019). Specifically, the relevant
portion e states:
motion by a party seeking sanctions under this section must be served but may
not be filed with or presented to the court unless, within 21 days after service of the
motion, the challenged paper, claim, defense, contention, allegation, or denial is not
withdrawn or appropriately corrected.
Fla. Stat. § 57.105(4). Likewise, "Mlle primary purpose of the safe harbor provision of §
57.105(4), Fla. Stat., is to provide the recipient of a motion for an award of costs and attorney's
4
CA/AroptLe) laera701.1.a6 PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735692
• •
fees with notice and the opportunity to withdraw or abandon a frivolous claim before sanctions are
sought." MC Liberty &press, Inc. v. All Points Servs., 252 So. 3d 397, 404 (Fla. 3d DCA 2018).
Here, Plaintiff contends that the State Attorney "did not serve his Amended Motion at any
time before filing it, and thus failed to comply with the 2I -day notice provision...." [See, Plaintiff's
Memorandum of Law in Response to Ai-tient:led Motion for Attorneys' Fees, p.6.). Plaintiff claims
that for this reason the Amended Motion should be denied and cites in support, Lego V:=Kame By
\
Design, LW, 120 So. 3d 73, 75 (Fla. 4th DCA 2013) (holding that "if a party,files a subsequent
or amended motion for sanctions under section 57.105 and raises an argument that was not raised
in the original motion for section 57.105 sanctions, the subsequent motion must independently
comply with the twenty-one-day `safe harbor' provision of Section 57.105(4).").
7 I
The instant case is distinguishable from Lagos. In Lagnitecause the case was still active
when the plaintiff's amended motion for attorneys' fees was filed and was not served on the
defendant in compliance with the 21 -day sa or provision before it was filed with the court,
pursuant to § 57.105, the defendant eit to notice and an opportunity to change its position
and withdraw its offending mo on b being subject to sanctions.
Here, despite Plaintiff's ion to drop the State Attorney as a party, the Florida Rules of
the dUr of Florida arc clear: Because Rule 1:250 specifies that a party is
et provided for voluntary dismissal in Rule 1.420(aX1)," dropping a party
as an adjudication on the merits." See, Siboni v. 52 So. 3d 779, 781
Civil Procedure
dropped "in
therefor
1(Fla. ft DCA 2010); Rule 1.420(a)( I) Fla. R. Civ. P. Notably, Plaintiff admits that "the entire
Notably, the court in Lago v. Kame By Design, LLC, 120 So. 3d 73, 75 (Fla. 4th DCA 2013),
despite finding that the plaintiff's amended motion for attorneys' fees was improper, the trial court
was instructed to rule as to the plaintiff's original motion for anomeys' fees as it was properly
served and filed pursuant to § 57.105, Ha. Stat.
5
CA/ArOplin5991 AtLaK M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735693
• •
action, which necessarily included Count 1 [of the First Amended Complaint], was dismissed as to
[the State Attorney] on October 21, 2020. [See, Plaintiff's Memorandum of Law in Response to
Amended Motion for Attorneys' Fees, p.7.]. Nonetheless, as a result of dropping the State Attorney
from the case, Plaintiff not only effectively made an admission that its allegations against the State
Attorney have no basis in fact or law, but also concluded the case as to the State Attgrtiey and
thereby became the losing party in this action.
Consequently, unlike the fact scenario and timeline in Lago, C becau 5 If concluded
the instant litigation by dropping the State Attorney from the actionit e filing of the
Amended Motion, it was impossible to give Plaintiff an opporttutity to rescind and withdraw its
7 — ,',
Count 1 of the First Amended Complaint since Plaintiff hectelre cione so, thus there can be.no -\:ity I
"c2H .NV
violation of the 21-day safe harbor provision set fortliin rte./stet. § 57.105(4). Based on the \'`..
foregoing, the State Attorney's Amended Motiondoes sot violate the 21-day safe harbor provision - ,
because Plaintiff dropped him from the action prior to the filing of the Amended Motion, and
therefore Plaintiff was not prejudiced by thg filing of the Amended Motion. Accordingly, as further
\--/ set forth below, Plaintiff has e osedcipelf to § 57.105 attorneys' fees as sanctions for failing to ,
drop the State Attorney as a pa Rd ithin the 21-day safe harbor period.
Additionall , the is othing improper about the First Motion for Attorneys' Fees or the
Amended M no argument or authority has been offered by Plaintiff that would make the
Amend moot. In fact, amended motions for attorneys' fees are filed consistently as a
matter course to include the entirety of fees in a lawsuit. Here, the State Attorney's total legal
fees were able to be calculated and submitted at the time of filing the Amended Motion.
Finally, despite Plaintiff's assertion that "[a] motion, for sanctions must be supported by
the record evidence at the time it is filed" [and] "[b]ecause the First Motion was not so supported,
6
CA/Aroplieffi-091AL 1.aa BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735694
•
it fails under the [S]tatute", Plaintiff has failed to provide any supporting authority and there is no
statutory requirement or language in § 57.105 that supporting record evidence must exist to
properly serve a § 57.105 demand and motion for attorneys' fees. [See, Plaintiff's Memorandum
of Law in Response to Amended Motion for Attorneys' Fees, p.8.]. "The central purpose of §
57.105, Fla. Stat., is, and always has been, to deter meritless filings and thus strealttline the
administration and procedure of the courts." v. Bailynson, 268 So. 3d 762j894 la. 4th
DCA 2019). In this vein, a § 57.105 demand and accompanying motion fore fees can be
filed at any time after a lawsuit is initiated, even directly in response t he ' of a complaint, c
regardless of whether any record evidence exists in support of the 57. OS demand.
Consequently, the foregoing indicates that the State First Motion for Attorney's
Fees, as served and filed, is sufficient under § 57.105 to [Ions from Plaintiff for its failure
to drop the State Attorney from the instant lawsdiC4'n the 21-day safe harbor provision after
being notified why its First Amended Coompplat had no basis in fact or law. Furthermore, as set
forth at length above, the State Attyney obligation to serve his Amended Motion prior to
filing it with the Court as PlaintifT lready dropped him from the case when it was filed.
III. THE COMPETENT SUBSTANTIAL EVIDENCE ON THE RECORD SHOWS
THAT THERE IS NO ARGUABLE BASIS IN LAW OR FACT FOR THE ISSUES
RAISED IN PLAINTIFF'S COUNT I, WHICH NOT ONLY LACK A GOOD
FAITH ARGUMENT FOR THE INTERPRETATION OF EXISTING LAW OR
ESTABLISHMENT OF A NEW LAW WITH A REASONABLE EXPECTATION
OF SUCCESS, BUT ALSO ARE NEITHER NOVEL OR COMPLEX.
Here, Plaintiff relies on § 57.105(3)(a), which sets forth a scenario where sanctions are
improper under the Statute:
3) Notwithstanding subsections (I) and (2), monetary sanctions may not be
awarded:
(a) Under paragraph .(//(b) if the court determines that the claim or
defense was initially presented to the court as a good faith argument for the
extension, modification, or reversal of existing law or the establishment of
7
CA/Aronicrepar0Q113.9 HUM) PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735695
•
new law, as it applied to the material facts. with a reasonable expectation
of success.
Notably, the § 57.105(3Xa) defense only applies to demands, made under § 57.105(IXb).
Accordingly, Plaintiff's attempt to prevent an award of sanctions here only applies to whether
Plaintiff or Plaintiff's attorney "knew or should have known" that the First Aniended Complaint
"when initially presented to the court or at any time before trial .„ (h) would not be sppjotred by
the application of then-existing lair to those material feels necessary to establi r c
0
5.17(1) makes clear.
57.1.03O)(b), Ha. Stat..
Regarding the disclosure of grand jury materials, Florida Sta
that there is no arguable basis in law that the State Attorney p
m.." §
Requested Materials:
The notes. records, and transcriptions are co exempt from the
provisions of s. 119.07(1) and s. 24(a), Art.1 nstitution and shall be
released by the clerk only on request by a or use by the grand jury or
on order of the court pursuant to s.90
Florida Statutei § 90117(1). Based on the age of 905.17(1), Fla. Stat. there can be
no good faith reasonable expectatio
Requested. Materials as he lac
demanded by Plaintiff in Count
for the State Attorney to produce and disclose the
authority to obtain and deliver the Requested Materials
the First Amended Complaint.
Even if P1 'Miff shjAided from § 57.105(1Xb) sanctions based on the § 57.105(3)(a)
defense, Pla' " ethtless subject to sanctions under § 57.105(1Xa), because Plaintiflor
Plainti s 'brew or should have blown' that Count I "when initially presented to the
court t any time before trial (a) was not suovorted by the material facts necessary to establish
the claim." Fla. Stat § .57.103100). Specifically, based On Plairitiff'S own research, statutory
constructive notice, the State Attorney's affidavit, all of the pleadings and correspondence in this
matter as well as through fife State Attorney's offimpress release and social media accounts, and
8
CA/AmPlat$9 10I BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735696
•
Chief Judge Man's statements during the June 3, 2020 hearing, Plaintiff and Plaintiff's attorneys
knew or should have known that Count I of the Amended Complaint was not supported by the
material facts necessary to establish the claim." See, Fla. Stat. 57.105(1)(a).
The material facts showing that Plaintiff has no reasonable expectation of success and is
unable to establish its claim for declaratory relief have been open, obvious, and apparent to
everyone involved in this matter from the start. The State Attorney's position has been-asistent:
neither he nor his office has possession, custody, or control of the Requested Materials and
therefore the declaratory relief sought by Plaintiff seeks materials tha iinposiible for him or C
his office to produce and he is not a proper party to this action. [S De . .A-12 ¶913-4]. Again,
these material negating Plaintiffs declaratory relief St the State Attorney were
not only set forth in the June 8, 2020, § 57.105 De , but have been the basis for the
State Attorney's defense in every pleading, filin r correspondence in this matter.
Accordingly, Plaintiff knew or shou h e known that the First Amended Complaint was
not supported by the material facts Dec o establish the claim for declaratory relief. At the
very least, Plaintiff should have kno at its First Amended Complaint was not supported by
, , the material facts after Judge Mares statements during the June 3, 2020 hearing on Defendant's
Motion to Dismiss Plaintirs Count II. During that hearing, Chief Judge Marx drew a bright line
as to when Plaultiff knew or should have known that Count l of the Amended Complaint had no
basis in fact or law since the relief sought thereby is impossible for the State Attorney to perform.
ChicfJudge Marx made several unequivocal statements on the record putting Plaintiff
on notice, if they weren't already, that the State Attorney does not have and cannot produce the
Requested Materials. [DelEx.A-6, pgs. 3:18 - 4:1; 5:17-19: 8:4-22; 10:21 - II:1; 11:12-15; 16:12
- 17:3; 17:6-9; 17:23- 18:2].
9
CA/Aropliteeioo t?rQ1.1. PA& BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735697
•
Additionally, Plaintiffs argument for novelty and complexity fails as to Count!, regardless
of Plaintiff's reliance on "Constitutional provisions and interpretive case law, along with Fla. Stat.
§ 905.27" ... "to propose a good faith interpretation of existing law in support of its declaratory
relief claim in Count 1." [See, Plaintiff's Memorandum of Law in Response to Amended Motion
for Attorneys' Fccs, p.10.]. The simple fact of the matter is that Count I is neither novel or complex
because Count I merely seeks declaratory relief and the State Attorney's lackof pthession,
custody, or control in conjunction with § 905.17(1) creates an impossibility of performance'as to
Count 1. Here, § 905.17(1) is abundantly clear that only the Clerk can release grand jury materials
pursuant to a court order. The record is likewise clear that not has the State Attorney never
had possession, custody, or control of the Requested Materi e,Also laCks any legal authority
to obtain and deliver the Requested Materials..
Thus, there is no arguable. "good faith" bylaw and/or fact as to Plaintiff's Count I.
Likewise, under no set of facts does Plaintiff a enable expectation of success against the
State Attorney in obtaining the Requ t als because he does not have possession, custody,
or control over them. In tiff acknowledged, admitted, and acquiesced to the
impossibility of the State Attom roviding the Requested Materials when he was dropped from
the action. Consequently, an tions against Plaintiff are appropriate under § 57.105, Fla. Stat.
CONCLUSION
Based- on, the foregoing, Defendant, Dave Aronbcrg, as State Attorney of Palm Beach
County, \Florida, respectfully requests the Court enter an order granting his Amended Motion for
Attorneys' Fees as well as such other and further relief as the Court deems just or proper.
SCHOLZ & WYLER, LLC
Is/Douglas A. Wyler
10
CAIAr° PlfErV9MS BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735698
• •
Arthur 1. Esq.
Fla. Bar No.: 10249
Richard J. Scholz, Esq.
Fla. Bat No.: 0021261
Douglas A. Wyler, Esq.
Fla. Bar No.: 19979
961687 Gateway Blvd., Suite 201-I
Fernandina Beach, Florida 32034
([Phone Redacted]
([Phone Redacted] Fax
Primary: jacobsscholzlaw* et
AttorneysforDefendanj ilberg
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on this 12th day of August, 29j, aiApyofthe foregoing has
been elCctroniCally filed with the Florida E-File Portal for e Tvile oif all patties of record herein.
/ A. tavler
( S \
11
CA/Arop~9,1" BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 1:04:39 PM
EFTA02735699
• •
Def.Ex.A-1
GO
(S. +0
Ca .3 9M BEACH COUNTY, FL, ABRUEEO, CLERIC 3/28/2023 P.30 PM
EFTA02735700
em" CASE NUMBER: 502019CA.81XXXXMB Div: AG • Filing # 98869063 E-Filed 11/14/2019 11:06:37 AM
CA FLORIDA HOLDINGS, LLC,
Publisher of THE PALM BEACH POST
v.
DAVE ARONBERG, as State Attorney of 4
Palm Beach County, Florida, SHARON It
BOCK, as Clerk and Comptroller of Palm
/
4 C
Beach County, Florida,
Defendants.
SU
IN THE CIRCUIT COURT, 15th
JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO.:
Plaintiff;
DEFENDANT: Dave Aronberg, as State Attorney of
Palm Beach Coonty, Florida
401 N. Dixie Highway
West Palm Beach, Florida 33401
A lawsuit has been filed against you. You have 20 calendar days after this summons is
served on you to file a written response to the attached Complaint with the Clerk of this
Court. A phone ball will not protect you. Your written response, including the case
number given above and the names of the parties, must be filed if you want the Court to
hear your side of the case. If you do not file your response on time, you may lose the
case, and your wages, money, and property may thereafter be taken without further
warning from the Court. There arc other legal requirements. You may want to call an
attorney right away. If you do not know an attorney, you may call an attorney referral
service or _a legal aid office (listed in the phone book). If you choose to file a written
response yourself, at the same time you file your written response to the Court you must
also mail or take a copy of your written response to the: Stephen A. Mendelsohn,
Esquire, Greenberg Traurig, PA., 5100 Town Center Circle, Suite 400, Boca Raton,
Florida 33486, Telephone: ([Phone Redacted].
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/14/2019 11:06:37 AM
CA/Aroplieff01 A145M. L BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735701
THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and
a copy of the Complaint in this lawsuit on the above named Defendant
DATED on November , 2019 N0Y 15 2019
IMPORTANTE
Sharon R. Bock
As Clerk & Comptroller of the Court
By: a
Deputy Cl
DOLLY fikRC
Usted ha sido demandado legalmente. Tient 20 Diu, contados a p del reetbo de esta
notificacion, para contester la demanda adjunta, por escrito, y presentarla ante e Uns Uamada
tclefonica no lo protegcra. Si tasted desca que el tribunal considcre su defets‘debc pretentar su respucsta
por escrito, incluyendo el numcro del easo y los nombres de las partes ineresadas. Si tasted no contesta la
demanda a tianpo, pudiese perde cl caso y poctria ser despojado de sus ingraos y propiedades, 9 privado
de sus dindes, sin previo aviso del tribunal. Exista otros reg& os male. Si lo desea, puede tasted
consultai a un abogado inmediatamentc. Si no conoce a im a llamas a tma de las ofieinas dc
asistencia legal que aparecen en la guis telefonica.
Si den responder a la demanda por su cucnta,,,al Mena ticnipo en que presenta su rcspuesta ante
cl tribunal, dcbcra tasted envie por correo o entrent uns copia de su respuesta a la persona denominada
abajo comp *Pliintiftelaintiff's Attorney" (Demandante o Abogado del Demandante).
P4PORTANT
Dcs poursuites judiciares ont etc entreprises antre vous. Vous avez 20 jours consecutifs a partir
de la date de l'assignation de cette citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de ce
tribunal. Un simple coup de telephone eu insuffisant pour vous proteger. Vous etes oblige de déposer
votre reponse cerise, avec mention du mimera de dossier ci-dessus et du nom des parties oonunees ici, si
vous souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votre repense ecrite dans le
salai requis, vous risquez de perdre la cause ainsi que votre salaire, vote argent, et vos biens peuvent Me
saisis par la suite, sans atterra préavis ulterieur du tribunal. Il y a d'autres obligations juridiques et vous
pouvez requerir les servies/ irnrnedies d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez
telephone atm lvicc de efcrenec d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de
telephones).
'Na
eh sise= de dcposer vous-meme une reponse arite, il vous faudra gaiement, en ment
'ormaie, faire parvenir ou expedicr une copie de votre reponse ecrite au
s Attorney" (Plaignant ou a son avocat) nomme ci-dessous.
2
CA/AM/plein:0Q 1146
PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735702
Filing # 98869063 E-Filed 11.2019 11:06:37 AM •
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC, CASE NO.:
Publisher of THE PALM BEACH POST,
Plaintiff,
v.
DAVE ARONBERG, as State Attorney of
Palm Beach County, Florida; SHARON R.
BOCK, as Clerk and Comptroller of Palm
Beach County, Florida,
Defendants.
COMPLAINT \T
CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Complaint against
Dave Aronberg, the State Attorney for Palm Beach County. Florida, in his official capacity ("State
Attorney"), and Sharon R. Bock, the e Court for Palm Beach County, Florida, in her
official capacity ("Court Clerk.' follows:
JURISDICTION.
I. This 's an a iotTwithin the exclusive jurisdiction of the Circuit Court pursuant to
Fla. Stat. Sectio 2 (2)(a). 0
PARTIES
The Palm Beach Post is a daily community newspaper published by Plaintiff CA
Florida Holdings, LLC, with offices located at 2751 S. Dixie Highway, Nest Patin Beach, Florida.
3. Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth
Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and
CA/Aropfari 599-11.47, ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735703
has authority in grand jury proceedings pursuant to Fla. Stat. section 27.03. He is sued herein in
his official capacity as his office is in possession of documents that are the subject of this action.
4. Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach
County, Florida. She is sued herein in her official capacity as her office is in possession of
documents that are the subject of this action.
INTRODUCTION
5. In what is now widely if belatedly recognized as a colossal mi of justice -
which led to the further needless victimization of countless young girls — a wealthy,
politically connected, and powerful financier was not held acco bl , nor even forced to
confront, allegations of serious sex trafficking crimes. While it is1c .a Ahat Jeffrey Epstein's 2008
deal with the State of Florida was not consistent witkftie. esildence gathered against him, what
remains shrouded in mystery is how that evidencewas-presented — and the extent to which it was
presented — to the grand jury that returned an indictment far more limited in scope than expected
and deserved. ,L.
6. Through this ac '0`if, The. Beach Post seeks public access to the testimony, tctintt i
minutes, and other evidence pre in 2006 to the Palm Beach County grand jury empaneled
during the first Epstein se b se investigation. Typically, access to such materials is limited, for
example, in or to vent the flight of those whose indictment may be contemplated and their
ability- to destroy evidence; to ensure jurors' candor in deliberations; and to protect an
accuse ho is
AA
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. Ha. Stat. § 905.27(1)(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.
2
CA/Aronteraz00.1.1.4B PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735704
• •
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 tvith the
solemn responsibility of enforcing our criminal laws equally as to all citizens fulfil lett their duties
in this instance. Justice will be furthered where it is either (I) demonstrated that Epstein was treated
like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those
who chose to give Epstein favorable — "unusual," in the words on& Town of Palm Beach Police
Chief— treatment, are exposed and held accountable. From what limited information is now in the
public domain, the State Attorney's referral to the grand jury — which would be out of the ordinary
for this type of case — gives rise to a strong inference of favoritism and corresponding disregard
for the rights of the minor victims of Epsteiestex trafficking. Access to the grand jury materials
will allow the public to determirieWhetherthe grand jury process, and the secrecy that comes with
it, was used to further justice or, instead, operated to shield Epstein and his co-conspirators from
the consequences of their criminal activities. Accordingly, Fla. Stat. Section 905.27 authorizes the
disclosure of Epstein's 2006 grand jury proceedings.
8, Even in the absence of such a statutory basis, this Court is empowered to order
public disclosure pursuant to its inherent authority and supervisory powers over the grand jury.
Indeed, courts throughout the country in the past several decades have ordered the disclosure of
high-profile grand jury proceedings pursuant to their inherent authority where the public's interest
in those proceedings has outweighed the general need for secrecy. This is particularly so where,
3
CA/ArIli eff R ILVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735705
• •
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 redacted,
esFACTUAL BACKGROUND
Cas appropriate, to protect those who deserve such protection.
10. The following facts were gathered, in largo 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 Investidation, Indictment, and Plea Agreement:
2005- 2008.
11. The investigation into Epstein's sex crimes began more than fourteen years ago,
when a 14-year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that
Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein
required the girl to-strip. exposed himself, and masturbated while touching her. The girl was paid
5300. Epste.in was 52 years old at the time.
12. Following this initial report in 2005, the Town of Palm Beach Police, and later, in
2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
disturbingly similar details, with each of the other victims.
4
CA/AroplieErV91150. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735706
•
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 the victims were
expected to testify. The proceeding was postponed, however, due to meetings between the State
Attorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan
Dershowitz.
15. Another grand jury was convened in April 2006, but canceled the day before it was
to begin receiving evidence.
(1) Police Chief Reiter's Letter to the Slate Attorney.
16. On May I, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a
"personal and confidential" letter to, then palm Beach County State Attorney, Barry Krischer,
stating:
I must renew my prior observation 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.
1 must urge you to examine the unusual course that your office's handling of this
matter has taken and consider if good and sufficient reason exists to require your
alification from the prosecution of these cases. (Emphasis supplied)
17Y 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
5
CA/AroplioN5091.1m.5. 1 Al BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735707
•
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 Jun , 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 grand jury in Palm
Beach County.
19. In July 2006, after State Attorney Krischer presented testimony and evidence from
one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.
There is no mention in the indictment of the victim being a minor.
20. On information and belief, a second of Epstein'a-Victims was supposed to testify
before the grand jury, but was unable to attend because of a school exam.
21. No reasonable explanation has been provided as to why the numerous other known
victims were not presented as witnesses and crime victims to the grand jury convened in July 2006.
Nor has any reasonable explanation beea'provided as to why State Attorney Krischer, who was
initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do z _
so.
22. rmation and belief, during the grand jury appearance of the single victim
who test tate Attorney presented evidence that vilified the victim and attacked her
credibih , including soliciting testimony regarding underage drinking and questionable personal
behavior that was unrelated to the charges against Epstein. Further upon information and belief,
this information was initially brought to the attention of the State Attorney's office by Epstein's
defense counsel.
6
CA/Arofilin991152 ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735708
(3) The FBI's Investigation and Epstein's Non-Prosecution
Agreement With Federal Authorities.
23. On information and belief, following the deficient July 2006 indictment, and with
Chief Reiter's encouragement, the FBI began its own investigation of Epstein.
24. Records unsealed in 2015 revealed that the FBI compiled reports on "34 confirmed
minors" that were victims of Epstein's sexual predations. Based on evidence gathered e 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 federal ran ury.
25. Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta,
negotiated a plea deal with Epstein's team of lawyers to grant-Mununity to Epstein (along with
four named co-conspirators and any unnamed potential cp-conspirators) from all federal criminal
charges.
26. Throughout the remainder of 2007 and. through the first half of 2008, Epstein's
lawyers and the U.S. Attorney continued fegetiating the plea arrangement. Upon information and
belief, Epstein's lawyers insisted that (1) the victims not be notified, (2) the deal be kept
confidential and under seal. and (3) all grand jury subpoenas (including one that had already been
issued for Epstein's computers) be withdrawn.
27. Op June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of
prostitution and one count of solicitation of prostitution with a minor under the age of IS. He was
sentenced to /8 months in jail, followed by a year of community control or house arrest, and was
adjudicated as a convicted sex offender required to register twice a year in Florida.
28. The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to
receive immunity from federal sex-trafficking charges that could have sent him to prison for life.
7
CA/AropIff959Qtrni*Avi BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735709
• •
On information and belief based on public records, former State Attorney Krischer communicated
with then U.S. Attorney Acosta concerning the NM'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 la 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„from "work."
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 Act Lititation.
32. Epstein's victims only learned after the fact abourhis plea in State court and filed
an emergency petition to force federal prosecutors to comply with. the Crime Victims' Rights Act
(18 U.S.C. § 3771, "CVRA"), which mandates certain rights for crime victims, including the right
to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge
Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify
Epstein's victims before allowing Mtn to plead guilty to only the two State offenses.
33. The rosectition's failure to keep the victims apprised, among other things, also
contravenes th Constitution. Article 1, § 16(b) and Fla. Stat. § 960.001.
3 wing publicity exposing the extraordinary leniency of the plea deal, dozens of
civil sui were brought against Epstein, most of which Epstein's lawyers settled out-of-court.
35. in 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense)
sex offender in New York, a lifelong designation. In 2011, the New York County District
Attorney's office unsuccessfully sought to lower his registration to low-risk "level one."
8
CAJAronlaerok001154 Hum: l'ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735710
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 ting
with law enforcement and told that they would be compensated only if they did not with AN
law enforcement. ----V
B. Second. Epstein Sex Crimes Invcstization. Indictment, Suicide: 2019.-
38. On July 6, 2019, Epstein was arrested on federal sex traffidlcing charges.
39. Upon information and belief, the United States government's investigation of new
allegations and charges stemmed, in part, from continued press. nvestigauons into and reporting
on the mishandling of the 2006 charges and the civil suits that followed.
40. In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the
Southern District of New York, Epstein was destribed as "a serial sexual predator who preyed on
dozens of minor girls over a period of years:" The letter emphasized that "the Government has real
concerns — grounded in past experience with this defendant — that if allowed to remain out on bail. •
the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this
case, including victims and their families, and otherwise attempt to obstruct justice." It also
described the results 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]," "Mist
nudes 1," and "Girl pits nude."
9
CA'AmPliegib°93\15A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735711
•
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 in, the Trump
administration, resigned from office.
42. Epstein was denied bail and was placed into pretrial (detention- at the federal
Metropolitan Correction Center in lower Manhattan.
43. On August 10, 2019, Epstein, was found dead fit his cell at the Metropolitan
Correctional Center. His cause of death was determined to be suicide.
C. The August 27. 2019, SDNY Hearing: Eifssein't Victims Sneak
44. On account of his death, prosecutors sought to dismiss the indictment against
Epstein, while maintaining that they would continue to investigate his co-conspirators.
45. United States Senior District Judge Richard M. Berman ordered a hearing on
August 27, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to
speak at the hearin
46. rse of the hearing, more than two dozen victims delivered their personal
stories o tration, and sexual abuse at the hands of Epstein. Several victims spoke of
violent rhpe by Epstein. Many more victims were present in the courtroom but did not testify.
47. While some questioned the reasoning behind the court's decision to give the victims
voice after Epstein's death, District Judge Berman noted that "a public hearing is [the] preferred
vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings
promote transparency and they provide the court with insights and information which the court
10
CA/Aror D urn,?Qas. iLE PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735712
• •
may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that
the court "is the institution that most people have confidence in, in these very troubled times."
48. At the August 27th hearing, the girls, now women, spoke about their "exploitation
and coercion," and to the fact that many of them "were in very vulnerable situations and in extreme
poverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their]
behalf...." One victim lamented that "as a victim, [she] never got to see what the agreetnept was
or why the special treatment got approved" in the Florida case years earlier. Another noted how
"completely different" the investigators leading to the 2019 federal indittment.Were from the
prosecutors in the Florida case, both in their treatment of her and their investigation of her
victimization by Epstein.
49. A former federal judge in attendance at the August 27th hearing emphasized that
"transparency is one of the overriding objectives in our criminal justice system."
50. Nearly all of the victims expressed the conviction that the secrecy that shielded
Epstein has caused them "irreparable has t= that an opportunity to address his criminal
wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
at least some measure of justice to be-served after his death. Indeed, one victim stated: "Any efforts
made to protect Epstein's Inglineand 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." ht short, the
"unusual" treatment Epstein received in Florida in 2006 based on his wealth, social status, and
connections severely eroded the public's faith in the integrity and impartiality of the criminal
justice system.
II
CA/Aroitittp QUEAL I4. P BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735713
D. The Palm Beach Post's Standing and the Public Interest.
51. Plaintiff, The Palm Beach Post. is a community newspaper serving readers in Palm
Beach County and the Treasure Coast vicinity.
52. The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist
three other times.
53. Beginning in 2004, The Palm Beach Post has extensively investiga nett
on the allegations against, the law enforcement investigation of; and the crjttf@ mMed by,
Epstein and his co-conspirators. The Newspaper's reportage has inchided publication of the
following articles:
• "The Man Who Had Everything: Jeffrey Epstein Craxted 'Big Homes, Elite Friends
and. Investigators 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 visitEpstein, 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
marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their
decision to take the case to a gittnd jury;" Palm Beach Police subsequently "received
complaints that two of the victims or their families had been harassed or threatened;"
"relations between police and prosecutors were fraying" as the investigation continued;
and "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 Gasman Estate for S41 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 011 6 oceanfront acres along
the storied 'Raider's Row' " in Palm Beach.
"Indictment: Billionaire Solicited 3 Times" published on July 25, 2006, reporting that
"Billionaire money Manager and Palm Beach part-time resident Jeffrey Epstein
solicited of procuted 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 arc 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."
12
CA/AroMIT :459. 9W% BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735714
• "After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006,
reporting that "Palm Beach police thought there was probable cause to charge Epstein
with unlawful sex acts with a minor and lewd and lascivious molestation." The article
further reported that "Police Chief Michael Reiter was so angry with State Attorney
Barry Krischer's handling of the case that he wrote a memo suggesting the county's
top prosecutor disqualify himself," and identified a 20-year-old on-the-record female
source who said "she gave Epstein a massage in the nude, then brought him six girls,
ages 14 to 16, for massage and sex-tinged sessions at his home."
• "Police Say Lawyer 'fried to Discredit Teenage Girls" published on July 29, 2006,
reporting that "[flamed Harvard law professor Alan Dershowitz met with the Palm
Beach County State Attorney's Office and provided damaging information about
teenage girls who say they gave his client, Palm Beach billionaire, Jeffrey Epstein,
sexually charged massages" and that "Mlle state attorney's office said it presented the
Epstein case to a county grand jury this month rather than directly charging Epstein
because of concerns about the girls' credibility."
• "Expert Ignorance of Age Isn't Defense In Sex Cases" published on August 5, 2006,
reporting that "Mather than file. charges, the state attorney's office presented the case
to a county grand jury" which "indicted Epstein last, week on a single, less serious
charge of felony solicitation of prostitution," and that "[t]tle case raised eyebrows
because the state attorney's office rarely, if ever, kicks such charges to a grand jury."
• "Epstein Camp Calls Female Accusers Liars" published.on August 8, 2006, reporting
that "[a] state attorney's spokesman would say only that the office refers cases to the
grand jury when there are iplt s with the viability of the evidence or witnesses'
credibility."
• "Palm Beach Chief Foc f re In Epstein Case" published on August 14, 2006,
reporting that Chief Reiter ressed for Epstein to be charged with the more serious
crimes of sexual activity with minors" and "slammed State Attorney Barry Krischer in
blunt language.seldom used by one law enforcement official with another because of
what he perceived as that office's mishandling of the case."
• "Delays In Epstein Case Unusual, Lawyers Say" published on March 13, 2007,
reporting that "[njearly eight months after Palm Beach tycoon Jeffrey Epstein was
charged with felony solicitation of prostitution, there has been no discernible progress
'41 his_ce.se."
• "Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published
on October 18, 2007, reporting on a lawsuit brought in New York State court against
Epstein "by a young woman who says he had sex with her when she was 16 and had
sought his help becoming a model."
• "Palm Beacher Pleads In Sex Case" published on July 1. 2008, reporting that "Epstein,
55, pleaded guilty . . . to felony solicitation of prostitution and procuring a person under
the age of 18 for prostitution." resulting in "a lifelong obligation to register as a sex
13
CA/Aroita 50911.59 99X 91 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735715
• •
offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their
investigation of Epstein, which they had taken to a grand jury."
• "Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon" published on
August 13 2008 re ning that "[d]uring his first month of confinement" Epstein was
visited by who allegedly escorted victims "upon their arrival at his Palm
Beach waterfront home to an upstairs room, where she prepared the masse e table and
provided the oils for their encounters" with Epstein, and by "a
young woman whom Epstein purportedly described as his Yugoslavian sex slave."
• "Billionaire Sex Offender Leaves Jail Six Days a Week For Work" published 0 n July
1, 2008, reporting that Epstein "is allowed to leave the Palm Beach County Stockade
six days a week on a work-release program."
• "Women Want Epstein Sex Plea Deal Unsealed" published on June 10,2009, reporting
that attorneys for women suing Epstein in various courts "want his [non-prosecution]
agreement. [NPA] with federal prosecutors unsealed" and were moving to unseal the
agreement in Circuit Court of the Fifteenth Judicial Circuit, and that "Epstein now faces
at least a dozen civil lawsuits in federal and state courts filed by young women who
said they had sex with him and now are seeking damages." On that date, The Palm
Beach Post moved to intervene in the matter. for the purpose of obtaining public access
to the NPA, which was ordered disclosed by this Court on June 25, 2009.
• "Epstein's Secret Pact With reds Reveals `Highly Unusual' Terms" published on
September 19, 2009, reporting that, owing to Epstein's non-prosecution agreement,
"federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein
pleaded guilty to prostitution-related felonies in state court" and "also a reed not to
charge any of Epstein's possible co-conspirators: ==, Lesley
Groff and Nadia Marcinkoya." The article further reported that, according to an
attorney representing three of Epstein's victims, "none of the 30 to 40 wom[e]n
identified as victims in the federal investigation" were informed ahead of time about
the NPA.
• "Judge Rules P4 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."
• "EP. 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."
14
CA/Aronlotenok00.1.16.0. tun) . l'ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735716
•
• "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims'
Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge
Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's
teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had
dropped plans to prosecute the billionaire on dozens of federal charges in connection
with the girls' claims that he paid them for sex at his Palm Beach mansion."
• "Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex
Trafficking, Conspiracy Charges In Federal Court In Manhattan" published on July 9,
2019, reporting on Epstein's appearance in U.S. District Court for the Southern District
of New York in which he "pleaded not guilty to charges accusing him of creating a vast
network of girls as young as 14 that he exploited for his sexual pleasure at his homes
O 81
in. Palm Beach and Manhattan."
A true and correct copy of the above news articles, in either the comp • in which they urare maintained in The Palm Beach Post's electronic archives or the ne print edition in which
originally published, is annexed hereto as Exhibit I.
54. The press has a constitutional right of nminal proceedings, see, e.g.,
Richmond Newspapers, Inc. v. Virginia, 448 U. 573 (1980), including pre-trial criminal
proceedings. v Graddick, 696 F. 11( I Cir. 1983). Indeed, "the integrity of the
judicial process, which public scrutpy sed to safeguard, is just as much at issue in
] as at trial." Id. at 801; see also Miami Herald Publ. proceedings of this kind [pre- C
Co. v. M, 426 So. 2d 1, 6-7 982) (identifying the news media as a "public surrogate" in
matters concerning the ci 9. of judicial proceedings). The press also has a First Amendment
interest in rem formation from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer
Council, 48, 756-57 (1976) ("Where a speaker exists . . . the protection afforded [by
the F &nein] is to the communication, to its source and to its recipients both."); Pittman
v. M. 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme Court has recognized that the
First Amendment offers protection to both speakers and those wishing to receive speech."); see
also Stephens v. Cty. of Albemarle, Va.. 524 F.3d 485, 492 (4th Cir. 2008) (providing that a plaintiff
15
cAlAr° Pliefb?AlTI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735717
•
has "standing to assert a right to receive speech" by "show[ing] that there exists a speaker willing
to convey the information to her").
55. Because of the unique role performed by the press as a "public surrogate" (-,
426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about
criminal proceedings, news organizations "presumptively have a right to access judicial records,"
Comm ir, Ala. Delft of Corr. v. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11t11eit1/2 019),
and "standing to question the validity of an order restricting publicity becauseita.ability to gather
news is directly impaired or curtailed." 426 So. 2d at 4; see also Carlton v. United States,
837 F.3d 753, 757-58 (7th CU. 2016) ("[a]s a member of the public, [the Reporters Committee]
has standing to assert [its] claim" to grand jury materials because such Materials are "public records
to which the public may seek access, even if that effortis ultimately unsuccessful").
56. Here, the continued denial of accestto 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 fl orida, 210 So. 3d 1243, 1263 (Fla. 2017); see also
Zerilli v. M, 656 F.2d 705, (D.C/Cir. 1981) (noting that "the press' function as a vital
source of information is weakened whenever the ability of journalists to gather information is
impaired," as it is by Attorney eeneral's refusal to disclose unredacted report and underlying grand
jury materials).
E. The Court's Supervision of the Grand Jun Process and Its Authority to Order
.7.6lic Disclosure of the Epstein Evidence.
577 The Florida Supreme Court has noted that "in states such as Florida, where the
grand jury is preserved, it is an important appendage of the court which impanels it. At the same
time it should not be forgotten that the judge of that court is equally important and he is generally
charged with the supervision of the grand jury's activities...lt is, therefore, of vital importance to
16
CA/AropliutrutN t -teZ ALm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735718
• •
maintain the dignity and the integrity of both the grand jury and the presiding judge." State v.
Clemons, 150 So. 2d 231, 233-34 (Fla. 1963).
58. Chapter 905 of the Florida Statutes governs the empanelment and conduct of
Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury
about its legal duties. Fla. Stat. § 905.18.
59. Florida Stat. Section 905.27(1) provides that "the testimony of a wi e ined
before the grand jury . . . or other evidence received by it" may be disclosed uired by a
court . . . for the purpose of: (a) Ascertaining whether it is consistent
the witness before the court; (b) Determining whether the witn
Furthering justice." Ha. Stat. § 905.27( I )(a)-(c).
60. Further, disclosure is appropriate purs
grand jury proceedings because of the exceptio
circumstances supporting transparency. C
has the inherent power to disclose
historic importance can be a suf¢cwnt r
61.
the testintony given by
ty of perjury; or (c)
Court's inherent authority over
interest in this case and the compelling
hired States, 837 F.3d at 766 ("a district court
materials in exceptional circumstances and . . .
n when there is little countervailing need for secrecy").
COUNT I
Til isir (Florida Stat. Section 905.27)
information learned by The Palm Beach Post through its Florida Public
Records tit% tequEsts, law enforcement sources with direct knowledge of the grand jury evidence
and proceedings, judicial documents obtained from independent but related court proceedings, and
documents otherwise available in the public record, the State Attorney for Palm Beach County
presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner
17
CA/AropM-9 91163, ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735719
•
that precluded his indictment for the serious crimes he committed, including sex trafficking and
sexual assault.
62. Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's
victims and the public, and to provide public disclosure to illuminate whether Epstein received
unreasonably lenient treatment based on the available evidence, The Palm Beach Post equests
immediate public access to the testimony, minutes, and other evidence presented the
Palm Beach County grand jury. In a case of this magnitude and importance, eased is
dead and so many of his crimes, as well as the identities arid crimes of
identities of the victims have already been exposed, the need forp d j secrecy is no more. Ai
See United States v. Socony-Vacuum Oil Co.. 310 U.S. 130 L (" [Alfter the grand jury's
functions are ended, disclosure is wholly proper whey justice require it.").
WHEREFORE, The Palm Beach Post re • equests that this Court, pursuant to Fla.
Stat. Section 905.27(1) and the Court's inh t rity, order the State Attorney and the Clerk
of the Court to file with this Court co sill e stimony, minutes, and other evidence presented
in 2006 to the Palm Beach CO uty during the first Epstein sex abuse investigation so
that, following an in cam ra Ion, it can be made available to The Palm Beach Post and the
public on an * d an d.exped grant any other and further equitable or legal relief the Courtle s,
arC5deems just
18
tors, and the
cAlArTiff95990A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735720
Dated: November 14,2Q19
CG
ACTIVE 456787090
Respectfully submitted,
GREENBERG TRAIIRIG, P.A.
Attorneys for CA Florida Holdings, LW,
Publisher of The Palm Beach Post
Stephen Mendelsohn,. Esq.
5100 Town Centel Circle, Suite 400
Boca Raton, Florida 33486.
Telephone: (561) 955-7625r
Facsimile: ([Phone Redacted]
By: /s/ &when A. Mendelsohn
STEPHEN A. MENDELk)
Florida Bar No. 849324
mendeisohns(aktiaw.cortr
hasenhgtgtlaW-.COM
FLService@gtlaw;
By: IS/ Michael J
MICHAE
(Pro.H a minion forthcoming)
54 S loor
ew ork 12207
: ([Phone Redacted]
e: ([Phone Redacted]
elme law.com
181 Vincent H Chieffo _ —
VINCENT H. CHIEFFO
(Pro Hac Vice applitation fordtoming)
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: ([Phone Redacted]
Facsimile: (310 586 780.0
chieffov@ellaw-cOm
riveraal@gthivtconi
By: Is/ Nina D. &maw;
NINA-D. Boy:Ana -
(Pro Hoc Vice application forthcoming)
1840 Ceniury Paiic East, Suite 1900
Los Angeles' A 90067
Telephone: ([Phone Redacted]
Facsimile: (3.10) 5867800
bovaiiann/iputlaw.com
riVeraalfhtlaw.com
19
CAIAMPIregn BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735721
EXHIBIT I
The Newspaper's Reportage on Jeffrey Epstein
CO :r\-
cA'An11115551AIVI BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 1:04:39 PM
EFTA02735722
The Palm Beach Post REAL NEWS STARTS RIFE
The Man Who Had Everything: Jeffrey Epstein craved big
homes, elite friends and underage girls By Andrew Marra
Posted Jul 17, 2019 at 6:02 AM
From the archives: When Palm Beach detectives started asking
questions and teenage girls started talking, a wave of resistance
followed.
Editor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after
Jeffrey Epstein's arrest in Palm Beach County on a charge of felony solicitation of prostitution.
WINGED GARGOYLES guarded the gate at Jeffrey Etats Palm Beach mansion. Inside,
hidden cameras trolled two rooms, while the girls carne and went.
For the police detectives who sifted through the garbage outside and kept records of visitors, it
was the lair of a troubling target.
Epstein, one of the most mysterious of the country's mega-rich, was known as much for his
secrecy as for his love of fine things: magnificent homes, private jets, beautiful women,
friendships with the world's. elite.
But at Palm Beach police headquarters, he was becoming known for something else: the
regular artjteenage girls he hired to give him massages and, police say, perform sexual
favors.
Epstein was different from most sexual abuse suspects; he was far more powerful. Ile counted
among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
with some of the most prominent legal, scientific and business minds in the country.
When detectives started asking questions and teenage girls started talking, a wave of legal
resistance followed.
CA/Aropli9091 AL16J. M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735723
• •
» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work -
release
if Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.
Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends
quietly, always in the background as he navigated New York high society.
When he first attracted notice in the early 1990s, it was on account of the woman.heiVas
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Mgx ell.
In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Sec ve the British
Mail on Sunday tabloid laid out speculative stories that the socialite's eau was a CIA spook, a
math teacher, a concert pianist or a corporate headhunter.
"But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both
flamboyant and intensely private."
The media frenzy did not begin in full until a decade later. In September 2002, Epstein was
flung into the limelight when he flew Clinton awl actors Kevin Spacey and Chris Tucker to
Africa on his private jet.
Suddenly everyone wanted to know who Bp-was. New York magazine and Vanity Fair
published lengthy profiles. The ew ork Post listed him as one of the city's most eligible
bachelors and began descrjbjfig him in its gossip columns with adjectives such as `mysterious"
and "reclusive."
Although Epst ' a o interviews, the broad strokes of his past started to come into focus. olif l
Building a life of extravagance
He was born blue-collarin 1953, the son of a New York City department employee, and
raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree
but became a math teacher at the prestigious Dalton School in Manhattan.
The story goes that the father of one of Epstein's students was so impressed with the man that
he put him in touch with a senior partner at Bear Stearns, the global investment bank and
securities firm.
CA/AroPlle i9 1A 1L% BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735724
• • In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J.
Epstein and Co. That is when he began making his millions in earnest.
Little is known or said about Epstein's business except this: He manages money for the
extremely wealthy. He is said to handle accounts only of SI 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 a d a.4. k
former Palm Beacher who is said to have been a mentor to Epstein.
Wexner sold Epstein one of his most lavish residences: a massive townhouse Rdominates a
block on Manhattan's Upper East Side. It is reported to have, among its eures, closed-
circuit
C
television and a heated sidewalk to melt away fallen snow.
no,That townhouse, thought to be the largest private residence • ttan, is only a piece of
the extravagant world Epstein built over time.
In New Mexico, he constructed a 27,000-square-fo
64% ,outside Santa Fe. Many believed it to be the lar( s it
In Palm Beach, he bought a waterfront
private island in the Virgin Islands.
•t mansion on a 10,000-acre ranch
e in the state.
On Brill° Way. And he owns a 100-acre
» PHOTOS: The players in the Jeffl9Ey Epstein saga
Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
the highest echelons of power. This includes not only socialites but also business tycoons,
media moguls,
funds.
taits, royalty and Nobel Prize-winning scientists whose research he often
Just It eople collect art, he collects scientists," said Nowak, who directs the
Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of
a $30 million research donation from Epstein.
Epstein is said to have befriended former Harvard President Larry Summers, prominent law
Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort
Zuckerman.
CA/ArOpliegy59 AL lea M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735725
And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
photographed.
'The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials
and tribulations of the very rich. 1 wasn't even aware of him: except for a Vanity Fair article.
Epstein's friendship with Clinton has attracted the most attention.
Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at
an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become
dose friends until after Clinton left the Oval Office and moved to New York.
Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John
Kerry's presidential bid, the reelection campaign of New Mexico Gov. Bill and the
Senate bids of Joe Hillary Rodham Clinton, Christopher Dodd and Charles
Schumer.
Powerful friends and enemies
A Vanity Fair profile found cracks in the veneer of Ep= life story. The 2003 article said he
left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange
Commission violation. It also poin gt \Nat Citibank once sued him for defaulting on a $20
million loan.
The article suggested that one of his business mentors and previous employers was Steven
Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million
in one of the largest Pond schemes in American history:
As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the
man who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less
than $16,000 in furnishings.
A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
owed him nothing.
» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says
CA/Arofilitte. BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735726
"It's a bad memory. I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the
retired former president of Electronics and Sega Corp. "Suffice it to say I have
nothing good to say about him."
Among the characteristics most attributed to Epstein is a penchant for women.
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian
model.
'He's a lot of fun to be with," Donald Trump told New York magazine in 2002At is even said . _
that he likes beautiful women as much as I do, and many of them axe on the youbger side. No
doubt about it, Jeffrey enjoys his social life."
Investigation leads to Epstein
cts;aoAs frtAlthough he was not a frequenter of the Palm Beach s I , he made his presence felt.
Among his charitable donations, he gave $90,000 to the Pa Beach Police Department and
$100,000 to Ballet Florida.
In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a
Harley-Davidson. His jet waited at a hangat at Palm Beach International Airport. At home, a
private chef and a small staff stood at the ready. From a window in his mansion, he could look
out on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man
who had everything.
But extraordina th fuel extraordinary desires.
» Epstet leave jail for mansion in sex -trafficking case
In March 005, a worried mother contacted Palm Beach police. She said another parent had
overheard a conversation between their children.
Now the mother was afraid her 14-year-old daughter had been molested by a man on the
island.
The phone call triggered an extensive investigation, one that would lead detectives to Epstein
but leave them frustrated.
CA/AronherEDz: 0Q1.1 PIL rAirm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735727
Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm
Beach police report detailing the criminal probe offers a window into what detectives faced as
they sought to dose in on Epstein.
Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to
perform a massage. She said the friend told her to say she was 18 if asked. At the house, she
said she was paid 8300 after stripping to her panties and massaging the man while he
masturbated.
Police interview 5 alleged victims
The investigation began in full after the girl identified Epstein in a photo as the man who had
paid her. Police arranged for garbage trucks to set aside Epstein's trash, so police could sift
through it. They set up a video camera to record the comings and goings at his home. They
monitored an airport hangar for signs of his private jet's arrivals and departures.
They quickly learned that the woman who took the 14-year-old girl to Epstein's house was
, a Palm Beach Community College student from Loxahatchee. In a sworn
statement at police headquarters, , then 18, admitted she had taken at least six girls to
visit Epstein, all between the ages of 14 apdr 16. Epstein paid her for each visit, she said.
During the drive back to her house old detectives, "I'm like a Heidi Fleiss."
Police interviewed five alleged and 17 witnesses. Their report shows some of the girls
said they had been instructed to have sex with another woman in front of Epstein, and one said
she had direct intercourse With him.
In October, police searched the Palm Beach mansion. They discovered photos of naked, young-
looking females, just as several of the girls had described in interviews. Hidden cameras were
found in the garage area and inside a clock on Epstein's desk, alongside a girl's high school
transcript.
Two of Epstein's former employees told investigators that young-looking girls showed up to
perform massages two or three times a day when Epstein was in town.
They said the girls were permitted many indulgences. A chef cooked for them. Workers gave
them rides and handed out hundreds of dollars at a time.
CA/Aronbeca.70a1172 LLD: rALm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735728
• One employee told detectives he was told to send a dozen roses to one teenage girl after a high
school drama performance. Others were given rental cars. One, according to police, received a
$200 Christmas bonus.
The cops moved to cement their cast But as they tried to tighten the noose, they encountered
other forces at work.
In Orlando they interviewed a possible victim who told them nothing inappropriate had
happened between her and Epstein. They asked her whether she had spoken to anyn_ne else.
She said yes, a private investigator had asked her the same questions.
-K-' » Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart
When they subpoenaed one of Epstein's former employees, he told' i 1.14 same thing. He
and a private eye had met at a restaurant days earlier to go ov the man would tell
investigators.
AS hgDetectives received complaints that private eyes wets as police officers. When they told
Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the
high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
Kennedy
While the private eyes were conducting a.parallel investigation, Dershowitz, the Harvard law
professor, traveled to West Palm Beach with information about the girls. From their own
profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
their use of alcohol and tijuana.
He took his re meeting with prosecutors in early 2006, where he sought to cast
doubt on t e ens eliability.
The priva e eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
did some of the girls have issues with drugs or alcohol but also some had criminal records and
other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she
told police she was younger than 18 when she started performing massages for Epstein.
After the meeting, prosecutors postponed their decision to take the case to a grand jury.
CA/AropkeN599WA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735729
• •
In the following weeks, police received complaints that two of the victirns,or their families had
been harassed or threatened. Epstein's legal team maintains that its private investigators did
nothing illegal or unethical during their research.
By then, relations between police and prosecutors were fraying. At a key meeting with
prosecutors and the defense, Detective Recarey, the lead investigator, was a no-show,
according to Epstein's attorney.
Sok"The embarrassment on the prosecutor's face was evident when the polictofficer
Al showed up for the meeting," attorney Jack Goldberger said.
Later in April, Recarey walked into a prosecutor's office at the state attc
learned the case was taking an unexpected turn.
The prosecutor, Lanna Belohlavek, told Recarey the state attoChrffice had offered Epstein
a plea deal that would not require him to serve jail time or eseivea felony conviction.
ASRecarey told her he disapproved of the plea offer,.
The deal never came to pass, however.
(\
Future unclear after charge
On May 1, the department askefiltose ors to approve warrants to arrest Epstein on four
counts of unlawful sexual activity'with a minor and to charge his personal assistant,
now 27, for her alltged role in arranging the visits. Police officials also wanted to
charge th 1f-described Heidi Fleiss, with lewd and lascivious acts.
By then, the pa e t was frustrated with the way the state attorney's office had handled the
case. On th ay the warrants were requested, Palm Beach Police Chief Michael Reiter
wrote a er o State Attorney Barry Krischer suggesting he disqualify himself from the case if
he would not act.
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
the grand jury.
CA/Aronlaera,00.1.1 nun): rA17,ivl BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735730
A •It is not known how many of the girls testified before the grand jury. But Epstein's defense
team said one girl who was subpoenaed - the one who said she had sexual intercourse with
Epstein - never showed up.
The grand jury's indictment was handed down in July. It was not the one the police
department had wanted.
Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was
charged with one count of felony solicitation of prostitution, which carries a maximum penalty
of five years in prison. He was booked into the Palm Beach County Jail early July 23 and
released hours later.
Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But
he said their claims that they had sexual encounters with him lack credibility.
"They are incapable of being believed," he said. "They had criminal tecords. They had
accusations of theft made against them by their employers. There was evidence of drug use by
some of them.'
What remains for Epstein is yet to be seen.
The Palm Beach Police Department bas .asked the FBI to investigate the case. It also has
returned the S90,000 Epstein donated in 2004.
In New York, candidates for governor and state attorney general have vowed to return a total
of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful
friends have remained silent as tabloids and Internet blogs feast on the public details of the
police investigation.
Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future
plea deal. He insists Epstein will emerge in the end with his reputation untarnished.
°He will recover from this, he said.
Staff writer Larry and staff researchers Bridget Bulger, Angelica Corte; Amy Hanaway and
Melanie Mena contributed to this story.
[Email Redacted]
civAr T11€899WA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735731
• @AMArraYBPost
•
Iliql-TELLtelEINIIT 890
C.A. PkTliNWRI BEACH co., FL, ABRUZZO, CLERIC .8,023 1,04,39 pm
EFTA02735732
•
273 / 278 - Tuesday, November 16, 2004
Edition: FINAL
Section: A SECTION
Page: IA
Source: By PAUL OWERS Palm Beach Post Staff Writer
Illustration: PHOTO (C & 2 B&W) & MAP (B&W)
Memo: Ran all editions.
Dateline: WEST PALM BEACH
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
When it came time to bid Monday for the palatial Palm Beach digs of Abe GoNtnatt, The
Donald was not about to be trumped.
"Nobody was going to outbid me," the brash developer-turned-TV-personality said from his
New York office.
Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot,
seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row."
But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at
513 N. County Road. He wants to - what else? - sell it and nitike more money.
The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super
luxury house" that would be the "finest anywhere in the United States." He might build
another house before flipping the entire package.
"I've known about this house for quite some tittle," Trump said. "It's probably the best piece
of land in Florida - and probably the country - for luxury real estate."
Althouitirump said he could subdivide the property into nine lots, Palm Beach Mayor
Lesly said zoning regulations allow for only two houses - and maybe a third.
said she's not worried about Trtunp's plans.
"He's been a very good property owner in the town of Palm Beach," she said. "He does his
projects very well. He's a perfectionist."
Monday's auction took plaee at U.S. Bankruptcy Court in West Palm Beach as part of
Gosman's Chapter 7 banloptcy case. Proceeds from the sale will, go into escrow for eventual
distribution to creditors.
The auction began at exactly noon after Judge Steven dismissed an objection from
an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully
that Trump was not a qualified bidder because his contract stipulated that he would not close
on the sale unless title insurance was in place beforehand.
With Trump listening via conference call, Epstein began the bidding at $37.25 million -
S250,000 higher than Trump's initial offer.
Mark Pulte, son of the founder of home-building giant Pulte Homes, passed when his turn
came, letting lawyers for Trump and Esptein bid against each other until the price hit $38.85
million.
Pulte then bid $39.1 million, briefly raising the ire of Trump, who believed that Puke had
given up his right to bid by passing the first time.
CA/Aroplie A.90911LM.7.7 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 I :04:39 PM
EFTA02735733
• •
But allowed the offerm stand, and Pulte and Trump went back and forth until
Pulte dropped out.at $41.1. million. Epstein; a part-time Palm Beach resident, bowed out at
$38.6 million.
closed the bidding 10 minutes after it started, leaving Trump with the right to buy
the 29,000-square-foot .home (ri typical Palm Beach County single-family. house is about
2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service
quarters.
The closing could take place within a week but probably won't happen until iteittmonth.
TrUsteeke Luzinski and creditors said they were pleased with the outcome.
"We knew we were dealing with some substantial people ... who were going:to b
bit,".Luzinski said.
"The system worked," said Charles Tatelbaumr a lawyer for creditor JPMo e Bank.
"In bankruptcy court, the idea is to get the most for creditors, and that's w
The auction proved to be a bonanza for creditors, Luzinski said, noti ghest offer
former listing agent Sotheby's International Realty received was $32 jllioim. otheby's won't
receive a commission, he said.
Nike; 42,, of Boca Raton, said he figured Trump wouldn't bac
"I got the feeling he was willing to go a lot higher, and I di
Pulte said Gosman asked him before the auction whethe
in the mansion after the closing until he decides whe
'Luzinski said they have had no such .discussions
Gosman, 75, had the honte built after paying $ ion for the land in 1986.
The former health-care magnate declined in eats before and after the auction
Monday. He was at the courthouse but left th auction took place.
The $41.35 million price tag eclipses4 illion sale of Lowell "Bud" Paxson's Palm
Beach home and guest house but fa e $45 million that Virginia home builder
Dwight Scher paid for Ron Pere square-foot estate, Casa Apava, a designated
landmark.
•Schar also paid $18.6 million a lakefront lot across the street from the main house, for a
total of $63.6 million. Insiders s Schar spent a total of $70 Million for his new property,
making it the priciest residential sale in.U.S. history.
Gosman once had ortuncthat Forbes magazine estimated at $480 Million. He voluntarily
filed for Chapte bankruptcy protection in 2001, listing assets of $250 million and
'liabilities of lion.
When a j d that Gosman had to give up all of hit exempt assets to creditors if he
wanted to ze under Chapter' 11, Gosman converted the case to Chapter 7 liquidation.
Last Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is •
invalid use Florida law does not recognize a Dominican Republic divorce that Lin
Gosman tried to obtain.from another man, Mithael Castle.
The judge's decision was a huge victory for creditors because it prevents Abe Gosman from
protecting assets by claiming joint ownership with his wife. Gosman's assets, which include
an extensive collection of artwork, could total as much.as $70 million and will be sold later.
Without Lessen's ruling, Luzinski would have had.a Much hardertiMe selling Gosman's
estate, said David Citho, Special counsel for the trustee.
"We would have been thwarted ... or at least substantially impaired." Cimo said.
.Monday.
o chase it," Pulte said.
be willing to let him stay
to move. Trump and
CA/ArTirEfeilk illk BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735734
• 41)
The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
an ownership interest in his home and other belongings only to avoid losing them in
bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in
1999, well before he filed for bankruptcy.
Lessen is expected to rule in the next two months whether Gosman made improper transfers,
a decision that will affect how much money will be available to creditors.
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
willing to move forward, in part because the upkeep of the estate now exceeds their means.
"This is not a happy occasion for them, but at least we're moving to the next level," Chao
said. "That's not a house you want to live in unless you're making large amounts °get
like Donald Trump."
paul_owers®pbpost.com
CO
CA/Aropharn:001A1LM9.Ltil l' BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735735
I II I Ile) I• one . comae, nommen a limes - news - i ne e'en oeacn 1-e ratm own, i., r •
The Palm Beach Post REAL NEWS S1ARTS HERE
Indictment: Billionaire Solicited 3 Times Posted Jul 1, 2008 at 12:01 AM
Updated Oct 2, 2019 at 2:30 PM
(EDITORS NOTE: This story originally published in The Palm Beach Post on July 25,
2006)
Billionaire money manager and Palm Beach part-time resident Jeffrey 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.
Epstein, 53, was booked at the Palm Beach County jail attA5 a.m. Sunday. He
was released on $3,000 bond.
Epstein's case is unusual in that suspected prostitution johns are usually charged
with a misdemeanor, and even a felo arge-is typically made in a criminal
information - an alternative to an t charging a person with the
commission of a crime.
His attorney, Jack Goldbrrgetr, 'ned to discuss the charge.
State attorney's office spokesman Mike Edmondson also had little to say.
,
'Generally \ king, there is a case that has a number of different aspects to it," sEdmond sat f a prostitution -related charge being submitted to a grand jury.
"W e aware of the case months ago by Palm Beach police."
Prosecutors and police worked together to bring the case to the grand jury, he
said.
littncllemw ristmlantlinnat rnm/nowaMMAAMIfintlirtmAnt.hillinnaireanfrieseLlaireben in
CA/ArOpiteN991180. 09ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735736
tittitgat?
0uto : patronage Joecneo a I met • neva • ine rail) macaw rwn coat rt.
Palm Beach police confirmed that and said the department will release a report
today regarding its investigation.
pool and a boat dock on the Intracoastal Waterway since 1990, acc at
a
property records. A man answering the door there Monday s ein
wasn't home. A Cadillac Escalade registered to him was park driveway,
which is flanked by two massive gargoyles.
Epstein sued Property Appraiser Gary Nikolits in kl );'cpntending that the
assessment of his home exceeded its fair market value. He dismissed his lawsuit
in December 2002.
AA" Epstein has owned a five-bedroom, 7 I/2 -bath, 7,234-square -foot hom
A profile of Epstein in Vanity Fair magazine said he owns what are believed to
be the largest private homes in Manhattan - 51,000 square feet - and in New
Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the
U.S. Virgin Islands and fleet of aitcraft
Epstein's friends and admirers, according to the magazine, include prominent
businessmen, academics and scientists and famed Harvard law professor Alan
Dershowirz.
liftnc.//www nolnthnerhanet anm/nowa.O/O11117111/1MichnitniJalesnialta.,nagiliktLitiment 2/7
CA/AroPPLW9k /Legl BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 I :04:39 PM
EFTA02735737
sl ier eongilloimonatre races soncianon cnarge • news - ine ram oea nest ram beam. rt.
The Palm Beach Post REAL NEWS STARTS HERE
After long probe, billionaire faces solicitation
charge Posted Jul 27, 2006 at 12.01 AM
Updated Oct 3, 2019 at 3:11 PM
(EDITOR'S NOTE: This story originally published in The Palm Beach PostonAk
2OD6)
Palm Beach billionaire Jeffrey Epstein paid to have underage o ng
women brought to his home, where he received massages and metimes sex;
according to an investigation by the Palm Beach Policepeparjment.
Palm Beach police spent months sifting through EPasqrash and watching his
waterfront home and Palm Beach International Airport to keep tabs on his
private jet. An indictment charging Epstein! 53, was unsealed Monday, charging
him with one count of felony solicitation.of prostitution.
Palm Beach police thought the a bable cause to charge Epstein with
unlawful sex acts with a d and lascivious molestation.
Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's
handling of the case that he wrote a memo suggesting the county's top
prosecutor cl. ualify himself. e s t
o examine the unusual course that your office's handling of this
n and consider if good and sufficient reason exists to require your
cation from the prosecution of these cases: Reiter wrote in a May 1
memo to Krischer.
While not commenting specifically on the Epstein case, Mike Edmondson,
spokesman for the state attorney, said his office presents cases other than
murders to a grand jury when there are questions about witnesses' credibility and
their ability to testify.
hrtne /Mewls nalrnhoarAntnt raminswanfIlIAA727/after-Innn.nrnhA-Nlitnnaum-farn-AcnIseitatIOSMOIVIR 1111.
cAmropirtypria2 ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735738
11110ZUIV ATM ouponage races soacrravon cnarge • news • ine ram sr - west ram wain. rt
According to police documents:
- A Palm Beach Community College
the nude, then brought him six
sessions at his home.
Bythe nature of their jobs, police officers look at evidence from a one-sided
perspective," Edmondson said. "A prosecutor has to look at it in a much broader
fashion,' weighing the veracity of witnesses and how they may fare under
defense attorneys' questioning, he said.
Epstein's attorney, Jack Goldberger, said his client committed no crimes.
"The reports and statements in question refer to false accusations that were not
charged because the Palm Beach County state attorney questioned the credibility
of the witnesses," Goldberger said. A county grand jury "found the. allegations
wholly unsubstantiated and not credible," and that's why his client was not
charged with sexual activity with minors, he said.
Goldberger said Epstein passed a lie detector test administered'by a reputable
polygraph examiner in which he said he did not !mow the girls were minors.
Also, a search warrant served on Epstein's home
fon1,% ,)
n,d ence to
corroborate the girls' allegations, Goldberger said. '
t
nt said she gave Epstein a massage in
ges 4 to 16, for massage and sex-tinged
- A 27-year-old woman who woFked as Epstein's personal assistant also
facilitated the liaisons, phoning the PBCC student to arrange for girls when
Epstein was coming to town. And she escorted the girls upstairs when they
arrived, putting fresh sheets on a massage table and placing massage oils nearby.
- Police took sworn statements from five alleged victims and 17 witnesses. They
contend that on three occasions, Epstein had sex with the girls.
A money manager for the ultra -rich, Epstein was named one of New York's most
eligible bachelors in 2003 by The New York Post, He reportedly hobnobs with
the likes of former President Clinton, former Harvard University President
Summers and Donald Trump, and has lavish homes in Manhattan,
New Mexico and the Virgin Islands.
httniv/Mtunm nalmhamehnnet enonlnee.va/WIR41777/014...Innet.nenha.hillinnalroaratanPritstinn-Hism.
CA/Aropirteat1,83, VALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735739
mil/tin? ester ion oiwonaire races sonatauon cnarge - news • I ne run ce - nest ralrll beam, N.
He has contributed tens of thousands of dollars to Democratic Party candidates
and organizations, including Sen. John Kerry's presidential bid, and the Senate
campaigns of Joe Hillary Clinton, Dodd and Charles
Schumer.
Goldberger is one of five attorneys EpsteV tained since he became the
subject of an investigation, Edmondson, saiNatong the others: Alan
Dershowitz, the well-known Harvard lawprofessor and author, who is a friend
of Epstein. Dershowitz could of beceathed for comment.Ak i
Police said the woman vCenl d young girls for Epstein was
20, of Palm Beach. Robson has worked at an Olive Garden restaurant in
Wellington and sat as a journalism major at Palm Beach Community
College whe he w questioned by police last October. She has an unlisted c
phone nun<be d could not be reached for comment.
Rob 'd she met Epstein when, at age 17, a friend asked her if she would like
money giving him a massage. She said she was driven to his five-
bedroom, 7 1/2 -bath home on the Intracoastal Waterway, then escorted upstairs
to a bedroom with a massage table and oils. Epstein and were both naked
during the massage, she said, but when he grabbed her buttocks, she said she
didn't want to be touched.
httna l/www nalmhostritnnat evirninonantntrIAA72 7/allar.lnnn-nrethpaqtlinnair•-farn.anGnistinnatarno
CA/Aronlaerac001184 r rAuv1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735740
11/11/1Q1 Now K. . . omsoname inn soncaauon coarse - News - Ina raw twAIDI - vvesi ram Noma, ri.ns
Epstein said he'd pay her to bring him more girls - the younger the better,
= told police. When she tried once to bring a 23-year-old woman to him,
Epstein said she was too old said.
, who has not been charged in the case, said she eventually brought six
girls to Epstein who were paid $200 each time, said. "I'm like a Heidi
Fleiss," police quoted her as saying. The girls knew what to expect when they
were taken to Epstein's horne,= said. Give a massage - maybe naked - and
allow some touching.
One 14-year -old girl= took to meet Epstein led police to start the
investigation of him in March 2005. A relative of the girl called to say she
thought the child had recently engaged in sex with a Palm Beach man.The girl
then got into a fight with a classmate who accused her of beingliacistitute, and
she couldn't explain why she had $300 in her purse.
The girl gave police this account of her meeting
She accompanied and a second giilststi
February 2005. Once there, a woman slie th t was Epstein's assistant told the
girl to follow her upstairs to a roornfeaturing a mural of a naked woman, several
photographs of naked women on %shelf; a hot pink and sofa and a massage
table.
's house on a Sunday in
She stripped to her bra ai hties and gave him a massage.
Epstein gave the 14 ea-old $300 and she and the other girls left, she said. She
said Robs, tcl her that Epstein paid her $200 that day.
a
Ot r Id similar stories. In most accounts, Epstein's personal assistant at
arah now 27, escorted the girls to Epstein's bedroom.
, whose most recent known address is in North Carolina, has not been
charged in the case.
Palm Beach police often conducted surveillance of Epstein's home, and at Palm
Beach International Airport to see if his private jet was there, so they would
know when he was in town. Police also arranged repeatedly to receive his trash
httnt. ItgivAv nalmilviarAnnet nronlnww•JXICIA117,7laflor-Innn-nrnhatillinnakatarnantritatinn-rAsmo 4./S
GA/Aropiteg991185, 09Auvi BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735741
Ill rllNri miser to monist us souczun cnarge - news ne ram - west ram weacn. r s
from Palm Beach sanitation workers, collecting papers with names and phone
numbers, sex toys and female hygiene products.
One note stated that a female could not come over at 7 p.m. because of soccer.
Another said a girl had to work Sunday - "Monday after school?" And still
another note contained the work hours of a girl, saying she leaves school at 11:30
a.m. and would come over the next day at 10:30 a.m.
Only three months before the police department probe. began, Epstein donated.
890,000 to the department for the purchase of a firearms simulator, said Jane
Struder, town finance director. The purchase was never made. The mo riic'was
returned to Epstein on Monday, she said.
heint -M,inv natraluarimne. rorfnmfazi7MR/1727/afti.annitaiiiNti".hiNinnalmJsen-italieitalinneham• S/S
CA/Aronbarat0at1.86, r LEI) FALAI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735742
II/II/(Ull, roil nye( tneo to ono:eon teenage gins - news - earn beam - num 01101.
Palm Beach Daily News
Police say lawyer tried to discredit teenage
girls Posted Jul 29, 2006 at 12:01 AM
Updated Oct 3, 2019 at 2:00 PM
(EDITOR'S NOTE: This story originally was published in The Palm Beath Postal
29, 24176)
Famed Harvard law professor Man Dershowitz met with the Patin acb County
State Attorney's Office and provided damaging information about teenage girls
who say they gave his client, Palm Beach billionaire Jeffrey Eta, sexually
charged massages; according to police reports.
The reports also state that another Epstein attorney agreed to a plea bargain that
would have allowed Epstein to have no criminal record. His current attorney
denies this happened.
And the documents also reveal that the father of at least one girl complained that
private investigators aggressively followed his car, photographed his home and
chased off visitors.
Police also talked to somebody who said she was offered money if she refused to
cooperate with the Palm Beach Police Department probe of Epstein.
The state attorney's office said it presented the Epstein case to a county grand
jury this month rather than directly charging Epstein because of concerns about
the.girlal credibility. The grand jury indicted Epstein, 53, on a single count of
felony solicitation of prostitution, which carries a maximum penalty of five years
in prison.
Police believed there was probable cause to charge Epstein with the more serious
crimes of unlawful sex acts with a minor and lewd and lascivious molestation.
Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
)(Tischer a memo in May suggesting he disqualify himself from the case.
den. Mee.w nalmbearh4advn4w4 net/amel•ThlaW17,11/14FINS/141101 747A 1/4
CA/Aropliegi0 9t1947. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735743
lull/suns r rueo to [Phone Redacted] teenage gins - news - ram Deem u ws - ram oeacn, rt.
The case originally was going to be presented to the grand jury in February, but
was postponed after Dershowitz produced information gleaned from the Web
site myspace.com showing some of the alleged victims commenting on alcohol
and marijuana use, according to the police report prepared by Detective=
Recarey.
a 20-year-old= Palm Beach woman who told police she
recruited girls for Epstein, also is profiled on myspace.com. Her page includes
photos of her and her friends, including one using the name "Pimpin' Made
M t, who was not charged in the case, is a potential prosecution wit
According to Recarey, prosecutor Lanna Belohlavek offered Epste
Dershowit2 and Guy Fronstin a plea deal in April. Fronstin, r sp rig with
Epstein, accepted the deal, in which Epstein would plead guil o one count of
aggravated assault with intent to commit a felony, be placed on five years'
probation and have no criminal record. The deal also called for Epstein to submit
to a psychiatric and sexual evaluation and have no unsupervised visits with
minors, according to Recarey's report. The plea bargain was made in connection
with only one of the five alleged victims, the,report states.
Fronstin - who declined to comment on the case - was subsequently fired and
veteran defense attorney Jack Goldhexger was hired. He denies there was any
agreement by any of Eps 'Tits at,rneys to a plea deal.
"We absolutely did not ag o a plea in this case," he said. Neither Belohlavek
nor a state attorney's spokesman could be reached for comment.
The parent or parents of alleged victims who complained of being harassed by
private investigators provided license tag numbers of two of the men. Police
found the vehicles were registered to a private eye in West Palm Beach and
another in Jupiter, according to Recarey's report.
"I have no knowledge of it: defense attorney Goldberger said.
The report also says a woman connected to the Epstein case was contacted by
somebody who was still in touch with Epstein. That person told her she would
be compensated if she didn't cooperate with police, Recarey's report says. Those
hitivrmaur rtabythaseittaikon•Ao% ervneIrsetennevar>onurwrm ano 7S7.7
cA/AmPlisettiNXI,11 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
7/.1
EFTA02735744
!I/II/Gt./1y r mei 10 =cream teenage gm - News - raim beam • Yeire meal, m-aceallsye
who did talk "will be dealt with," the woman said she was told. Phone records
show the woman talked with the person who allegedly intimidated her around
the time she said, Recarey reported.
Phone records also show that the person said to have made the threat then
placed a call to Epstein's personal assistant, who in turn called a New York
corporation affiliated with Epstein, the report states.
The issue in the Epstein case is not whether females came to his waterfront I
home, but whether he knew their ages.
"He's never denied girls came to the house," Goldberger said. But when %ein
was given a polygraph test, "he passed on knowledge of age,' e atNine c said.
After the indictment against Epstein was unsealed this weekyolice Chief Reiter
referred the matter to the FBI. "Cfe've received the referral, and we're reviewing
it," said FBI spokeswoman Judy Orihuela in Miami.
The chief himself has come under attack from a lawyers and friends in
New York, where he has a home. The New Yell Post quoted Epstein's
prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
only "because of the craziness of the polite chief."
Reiter has declined to comment on the case.
Prosecutors have not presented a sex-related case like Epstein's to a grand jury
before, said Mike Edmondson, spokesman for the state attorney's office. "That's
what you do with a case that falls into a gray area; he said.
The state attorney's office did not recommend a particular criminal charge on
which to indict Epstein, Edmondson said. The grand jury was presented with a
list of charges from highest to lowest, then deliberated with the prosecutor out of
the room, he said.
"People are surprised at the grand jury proceeding," West Palm Beach defense
attorney Richard Tendler said. "It's a way for the prosecutor's office to not take
the full responsibility for not filing the (charge), and not doing what the Palm
Beach Police Department wanted. I think something fell apart with those
underage witnesses."
httralhinona nalmhnetteialhownsm eranhteWW41770/NMS/11:100 • 7S73
CA/Ar9119{95 9. ilkr#1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
va
EFTA02735745
tut titula YOH f meg to OISCIEOrt teenage gun • NEWS - rain, macro Ld pWS - ran MEM. rt.
Defense attorney Robert Gershman was a prosecutor for six years. "Those girls
must have been incredible or untrustworthy, I don't know," he said.
Other attorneys said Epstein's case raises the issue of whether wealthy, connected
defendants like Epstein - whose friends include former President Clinton and
Donald Trump - are treated differently from others. Once he knew he was the
subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as
Dershowitz and Lefcourt, who is a past president of the National Association of
Criminal Defense Lawyers.
Antic
Miami lawyer Roy Black - who became nationally known when he sue tlly
defended William Kennedy on a rape charge in Palm Beach
involved at one point.
Said defense attorney Suskauer: "I think it's unfortunate the public may
get the perception that with power, you may be treated*fe3ently than the
average Joe."
i tert -thwav radmhantirbilvrwrom enrninfirieMIR177R/NFINSJIAECII7A71 AM
CA/Arop 94t1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735746
Tte Palm Beach Pot REAL HMS STARES HERE
Expert: Ignorance of age isn't
defense in sex cases Posted Aug 5, 2006 at 12:01 AM
Updated Oct 3, 2019 at 1:38 PM
(EDITOR'S NOTE: This story originally published in The
Palm Beach Post on Aug. 5, 2006)
Even if Palm Beach money manager Jeffrey Epstein didn't
know that girls who police say gave him sexual massages at
his Intracoastal home were under the legal age, that alone
wouldn't have exempted him from criminal charges of
sexual activity with minors.
"Ignorance is not a valid defense," said Bob Dekle, a legal
skills professor who was a LakeCity prosecutor for nearly
30 years, half of that tune specializiog in sex crimes against
children.
"There is no knowledge element as far as the age is
concerned," Dekle said.
After an II -month investigation, Palm Beach police said
there was probable cause to charge Epstein, 53, with
unlawful sex acts with a minor and lewd and lascivious
Molestation. They contend that Epstein - friend of the rich
—and famous and financial patron of Democratic Party
organizations and candidates - committed those acts with
five underage girls.
In the past week, New York AttorneyGeneral and
gubernatorial candidate Eliot Spitzer has returned about
S50,000 in campaign contributions he received from
Epstein, and Mark , a candidate to replace Spitzer in
CA/ArOpknoatia PAL .41 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735747
his cure job, has returned 510,000 to him becausAte
Palm Beach scandal, the New York Daily News has
reported.
Rather than file charges, the state attorney's office
presented the case to a county grand jury. The panel
indicted Epstein last week on a single, less serious charge of
felony solicitation of prostitution.
The case raised eyebrows because the state attorney's office
rarely, if ever, kicks such charges to a grand jury. And it
increases the difficulty of prosecuting child sex abuse cases,
especially when the defendant is enormously wealthy
can hire high-priced, top-tier lawyers.
At least one of Epstein's alleged victims told e Sew
she was underage when the two of them got ink for
massages and sexual activity. She was 16 years old at the
time and said Epstein asked her questions about her high
school, according to police reports.
A girl who said she met Epstein when she was 15 said he
told her if she told anybodywhat happened at his house,
bad things could happen, the police reports state.
Epstein's youngest alleged victim was 14 when she says she
gave him a/ massage that included some sexual activity. She
is~w 16. The girl's father says he doesn't know whether
Epstein her age.
a y daughter has kept a lot of what happened from me
because of sheer embarrassment," he said. "But she very
much looked 14. Any prudent man would have had second
thoughts about that."
Defense attorney Jack Goldberger maintains that not only
did Epstein pass a polygraph test showing he did not know
the girls were minors, but their stories weren't credible.
The state attorney's office also implied that their credibility
was an issue when it decided not to charge Epstein directly,
but instead give the case to the grand jury.
CAJAropilen1192 99 AUNI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735748
"A prilltor has to look at it in a much broader fa," a
state attorney's spokesman said last week.
3IN4 r,e 3t 14,Cis Cap
r.
CO
Epstein hired Harvard law Professor Alan .1:Cnnto 'tz
when he became aware he was under investigation, and
Dershowitz gave prosecutors information that some of the
alleged victims had spoke of using ikohol and marijuana on
a popular Web site, according to a Palm Beach police
report.
Prosecutors typically consider two things in deciding
whether to charge somebody with sex-related offenses
against minors - whether there. is sufficient evidence and
whether is a public interest in doing so, DItle said.
ic o teens are in a sexual relationship and the boy turns
before the girl, he could be charged with a sex crime if
sex continues. There would be no public interest in
pursuing that, Dekle said.
But where there is a large gap in ages - and especially in
cases of teachers with students - there is a public interest in
prosecuting, he said. Likewise if the accused has a track
record of sex with minors.
CA/Aropirm0 arkt alm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735749
Still the a "universal constant" in prosecuting thili
cases, Dekle said. Men who exploit underage children for
sex often carefully choose their victims in ways that will
minimize the risk to them, he said.
Victims usually are from a lower social status, and they may
suffer from psychological problems, Dekle said.
"Lots of child sexual abuse victims have been victimized by
multiple people over a period of time. Then the act of abuse
produces behavior in the victims that further damages their
credibility." Examples include promiscuous behavior and
drug abuse.
Some of the alleged victims in the Epstein case returned to
his home multiple times for the massage sessions and The
8200 to $300 he typically paid them per visit. "That would
1%5 be a definite problem for the prosecut , d Betty Resch,
who prosecuted crimes against childfe . alm Beach
County for five years and now • s . vate practice in Lake cs ,
,A'
"The victim becomes lesssympathetic" to a jury, Resch said.
"But she's a victim'nevertheless. She's a kid."
Most men charted with sex crimes against minors look
normal, Dekle said. A jury expecting to see a monster
seldom will. And the victims' ages work against them and in
favor of the defendant in a trial, Dekle said.
Worth.
if a child and an adult tell different stories and both swear
they're telling the truth, adult jurors are more likely to
believe the adult, Dekle said.
"You have all these things working against you in a child
sex abuse case. Prosecutors normally try to be very careful
in filing those cases because they know what they're getting
into. There is no such thing as an iron-dad child sexual
abuse case."
CA/ArctirE rt99X /L9A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735750
T,e Palm Beach Post HESS KERE
Epstein campicallsimicale attars
liars Posted Aug 8, 2006 at 12:01 AM
Updated Oct 3, 2019 at 3:35 PM
(EDITORS NOM: This Slaty originally pulilisheel in The
Palm Beach Post on Ant g Iwo
Attorneys and publicists for Palm Beach financier Jeffre AS A
Epstein went on the.offensive Monday, contending a
teenage girls who have accused Epstein of sexual
shenanigans at his waterfront home are liar
that the Palm Beach Police Department
"There :never was any sex betty and any
underage women," his lead a Goldberger, said
from Idaho where he was i0 • g with his family..
Epstein did haveyti come to his housetolive
him massages, said. "Mr. Epstein absolutely
insisted an came to his house be over the age of
18. Ho he ve that,. I don't know; The question is,.did
anythin l occur. The law was hot violated here.'
no explanation as to why Epstein would paygirb or
men with no massage training - as the alleged victims
'd was the case - 8200 to $300 for their visits. 'The
credibility of these witnesses has been seriously
questioned, Goldberger said.
Epstein, 53, was indicted by a county grand jury last month
on a charge of felony solicitation of prostitution. After an
11-month investigation that included sifting through
Epstein's trash and surveilling his home, Palm Beach police
concluded there was enough evidence to charge him with
sexual activity with minors. When the grand )ury indicted
CA/ArOpitettpill ALI% BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735751
Epstei• the less serious charge, Police Chief Mill)
Reiter referred the case to the FBI to determine whether
there were federal law violations.
After a spate of stories about the case last week, New York
publicist Dan Klores - whose client list has included Paris
Hilton and Jennifer.. - said on Saturday that Epstein's
camp was ready "to get their story out."
They did that Monday via Goldberger and a Los Angeles
publicist for Miami criminal defense attorney Roy Black,
who also has represented Epstein in the case.
"We just think there has been a distorted view of t
in the media presented by the Palm Beach police:
Goldberger said.
‘Th Reiter has consistently declined to comment on the case
and did not respond to a request fo -comment Monday. 1/4
The implication that State Attorney Barry Krischer was
easy on Epstein by presenting the case to a grand jury
rather than filing charges directly against him is wrong,
Goldberger said.
CA/ArOpeifi-99 AL1.i9 M. BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735752
The PI/teach Police Department was "happy and®
ecstatic" that the panel was going to review the evidence. 1
think what happened is they weren't happy with the result.
They decided to use the press to embarrass Mr. Epstein?
But records show that Reiter wrote Krischer on May 1 -
well before the case went to the grand jury - suggesting that
Krischer 'consider if good and sufficient reason exists to
require your disqualification from the prosecution of these
cases."
Rather than flat-out decline to charge Epstein, Krischer
referred the case to the grand jury to "appease" the chief,
Goldberger said.
A state attorney's spokesman would say only that the office
refers cases to the grand jury when there are issueswith the
viability of the evidence or witnesses credibility.
Both the state attorney and thegrand jury concluded there
was not sufficient evidence that Epstein had sex with
minors, according to Goldberger. "it was just a childish
performance by thefalm Beach Police Department,"
Goldberger said.
The defense attorney said one of the alleged victims who
claimed she was a minor was in fact over the age of 18.
Another alleged victim who was subpoenaed to testify to
the grand jury failed to do so. Epstein's accusers, he added,
have histories of drug abuse and thefts. "These women are
liars. We've established that."
But why would they all invent their stories about meeting
Epstein for sexual massages?
1 don't have an answer as to what was the motivation for
these women to come forward and make these allegations,"
Goldberger said.
CAlikutPitegt:ML 9g4 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735753
•
Aft::;). • 4.ww.t.yri -
- Cloiericads0 corkre 11.2019
• The Palm Beach Post (Wasl Palm Beach, Ronda) • 10 Aug 20:6. WA. Pap 7
Palm Rltilvtlite{ locus
of !rt. in Epstein eaH,
aviHei, „:,it2.5.4. tri tiaist rize42
re-littiati t ; ; 140 4 0 9tt -' 7rPt2
•,— .....‘,..C .: ' - I:4iit ic "- ..: - i '•• ' .; 81,‘
" "s ".cnifi'Mgl irttrg t lit.
i t • . i..
...". I * 14 4- 'sr •- 0 0414,i: tin ....?, ....
ro:L " Iti lir . l: 77: 44:P e1/2 4.;4116211;71 1: ::::: )...taMon.t -itif.14.1-; tte TO:, avateme 'eta ..
4 .444 • Creett".. r... l
4a21‘114 11'; 'Mt-. .N4 w.«
I:..4.:617:47;.t.,....riH.7114:-.4:147t 1":;;I tt rt1/4 14 C.4.47% %litliri g it4 :1. ;
. -- .c.lauelke'fa Wild ,e4 .7 aopeallt4 r . ist ,...N.
tuts. i.i.e.% laj•Ive..pilarem• . An' ,Lit, ,, ,,at.eant• 4, arsiKooliCt..1430t. lq .
*Wallgittgla s ....r.itl iZet tair4tte .41 .:
Ow:. sable- :t r." S Ire.:111,W ,•11 t ,...r,
001..i.„..-”UP,41.1",060,4k,'Itn rab-i•ra•dal.44;enihlt:f
ti
ic.f.r SV.tptir ri4-44';;.••:.;4 4.#.14;"8 -4 4.4 4 te.r•alo'W ...• ilm ara.. 41; 41.1t. k g:
:retti. 1)1 1ra C 4:4.1AN; • Cdra.WelitreZ 71;4 7/1•,......ruetto .,- tw.....t..e0sn.r a eit.07..i .....0.
altar 40 Irirtil.;,- OZ‘edite•et.rp•rds
.....1 ..;"4 .e" . :::= 1. .... f:114 i'V. :41 ,4: 61 14"4 1 1.1).. t."1.yet % ‘
41.11/1”...r. rkillre". ....lt."'" Ti er -q, ..,waz nwmaffintr fie .-zz,„,,,q..„42:,. .4..attrqwma4 •Tatn;"","' abectirt.t e lo .4 k1 4.P.14%j ,ZIT Y: "Ctin ..4cji t. 31 4.1.7.... C .4 .r.-
t enitri72,11'43,,61} ....:7:r .::.
i*44 • "-- - ' ". .1.
daritAgitAratThe-I' t ••• 04.iI
At e2 . gNat. • '
S::trz•L'szteareti•
Reiter focus of fire in Epstein case
Clipped By:
..,2, I refit] . m
lw Sat. Ape 22. 2017
Copyright O 2019 Newspapers.com. All Rights Reserved. •
CAMM PFL e t9599X151 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735754
lt Palm Beach Post REAL NEWS STARTS KBE
Delays in Epstein case unusual,
lawyers say Posted Mar 13, 2007 at 12.01 AM
Updated Oct 3, 2019 at 3:48 PM
(EDITORS NOTE: This story originally published in The Palm
Beach Post March 13, 2W7)
A federal probe or a plea deal could explain the wait in
Palm Beacher's solicitation case. C
Nearly eight months after Palm Beach tycoon)•• ey eitiss
Epstein was charged with felony solicitation of pr titution,
there has been no discernible progress in his case. No
witnesses deposed. No trial date set. Nothing, save for
routine court hearings reset without explanation.
"Usually that would be unusuar said criminal defense
attorney Glenn Mimbell, who has no involvement in the
case.
"As a general rule, it would be unusual for nothing to have
happened;" ag. Michael Dutko, a criminal defense
attorney in Fort Lauderdale. He represents
20, of Palm Beach, potentially a key witness in the
case.
A routine hearing for Epstein was pulled from the court
docket last week and reset for May 16. The delays and
inaction could be due to a potential federal probe of Epstein
or because a plea deal is in the works, attorneys say.
Unusual is the word that best describes everything about
the case against Epstein, 54, an enigmatic money manager
in New York City who counts Bill Clinton and Donald
Trump among his friends.
CA/AropberatQ 2. ELT:O7 0 V1AL19 M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735755
"Highleusuar is how Palm Beach Police Chief Mieel
Reiter described State Attorney Barry Krischer's handling
of the case in a bluntly critical letter to Krischer last year
before Epstein was indicted.
Reiter referred the matter to the FBI to determine whether
any federal laws had been violated. Epstein's allies
countered by attacking the chief personally and
professionally.
Reiter's department investigated Epstein for I I months.
Police sifted repeatedly through his trash and conducted
surveillance on his five-bedroom, 7 I/2 -bath, 7,234-squ
foot home on the Intracoastal Waterway.
Police said Epstein paid women and girls as 14 to
give him erotic massages at his hortie. Police cm t there
was probable cause to charge him with unlawful sex acts
with a minor and lewd and lascivMus molestation.
Epstein responded by hiring a phalanx of lawyers. One of
them, Harvard law professor and author Alan Dershowitz,
provided the state attorney's office with information about
alcohol andErijuana use by some of the girls who said
they were with Epstein.
Prosecuto7 then referred the case to the grand jury rather
than file charges directly against Epstein.
Epstein's attorneys deny he had sex with underage girls.
_The lawyers say the girls' stories are not credible. But if the
court file is any indicator, they've made no effort to depose
the girls.
Neither prosecutors nor defense attorneys have sought to
question Robson, said Dutko, her attorney. She recruited
teenage girls to visit Epstein for massages and sexual
activity, Palm Beach police said, and presumably would be a
key witness.
CA/ARTIM99 1a.C91 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735756
Epsteilittomey Jack Goldberger did not return phi1
messages.
A source dose to the case suggested it is languishing
pending a decision by the FBI on whether to refer it to
federal prosecutors.
"We still have a pending case," FBI spokeswoman Judy
Orihuela said Monday.
State Attorney Krischer did not return a call for comment.
His spokesman, Mike Edmondson, declined to say whether
federal investigators are delaying the Epstein case. But,
Cadded, "if another agency is looking at something, w
wouldn't want to step on their toes."
Attorneys say inertia in a criminal case oft to a
pending plea deal.
\t'"It would not surprise me if sOmeCutg h happened that's
not reflected in the court file," said Dutko, such as an
agreement that will be formalized later.
Defense attorney Marc Shiner said defense attorneys
sometimes put off overtly conducting discovery -- deposing
witnesses, requesting documents and the like -- because
doing soicreates more work for harried prosecutors who
icy become angry and not offer a plea deal.
O
d
ordetitnes defense lawyers, knowing that, will try and do
covery without taking depositions," said Shiner, a former
a prosecutor for 13 years.
Instead, they may conduct a below-the-radar probe such as
having a private investigator check out leads, he said.
Shiner and others say a plea deal for Epstein probably
would result in pretrial intervention, in which a defendant
may be ordered to undergo a psychological evaluation,
counseling or other conditions in return for dropping the
charge.
GA/AroppLeRpa120.1 rtuiLivl BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735757
Edmoilln, spokesman for State Attorney Krischeill
there is no plea offer and nci request for the prosecution to
show its cards.
"To my knowledge, it's never happened before on a filed
case,' he said.
A Cos
CIVArTIMPAN BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735758
252 / 278 - Thursday, October 18, 2007
Edition:'FINAL
Section: LOCAL
Page: 5B
Source: The Associated Press
Illustration: PHOTO (B&W)
Mario: Rah all editions.
Dateline: NEW YORK
WOMAN:SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN S$E1WAS.16
A billionaire investor, already facing jail in Palm Beach County on charges of soli underage
prostitutes, is being sired by it ytamg woman who says he had sex with her 16 and had
sought his help becoming a model.
C i6The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says man effrey Epstein had
the teen perform a sex act when she brought photographs of herself for .h to view in his Upper
East Side mansion sometime in 2000.
Epstein, 54, a money manager, told the teen he managed Imam toria's Secret and "could get
you into the catalog" if she were."nice" to him, coutt papers - • <pers say being "nice"
included massages and other favors.
When the girl told Epstein, "I am 16 yeals 61d and just
won't tell anybody," court papers say,..
Epstein, said by London's Mail on Sunday to be
indicted in Palm Beach on charges of soliciting u
The girl visited Epstein "several times over the sev
sex acts" while she was a minor, the lawEit says.
Epstein "repeatedly requested that (theagirl) return with her 14-, 15-, and 16-year-Old girlfriends,
stating, 'Come by with your friend ur age next time. Dona bring Sherrie (a mutual friend in her
40s). I love girls your age? "
The young woman, now 23, kept relhwrTng to Epstein because she has "mental issues," said her
lawyer, William J. Unroch. ed to elaborate, but court papers say she Was "disabled as a tetult
of severe mental diseas and. f t"
Epstein's lawyer in York, ld Lefcourt, said, "The girl has admitted she is insane, but she can
read a newspaper "ze the word 'rich.'"
.Lefcourt also to of limitations has expired for the woman's case criminally and Civilly,
and will aim ly be dismissed..
He refus ent on Epstein's Florida charges.
Meanwhile, h, 57, also acknowledged that his client was living.with hint and was at the center
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 doing at 22 is irrelevant to what happened to her when she was 16," Unroch said
Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client.and resolve
the case out of court.
I," he replied, "Don't worry, I
of England's Prince Andrew, has been
prostitutes. That case is pending.
months.arid engaged in bizarre and unnatural
CA/AropkeN599120.1. Pa;ivi BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735759
The Palm Beach Post REAL REY6 STARTS HERE
Palm Reacher pleads in sex case Posted Jul 1, 2008 at 12:01 AM
Updated Oct 3, 2019 at 1:47 PM
(EDITOR'S NOTE: This story originally published in The
Palm Beach Post on July 1, 2008)
Jeffrey Epstein will serve 1 1/2 years on teen solicitation A40041
charges.
He lives in a Palm Beach waterfront mansion and h kepicY
company with the likes of President Clinton, Prince
Andrew and Donald Trump, but investment banker Jeffrey
Epstein will call the Palm Beach County Jail horite for the
next 18 months.
Epstein, 55, pleaded guilty Monday toielony solicitation of
prostitution and procuring a person under the age of 18 for
prostitution. After serving 18 months in jail, he will be
under house arrest for a year. And he will have a lifelong
obligation to register as a sex offender. He must submit to
an HIV test within 48 hours, with the results being
provided to.his victims or their parents.
As part of the plea deal, federal investigators agreed to drop
their investigation of Epstein, which they had taken to a
grand jury, two law enforcement sources said.
Epstein was indicted two years ago.after an 11-month
investigation by Palm Beach police. They received a
complaint from a relative of a 14-year-old girl who had
given Epstein a naked massage at his five-bedroom, 7,234-
square-foot, $8.5 million Intracoastal home.
Police concluded that there were several other girls brought
in 2004 and 2005 to an upstairs room at the home for
similar massages and sexual touching.
CA/Aronhaerac0atw 1-112:1): rAuv1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735760
The itement charged Epstein only with felony 0
solicitation of prostitution. The state attorney's office later
added the charge of procuring underage girls for that
purpose.
Prosecutor Lanna Belohlavek said of the plea: "I took into
consideration the length the trial would have been and
witnesses having to testify" about sometimes embarrassing
incidents.
Epstein may have made a serious mistake soon after he was
charged. He rejected an offer to plead guilty to one count of
aggravated assault with intent to commit a felony,
according to police documents. He would have gott
years' probation, had no criminal record and not b
registered sex offender, the documents indic2te
Epstein arrived in court Monday with a 1free
attorneys. He wore a blue blazer, ue shin, blue jeans and
1 .and gray sneakers. Afte • t Judge Deborah Dale
elSPucillo accepted the plea, 4 as Fingerprinted. Epstein
then removed his blazer and w s handcuffed for the trip to
jail while his attor dif ird to shield him from
photographer ' len
d
c i
When he even y is released to house arrest, Epstein will
have to observe a 10 p.m. to 6 a.m. curfew, have no
Ks• supervised contact with anyone younger than 18 and
O1eit pornographic er own nor possess or sexual materials
at are relevant to your deviant behavior,' the judge said.
Epstein will be allowed to leave home for work. The New
York-based money manager told the judge he has formed
the not-for-profit Florida Science Foundation to finance
scientific research. "I'm there every day," Epstein said.
The foundation was incorporated in November. Epstein
said he already has awarded money to Harvard and MIT.
CAlArTirE1599X 2LCA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735761
When. released from jail, there is a chance that inein
will be forced to move. Sex offenders are not allowed to live
within 1,000 feet of a school, park or other areas where
children may gather. No determination has been made as to
whether Epstein's home complies, but attorneys said it
likely does.
Sex offenders also typically must attend counseling sessions.
Belohlavek said that was waived for Epstein because his
private psychiatrist is working with him. The judge was
skeptical but agreed to it.
Epstein's legal woes don't end with Monday's plea. There
are four pending federal civil lawsuits and one in state court
related to his behavior. At least one woman has sued himin
New York, where he owns a 51,000-square- Manhattan
mansion.
t"It's validation of what we're sayin ' cases," said
Miami attorney Jeffrey Herm "resents the alleged
victims in the federal laws alm Beach attorney
Ted Leopold represen a alle ed victim in a civil suit in
state court. He sa' pates amending that lawsuit to
add "a few otherth well.
iIn the criminal , police went so far as to scour Epstein's
trash and conduct surveillance at Palm Beach International
Airport, where they watched for his private jet so they
would Icnoi.v when he was in town. They concluded that
EL paid girls 8200 to 5300 each after the massage
sessions.
"I'm like a Heidi Fleiss," now 22, told police
about her efforts in recruiting girls for Epstein.
There was probable cause to charge Epstein with unlawful
sex acts with a minor and lewd and lascivious molestation,
police concluded.
CA/Aronlaerck0a120,a riLry: rivLm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735762
The stgittorney's office said questions about the JD
credibility led it to take the unprecedented step of
presenting the evidence against Epstein to a grand jury,
rather than directly charging him.
Palm Beach Police Chief Michael Reiter was furious with
State Attorney Barry Krischer, saying in a May 2006 letter
that the prosecutor should disqualify himself. "1 continue to
find your office's treatment of these cases highly unusual,"
he wrote. He then asked for and got a federal investigation.
Epstein hired a phalanx of high-priced lawyers - including
Harvard law professor and author Alan Dershowitz -
public relations people who questioned Reiter's co
and the victims' truthfulness.
In addition to mansions in Palm Beach and Manhattan,
Epstein owns homes in New Mexico and the Virgin Islands.
He's a frequent contributor to De o ratty Parry candidates.
He also donated S30 million t i in 2003.
Former New York Govajiot S7dtzer returned a 550,000
campaign contribution fzcri Epstein after his indictment,
i temthen resigned this 'ng his own sex scandal. And the
same Palm Beach Police Department that vigorously
investigated Epstein returned his $90,000 donation for the
purchase a firearms simulator. t'
iter Eliot Kleinberg and former staff researcher
Michelle Quigley contributed to this story.
CA/AroppLetb0A 2L,Q7,w' BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735763
Tt Palm Beach Pt REAL KM STARTS IBE
Jeffrey Epstein: Scientist,
stuntman, `sex slave' visit jailed
tycoon By LARRY / Palm Beach Post Staff Writer
Posted Aug 13, 2008 at 12:01 AM
Updated Jul 16, 2019 at 4:54 PM
Tycoon Jeffrey Epstein mingled with an eclectic mix of
people, including beautiful young women, before he got(
into trouble for paying teenage girls to give him s
massages at his Palm Beach mansion.
Not much has changed, even though he now s in a
dorm at the Palm Beach County Sher ' s s 17-acre, ic
967-bed stockade near the fairgrq i4.
\ .."" During his first month of confine ent, Epstein was visited
by the female assistant who, girls told police, had escorted
them to the room ar his Nansion where they gave him
naked massagc h
Also trekking e jail was a young woman whom Epstein
purport escribed as his Yugoslavian sex slave.
wealthy financier and science wonk also has been
•• liy 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
CA/Aropliett001.208 rA-Livi BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735764
girls o $300 in 2004 and 2005 for massages in,
home that sometimes included sexual touching, Palm Beach
police said.
His jail visitors in July included:
-==, 29, who some of the teen masseuses said
phoned them when Epstein was in town and escorted them
upon their arrival at his Palm Beach waterfront home to an
upstairs room, where she prepared the massage table and
provided the oils for their encounters with him.=
visited Epstein three times in July, according to a jail
visitor's log.. lists a Manhattan home address.
Reached by telephone, she declined to discuss Epstein.
23, whose family in Yugoslavia
Epstein paid money to so that he could bring her to the
United States to be his "sex slave," two teenage girls told
police. One girl told police that Epstein instructed
Marcinkova and her to kiss and have sex while he watched
and masturbated. Another said she engaged in sex with
la at Epstein's urging. Marcinkova visited Epstein
in jail four times in 13 days. She lists her address as on the
Upper East side of Manhattan, not far from Epstein's
enormous apaxtment.
- Roger Schenk, 62, founder of the Institute for Learning
Sciences at Northwestern University and an expert on
artificial intelligence, paid one visit to Epstein. Schank has
wtitten numerous books on that subject and has a doctorate
degree from Yale University in linguistics. He was one of 19
people who applied to be president of Florida Atlantic
University in 2003. He became "chief learning officer' at the
online Trump University in 2005. Schank listed his address
as being in Stuart, and records show he also owns a home
in Lake Worth.
CA/Arop : harac0arl2Q9, (LW ['ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735765
Epsteit financed a number of scientists over thus,
including Nobel Prize winners. He gave $30 million to
Harvard University in 2003. In November, he formed the
not-for-profit Florida Science Foundation, which he said
finances scientific research.
- Igor Zinoviev, a Russian mixed martial arts fighter, who
coaches a Chicago team in the International Fight League.
He also has worked as a personal trainer, celebrity
bodyguard and movie stuntman, according to the league's
Web site. The New Jersey resident visited Epstein seven OA'
times in July.
Zinoviev, Schank and could not be rea e
comment.
Staff researcher Niels Heimeriks contrib story,4
CA/Aropnerocootna FEW:- PNLIVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735766
0 Palm Beach Daily News
Billionaire sex offender leaves jail
six days a week for work Posted Jul 1, 2008 at 12:01 AM
Updated Oct 4, 2019 at 9:27 AM
Palm Beach billionaire Jeffrey Epstein, who's serving 18
months in jail for soliciting an underage girl for
prostitution, is allowed to leave the Palm Beach County
Stockade six days a week on a work-release program.
Teri Barbera, spokeswoman for the Palm Beach County
Sheriffs Office, confirmed that Epstein, 55, hasbeen in the
work-release program since Oct. 10.
'He works six days a week: Friday r h ednesday 10
a.m. to 10 p.m.: Barbera said • . He) works at his
local West Palm Beach office! red on an active GPS
system (he wears an ankle bracelet). Mr. Epstein hires a
permit deputy, at his expense, for his own security at his
workplace during the time he is out"
Miami attonaeyieffrey Herman represents six young
women'who've sued Epstein, claiming he sexually abused
them at Ms Palm Beach home when they were minors.
Herman said he received a letter about the work -release
program from the U.S. Attorney's Office within the past
few days. But Herman says Epstein had been out on, work-
release for several weeks before the notification.
"My clients expressed shock and disappointment, Herman
said. "I find it incredible that he's on work-release in the
community and my clients aren't notified of this and we get
this letter weeks after the fact."
Jack Goldberger, Epstein's criminal attorney, said the
CA/Aropcm09,h2L1m,l, BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735767
arrangent is not unusual.
"He goes to work every single day and goes back to jail at
night, just like everybody else (in the program),"
Goldberger said.
Epstein pleaded guilty June 30 to two felony counts:
soliciting prostitution and procuring a person under 18 for
prostitution. As part of the plea agreement, Epstein must
serve one year of house arrest and register as a lifelong sex
offender.
4s)
CA/Aropileft0 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735768
'It Palm Beach At REAL HEWS STARTS HERE
Women want Epstein sex plea deal
unsealed Posted Jul 1, 2008 at 12:01 AM
Updated Oct 2, 2019 at 2:23 PM
(EDITOR'S NOTE: This story originally published in The
Palm Beach Post June 10, 2009)
Their attorneys will ask a judge to open Jeffrey Epstein's
records.
When wealthy money manager Jeffrey Epstein of Palm
Beach pleaded guilty last year to procuring teens CM
prostitution, his case detoured around / dstate rules
regarding the sealing of court doc
4 eAt a plea conference on the ;tat a s, a judge, a defense
lawyer and a prosecutor huddled a. the bench and decided
that a deal Epstein had sit-tick with federal prosecutors to
avoid charges shoWd/be sailed, according to a transcript of
the hearing. CV
And so
t Florida rules of judicial administration, as well as rules
Palm Beach County court system, require public
tification that a court document has been or will be
sealed, meaning kept from public view. The rules also
require a judge to find a significant' reason to seal, such as
protecting a trade secret or a compelling government
interest.
Yet no notification or reason occurred in Epstein's case,
according to court records.
CA/Aropkett 0Clialann BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735769
EpsteiSwn attorneys, in federal filings, have ream
his confidential deferred prosecution agreement with the
U.S. attorney's office, struck in September 2007, as
"unprecedented' and "highly unusual." And it was "a
significant inducement" for Epstein to accept the state's
deal, observed the state judge who accepted his plea,
County Judge Deborah Dale Pucillo.
Epstein now faces at least a dozen civil lawsuits in federal
and state courts filed by young women who said they had
sex with him and now are seeking damages.
Attorneys for some of those women want his agreemen IS
with federal prosecutors unsealed and will ask Circ
Jeffrey Colbath to do so today.
"It is against public policy for these documents to be have
been sealed and hidden from public scnitiny. As a member
of the public, E.W. has a right to have these documents
unsealed," wrote former Circuit Judge Bill Berger, now in
private practice and representing one of the women.
The Palm Beach Post also will ask Colbath to unseal the
agreement. Post attorney Deanna Shullman will argue that
the public has a right to know the specifics of Epstein's deal.
Afording to various media accounts, Epstein moved in
es that included President Clinton, Donald Trump and
or, ' Andrew. "International Moneyman of Mystery,"
dared a 2002 New York magazine profile of Epstein.
Epstein, 56, is in the Palm Beach County Stockade, serving
an 18-month sentence after pleading guilty nearly a year
ago to felony solicitation of prostitution and procuring
teenagers for prostitution.
He is allowed out from 7 a.m. to I I p.m., escorted by a
deputy, said Palm Beach County Sheriffs Office
spokeswoman Teri Barbera.
CA/AroP11,4599k2L1Aw1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735770
Durinailm Beach Police Department investigative
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 the
attorney's office in which federal prosecutors brokeet
pursuing charges against him if he pleaded g ' state c is ,
court. Pucillo then said she wanted a sealed'co o the
agreement filed in his case, and Goldllerier)1/4. concurred that
he wanted it sealed. Belohlavek la '2,1 off on it.
' pThe Florida Supreme Cou s e S ressed "serious concern"
and launched an all-ou to sealing procedures
across the state foll to is reports in 2006 of entire
cases being sealed ppearing from court records.
"The public's constitutional right of access to court records
must remaininviolate, and this court is fully committed to
uarding this right," justices wrote in their final report.
Os itdbn's officehondTuesed7 referred any questions
also
tohas
o o comment. o
declined to comment.
CA/ArofibeLrocomaLIVIs FE : PA- BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735771
rile Palm Beach at REAL NEWS STARTS HERE
Epstein secret pact with Feds
reveals "highly unusual" terms Posted Jun 10, 2009 at 12:01 AM
Updated Oct 4. 2019 at 9:23 AM
(EDITOR'S NOTE: This story originally published in The
Palm Reach Post on September 19, 21309)
A secret non-prosecution agreement multimillionaire
financier Jeffrey Epstein struck with federal prosecutors is
being called °highly unusual" by former federal prosecutors
and downright outrageous by attorneys now, representing
young women who serviced him.
The deal reveals that the FBI and the US. Attorney's Office
investigated him for several federal crimes, including
engaging minors in commercial sex. The crimes are
punishable by anywhere from 1O years to life in prison.
But federal prosecutors backed down and agreed to recall
grand jury subpoenas if Epstein pleaded guilty to
prostitution -related felonies in state court, which he
ultimately, did.- He received an 18-month jail sentence, of
which he served 13 months.
The U.S. Attorney's Office also agreed not to charge any of
-Epstein's possible co-conspirators: ==
M , Lesley Groff and
The deal was negotiated in part by heavyweight New York
criminal defense attorney Gerald Lefcourt.
Unsealed on Friday after attorneys for some of Epstein's
victims and The Palm Beach Post sought its release, it offers
the first public look at the deal Epstein's high-powered legal
counsel brokered on his behalf.
CA/Atopliecep2ts. 0~,ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735772
Markeon of Stuart, a former federal prosecute")
described the disparity in potential sentences as unusual,
but even more so a provision on attorney payment.
The first draft of the agreement in September 2007
required that Epstein pay an attorney -- tapped by the U.S.
Attorney's Office and approved by Epstein -- to represent
some of the victims. That attorney is prominent Miami
lawyer Bob Josefsberg.
month struck Epstein's duty to pay Josefsberg if he and the
But an addendum to the agreement signed the following
,S,victims did not accept settlements -- capped at $150,000 -
and instead pursued lawsuits.
said it appears the government was
balance the lesser sentence for Epstein with
$150,000 for each victim. "I've never, e
like that in my life," he said. It's hi hiy al.°4,,
The deal does not say whe
tom'
ove ing
en anything
• ms were contacted
or consulted before th " e al. ade. <t at e
Attorney Brad Edv‘r‘ds o ort Lauderdale, who represents
three of the young women, believes that none of the 30 to
40 woman identified as victims in the federal investigation
were told ahead of time. said his clients received
letters from the U.S. Attorney's Office months after the deal
was signed, assuring them Epstein would be prosecuted.
"Never consulting the victims is probably the most
outrageous aspect of it," said. "It taught them that
someone with money can buy his way out of anything. It's
outrageous and embarrassing for United States Attorney's
Office and the State Attorney's Office."
Epstein now faces many civil lawsuits filed by the women,
who are represented by a variety of attorneys. In many, the
allegations are the same: that Epstein had a predilection for
teenage girls, identified poor, vulnerable ones and used
cAm"Pli eR599X2O14 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735773
other lig women to lure them to his Palm Beach')
mansion. They walked away with between 8200 and
$1,000.
Former Circuit Judge Bill Berger, also representing victims,
called the agreement a "sweetheart deal."
"Why was it so important for the government to make this
deal?" Berger asked rhetorically. "We have not yet had an
honest explanation by any public official as to why it was
made ... and why the victims were sold down the river."
Former federal prosecutor Ryon McCabe described the
agreement as *very unorthodox." Such agreements, hems
are usually reserved for corporations, not individu
"It's very, very rare. I've never seen or hear
procedure that was set up here," said McCly!,
involvement in any Epstein litigation. )
"He's essentially avoiding federal prosecution because he
can afford to pay that many lawyers to help those victims
review their cases.... son has no money, he couldn't
be able to strike a his and avoid federal
prosecution."
cThe backroom eal with federal prosecutors is all the more
interesting in light of the legal powerhouses who have
worked for Epstein, including Harvard professor Alan
Dershowitz and Bill Clinton investigator Kenneth Starr.
Lefcourt is a past president of the National Association of
Criminal Defense Lawyers.
Epstein't local defense attorney, Jack Goldberger, issued a
statement Friday saying he had fought the release of the
sealed agreement to protect the third parties named there.
"Mr. Epstein has fully abided by all of its terms and
conditions. He is looking forward to putting this difficult
period in his life behind him. He is continuing his long-:
standing history of science philanthropy."
CA/AroploesoalrlAuvi21.8. BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735774
The infkgation triggered tensions between police.
prosecutors, with then -Palm Beach Chief Michael Reiter
saying in a May 2006 letter to then-State Attorney Barry.
Krischer that the chief prosecutor should disqualify himself.
1 continue to find your office's treatment of these cases
highly unusual: Reiter wrote. He then asked for and got
the federal investigation that ended in the sealed deal.
'The Jeffrey Epstein matter was an experience of what a
many-million-dollar defense can accomplish: Reiter told
40Athe Palm Beach Daily News upon his retirement.
CY '
( S HSCIC/ASS9
Cr
Th(Sy ' 1141'9
CA/AropILLY) P
iaera,901212 ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735775
187'/ 278 - Wednesday, January 27, 2010
Edition: FINAL
Section: LOCAL & BUSINESS
Page: 3B
Source: By JANE.MUSORAVE Palm Beach Post Staff Writer
Dateline: WEST PALM BEACH
:RIDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RE. RDS ;
In a decision that could spark a constitutional showdown over privacy rights, e.
Tuesday gave lawyers representing multimillionaire sex offender jeffrey.E e right to
subpoena abortion records from women who are seeking Millions in d the part-
time Palm Beach resident
Palm Beach county Circuit Judge Donald Hafelc said the records co d he p Epstein rebut
the women's claims that they suffered psychological ills after bein p give him
sexually-charged massages at his Palm Beach mansion when re as. Sung as 14.
Hafele told Epstein's attorneys they couldn't go on a fishi n. Thermedical. records,
he said, can't be sought until the women are asked whe , :ve ever had an abortion,
how many and where. Further, he said„ the records n. made public and might not
be adinistible during trial.
But, he said, since the women claim Epstein, 5 responsible for their emotional
distress, his attorneys can explore the lima o vents. Medical records, Hafele said,
area better source of information than a ernory.
Attorney Louis. Silver, who represents resi ential Women's Health Center, a West Palm
Beach clinic where abortions. are warned Hafele that he was stepping on shaky
constitutional grounds.
"These records are protected bf our c titutional right of privacy," he said, referring to the
Florida Constitution.
After the hearing, alive id air appeal won't be necessary until Epstein attorneys seek the
records.
In another ruling Wednes y, Miele also said that videos from depositions in the state cases
can't be released • outs court order. The ruling came after Epstein attorney Robert Critton
complained vi of Epstein being asked whether he had an "egg-shaped" penis
became a y corn sensation. It first appeared on The Palm Beach Post. Web site.
Critton bl orney Spencer Kuvin.for releasing it. Kuvin said it was public record.
The r began mourning after Epstein agreed to plead guilty to two state. charges:
procurin minor for prostitution and soliciting prostitution. He served 13 months of -an 18-
month sentence. As part.of the deal brokered with federal prOtecuters, he agreed not to
contest the accusations in the civil lawsuits. He can argue thewomen don't deserve. the
millions they are seeking.
—jane_mitsgravt®phpostcom
CA/AMPlat i.WL 2A BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735776
rite Palm Beach At REAL Nnvs STARTS HIRE
Epstein Journal's Findings Could.
Resurrect Case By Jane Musgrave
Posted Sep 17,2019 at 12:01 AM
Updated Oct 1,2019 at 10:51 AM
(EDITOR'S NOTE This story originally published in The
Palm Beach Post on March 24 2010)
A purloined journal that is said to contain the names
"hundreds" of victims of convicted sex offender Jeff
Epstein could be used to reopen the investigat • ta1lle
multi-millionaire's appetite for teenage girls, rney
representing seven of the victims said i t: said
New details about the contents oft hejou al were released
this week when Alfredo Rodriguez, who worked as a
property manager for the Palm Beach resident, pleaded
guilty to obstruction of justice for lying to federal agents
when asked if he had any information about his former
boss' criminal,activity. He later tried to sell the journal he
stole from Epstein for S50,000 to an unidentified person,
who ale thorities, according to court records.
of the plea agreement, federal prosecutors said the
mal `contains information material to the Epstein
AAvestigation, including the names of material witnesses
arid additional victims."
"Had the items been produced in response to the inquiries
of state or federal authorities ... the materials would have
been presented to the federal grand jury," federal
prosecutors wrote.
CA/Aropbarac t.z.): 001221 iL FAUNA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735777
Instealliosecutors short-circuited the grand jury
investigation and cut a deal with Epstein. They agreed not
to pursue federal charges if he didn't contest prostitution -
related felonies in state court. The money manager pleaded
guilty in July 2008 to procuring a minor for prostitution
and soliciting prostitution. He served 13 months of an 18-
month sentence.
Attorney Adam Horowitz, who represents seven of the
roughly 18 women who have filed civil suits against
Epstein, said the new information could trump the so-
called non-prosecution agreement.
The multifaceted agreement, he said, deals only with a
specific list of victims that the U.S. Attorney's Office knew
about when it penned the deal in 2007. If additional victims
are listed in the journal Rodriguez stole, Horowitz said
federal prosecutors could reopen the investigation.
"It opens the door for further prosecution,- he said.
In addition to turning over thrjournal to federal agents,
Rodriguez told them he knew his former boss was having
sex with underage girls when he worked for him in 2004
and 2005. He had seen naked girls, who looked like minors,
in the pool of Epstein's $8.6 million mansion. He had seen
poniograppic images of young girls on Epstein's computer,
accordingio court records.
Neither Epstein's criminal defense attorney, Jack
Goldberger, nor attorney Robert Critton, who represents
Epstein in the civil lawsuits, could be reached. Federal
prosecutors have consistently declined comment.
The wording of the controversial agreement is unclear. It
says federal prosecutors would provide Epstein's attorneys
'with a list of individuals whom it has identified as victims."
Miami attorney Robert Josefsberg was appointed to
CA/AroppLeffeK222. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735778
represlany of the victims on the list who wanted.
pursue Epstein in civil court.. As part of the agreement,
Epstein is to pay for Josefsherg to represent the women'
Some of the women, most identified as Jane Doe in
lawsuits, had already hired attorneys to represent them.
Some have slate settled their suits with Epstein, although
terms were not disclosed.
Horowitz said he has filed court papers to get the journal
that Rodriguez stole. 'It's another piece of evidence that
shows our clients were at Epstein's mansion," he said.
Rodriguez told prosecutors he didn't turn over the jo
when both FBI and Palm Beach police asked for it
he wanted money for it. He also said he Was Ep
would make Min "disappear." The informp old
investigators, was his Insurance poli
He faces a maximum 20 years:i\
? S .,sentenced on June 18.
jane_musgraveitipph
@pbpcourts;
A %
C
+o
en he is.
CA/AmftkeLe9390120I BEACH COUNTY, FL, ABRUZZO, CLERK. 1/28/2023 1:04:39 PM
EFTA02735779
•
The Palm Beach Post REAL NEWS STARTS HERE
Epstein paid three women. $5.5 million to end underage-
sex lawsuits
By Jane Musgrave
Posted Oct 3, 2017 at 12:01 AM
Updated Oct 4, 2017 at 12:46 AM
Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young
women who claimed he used them as sex toys, court documents filed last week show he shelled
out $5.5 million to settle lawsuits with three of more than two dozen eens who sued him.
Responding to requests from Epstein's attorneys in a complea that was spawned by the
offender paid more than $1 million to each of the th represented.
said the politically netted 64-year-old convicted sex sex scandal, attorney
Identified in court papers only by their initials
allegations and their youthful ages, L.M. wa
$2.5 million, said of the settle
ul>brtyms because of the nature of the
$1 million, E.W. $2 million and Jane Doe
negotiated with Epstein to end the lawsuits.
Jack Goldberger, one of Epstein's en defense attorneys, on Tuesday declined comment on
the revelations, citing confidenfiality, agreements that were part of the settlements. For the
same reason, he declined to say whether Epstein paid similar amounts to settle roughly two
dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex
when some were4aacmg as 14 years old.
Attorney J,1cl carala, who is representing M, said his client was compelled to divulge
the confidential settlements to answer questions posed by Epstein's attorneys. 'Brilliant move
on their pin," he said.
Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have
likely come out. He says the information will help him undermine Epstein's claims that
"ginned up" the allegations to help his former law partner, imprisoned and disbarred
Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.
CA/Aropliegb0Q12 . l'AA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735780
• •
The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute
between Epstein and Rothstein, both billionaires.
A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a
minor for prostitution, he sued Rothstein ands, claiming they trumped up the
allegations of sexual molestation to perpetuate the Ponzi scheme.
Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly
successful law firm by forging the names of federal judges and others to persuade investors he
had negotiated settlements in lawsuits against high-profile people. Investors were told they
could get a cut of the cash.
One of the high-profile people Rothstein used to lure investors was ES, according to a
lawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the
lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the lawsuits
with the teens for 8200 million — a claim Critton described as "a complete fabrication."
After Epstein dropped the lawsuit in 2012, Edwards turtiedthe tables on him. S accused
Epstein of filing the lawsuit maliciously to punish him for representing the young women.
Although was a partner in Rothstein's now defunct firm, Scarola claims Epstein had
no evidence was involved in the ponzi scheme. Federal prosecutors successfully
charged other attorneys and members of the firm, but was never implicated, Scarola
said in the malicious prosecution lawsuit.
The revelations about themoney Epstein paid to three of the young woman came last week in
documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit.
Attorney-Torna Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the
trial, in part, because she claimed she has been unable to talk to her client since his estate on his
private island in the U.S. Virgin Islands was devastated last month by Hurricane Irma. "I've had
no ability to communicate with Mr. Epstein," she said.
CA/AroppLegi500.1225 rAL1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735781
Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge
Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those
victimized by the storm that hammered the Caribbean and roared through South Florida, he
said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.
Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide
before the case goes to trial.
Despite Scarola's insistence that had nothing to do with Rothstein's Ponzi scheme,.
Coleman said the evidence indicates otherwise. Why else would he try to deposetpstein's
well-known friends, such as now President Donald Trump, former President Bill Clinton and
illusionist David Copperfield, she asked. He used the celebrities as a draw, she said.
"The Epstein cases were used to fleece money and defraud investors: she said.
Edward's malicious prosecution case has been difficult for both sides because both Epstein and
have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked
his Fifth Amendment right against self-incrimination when questioned by Scarola.
has claimed that much of the information Epstein is seeking is protected by attorney -client
privilege.
The malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit
against Epstein. Edwards alsois suing the U.S. attorney's office, claiming it violated
the federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with
Epstein.
Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to
plead guilty to two,prostitution charges in Palm Beach County Circuit Court. In federal court
records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein's
agreement to settle lawsuits filed against him by dozens of his underage victims.
CA/Aroribtera z00,12,2B t• l'Auvl BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735782
Pat Beach Daily News
Judge rules fells' agreement with
Jeffrey Epstein pact violated teen
victims' rights By JaneMusgrave
Posted Sep 17, 2019 at 4:02 PM
Updated Oct 8, 2019 at 12:31 PM
•S ,(EDITOR'S NOTE: This story originally published in The
Palm Beach Post on February 22, 2019)
Federal prosecutors violated the tights of Jeffrey Ep inn)C
teenage victims by failing to reveal they had dropped plans
to prosecute the billionaire on dozens of federal charges in
connection with the girls' claims that he paid them for sex
/ at his Palm Beach mansion, U.S. ,), 'ct Judge Kenneth c,Marra ruled on Thursday. aCS
0
In a blistering 33-page g, Marra meticulously and
methodically detai umerous steps federal
prosecutors to le•to d the agreement from more than 40
young wome lairn Epstein paid them for sex when
they we yang as 14.
Mk the government spent untold hours negotiating the
rm d implications of the NPA with Epstein's attorneys,
nt information was shared with the victims," Marra
wrote. "Instead, the victims were told to be 'patient while
the investigation proceeded."
By then, it was too late. A deal had already been cut with
then-South Florida U.S. Attorney Alex Acosta and Epstein's
attorneys to shelve a 52-page federal indictment against
Epstein, a former math teacher turned money manager
who counts Presidents Donald Trump and Bill Clinton
among his friends.
CA/Aroppnookin rALZ1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735783
Prose* failure to alert the young women abou
deal violated the Crime Victims' Rights Act, Marra ruled.
"At a bare minimum the (act) required the government to
inform (the young women) that it intended to enter into an
agreement not to prosecute Epstein," he wrote.
Still, Marra said he wasn't second-guessing prosecutors'
decision not to pursue Epstein on federal charges if he
pleaded guilty to minor state prostitution charges and
agreed to compensate his victims for the trauma he caused.
''The court is not ruling that the decision not to prosecute
was improper," Marra wrote. The court is simply rulin
that, under the facts of this case, there was a violatio
the CVRA."
Further, he made no decision about what tht§xem ly
should be. He gave prosecutors and att epresenting
the young women 15 days to meet o ' . . ow to unravel
otv
Sicmeet
the complex legal web that has ee angIng over Epstein
and his young victims for e a decade.
„Is is
dei
Ss
The chances an accot eached are slim, said
attorney Jack Scarolaiwli s representing the two Jane
Does who ch enge011e prosecutors' actions.
Further t he said, there is no road map to follow. The
lawsuit attorney filed on behalf of the two
abSentified young women, claiming prosecutors violated
Oe f eral act, is unique, he said.
We are treading on virgin ground, to use what is probably
an inappropriate phrase in this situation," he said.
Scarola said he and will ask that the non-
prosecution agreement be thrown out. That would open
the possibility that the long-shelved federal indictment
could be dusted off and filed against the 66-year-old
Epstein, who spends most of his time on a private island he
owns in the U.S. Virgin Islands.
CA/AmilifErt °11X2L2A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735784
1 don,/ the government conceding to that reme
Scarola admitted. Further, he said, it is likely Epstein will be
allowed to weigh in. Miami attorney Roy Black years ago
filed papers asking to intervene on Epstein's behalf.
The U.S. Attorney's Office said it wouldn't comment on
Marra's ruling. Neither Black nor New York City attorney
Jay Lefkowitz, who led efforts to bury the federal
indictment, responded to emails or phone calls for
comment. West Palm Beach attorney Jack Goldberger, who
represents Epstein, also didn't respond.
Scarola said it is likely Epstein's star-studded legal team IS. ,
argue that. Epstein fully complied with the terms of the
agreement he made in 2007 with federal prosecutor t9
therefore the agreement can't be undone.
As he promised, Epstein pleaded guil X608 to state
charges of soliciting a minor for i p sti 'o and soliciting
k
i /
kaprostitution. He served 13 mon s ( an 8-month jail term
in a vacant wing of the county stoc de that he was allowed
to leave 12 hours a day ' da0weelcAt e
Further, as agre settlements to the young women
who sued hint Whilellte settlements were confidential,
court records show he paid three women a total of 85.5
million.
urn, federal prosecutors held up their end of the
ain. Their investigation ceased.
Having done all that prosecutors asked of him, Scarola said
Epstein will make a simple argument: "You can't turn
around and deprive me of the benefits I bargained for."
However, Scarola said, using Marra's ruling, he will counter
that the contract Epstein signed was illegal and therefore
unenforceable.
CA/Arctrri cii99X 2L21A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735785
Even illOrra agrees to toss out the non-prosecutio.
agreement, Scarola conceded that doesn't mean Epstein will
face federal charges.
"The contract can be set aside and the federal government
can attempt to enter into the same agreement," he said.
"Except the spotlight of public attention will be on them
and the 40 victims will be able to explain to the court why
this sweetheart deal should not be approved."
Scarola said that prosecutors may have had good reason not
to pursue Epstein. "There may be a reasonable explanation
but we don't know what that reason may have been," heO
said.
In court papers, federal prosecutors have said
the young women were afraid to cross the, ,
'ypolitically connected money manager ant' refused to
AC I\In other cases, they said, thepote anged their stories.
Jane Doe 2, who is trying to have the non-prosecution
agreement thrown out, initially described Epstein as "an
awesome man" and told pMsecutors she hoped "nothing
happens" to him. While she later agreed to testify against
Epstein, prosecutors said they feared Epstein's attorneys
would use her words to destroy her if she ever took the
witness stand.
testify against him.
Marra, however, said the young woman's comments didn't
mean she wasn't entitled to know about the prosecutors'
plans to drop the charges. 'There is no dispute that Epstein
sexually abused Jane Doe 2 while she was a minor," he
wrote. "Therefore, regardless of her comments to the
prosecutor, she was a victim."
Before the case is finally resolved, Scarola predicted that "a
lot of people are going to have to answer a lot of questions."
CA/Aropilr ti M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735786
•
In his lilg, Marra detailed what appeared to be a ID
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 US. solicitor general whose investigation
led to the impeachment of President Clinton.
Marra describes an October 2007 breakfast meeting
between Acosta, who is now U.S. labor secretary, and
Lefkowitz shortly after the non-prosecution agreement was
inked.
After the meeting, Lefkowitz sent Acosta a note thanking
him for "the commitment you made to me during our
October 12 meeting in which you assured me that your
Office would not ... contact any of the identified
individuals, potential witnesses, or potential civil claimants
and their respective counsel in this matter."
Marra quoted an equally pleasant note then-Palm Beach
County State Attorney Barry Kristher sent to Assistant U.S.
Attorney Villafana, who was the lead prosecutor in
Epstein's case. "Glad we could get this worked out for
reasons I won't put in writing," Krischer wrote, shortly
after the nontecution agreement was signed. "After this
is resolved I would love to buy you a cup at Starbucks and
have a conversation'
Many of the notes that were exchanged dealt with
prosecutors' and Epstein's lawyers' shared desire to keep the
- deal secret from Epstein's accusers. In a September email,
Villafana asked Lefkowitz for guidance about what she
should reveal. "And can we have a conference call to discuss
what I may disclose to ... the girls regarding the
Agreement," she asked.
4
civA 911,1,1594X2a BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735787
Such oration between prosecutors and defense 40
attorneys is unusual, Marra said. 'It was a deviation from
the government's standard practice to negotiate with
defense counsel about the extent of crime victim
notifications: he wrote.
Further, he noted, that when and his two young
clients asked for information, they were repeatedly misled.
"The CRVA was designed to protect victims' right and
ensure their involvement in the criminal justice process:
Marra wrote. When the government gives information to Alhaic
victims it cannot be misleading:
Ultimately, the terms of the non-prosecution agreement
were revealed only after and attorneys for tk ....)
press successfully sued to make them public.
[Email Redacted]
AS )
@pbpcourts
CA/AmillieR599\ 2INI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735788
76 / 278 - Tuesday, July 9, 2019
Edition: Final
Section: A Section
Page: 1A
Source: By Jane Musgrave, The Palm Beach Post
Epstein indicted on sex charges
Part-time Palm Beacher pleads not guilty to sex
trafficking, conspiracy charges in federal court in
Manhattan
Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not guilty
to charges accusing him of creating a vast network of girls as young as 14 that he exploited
for his sexual pleasure at his homes in Palm Beach and Manhattan.
The 66-year-old money managers appearance in U.S. District Court in New York City
capped more than a decade of recriminations by young.wonien and their attorneys who
claimed Epstein used his money and political influence to avoid federal prosecution.
Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking
charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach
County Jail for 13 months more than a decade ago.
However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to
shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state
prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is
now U.S. labor secretary.
"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey
Berman said at a
morning news conference. "And while the charged conduct is from a number of years ago, it
is still profoundly important to many of the alleged victims, now young women. They
deserve their day in court."
At a detention hearing scheduled for Monday, Berman said he will ask a federal judge to
keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to
commit sex trafficking. Epstein paid dozens of young women to give him nude massages
that, for most, led to sex, he said.
If convicted of exploilizens of young women, including many Palm Beach County girls
who were students at Palm Beach High School, Epstein faces a maximum 45-year
prison sentence.
Citing Epstein's enormous wealth, his homes in New York, Palm Beach, the U.S. Virgin
Islands, New Mexico and Paris and his ownership of two jets, Berman said there are few
conditions that could keep Epstein from fleeing to a foreign country to evade prosecution.
CA/Aroplien09123.3. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735789
• •
"We think he's a significant, flight risk," Berman said of the marl who ferried Britain's Prince
Andrew, actor Kevin Spapey, famed Harvard law professor Alan Dershowitz and former
President Bill Clinton on his jet, dubbed the Lolita Express.
Berman's hard-line stance Was Welcornedbyygung women who for years have been told that
Epstein couldn't be touched because Acosta signed.off on the nonprosecution agreement,
promising not to charge Epatein in federal court.
Fortner Palm. Beach County resident Virginia Guiffre, who has accused Epstein of turning
her into his sex slave and forcing her to have Sex viith.others, including Dershowitz and
Prince Andrew, praised Berman, He showed the case is "being taken in a serious wa " she
told the Associated Press. Dershowitz has vehemently denied Gtiiffre's claims.
New York prosecutors were able to ignore the controversial nonprosecution a en
because it contained some significant fine prim, said former federal Judge Pat ssell, who
for years has fought to get the agreement thrown out. It says only that no is s uld be
filed against Epstein in South Florida, he said.
Berman agreed. "That agreement only binds, by its term; only bi the S lfiein District of
Florida," he said- "The Southern District of New York.iS hot bound b agreement and
wasn't a signatory Ofit."
That means the sordid allegations that have been leveled or years are now part of
a federal indictment.
Contrary to Epstein's claims,he knew the women w homes in New York. and
Palm Beach were miners because they told him t rding to the indictment.
Epstein preyed on young girls because he knew. ere "vulnerable to exploitation,"
prosecutors added.
As part of a careftilly orchestrated sex ring, n or his associates would call girls while
he was in New York so they would be able or sex once he returned to Palm Beach, the
indictment says. The employees wefen f. They were identified only as "Employee-1,"
"Employee-2" and "Employee-3
To ensure he:had a steady s g girls, Epstein would turn some victims into
recruiters. He 'Would pay the new girls tO. his home on El Brillo Way along the
Intratoistal Waterway i Palth h orto his palatial townhouse on New York's Upper East
Side.
"This allowed Ep n to eate an ever-expanding web of new victims," Berman said.
In both New.? d Palm Beach, the lurid operation was similar. Unidentified employees
of Epstein's d e rt the teens into a room. They were told to take off all or most of their
clothe§ bef g the naked billionaire massages, according to the indictment.
"Epsteit4 o typically masturbate during these encounters, ask victims to touch him
whil bated,• and touch victims' genitals with his hinds or with sex tUys," the
indictme tisays.
As part of the criminal complaint, prosecutors are asking that Epstein be forced to tarn over
his multimillion-dollar townhouse on East 7.1st Street. The complaint does not seek forfeiture
of Epstein's house in Palm Beach,
While heartened that Epstein now faces serious criminal charges in New York, Cassell. said
he would continue to push a West Palm. Beach-based federal judge to throw out the
nonprosecution agreement that Acosta.forged with Epstein's star-studded legal team.
CA/Arofillegimmt AIM BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735790
•
• • •
U.S. District Judge Kenenth Marro has, already niled that Attista:Violated the federal Crime
Victims' Rights Act by not.tellitig 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 Marta Should take to redress that wrong.
Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida
victims deserve justice in Florida? said Cassell, who is working on behalf of Epstein's
victims with attorneys and Jack Scarola..
Since it's likely Florida women will get to testify against Epstein in New York, Scarola said
he's not focused on.whether Epstein will face charges here. Instead, he said he.wants4o know
how and why the agreement was reached.
"There's been no explanation as to howa deal like this could have been cut an
federal government could have been involved in a conspiracy to violate fede , Scarola
saidof his interest in continuing the legal battle over the nonprOsecution
When Acosta agreed to drop the federal investigation, Epstein in 200 ilty to two
prostitution charges and served 13 months of an 18-month sentence a vacant wing of the
Palm Beach County Jail - 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 1 u more than 30 young
women filed against him.
U.S:. Rep. Lois Frankel, D-West Palm Beach, said she s la's interest in finding out
how the agreement came to be."I am especially mo in why EpStein got the deal
he got," Frankel said. "We need.to know why he uch an easy sentence.
While she has asked the House Oversight Co investigate Acosta, Frankel said she
is not sure that will happen. "It just seems e r a travesty that this guy got off the
way he did and, without pre judging it, let' h a roper court case," Frankel said.
Former Palm Beach Police Chief Mic eite was inflamed in 2006 when then-State
Attorney Barry Krischer refused to tein with serious crimes. Reiter took the
information his officers had gat ozens of Epstein's victims to Acosta, believing
he would prosectite Epstein.
Reiter said he was heartened 13 ears later, Epstein will finally face justice.
"Thankfully, U. S. Anti ey Be and the other authorities in New York have the gOod
judgment.to investigate ecute Epstein in the way that should have occurred in.
Florida over a dec ago " Reiter said Ma statement
And, Scarola s ere are signals that Berman's investigation is far from. over,
Berman dec wer questions about whether others, such as Epstein's high-powered
friends, w d be harged. He brushed off questions about the significance that the
investiga in handled by the Public Corruption Unit.
Whil n Saturday were. arresting Epstein aboard his private jet at the Teterboro
Airport ew Jersey after returning from Paris. Other officers were searching his New York
City townhouse. Agents seized nude photos of young girls who appeared to be minors,
Bennonsaid.
He said:his focus was On finding more women who were exploited and abused by Epstein.
Turning to a poster,- detailing the charges that had been filed against Epstein,.he pointed a
finger at.a photo of the convicted sex offender who was once described as "a man of
mystery:"
CA/ArOpitgy)91235. Pax% BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 1:04:39 PM
EFTA02735791
•
• • •
"If you believe you are a. victim of this man, Jeffrey. Epstein, we want to heat fnimytiu,"
Berman said. A special number,1-800-CALLFBI, will link victims of authorities.
Bill. Sweeney, assistant director of the FBI's New York office, said after years of being
ignored by federal agents, the victims' voices will be. heard:
"The Jeffrey Epstein matter is No. 1 on the malorcase list in the country," Sweeney said.
Turning to address Epstein's victims directly, he said; "Your bravery may empower others to
speak out against crimes against them."
[Email Redacted]
cos
ts)c
G
CAJArctli effilWRI BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735792
• •
Def.Ex.A-2
cps
CNA. VIMWEY1 BEACH COUNTY, FL. ABRUZZO, CLERK- 3/28/2. 1..39 pm
EFTA02735793
• ire infiNTIOCiCir
.1A9 75ille I Ailiet*Ta pA
. • •eittans4scrwa
.November 26;20i9
ellt.COSS: SCHOLZ & WYLER, LW. 41: uiiniittulaurry. C:OrM! ....1Y OF PPOPT.SLONA‘o,a0eATIONS
ATTORMCYS AT ( •
88119IiYTO AilleL91
• , 04111141870thoiAVOL.Vp SINTC1014
Preatintsu. Sinn. nos* cisona
TWI4011;100.4) ZSI-3693
FAX WO. (004) alit 7879
. ,
Office of the State Attorney
15th dhadicial Circuit
Attn: Jeanne Howard
401 North Dixie Highway
West Paim*Beacli,-FL 33401
Re: CA Florida Holdings, LLC v. Dave A ronberg et at.
- Case No.: 2019-CA-014681
Dear.Mrs. Howard:.
.-• .
The purpose of this letter is to confirm that
above-referenced matter.
IV CNA RD 4.11,101.1.
IIRr4LY0 J. sa:Oka
00.11114.4.11 sti.VMSR.P.A.
ODUOLASA.ven.ci•
will represent.you regarding the
Our fees will be contingent upon our success in this tt ou will not be liable or required.to pay any
monies to our office unless we are successful in our re intim Of you regarding the above-referenced
litigation and orneive a court order awarding attorneys' kes.
. •
Accordingly, should we be sucemsfu this matter, you agree to be billed for the time incited in defending
this action at our current hourly t hr time, our current hourly rates are: $475 00/hour for senior
partners, $425.00/hour for of nnj 5375:00/hour for associate attorneys, and $125.00/hour for
paralegal time.
Furthermore, the anorkeys' fees paid to our firm shall be calculated by the above lista:flour* rates
multiplied by the Mini i of hours expended in defending this action oerhe total fee mandated and awarded
by the court ordf{hereir whichever is:greater.
•
By Sign' agree to the terms as set forth above. Please return a signed and dated copy of this
letter: ' i f you have any questions or concerns, please contact our office. On behalf of the
rani to represent youth this matter.
• Deglitas J.41•VelYier, Esq.
For *firm
141 Date
CA/ArTIM59904 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735794
• •
c.A.1.559. BEACH COUNTY, , =ABRUZZO, CLERIC 3/288023 1:0439 PM
EFTA02735795
• •
IN THE CIRCUIT COURT OF THE FIFIEENTH JUDICIAL C&CUIT
IN AND FOR PALM REACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLG,..
Publisher of the PALM BEACH POST,.
Plaintiff,
V. CASE Nti..! 19-CA-014881
BOCK, as Clerk and Comptroller of Palm
Palm Beach County, Florida; SHARON 'R.
4, AA
DAVE ARONBERG. as State Attorney of
Beach county, Florida.
0 Defendants. 1.-/
Co )MOTION TO DISMISS
Defendant, DAVE ARQNBERO, as State Attorney. I ach County, Florida, by and
through the undersigned counsel, hereby files this Motio Plaintiff's Complaint for failure to
state a cause of action, and in support thereof states:
MOTION T 'SSTANDARD When confronted with a mho t the Court must determine whether the Complaint as
phrased .within its four comers a cause of actin°, whereby relief can be granted. Fox
Professional Wrecker Operatic 2d 115, .178 (Fla. 5th DCA 2001). A motion to dismiss tests
whether the plaintiff has ause of action. The test for a motion to dismiss under Florida Rule of
ther the pleader could prove any set of facts as alleged in the Complaint to Civil Procedure I
support his
O1
irk
See, Connolly v. Sebeco. Inc. 89 So. 2d 482,484 (Ha. 1956). Wasua Ins. Co. v.
123 (Fla. 4th DCA 1990,
rder to meet this test, "a complaint must allege sufficient ultimate facts to show that a pleader
it entitled to relief" W.R. Townsend Contr.. Inc. v. Jensen Civ. Constr.. Inc. 728 So. 2d 297, 300 (Fla.
1st DCA 1999) (quoting v. Coserove, 464 So. 2d 664, 665 (Ha. 2d DCA 1985); Fla R. Civ. P.
1.110(b)). The court need not accept internally inconsistent factual claims, conclusory allegations,
unwarranted deductions, or mere legal conclusions made by a party. .Id (citing Response Oncoloev, Inc.
CA/ArOpirgb,2 LM40. A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735796
•
v. Metrahealth Insurance Co.. 978 F. Supp. 1052, 1058 (S.D. Fla. 1997)): Oxford Asset Mann. v. Jaharis.
297 F.3d 1182, 1188 (11th Cir. 2002) ('"(On a motion to dismiss,] the plaintiff's factual allegations are
accepted as true.... However, legal conclusions masquerading as facts will not prevent dismissal."). To
avoid dismissal, a pleading "must allege a cause of action recognized under law" against the defending
party. Kislak v. Kreedian. 95 So. 2d 510, 514 (Fla. 1957).
COUNT I,
(Florida Statutes Section 905.27)
Plaintiff attempts to assert a cause of action, in the interest of "furthering. tinder Florida
Statute § 905.27; however, a review of the statute in question reveals that n riot is provided
for therein and consequently Plaintiffs Complaint must be dismissed a er of law. Despite
Plaintiff's extensive recitation of the factual background regardin pstein and the testimony and
evidence presented to the 2006 grand jury in Palm Beach orida, Fla. Stat. § 905.27, merely
explains the exceptions to the disclosure of grand jury teithson d does not set forth in any way a cause
of action upon which to initiate a valid law suit. C '
Moreover, a review of the statute-a l issue clearly indicates that even if § 905.27. Fla. Stat.
provided a basis for a cause of action(Plaintiffis barred from access to the records it seeks. To wit, in
pertinent part, Fla. Stat. § 905.27(2) states"-
When such disclosure is ordered by a court pursuant to subsection (1) for use in a civil
case, it may be disclosed:Ito all parties to the case and to their attorneys and by the latter
to their legatassociates and employees. However, the grandjury, tesihnony afforded such
persons bycthe court can only be used in the defense or prosecution of the civil or
crhuin lease and for no other purpose whatsoever.
desp te the clear statutory guidelines for disclosure of grand jury materials in a civil case,
Plainlif properly seeking the requested 2006 grand jury materials for the purposes of public
disclosure pursuant to the court's inherent authority and supervisory powers over the grand jury. [See,
Complaint y18, 62]. Again, even if Plaintiff properly asserted a cause of action under Fla. Stat. 905.27,
the statute unambiguously states that grand jury testimony "can only be used in the defense or prosecution
of the civil or criminal case and for no other purpose whatsoever". which is distinctly different from
CA/Aro PRW.9X 2LV1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735797
• •
Plaintiffs intended purpose for public disclosure of the grand jury evidence. Fla. Stat. 6 90527(21
Finally, iris significant to note that despite Plaintiffs allegations to the contrary, Defendant Aronberg is
not in custody or control of the records sought and is therefore not a.proper party to this:action.
WHEREFORE based on the foregoing argument and supporting authority, Defendant, DAVE
AR0NBERG, as State Attorney of Palm Beach County, Florida, respectfully request's that this Honorable
Court grant the instant Motion and dismiss Plaintiffs Complaint With prejudice, and fendam
Aronberg all other and Rather relief deemed just and proper, including attorney's nd 2bsts for
O)
defending. this frivolous action.
CERTIFICATE OF SERVICE
1 I3EREBY CERTIFY that on this 6th
cr
20 day of December. py the foregoing has been.
electronically filed with the Florida E-File. Portal for e-service 0 y Of record herein.
J B ; OLZ & WYLER, LW
\ th 'gins A. Wyler
Ur I. M. al -
Pa. Bar No.: 10249
Richard J. Scholz- Erg.
.Fla. Bar No.: 0021261
DOufiltta A. Wyler, Esq.
Fla. Bar No.: 119979
961687 GateWay Blvd., Suite 201-I
Femandina Beach, Florida 32034
([Phone Redacted]
([Phone Redacted] Fax
Primary:. jacobsscholzlaw®comcastmet
General Counsel for theFlorido Prosecuting
Attorney's Assodation
CA/A ropM01.242.
PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735798
• •
Def.Ex.A-4
GO
(S.
CAIA.P1.99. BEACH co., , ABRUZZO, CLERK. 3/28,023 ,.(14,39 pm
EFTA02735799
Filing # 101840557 E -Filed /2020 12:23≥06 PM
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC, CASE NO.: 50-2019-CA-0146814O= -MB
Publisher of THE PALM BEACH POST, Div.; AG
Plaintiff,
v.
DAVE ARONBERG, as State Attorney of
Palm Beach.County, Florida; SHARON It
BOCK, as Clerk and Comptroller:of Patin
Beach County, Florida,
Defendants.
FIRST AMENDED
CA Florida Holdings, LLC, publisher of each Post, for its First Amended
Complaint against Dave Aronberg, the Stat4tt for Palm Beach County, Florida, in his
eofficial capacity ("State Attorney"), of n : Bock, the Clerk of the Court forPahn Beach
County', Florida, in her official ca ' ' urt Clerk"), alleges as follows:.
JURISDICTION
1. This is aeon within the exclusive jurisdiction of the Circuit Court pursuant to
Fla. Stat. Sectio 6:012(2)(a) and 86.011 et seq.
Q PARTIES
ze Paint Beach Post it a daily community newspaper published by Plaintiff CA.
Florida Iclings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.
3. Defendant Dave .Aronberg is the duly elected State Attorney for the Fifteenth.
Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Slat. Section 27101 and.
has authority in grand jury proceedings pursuant to Fla. Suit Section 27.,.0. He is sued herein in
Cos
CArnrcriff95991 2661 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735800
•
his offiCial capacity as his office is in possession and/or control of 'documents that are the subject
of this action.
4. Defendant Sharon R. Bock is the duly elected. lerk 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
5. In what is now widely if belatedly recognized at a colossal i t of Amite —
which led to the further needless victimization of countless young gir — a wealthy,
politically connected, and powerful financier 'was not held acco tab , nor even forced to
confront, allegations of serious sex trafficking crimes. 'Ail that Jeffrey Epstein's 2008
deal with the State of Florida was not consistent wt nce gathered against him, what
remains shrouded in.mystery is how that evidencit w resented — and the extent to which it was
presented — to the grand jtuy that returned at r c ent far more limited in scope than expected
and deserved.
AS al
6. Through this a obit Beach Post seeks public access to the testimony,
minutes, and other evidence p ed in 2006 to the Palm Beach County grand. jury empaneled
during the first E i S s se investigation. Typically, access to such materials is limited, for
example, in ent the flight of those whose indictment' ay be contemplated arid their
ability t: r destroy evidence; to ensure jurors' candor in deliberations; and to protect an
accus • ho is later exonerated. However, these factors are inapplicable here. Also, Florida law
expressly authorizes the disclosure of grand jury proceedings under certain circumstances,
including, as here, in the furtherance of justice. Fla. Stat. § 905.27(1)(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.
CA/Awit eifign 2LitIl BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735801
• •
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 aperiod of several years while exploiting his wealth and political connections
to obstruct the administration of justice at every firm. Publie disclosure of the. Epstein d jury
proceedings will shed light on tile. extent to which those in, our government en *th the
solemn. responsibility of enforcing our criminal laws equally as to all citiz their duties
in this instance. Justice will be furthered where it is either (1) demo ern was treated
like others accused of similar heinous crimes, or (2) as appears e to be the those < 5 1.
who chose to give Epstein favorable.— "(Mutual," in the w o ownof Palm Beath Polite
Chief -treatment,. treatment, are exposed and held accountable. imited information is now in the
public domain, the State Attorney's referral of to the grand jury - which would be
out of the ordinary for this type of case se to a strong inference of favoritism and
corresponding disregard for the ri or victims of Epstein's sex trafficking. Access to
lic to determine whether the grand jury process, and.the
secrecy that comes with it, wasted to further justice or, instead, operated to shield Epstein and
his co-conspirat fio c consequences of their criminal activities. Accordingly, Fla. Stat.
Section Si05 es the disclosure of Epstein's 2006 grand jury proceedings.
in the absence of such a statutory basis, this Court is empowered to order
public sclosure 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,
the grand jurymaterials will
3
CAB1/4"VirL50.% 2L4101 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735802
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 Beat County
grand jury first being submitted to this Court for in camera review, where be redacted,
as appropriate, to protect those who deserve such protection.
FACTUAL BACKGROUND
-14110. 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 z
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:
2005-2008.
I I. The investigation into Epstein's sex crimes began more than fourteen years ago,
when a 14-year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that
Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein
required thegiii to strip, exposed himself, and masturbated while touching her. The girl was paid
$300.Ips -tein UfSs 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.
4
CA/Alt itt'S 261 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735803
• •
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 schethiled at which all of the were
expected to testify. The proceeding was postponed, however, due to meeti eeu the State
Attorney's office and Epstein's prominent criminal defense lawyer a 1 friend, Alan
Dershowitz.
15. Another grand jury-Wit conVittiedin April 2 ,. celed the•dity before it was g )
to begin receiving evidence.
(1) Police Chief Reiter's to the State Attorney.
/161 On May 1, 2006, Town o • Ich Police Chief Michael Reiter wrote a 011143„
"personal and confidential" letter t Beach County State Attorney, Barry Krischer,
Stating:
I must renew my prior tion to you that I continue to fmd your office's
treatment of [the Si] cases.highly unusual. It is regrettable that I am forced to
communi to in et, but my most recent telephone calls to you and those
of the 1 detec e to your assigned attorneys have been unanswered and
messa r aim unreturned. After giving this much thought and consideration,
yo t to examine the unusual course that your office's handling of' this
had taken and consider ligood. and sufficient reason twigs to require your
Alification from the prosecution of these cases, (Emphasis supplied)
Chief Reiter's letter to State Attorney Krisehet enclosed the Town of Palm Beach.
Police Department's probable cause affidavits charging Epstein and two of his assistants with
multiple counts of unlaviful sex acts with a minor and one count of sexual abuse,. and requested
5
tAlArofeN99ali BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735804
• •
that either an arrest wanant 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 an other crimes. According to official
spokesperson, this was the first time that a sex crimes toe was presented to a grand a. Palm
Beath County.
AS
et ht19. In July 2006, after State Attorney Krischer presented t ' evidence from
one victim, the grand jury returned au indictment on a sole coun of i ' 'Cation of prostitution.
There is no mention in the indictment of the victim being a
20. On information and belief, a second o
j
l st victims was supposed to testify
before the grand, jury;.but was unable to attend b of a school exam.
21. No reasonable explanation ovided as to why the numerous other known
victims were not presented as witnes evictiins to the grand jtuy convened in July2006.
Nor has any reasonable expl n provided at to why State Attorney Kritcher, who was
initially eager to investigate an ecute Epstein for his crimes, over time lost the desire to do
SQ.
22. Oh' Marion. and. belief, dining. the grand jury' appearance of the: single victim
who t th State Attorney presented evidence that vilified the victim: and attacked her
credib including soliciting testimony regarding underage; drinking and questionable personal
behavior that was unrelated to. the charges against Epstein. Further upon information and belief,
this information was initially brought to the attention of the State Attorney's office by Epstein's
defense counsel.
6
CA/Arcf litegbnat BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735805
• •
(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 investigationof. Epstein,
24. Records unsealed in 2015 reVealed that the FBI compiled. eptuis on "34.conftrined.
minors" that were victims of Epsteil'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 at
request of Epstein's lawyers, the indittmenrivas never presented to a
25. Instead, then U.S. Attorney for the Southern District of Alexander. Acosta,
negotiated a plea deal with. Epstein's team of lawyers to ty to Epstein (along with
four named co-conspirators and any unnamed potential ors) from all federal criminal
charges.
26. Throughout the remainder of,S 6 Ugh the first half of 2008, Epatein'a
lawyers and the U.S. Attorney confi
?
rm otia g the plea arrangement. Upon information and
belief, Epstein's. lawyers insistcvil the victims not. be notified, (2) the deal be kept
confidential and wider teal, grand jury subpoenas (including one that had already been
issued for Epstein's co. be withdrawn..
27. tine 3 . 0Q8, Epstein pled guilty to State charges: one count-of solicitation of
prostitutio e crount of solicitation of proatitution with a minor under the age of 18. He was
sent months in jail, followed by a. year of community control or house arrest, and was
adjudicat as a.convicted.sex offender regwred.to register twice a year inFlorida.
28. The plea .deal, called a non-prosecution agreement (INPA"), allowed Epstein to
receive immunity from federal sex-trafficking charges that could.have sent him to prison for life.
7
CAffirlifeWriel BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735806
• •
On information andbefief, 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 Stale crimes for
which he was convicted. Instead, he was placed in a private wing of the Palm Beach County
Stockade, where, after 3 I/2 months, he was allowed to leave the jail on "woik release" for up to
12 hours a day, 6 days a week. His private, driver provided his transportation to an "work,"
30. Epstein was released five months early.
31. Upon information and belief, Epstein violated the. t ration, but was
not Ptosegited,
/Th
(4) The Crime Victims' Rights Act Lineation.
32. Epstein's victims only teamed after th Nisi his plea, in State court and filed "ftifi re4
an emergency petition to force federal prosecut to mp y with the Crime. Victims' Rights Act
(18 U:S.C. § 3771, "CVRA"), which manila ' rights for crime victims, including the right
to be informed about plea. agreeme 'Or to appear at sentencing.U.:S, District Judge
Kenneth A. Matra recently m . prosecutors violated the CVRA by failing' notify
Epstein's victims before allow to plead guilty to only the two State offenses.
33. The 's failure to keep the victims apprised, among other things, also
Contravenes y " Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001.
owing publicity exposing the extraordinary leniency of the plea deal, dozens of
civil were brought against Epstein,. mostof whith Epstein's lawyers settled out-of-court.
55. In 2010, Epstein was registered as a "level three". (t: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 lowerhis regittration to low-riSk "level one."
8
CA/AroptepeOLUSt ram BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735807
•
36„ lJpou 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.
17. Upon information and belief Epstein's victims were threatened against peratiii,g
with law enforcement and told that they would be compensated only if they did not to with
law enforcement.
("I N B. Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019.
38. On July 6,2019, Epstein was arrested on federal sex trafficking charges.
39. Upon information and belief, the United S ent's investigation of new
allegations and charges stemmed in part, from con vestigations into and reporting•
on the mishandling of the 2006.charges and the • • Is that followed.
40. In. a July 8, 2019, letter to the district court by the U.S. Attorney for the
Southern District of New York Epst ribed as "a serial sexual predator who preyed on
dozens of Calor girls over a ." 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 coul .att pressure and intimidate witnesses and. potential witnesses in this
case, includin" vi and their families, and otherwise attempt to.obtfruct justice." It also
totIts of the FBI's search of Epstein's Manhattan tow.phouse:, evidence of sex
g tu 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] 4 [Name]," "Misr
nudes 1," and "Girl pies nude."
9
CA/ArOla99125a A1,1% BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735808
• •
41. On July 8; 2019, prosecutors with the Public Corruption Unit oft 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 o Florida,
Alexander Acosta, who 'by then was
administration, resigned from office.
AS
42. Epstein was denied bail and was placed into pretria t at the federal
Metropolitan Correction Center in lower Manhattan.
43. Oil or about August 6, 2019, Hestia Goir. is ordered a state criminal
probe into the actions of the Palm Beach Sheriff tate Attorney Krischer for their
handling of the Epstein underage sex Iniffickin
.44. On August 10, 2019, Eps found dead in his cell at the Metropolitan
Correctional Center. His cause of d ermined to be suicide,
CS d)C. The August 27. 20 . eating: Epsteln's Victims Speak.
45. On account of eath, prosecutors sought to dismiss the indictment against
Epstein, while ma taioi they would continue to investigate his co-conspirators.
46. 1 States Senior District Judge Richard M. Berman Ordered a hearing. on.
August on the prosecutors' decision to dismiss the indictment and allowed victims to
speak
serving as V.S. Secretary of Labor id Trump
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 vittims were present in the courtroom but did not testify.
10
CA/AroppiefarI) 001253 VIX1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735809
• •
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 ab "exploitation
andcoercion, and to the fact that many of them "were in very vulnerab and in extreme
poverty, circumstances where [they] didn't have anyone on , to speak, on [their]
behalf...." One victim lamented that "as b. Vittia [she] n what the agreement was
or why the special treatment got approved" in the Fl ars earlier. Another noted how
dmg\"completely different" the investigators lea • o 2019 federal indictment were from the
A, prosecutors in the. Florida case, both in . ea ent of her and their investigation of her
victimization by Epstein.
*
50. A former fed attendance at the August 27th tearing emphasized that
"transparency is one of the.ova g objectives in our criminal justice system."
51. Ne y a e victims expressed the conviction that the secrecy that shielded
Epstein. has
YYYYYY
"irreparable harm" and that at. opportunity' to. address his alining
wrongd those of the individuals who enabled his sexual racketeering, would allow for
at leas me measureof 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
11
CA/Ar IlLeirtMa% BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735810
"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 Ilas Reported Extensively On Loan
Crimes For Nearly 15 Years.
52. Plaintiff, The Pains Beach Post, it a community newspaper se
Beach Countyand the Treasure Coast vicinity.
53. The Pahn..Beach Post WS. been, 0 Pftlitzer Prize winner
three other' tithes.
54. Beginning in 2004, The Palm Beach Post
on the allegations against, the law enforcement i
Epstein and his co-conspirators. The New
following articles:
ders. Palm
ted as a finalist
ely investigated and reported
of, and the crimes committed by,
rtage has included publication of the
• "The Man Who Had Jeffrey Epstein Craved Big Homes, Elite Friends
and, Investi tors e Girls;" published on August 14, 2006, reporting that:
unity college student, admitted in a sworn statement to
police that "she ha at least six. girls to visit: Epstein, all between the ages of 14
and 16;" Pa act Police 'Interviewed five alleged victims and 17 witnesses;"
"Dershowitz arrtlaw professor, traveled to West Palm Beach.With information
abou ie girls including social media discussions about "their use of alcohol and
." after meeting with. Epstebi'S legal teat, "proteCutors postponed their
n take the case to a grand jury," Palm Beach Police subsequently "received
mpr rots that two of the victims or their (=lies had been harassed or threatened;"
ons between police and prosecutors were fraying" as the investigation continued;
d "one girl who was subpoenaed — the one who said she had sexual intercourse with
Epstein —never showed up" to testify before the grand jury.
• "Trump Snags Gosman Estate for $41 Million" published on November 16, .2004,.
reporting on the bidding war between Donald Trump and Jeffrey Epstein for the
purchase of a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along
the Storied `Raider's. Row' " in PAM Beach.
12
cA 'AmPitegOIS BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735811
• •
• "Expert: Ignorance of A
reporting that "[lather
to a county grand j
charge of felony
because the state a
• "Indictment: Billionaire Solicited 3 Times" published on,Jtny 25, 2006, reporting that
"Billionaire money manager and Palm Beach part-time resident Jeffrey. Epstein
solicited or procured prostitutes three or mote times betweeti.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 th anindictment charging a person with
the commission of a crime."
• "After Long Probe, Billionaire faces Solicitation Charge" published on Jul
reporting that "Palm Beach police thought time was probable cause to
with unlawful sex acts with a minor and lewd and lascivious moles
further reported that "Police Chief Michael Reiter was so angry _W: State Attorney
Barry Krischer's handling of the case that he wrote a menio suggesting the county's
top:prosecutor disqualify himself," and identified a 20-y on-the-record female
source who said "she gave Epstein a massage in the nude, en brought him six girls,
ages 14 to. 16, for massage and sex-tinged sessions at •s ho "
• "Police Say Lawyer Tried to Discredit Teenag
reporting that "[flamed Harvard law profess
Beach County State Attorney's Office
teenage girls who say they gave his c
sexually charged massages" and that.'
iblished on July 294. 2006,
owitz met with the Palm
damaging information, about
ach billionaire. Jeffrey. Epstein,
at attomey's office said it presented the
Epstein case to a county grand juet in r i th rather than directly charging Epstein
because of concerns about the girls' credibility?'
t Defense In Sex Cases" published on August 5, 2006,
lefharges, the state attorney's office presented the case
"indicted Epstein last week on a single, less serious
of prostitution," and that "[tjhe case raised eyebrows
s office rarely, if ever, kicks such charges to a grand jury."
Female Accusers Liars" published on August 8, 2006, reporting
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,
g that Chief Reiter "pressed for Epstein to be charged with the more serious
crimes of sexual activity, with minors" and "slammed StattAttomey Barry Krischer in
blunt language seldom used by one law enforcement official with another because of
what he perceived as that office's mishandling of the case:
• "Delays in Epstein Case Unusual, Lawyers Say" published on Mtirell 13, 2007,
reporting that "[njearly eight months after Palm Beach tycoon Jeffrey Epstein was
charged with felony solicitation of prostitution, there has been no discernible progress
in his case."
13
CA/Aroglegb99,12.% am BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735812
• •
• 'Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published
on October 18, 2007, reporting- on a lawsuit brought in New York State court against
Epstein "by a young woman who says he had sex with her when she was 16 and had
sought his help becoming a model."
• "Palm Beacher Pleads In Sex Case." published on July 1,2008? reporting that "Epstein,
55,.pleaded guilty ... to felony solicitation of prostitution and procuring a person under
the age of 18 for prostitution," resulting in "ilifelong obligation to register as a sex
offender;'' and that "[a]s part of the plea deal, federal investigators agreed to jirop their
investigation of Epstein, which they had taken to a grand jury."
• "Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Ty ub1i1ted on
August 13 2008 thin; that "[d]uring his first month of co • Epstein was
visited by who allegedly escorted victims ‘'upon v at his Palm
Beach waterfront home to an upstairs room, where she prep ssa and
provided the for their encounters" With. Epstein, and
e table
"a
young woman whom Epstein purportedly, described as his avian sex slave."
• "Billionaire Sex Offender Leaves Jail Six Days r Work" published on July
1, 2008, reporting that Epstein "is allowed to aim 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 ous courts "want his [non-prosecution]
agreement [NPA] with federal to unsealed" and were moving to unseal the
agreement in Circuit Court of .ludicialCircuit, and that "Epstein now faces
at least a dozen civil law I and state courts filed by young women who
said they had sex with an ow are seeking dantages." On. that date, The Palm
Beach Post moved t in the matter for the purpose of obtaining public access
to the NPA, which as or disclosed by this Court on June 25, 2009.
• "Epstein's. Secret Pact With Feds Reveals 'Highly Unusual' Terms" published. on
September 19, 2009; reporting that, owing to Epstein's nontrOsetution.agreettient,
"federal pEcutors backed down and agreed to recall .grand jury subpoenas if Epstein
pleaded guilty to prostitution-related felonies in state court" and 'talso agreed not to
e any ' ' ' le co-conspirators; IMM Adriana. ROSS, Lesley C ue
roff iand " The. article further reported that, according to an
y representing three of Epstein's victims, "none of the. 30 to 40 wom[e]n
titled 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 iadamages from the part-time Palm Beach resident."
14
cA' ArcTlilc$5911074 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735813
• •
• "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 S5,5 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 dOzetteeias who sued him."
• "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Tee
Rights" published on February 22, 2019, reporting on a ruling by U.S.
Kenneth Marra that "Federal prosecutors violated the rights of
teenage victims [under the Crime Victims' Rights Act] by faihn
dropped plans to prosecute the billionaire on dozens of federal
with the girls' claims that he paid them for sex at his Palm
Victims'
t Judge
y E rein's
eat they had
connection
on."
• "Epstein Indicted On Sex Charges/Part-Time Palm BeacheMJ ds Not Guilty to Sex
Tiafficking„ Conspiracy Charges In Federal Court ttan" published on July.9,
201.9, reporting on Epstein's appearance in U.S. i for the.Southem District
of New York in which he "pleaded not guilty cusing him of creating a vast
network of girls as young as 14 that be ex sexual pleasure at his homes
in Palm Beach and Manhattan_"
A true and correct copy of the above news arti the computerized format in which they
are maintained in The Palm Beach Post Iec archives or the news print edition in which ,. ..ri
originally published, is annexed h t • Wit I.
55. Since the filing f the al Complaint in this matter, The Palm Beach Post —along
with media worldwide continued to report on Epstein's crimes and the ongoing official
proceedingsresu gfro ose. crimes.
(2) 7he Palm Beach Post's Standing and the Public Interest.
Q Richmen Newspapers; Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal
e press has a constitutional right of access to criminal proceedings, see, e.g.,
proceedings. v. Graddick 696 Fld 796 (11th Cir. 1983). Indeed, "the integrity of We
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
cAtArcifirE1599X2C101 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735814
• •
Co. v. M, 426 So, 241, 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, 754-57 (1976) ("Where a speaker exists . the protection afforded [by
the First Arnenditient] is to the communication, to its sOtute and to its recipients both.' • Pittman
v. 207 F.3d 1269, 1283 tt,12 (11th Cir. 2001) Ole Supreme Courthas t the
First Amendment offers protection to both speakers and those wishing to ia h."); see
also Stephens v: Cry. ofAlbentaile, Va., 524 F.3d 485, 442 (4th Cir. 200
has "standing to assert a right to receive speech" by "showlingl
to convey the information to her).
57. Because of the unique role performed as a "public surrogate" (M,
426 So. 2d at 6-7) in protecting the right of act is interest. in reporting information about
that a plaintiff
sts a speaker willing
criminal proteedings, news organizations ' ely have a right to access judicial records,"
Comm 'r, Ala. Dep't of Corr. v. A
and "standing to question the
news is directly impaired or
837 F.34 753, 757-58 (7 , 2016) ("Eals a member of the public, [the Reporters Committee]
has standing ] claim" to grand jury materiahbecause such materials are "public record.s
to whit 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 jounudistS and the pUblk it serves "unquestionably constitutes irreparable injury:"
Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also
Zerilli v. M, 656 F.2d 705, 711 (DC Cir. 1981) (noting that "the press' function as a vital
eciia,.LLC, 918 F.3d 1161, 1166 (11th Cir., 2010),
order restricting publicity because its ability to gather
426 So. 2d at 4; see also Clifton v. United States,
16
cAmropirg591^45.a . BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735815
source of information is weakened whenever the ability of journalists to gather information is
impaired," as it is by Attorney Genetal's refusal to disdlose tairechicted report and underlying grand
jury materials).
59. The Palm Beach Post has the right to maintain this private right of action because
the furtherance of justice, an express legislative exception. to grand jury secrecy, is int • ded for
the public benefit, and The Paint Beach Post seeks access ou behalf of the pubIll. a. Star,
§ 905.27(1 Xc). It is further express in Fla. Stat. § 905.27 that the legislatur for a court
to be the party to make the determination of disclosure: Fla. Stat. § 90 ther words, the
legislature intended for recourse to the courts is c.onsidering an g the propriety and
scope of grand jury secrecy.
E. The Court's Jurisdiction And Authority
(1) The Court's Sunervision of the Grand Jury Process and Its
Authority to r Public Disclosure of the Epstein Evidence.
60. The Florida Supreme C has red that "in states such as Florida, where the ...
grand jury is preserved, it is an i dage of the court which impanels it. At the same
time it should not be forgott udge of that court is equally important and he is generally
charged with the . ' of the grand jury's activities...lt is, therefore, of vital importance to supeW
maintain the di and' integrity of both the grand jury and the presiding judge." State v.
Q Clemons, 1 2d7131, 2313-34 (Fla. 1963).
61. apter 905 of the Florida Statutes governs the empanelment and conduct of
Florida d juries: The court gives the grand jury its initial. charge and advises the grand jury
about its legal duties. Fla. State § 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
CAVAITh elrffinn BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735816
court . . for the purpose of; (a) Ascertaining whether it is consistent with the' estimony 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 bet/line of the exceptional public interest in this case and the cgntpelling
circumstances supporting transparency. Car/sop v. United Stoles, 437 F.3d at 760
has the inherent power to disclose [grand jury] materials in exceptional c
historic importance can be a sufficient reason when there is little coun
64. The Florida Supreme Court has confirmed that
and that any "potential !faun to publie officeholders" froni
own conduct, and not the consequence of an unr
Herald PO. Co. v. Marko, 352 So. 2d 518
extraordinary exercise in citizen participati
fruits of that activity were not avail.
the power of the grand jury to
to be informed of its findings
risk of reputati
officeholders will
S eth grand jury] would be severely limited if the
uhlic on whose behalf it h undertaken. Implicit in
J
ct court
ces and .
d for secrecy's).
recy is not absolute.
'Will be the product of their
of misguided citizens." Miami
e benefits to be derived from this
and expose official misconduct is the right of the people
public disclosure of grand jury findings inevitably entails the
the legislature has ensured that any potential harm to public
e product of their own conduct, and not the consequence of an unrestrained
body of mist& 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 umber relief is or could be claimed. Florida Stat. Section 86.011.
18
CA/Aropiron12fil. am BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735817
• .
66. Florida law specifically provides that a declaration, may be sought from the Cotut
concerning a petitioner's rights Wider a statute. Florida Stat. Section 86.021 ("Arty person...whose
rights, status, or other equitable or legal relations are affected by a statute, or any regulation
under statutory authority,...mayhave determined any question of construction or validity arising
under such statute,...or any pat thereof, and obtain a declaration of rights, status, or other 'table
or legal relations thereunder.").
67. The Cowl's exercise of its power to declare rights "is to be dministered
and construed." Florida Stat. Section 86.101.
COUNT I
(Declaratory Relief- Florida.Stat. Seeti et seg.)
68. The allegations set forth in paragraphs. 67 are incorporated by reference
as if fully set forth herein.
69. This is an action for Decl'
and other supplemental relief
70. The Palm Bea lpfectfiillyregttests that the Court declare that pursuant to
Fla. Stat. Section 905.27(1), it. titled access to the testimony, minutes, and other evidence
presented in 2006 the ch. County grand jury because such disclosure and access would
be in the f justice. Fla. Stat. § 905.27(1Xc). Because The Palm Beach Post is not
seeking, s in connection with either a civil or criminal case, it seeks .a declaration that
the sco of its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2).
71. The Pahn Beach Post further seeks a declaration that distlesure of the testimony,
minutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate
►Relief pursuant to Chapter 86, Florida Statutes,
19
C
CA/Amft e#O9a 61i BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735818
• •
pursuant to this Court's inherent apthorityover grind jury proceedings because of the exceptional
public interest in this case and the compelling circumstances supporting transparency.
72. The Pahn.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 Moulins to dismiss the Complaijtt and the
relief it sought under Fla, Stat. Section 905,27()). Accordingly, a good-faith dispute tween
Ociable question
the patties.
73. Through this Complaint, The Palm Beach Post present!
concerning its rights to obtain the 2006 grand jury materials pursu to bWat. Section 905.27(1)
and the Court's inherent authority.
74. A bona fide, actual, present, and prat or the declaration exists in that
oi\Defendants have denied to The Palm Reach P — d to the public at large — the grand jury
materials sought to be disclosed. The relief
of legal advice or to answer hypothe
WHEREFORE, The P
fro the Court is ihereforenot merely the giving
or respectfully :requests that the Court. determine the
rights and obligations of the by@tclariiig- thatpurstfant:to Fia4StitY;Secnozir905.27(i)(4
the Courts eren u rity, Port :SAS, •geinNas:, to the. testimony'
ence C0untitiandityy:antinseihoie)(minutes,;and'
(mater tebeinforiningatMie)
=MIL
(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
CA/ArOpribly ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735819
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
sexual assault.
77. Pursuant to Florida. Stat. Section 905:27, in order to enr jusSti e for Epstein's
victims and the public, and to provide public disclosure to te whether Epstein received
'unreasonably lenient treatment based do the available evi• ce, jl Palm Beach Post requests
immediate access to the testimony, minutes, and o ewe presented in 2006 to the Palm
Beach County grand jury.
78. In a case of this magnitude
of his crimes, as well as the identil
victims have already been ex
v. Socony-Vacuum Oil Co., 31' .S. 150,. 234 (1940) ("Vifter the grand jury's functions are
d
ended, disclosure
‘ ce, where the accused is dead and so many
es of his co-conspirators, and the identities of the
for grand jury secrecy is no. more. See United Stow
who p oper where the ends of justicerequire
ThePahn Beach Peon respeotfilly requests.that this Court, pursuant to
Stat. S 7(1) and the Court's inherent authority, order the State Attorney and the Clerk
of the urt to fileWith this Court copies of the testimony, minutes, and, other evidence presented
in 2006rn the Palm Beach County grand jury during the first Epstein sex abuse :uoresngation so
duit, following an in camera inspection, it can be made available to The Palm Beach Post and the
21
CA/Aropitefftippt2CA A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735820
public on an expedited basis, and grant any other and further equitable or legal relief the Cowl
deems just and proper.
Dated: January 17, 2020
CG
Respectfully submitted,
GREENBERG TRAURIG,?.A.
Attbtheys for CA Florida HOldifigt, LLC,
Publisher of The Palm Beach Post
Stephen A. Mendelsohn, Esq.
5100 Town Center Circle, Suite 4
Boca Raton, Florida 33486
Telephorie:. ([Phone Redacted]
Facsimile: (561) 338-709
Bya /s/ Stephen A Models
STEPHEN A
Florida Bat N
mendelso
hasenh
FLSe
GRYG1EL.
tted Pro Hat Vice)
54 State St,; 6th. Floor
Albany; New York 12207
Telephone: ([Phone Redacted]
Facsimile: ([Phone Redacted]
grygielm@gtlaw:com
By: /s/ Nina D. Bovaiian
NINA D. B0YATIAN
(Pro Hoc Vice application pending)
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: (310) 586 -7700
Facsimile: (310) 586 -7800
[Email Redacted]
[Email Redacted]
22
CA/Ar0ppegb5M5. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735821
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/Sievhen A. Mendelsohn
STEPHEN A. MENDELSOHN.
23
CA/AnlifEb C.WL14 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735822
0
EXHIBIT 1
Tlie Newspaper's Reportage on Jeffrey Epstein
7CA/Arophc1- 00t2fi rAL4 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735823
•
The Palm Beach Post REAL NEWS STARTS HERE
The Man Who Had Everything: Jeffrey Epstein craved big
homes, elite friends and underage girls
By Andrew Marra
Posted Jul 17, 2019 at 6;02 AM
From the archives: When Palm Beach detectives starte
questions and teenage girls started tAlking, a wave o esistance
followed.
Editor's Note: This artiatappeared in The Palm Beach Post on 2006, three:weeks after
Jeffrey Epstein's arrest in Palm Beach County on a charges sy citation of prostitution.
WINGED GARGOYLES guarded thegate at je
hidden camera trolled two rooms, while th e and went.
Sst m's Palm Beach mansjon. Inside,
hFor the police detectives who sifted t¢r e garbage outside and kept records of visitors, it
was the lair of a troubling target.
Epstein, one of the most Myst us f the country's mega-rich, was known as much for his
secrecy as for his love of
friendships with th orl elite.
But at Palm
regular
favo
things: magnificent homes, pritate jets, beautiful women,
e headquarters, he Was.becomirig known for something else: the
enage girls he hired to give him massages and, police say, perform sexual
Epstein was different from most sexual abuse suspects; fie was far more powerful: He tounted
among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
with some of the most prominent legal, scientific and business minds in the country.
When detectives started asking questions and teenage girls started talking, a wave of legal
resistance followed.
I
CA/Aropiten599t268, awl BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735824
• I
NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work -
release
If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.
Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends
quietly, always in the background as he navigated New York high society.
When he first attracted notice in the early 1990s, it was on account of the womatlhdwas
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Mirell.
In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love,"'the British
Mail on Sunday tabloid laid out speculative stories that the socialite's beau Was a CIA spook, a
math teacher, a concert pianist or a corporate headhunter.-
"But what is the truth about him?" the newspaper wondered. "Like' Maxwell, Epstein is both
flamboyant and intensely private."
The media frenzy did not begin in full until a decade later. In September 2002, Epstein was
flung into the limelight when he flew Clinton -and actors Kevin Spacey and Chris Tucker to
Africa on his private jet.
Suddenly everyone wanted to kpowWho Epstein was. New York magazine and Vanity Fair
published lepaliy profiles. The New, York Post listed him as one of the city's most eligible
bachelors and began describing him in its gossip columns with adjectives such as "mysterious"
and "reclusive."
Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
Building a life of extravagance
He was born blue-collar in 1953, the son of a New York City department employee, and
raised in Brooklyn's Coney Island neighborhood. He left college without .a bachelor's degree
but became a math teacher at the prestigious Dalton School in Manhattan.
The story goes that the father of one of Epstein's Students was so impressed with the man that
he put him in touch with a senior partner at Bear Stearns, the global investment bank and
securities firm.
1
CA/AropEgb9qAPPA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735825
• • hi 1976, Epstein left Dalton fora job at Bear Stearns. By the early 1980s, he had started J.
Epstein and Co. That is when he began making his millions in earnest.
Little is known or said about. Epstein's business except this: He manages.tnOney for the
extremely wealthy. He is said to handle atcotnits only of $1 billion or greater.
It has been .estimated he has roughly 15 clients, but their identities are the subject of only
speculation. All except for one; Leslie Wexner, founder. of The Limited retail chain dAtimrka
former Palm Beadier who is said to have been a mentor to Epstein.
a
Weiner sold Epstein one of his Most lavish residences: a massive townho
block on. Manhattan's UpperEast Side. It is reported to have, among c is)
circuit television ands heated sidewalk to meltaway fallen snow.
don:Unites a
tures, closed-
That townhouse, thought to be the largest private.residenc attan, is only a piece of
the extravagant world Epstein built over time.
A OIn New Mexico, he constructed a 27,000-square-foc Si p mansion on a 10,000-acre ranch
outside Santa Fe. Many believed it to be the largesciorne in the state.
In Palm Beach, he bought a waterfront home on I Brill° Way. And he owns a 100-acre
private island in the Virgin Islands.
» ?HEIM; tlitplinyets Epstein #40a.
Perhaps' s remarkable as sh homes is his extensive network of friends and associates at
the highest echelo •fpo r. This includes not only socialites but also businesstycoons,
media moguls s, royalty and Nobel Prize-winning scientists whose research he often
"just lik ter people. collect art, he collects scientists,' said Nowak, who directs the
Program for Evolutionary Dynamics. at Harvard University and was reportedly the recipient of
a $30 million research donation from Epstein.
Epstein is said to have befriended former Harvard President Larry Summers, prominent law
Professor Alan Derihowitz, Donald Trump and New York Daily News Publisher Mort
Zuckerman.
CNArclianiVilarla BEACH COUNTY, FL,
- - .
ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735826
• •
And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
photographed.
"The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials
and tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article.
Epstein's friendship with Clinton has attracted the most attention.
Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars toot him at
<tan intimate fund-raising dinner in. Palm Beach. But from all appearances, they • no come
close friends until after Clinton left the Oval Office and moved to New YoC )
s;CEpstein has donated more than $100,000 to Democratic candidates' mp , including John
Kerry's presidential bid, the reelection campaign of New Mexico Co ill)Rithardson and the
Senate bids of Joe Hillary Rodhain Clinton, Chi Dodd and Charles
Schumer.
Powerful friends and enemies
A Vanity Fair profile found cracks in the v life story. The 2003 article said he
left Bear Stearns in the wake of a federal probe a d a possible Securities and Exchange
Commission violation. It also poin 2u at Citibank once sued him for defaulting on a $20
million loan.
bcThe article suggested that one • s business mentors and previous employers was Steven
Hoffenberg, now serving , zprison term after "bilking investors out of more than $450 million
in one of the lark Ponzi schemes in American history."
As he amassed his alth, Epstein made enemies in disputes both large and small. He sued the
man who in'1990 sold him his multimillion-dollar Palm Beach home over a dispute about less
than $16,000 in furnishings.
A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
owed him nothing.
» JeffreyEpstein. Model prisoner who swept, mcpped floors, official says
1
I
CA/Aronlaerac0Q127.1 Him rALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735827
• •
"It's a bad memory. I would rather not have ever met Jeffrey Epstein,' said Michael Stroll, the
retired former president of Electronics and Sega Corp. "Suffice, it to say I have
nothing good to say about him."
Among the characteristics most attributed to Epstein is a penchant for women.
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
and London. Previous girlfriends are said to include a former Ms. Sweden and a Ro anianAimek
model.
"He's a lot of fun to be with," Donald Trump told New York magazine in 2,00R is even said
that he likes beautiful women as much as I do, and many of them are o ttoynger side. No c )
doubt about it, Jeffrey enjoys his social life."
Investigation leads to Epstein
Although he was not a frequenter of the Palm Beach social scene, he made his presence felt.
Among his charitable donations, he gave $90,000 tp die Patm Beach Police Department and
$100,000 to Ballet Florida. - -
4/7 \
In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a
Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a
private chef and a small staff stood atthe ready. From a window in his mansion, he could look
out on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man
who had everything.
3 .1Iff
But extraordina lth n fuel extraordinary desires.
» Epstet , - to leave jail for mansion in sex -trafficking case
In Marc 005, a worried mother contacted Palm Beach police. She said another parent had
overheard a conversation between their children.
Now the mother was afraid her 14-year-old daughter had been molested by a man on the
island.
The phone call triggered an extensive investigation, one that would lead detectives to Epstein
but leave them frustrated.
CA/Aropkettp BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735828
• Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm
Beach pollee report detailing the criminal probe offers a window into what detectives faced as
they sought to close in on Epstein:
Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to
perform a massage. She said the friend told her to say she was 18 if asked. At the house, she
said she was paid $300 after snipping to her -panties and massaging the.man while he
masturbated.
AS'
The investigation began in full after the girl identified Epstein in a ph man who had
paid her. Police arranged for garbage trucks to set aside Epstein's 'tra so olice Could sift
through it. They set up a video camera to record the comings oin at his home. They
monitored an airport hangar for signs ofhis private jet's departures.
They quickly learned that the woman who took the - a d girl to Epstein's house was
a Palm Beach Coinniunity Coll s era oizi Loxahatchee. In a s"worn
statement at police headquarters, itted she had taken at least six girls to
visit Epstein, all between the ages of 14 16. tein pail/ her for eachvi,sit, she said.±
AlcPolice interview 5 alleged victims
During the drive back to her ho told detectives, I'm like a Heidi Reiss.*
Police interviewed five alleged s and 17 witnesses. Their report shows some of the girls
said they had been ins to have sex with another woman in front of Epstein, and one said
she had direct intercourse him.
In October, ed the Palm Beach. mansion. They discovered photos of naked, young-
looking f t as several of the girls had described in interviews. Hidden cameras were
found rage area and inside a clock on Epstein's• desk, alongside it girl's high school
transcript.
Two of Epstein's former employees told investigators that young-looking girls showed up to
perform massages two or three times a day when Epstein was in town.
They said the girls were permitted many ind‘dgences. A chef cooked for them. Workers gave
them rides and handed out hundreds of dollars at a time.
j
r
CIVAropiteb, LM BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735829
• One employee told detectives he was told to send a dozen roses to one teenage girl after a high
school drama performance. Others were given rental cars. One, according to police, received a
$200 Christmas bonus.
The cops moved to cement their case. But as they tried to tighten the noose, they encountered
•
other forces at work.
In Orlando they interviewed a possible victim who told them nothing inappropriate had
happened between her and Epstein. They asked her whether she had spoken to atueselse.
She said yes, a private investigator had asked her the same questions.
» Jeffrey Epstein: Acosta, Krischer trade barbs over sweethear d
When they subpoenaed one of Epstein's former employees, he told t e same thing. He
and a private eye had met at a restaurant days earlier to go o wjjt the man would tell
investigators.
StDetectives received complaints that private eyes were rt g as police officers. When they told
Epstein's local attorney, Guy Fronstin, he sai vestigators worked for Roy Black, the
high-powered Miami lawyer who has defer de es of Rush Limbaugh and William
Kennedy
While the private eyes were co parallel investigation, Dershowitz, the Harvard law
professor, traveled to West P Be with information about the girls. From their own
profiles on the popular site MySpace.com, he obtained copies of their discussions about
their use of alcohol d m ij ana.
He took his r - -b meeting with prosecutors in early 2006, where he sought to cast re
doubt on the teens)reliability.
- . -
The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
did some of the girls have issues with drugs or alcohol but also some had criminal records and
other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she
told police she was younger than 18 when she started performing massages for Epstein.
After the meeting, prosecutors postponed their decision to take the case to a grand jury..
I
•
CA/Aropilefg50 4rmir...Aivi BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735830
In the following weeks, police received complaints that two of the victims or their families had
been harassed or threatened. Epstein's legal team maintains that its private investigators did
nothing illegal or unethical during their research.
By then, relations between police and prosecutors were fraying. At a key meeting with
prosecutors and the defense, Detective Recarey, the lead investigator, was a no-show,
according to Epstein's attorney.
"The embarrassment on the prosecutor's face was evident when the police office
showed up for the meeting," attorney Jack Goldberger said.
Later in April, Recarey walked into a prosecutor's office at the state c att e and
learned the case was taking an unexpected turn.
J
The prosecutor, Lanna Belohlavek, told Recarey the state attorney% office had offered Epstein
a plea deal that would not require him to serve jail time or receive a felony conviction..
'S !
Recarey told her he disapproved of the plea offer.
The deal never came to pass, however. ?S r,
On May 1, the department ask approve warrants to arrest Epstein on four aR2ros tors to
counts of unlawful sexual activity with a minor and to charge his personal assistant,
now 27, for her alleged role in arranging the visits. Police officials also wanted to
charge IM, the self-described Heidi Fleiss, with lewd and lascivious acts.
Future unclear after charge
By then, the epartment was frustrated with the way the state attorney's office had handled the
case. On th e day the warrants were requested, Palm Beach Police Chief Michael Reiter
wrote a tter to State Attorney Barry Krischer suggesting he disqualify himself from the case if
he would not act.
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
the grand jury.
I
CA/AV :Le: IOWA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735831
It is not known how many of the girls testified before the grand jury. But Epstein's defense
team said one girl who was subpoenaed - the one who said she had sexual intercourse with
Epstein - never showed up.
The grand jury's indictment was handed down in July. It was not the one the police
department had wanted.
Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was
charged with one count of felony solicitation of prostitution, which carries a lxignirn penalty
of five years in prison. He was booked into the Palm Beach County Jail early July 23 and
released hours later.
Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But
he said their claims that they had sexual encounters with him lack credibility.
"They are incapable of being believed," he said. "They had cijrnittal records. They had
accusations of theft made against them by their emp yers. There was evidence of drug use by
some of them."
\What remains for Epstein is yet to be seen.
The Palm Beach Police Departmen s e the FBI to investigate the case. It also has
returned the $90,000 Epstein cloven j 004.
In New York, candidates for go or and state attorney general have vowed to return a total
of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful
friends have remained silent as tabloids and Internet blogs feast on the public details of the
police investigation.
Goldbergettnaltif jains Epstein's innocence but says the legal team has not ruled out a future
plea dea\l. He insists Epstein will emerge in the end with his reputation untarnished.
"He will recover from this," he said.
Staff writer Larry and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and
Melanie Mena contributed to this story.
[Email Redacted]
CA/AroPftnk 2L7Piv1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735832
• •
INiTELLIGENT ORD ItiatgA I A,
CNAm PtLet43. 4f4 BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 I:04:39 PM
EFTA02735833
273 /278 - Tuesday, November 16, 2004
Edition: FINAL
Section: A SECTION
Page:. lA
Source: By PAUL OWERS Palm Beach Post Staff Writer
Illustration: PHOTO (C& 2 B&W) & MAP (B&W)
Memo: Ran all editions.
Dateline: WEST PALM BEACH
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
When it came time to bid Monday for the palatial Palm Beach digs of
Donald was not about to be trumped.
"Nobody was going to outbid Me," the brash developer-turned-TV- lity said from his
New York office.
Trump bested two other bidders with a $41.35 million offer 43,000-square-foot,
seven-bedroom estate on 6 oceanfront acres along the st es Row."
But Trump, 58, proud possessor of Mar-a-Lago, has we in the Gosman home at
513 N. County Road. He wants to - what else? - se d e more money:
The star of the tnegyhit The Apprentice Said he i s redtVelOp the site into a "Super
homy house" that would be the "finest anyw United States," He might build
another house before flipping the entire p
"I've !mown about this house for quite " Trump said. "Ifs probably the best piece
of land in Florida - and probably the or Unity real estate."
AlthenaLTrump said he could su property into nine lots, Palm Beach Ma.
Lesly said toning regul for only two houses - and maybe .a third.
said she's not worried about ans.
"He's been a very good props er in the town of Paint Beach," she said. "He does his
projects very well, He ectionist."
Monday's auction took t U.S. Bankruptcy Court in West Patin Beach as part of
Crosman's Chaps b ptcy case. Proceeds from the sale will go into escrow for eventual
distribution to ors.
The auctio eg a exactly noon after Judge Steven dismissed an objection from
an atto pre enting Money manager Jeffrey Epstein. The lawyer argued unsuccessfully
that not a qualified bidder because his contract stipulated that he would not close
on the le unless title insurance was in place.beforehand.
With T p listening via conference call; Epstein began the bidding at $37.25 million -
$250,000 higher than Truirm'S initial offer.
Mark Pulte, son of the founder of home-building giant Puke Homes, passed when his turn
came, letting lawyers for Trump and gsptein bid against each other until the price hit $38.85
million.
Pulse then bid $39.1 million, briefly raising the ire of Trump, who believed that Pulte had
given up his right to bid by passing the first time..
CA/Aroptegtpia7mo BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735834
• •
But allowed the offer to stand,.and ite and Trump went back and forth until
Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident; bowed out at
$38.6 million.
.closed the bidding 10 minutes after it started; leaving Trump with the right to buy
the 29,000-squard-foot home (a•typicil Palm Beach County single-family house is about
2200 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:
Tiustee Joe Luzinski and creditorssajd they were pleased with the outcome.
"We knew we were dealing with some substantial people . . Who were going tO up a
bit," Luzinski said.
"The system worked," said Charles Tatelbaum; a lawyer for creditor JPMo hase Bank..
"In bankruptcy court, the idea is to get the most for creditors, and that's p
ed.''
The, auction proved to be a bonanza for creditors, Luzinski said, noti highest offer
former listing agent Sotheby's International Realty received was $3 rh.Sotheby's won't
receive a commission, he said:
Pulte, 42, of Boca Raton, said he figured Trump wouldn't b n Monday,
"I got the feeling he was willing to go.a lot higher, and I •n to chase it," Pultattild.
*Pultesald Qosman asked him before the auction whet d be willing to let him stay
in the mansion after the closing until he decides wh to move..Trump and
Luzinski said they have had no such discussions an.
Gosman, 75; had the house built after paying_ l 'Ilion for the land in 1986.
The former health-care magnate declined intervie quests before and after the auction
Monday. He was at the courthouse but left before e auction took place.
The $41.35 million price tag eclipses The $30.35 million sale of Lowell "Buds" Paxson's Palm
Beach home and guest house but shoLt of the $45 million that Virginia home builder
, 00-square-foot estate, Casa Apava, a designated Dwight Scher paid for Ron Pe
landmark.
Schar also paid $113.6 milli on akefront lot across the street from the main house, for a
total of $63.6 million. I iders say Scher spent a total of $70 million for his.new property;
making it the priciest I sale in U.S. history.
Gosman once ham fo that Forbes magazine estimated at $480 trillion. Hevoluntarily
filed for Chapt bankruptcy protection in.2001, listing assets of $250 million and
liabilities o .6 'Ilion.
When a * d that Gosman: had to give. up. all ofhis exempt assets to creditors if he
wan nize under Chapter II, Gosman converted the case to Chapter 7
Last y . Bankruptcy Judge Laity Lessen ruledthat Abe and Lin Gosman's marriage. is
invalid ause Florida law does not recognize a Dominicah Republic divorce that Lin
Gosman tried to obtain. from another man, Michael Castre.
The judges decision was a huge victory for creditors because it prevents Abe Gosman from
protecting assets by claiming jbint ownership with his wife, Gosman's assets, which include
an extensive collection of att*Orlc, Could total as much as $70 million and will be sold later.
Without Lessen's ruling, Luzinski woUld.have had a much harder time selling Gosman's
estate, said' David Cirrio, spetial counsel fOt the. trustee.
"We would have been thwarted ... Or at lett substantially impaired," Cimo said,
•
CA/Aroptifs#500127.9. PM:,IVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735835
The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
an ownership interest in his home and other belongings only to avoid losing them in
bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in
1999, well before he filed for bankruptcy,
Lessen is expected to rule in the next two months whether Gosman made improper transfers,
a.d.ecision thatwill affect how much money will be available to creditors.
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
willing to move forward, in part because the upkeep of the estate now exceeds their means.
"This is not a happy occasion for them, but at least .we're moving to the next.level," imo
said. "That's not a house you want to live in unless you're making large amounts ney
like Donald Trump."
[Email Redacted]
O
1
log
1
1
1
CA/Arophsra30a1.280. n-r rpn:Ivr BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
1
EFTA02735836
171tV2o1C' I. t Billionaire Solicited 3 Times • News - The Palm Beach st Palm Beach. FL
Beat, lost REAL NBVSVARTS.RERE_______
Indictment: Billionaire Solicited 3 Times Posted Jul 1, 2008 at 12:01 AM
Updated Oct 2, 2019 at 2:30 PM
(EDITORS NOTE: This story originally published in The Palm Bead* Post on fitly 25,
2006)
Billionaire money manager and Palm Beath part-time resident Jeffre
solicited or procured prostitutes three or more times between A
of last year, according to an indictment charging Jim with f
prostitution.
Epstein, 53, was booked at the Palm Beach Coun g 5 a.ni. Sunday. He ,a t ,)
tern
d ct. 31
anon of
was released on 83,000 bond.
Epstein's case is unusual in that suspect r titionjobns - are usually charged
with a misdemeanor, and even a fe 777 is typically a criminal
information - an alternative to diculfent charging a person with the
commission ore crime.
His attorney, Jack Gol erger,aeclined to discuss the charge.
State attorney's o okesnisn Mike Edmondson also bad Ettle to say:::
tenerally‘alcing, there is a case that has a number of different aspects to it,"
Edm ndson said of a prostitution -related charge being submitted to a grand jury. C
t became aware of the case months ago by Palm Beach police?
Prasecutors and police worked.together to bring the case to the grand:jell, he
said.
i
lidpslhAmpalinimpachpostconVneva/20080701Andiament-billionaire.solkited-34imes
CA/Aroppeffl50=j 8.. : rAa BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
1/2
EFTA02735837
11(11(2019 In 1: Billionaire Solicited 3 Times - News • The Palm Beach Palm Bead% FL
Palm. Beach police confirmed that and said the department will release a report
today regarding its investigation.
Epstein has owned a five-bedroom, 7 1/2 -bath, 7,234-square-foot ho
pool and a boat dock on the Intracoastal Waterway since 1990, ac
property records. A man answering the door there Monday
wasn't home. A Cadillac Escalade registered to him was parke e driveway,
which is flanked.by two massive gargoyles.
Epstein stied .Property Appraiser 'Gary Nikelits- emending that the
atassessment. of his home exceeded its fair In He disinissed.his lawsuit
A profile of Epstein in VailityTairmagactn e said he owns what are believed to
be the largest private homes' Matattan - 51,000 square feet - and in New Aciie
Mexico - a 7,500-acre ra . o are in addition to his 70-acre island in the G
U.S. Virgin Islands and eet 'icraft.
in Deceniber 2002.
tinEpstein's friends a firers, according to the magazine, include prominent
businessm acade is and scientists and famed Harvard law professor Alan
Dersh
lar @.P4P?g,c.9.41
I
hrips:/hvisw.palmbeachwastcominews/20080701401c1menl-billoralre-solicited-3-fla
CNArlit ee fieVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735838
11(1112019 After lo billionaire faces solicitation charge - News - The Palm st - West Palm Bead% a
The Palm Beach. Post REAL NEWSSTARTS HERE
After long probe, billionaire faces solicitation
charge Posted Jul 27, 2006 at 12:01 AM
Updated Oct 3, 2019 at 3:11 PM
(EDITOR'S NOTE: This story originally published in The Palm Beath Post on
2096)
nPalm Beach billionaire Jeffrey Epstein paid to have underage girls dy ung
women brought to his home, where he received massages and sometimes sex,
according to an investigation by the Palm Beach Polic De rtment. \2
Palm Beach police spent months sifting through *its sh and watching his
waterfront home and Palm Beach Internatio al Ajort to keep tabs. his
private jet. An indictment charging Epst s Was unsealed Monday, charging el )
him with one count of felony solicitatrion o rostitution.
Palm Beach police thought th
unlawful sex acts with a'
robable cause to charge Epstein with
wd and lascivious molestation.
Police Chief Michael R rylas so angry with State Attorney Barry Krischer's
handling of the c
prosecutor disquali himself.
1 mu tinge yen' to examine the unusual course that your office's handling of this L i
tn e as taken and consider if good and sufficient reason exists to require your
fication from the prosecution of these cases," Reiter wrote in a May I
memo to Krischer.
at he wrote a memo suggesting the county's top
While not commenting specifically on the Epstein case, Mike Edmondson,
spokesman for the state attorney, said his office presents cases other than
murders to a grand jury when there are questions about witnesses' credibility and
their ability to testify.
httpsibretewpalmbeaohpost.conVnews/20080727/after-long-probe-Ishlionaire-faces-solloitatIon-charge
1
t
i
1
1
CA/Aropiaerac0 A2.1Q-8.3 rLm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735839
11/1112019 Alter Ion billionaire faces solicitation charge - News - The Palm st - West Palm Beach, FL
By the nature of their jobs, police officers look at evidence from a "one-sided
perspective," Edmondson said. "A prosecutor has to look at it in a much broader
fashion: weighing the veracity of wimesses and how they may fare under
defense attorneys' questioning, he said.
Epstein's attorney, Jack Goldberger, said his client committed no crimes.
"'The reports and statements in question refer to false accusations that were not
charged because the Palm Beach County state attorney questioned the credit)" ity
of the witnesses," Goldberger said. A county grand jury "found the allegat
wholly unsubstantiated and not credible," and that's why his client w•asoc
charged with sexual activity with minors, he said.
Goldberger said Epstein passed a lie detector test administer by a teputahle
polygraph examiner in which he said he did not know the irls re minors.
Also, a search warrant served on Epstein's home foyn
corroborate the girls' allegations, Goldbergerai\
A
d.
According to police documents: \,,, /
- A Palm Beach Community College student said she gave Epstein a massage in
the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged
sessions at his home. , /
- A 27-year-old woman•who worked as Epstein's personal assistant also
facilitated the liaisons, phoning the PBCC student to arrange for girls when
Epstein was coming to town. And she escorted the girls upstairs when they
arrived, Ppttyttg fresh sheets on a massage table and placing massage oils nearby.
- PRI took sworn statements from five alleged victims and 17 witnesses. They
contend that on three occasions, Epstein had sex with the girls.
A money manager for the ultra-rich, Epstein was named one of New York's most
eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with
the likes of former President Clinton, former Harvard University President
Summers and Donald Trump, and has lavish homes in Manhattan,
New Mexico and the Virgin Islands.
httpsWeenr.palmbeachposLcorrynews/20060721/after-long-probe-billionike-Ndes-solicitation-qhwge 2/5
I
t
1
CA/Aropketrip1.284 PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735840
111112019 Met . billionaire faces solicitation charge • News - The Palm Best • West Palm. Beach. FL
He has contributed tens of thousands of dollars to Democratic Patty candidates
and organizations, including.Sen. John Kerry's presidential bid, and the Senate
campaigns ofelot a Hillary Clinton, Dodd and Charles
Schumer.
GO
4 9:2Goldberger it One of five attorneys Epst ' . h • Mined Since he .becathe the <4eris sit
subject of an investigation, Edmond sar . mong the others: Man
Dershowitz; the well-known Ha d la rofessor and author, who is a friend
ofEpstein. Dershowitz coul t • re chedfor comment.
Police said the woman ho enli fed, young girls for Epstein was
20, of Palm Beach. son has worked at an Olive. Garden restaurant in
Wellington and sa as a journalism major at Palm Beach Community
College w she questioned in police last October. She has an unlisted
phone d could not be reached for comment.
Rob she met Epstein when, at age 17,.a friend asked her if she wouldlilte
to ake money giving him a massage. She said she was driven to his five-
bedroom, 7 1/2-bath home on the Intracoastal WaterWay; then escorted upstairs,
to a bedroom with a massage table and oils:Epstein and were both naked
during the massage, she said, but when he grabbed her buttocks, she said she
didn't want to be touched.
letptfienvw.paimbeaehposteamineves/20060727/after•long-probe•bnonairateces-soNcItsteoe-chasge 36
CA/A91 3LTIML 8P4 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735841
[Phone Redacted] After Ion ; bieionaire faces solicitation charge - News - The Palm Best- West Palm Beach, Ft.
Epstein said he'd pay her to bring him more girls - the younger the better,
told police. When she tried once to bring a 23-year-old woman to him,
Epstein said she was too old, said.
who has not been charged in the case, said she eventually brought six
girls to Epstein who were paid $200 each time, said. "I'm like a Heidi
Fleiss," police quoted her as saying. The girls knew what to expect when they
were taken to Epstein's home, said. Give a massage - maybe naked - and
allow some touching.
'h eal
One 14-year-old girl took to meet Epstein led police to start the
investigation of him in March 2005. A relative of the girl called to sayshe
thought the child had recently engaged in sex with a Palm Beach man. The girl
then got into a fight with a classmate who accused her of bein1/4 "ostitute, and
cshe couldn't explain why she had $300 in her purse.
N,The girl gave police this account of her meetin . in: \
She accompanied and a second girl to Epst n's house on a Sunday in
February 2005. Once there, a woman she thought was Epstein's assistant told the
girl to follow her upstairs to .a room featuring a mural of a naked woman, several
photographs of naked women on a shelf, a hot pink and
table.
She stripped to her bra anties and gave him a massage.
sofa and a massage
Epstein gave the I e -old $300 and she and the other girls left, she said. She.
said Robs old her that Epstein paid her $200 that day.
Ot etkirls d similar stories. In most accounts, Epstein's personal assistant at
e, now 27, escorted the girls to Epstein's bedroom.
whose most recent known address is in North Carolina, has not been
charged in the case.
Palm Beach police often conducted surveillance of Epstein's home, and at Palm
Beach International Airport to see if his private jet was there, so they would
know when he was in town. Police also arranged repeatedly to receive his trash
I
•
1
I
httpsdAwm.oalrnbeachpost.conVnews/20060727/after-long-probe-bilionalre-faces-solicitation-charge
CA/Arop az0.loar 128.6. :LTD PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
4O
EFTA02735842
11/11/2019 Alter loner, billionaire laces solicitation charge - News - The Palm st west Palm Bead), FL
from Palm Beach :sanitation workers, collecting papers with names and phone
numbers, sex toys and female hygiene prodUcts.
One note stated that a female could not come over at 7 p.m. because of soccer.
Another said a girl had to work Sunday - 'Monday after school?' And still
another note contained the work hours of a girl, saying she leaves school at 11:30
a.m. and would come over the next day at 10:30 a.m.
Only three months before the. police department probe began, Epstein donat
890,000 to the department for the purchase of a firearms simulator, said)
Strpder, town finance director, The purchase was never .made. The r was
returned to Epstein on Monday, she said.
co
https://wrompalmbeacbpostoorn/newst20060727/after4ong-Kobe•bill000laoes-soicitelionchame 515
1
CA/ArOpli den59128
ALIA1 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735843
11M/20I9 wyer tried to discredit teenage glrts - News • Palm Beach -flews - Palm Beach. FL
Palm Beach Daily News
Police say lawyer tried to discredit teenage
girls Posted Jul 29, 2006 at 12:01 AM
Updated Oct 3, 2019 at 2:00 PM
(EDITOR'S NOTE: This story originally was published in The Palm Beadt Pos ily
29, 2006)
Famed Harvard law professor Alan Dershowitz met with the P County
State Attorney's Office and provided damaging information about teenage girls
who say they gave his client, Palm Beach billionaire Jeffrey EA'', sexually
charged massages, according to police reports.
The reports also state that another Epstein attorney agreed to a plea bargain that
would have allowed Epstein to have no criminal record. His current attorney
denies this happened.
And the documents also reveal that the.father of at least one girl complained that
private investigators aggressively followed his car, photographed his home and
chased off visitors.
Police also talked to_somebody who said She was offered money if she refused to
cooperate with the ,. ralm Beach Police Department probe of Epstein.
The s torney's office said it presented the Epstein case to a county grand
jury.[ mOnth rather than directly charging Epstein because of concerns about
the girls' credibility. The grand jury indicted Epstein, 53, on a single count of
felony solicitation of prostitution, which carries a maximum penalty of five years
in prison.
Police believed there was probable cause to charge Epstein with the more serious
crimes of unlawful sex acts with a minor and lewd and lascivious molestation.
Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
Krischer a memo in May suggesting he disqualify himself from the case.
htlps:/Nmw.palrneeacndatynews.corolarUcter20060729/NEVVS1190917573 1.14
CA/ArTtl egi9i 1X2L801 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735844
11/11/2019 Poi wyer tried to discredit teenage girls - News - Palni Beach OWS • Palm Beach. FL
The case originally was going to be presented to the grand jury in February, but
was postponed after Dershowitz produced information gleaned from the Web
site myspace.com showing some of the alleged victims commenting on alcohol
and marijuana use, according to the police report prepared by Detective=
Recarey.
a 20-year-old =Palm Beach woman who told police she
recruited girls for Epstein, also is profiled on rnyspace.com. Her page includes
photos of her and her friends, including one using the name "Pimpin' Made
=II who was not charged in the case, is a potential prosecution witn
According to Recarey, prosecutor Lanna Belohlavek offered Epste: ys
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speak), g with
Epstein, accepted the deal, in which Epstein would plead guilty to one count of
aggravated assault with intent to commit a felony, be plated on five years'
probation and have no criminal record. The deal also called/for Epstein to submit
to a psychiatric and sexual evaluation and have no unsupervised visits with
minors, according to Recarey's report. The plea bargain was made in connection
with only one of the five alleged victims, the report states.
Fronstin - who declined to comment on the case - was subsequently fired and
veteran defense attorney Jack.Goldberger was hired. He denies there was any
agreement by any of Epstein tattotneys to a plea deal.
"We absolutely did not agree to a plea in this case," he said. Neither Belohlavek
nor a state attorney't spokesman could be reached for comment.
The parerit or parents of alleged victims who complained of being harassed by
(-- private in8stigators provided license tag numbers of two of the men. Police
loured thevehicles were registered to a private eye in West Palm Beach and
ahother in Jupiter, according to Recarey's report.
1 have no knowledge of it," defense attorney Goldberger said.
The report also says a woman connected to the Epstein case was contacted by
somebody who was still in touch with Epstein. That person told her she would
be compensated if she didn't cooperate with police, Recarey's report says. Those
httesjniomq.palmpeachdailynews.oamlecticle/2906072g/NEWS/190917573 214
CA/Aroplitip ALmt28.9. r BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735845
11/11/2019 Poll wyer tried to discredit teenage girls - News - Palm Beach ews • Palm Beach. FL
who did talk "will be dealt with, the woman said she was told. Phone records
show the woman talked with the person who allegedly intimidated her around
the time she said, Recarey reported.
Phone records also show that the person said to have made the threat then
placed a call to Epstein's personal assistant, who in turn called a New York
corporation affiliated with Epstein, the report states.
The issue in the Epstein case is not whether females Caine to his waterfront
home, but whether he knew their ages.
"He's never denied girls came to the house," Goldberger said. But hen\Stein
was given a polygraph test, "he passed on knowledge of age,
After the indictment against Epstein was unsealed thi
referred the matter to the FBI. "We've received th
it: said FBI spokeswoman Judy Orihuela in Mi
rney said.
Police Chief Reiter
nd we're reviewing
The chief himself has come under attack4 lawyers and friends in
New York, where he has a home. The lvew York Post quoted Epstein's
prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
only "because of the craziness of the police chief."
/ Reiter has declined to comment on the case.
Prosecutors have'not-presented a sex-related case like Epstein's to a grand jury
before, said Mike Edmondson, spokesman for the state attorney's office. "That's
what yotedo‘ch a case that falls into a gray area," he said.
omey's office did not recommend a particular criminal charge on
indict. Epstein, Edmondson said. The grandlury was presented with a
list of charges from highest to lowest, then deliberated with the prosecutor out of
the room, he said.
"People are surprised at the grand jury proceeding," West Palm Beach defense
attorney Richard Tendler said. "It's a way for the prosecutor's office to not take
the full responsibility for not filing the (charge), and not doing what the. Palm
Beach Police Department wanted. I think something fell apart with those
underage witnesses."
4
https:Mmwe.palmbeachdailynews.corniarticle/20060729/NEWS/190917573
CA/AroplieAt rar0Q129A, rAi., m BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
3/4
EFTA02735846
11/11/2019 Pei er hied to dist-Sit teenage gels - News - Palm Beach evs- Par Beach, FL
Defense attorney Robert Gershman was a prosecutor for six years. "Those girls
must have been incredible or untrustworthy, I don't know," he said.
Other attorneys said Epstein's case raises the issue of whether wealthy, connected
defendants like Epstein - whose friends include former President Clinton and
Donald Trump - are treated differently from others. Once he knew he was the
subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as
Dershowitz and Lefcourt, who is a past president of the National Association of
Criminal Defense Lawyers.
Miami lawyer Roy Black - who became nationally known when he successfully
defended William Kennedy on a rape charge in Palm Beach - also was
involved at one point.
Said defense attorney Suskauer: "I think it's un a e public may
get the perception that with power, you may be treate it ently than the
average Joe."
httptinwnv.palmbeachdanynews.comianicle/120060729/NEWS/190917573 4/4
I .
j
t
tt
1
I
I
I t
yt
CA/AroPiffe. M il BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:04:39 PM
EFTA02735847
It Palm Beach Post REAL NEWS STARTS HERE
Expert; Ignorance of Age isn't
:defense: in sex cases
Posted Aug 5, 2006 at 12:01 AM
Updated 00 3, 2019 at 1:38 PM
(EDITOR'S NOTE: This story originally published in The
Palm Beach Poston Aug. 5, 2000
Even if Palm Beach money manager Jeffrey Epstein di
know that girls who police say gave him sexual in
his. Intracoastal home were under the legal age, th
wouldn't have exempted hiin front criminal et o
sexual activity with minors.
Ignorance is not a villadefense 4ilob Dekle, a legal
skills professor who was a Lakc s prosecutor for nearly
30 years, half of that.time‘splCializing in sex crimes against
children.
'There is no ta ement as far as the age is
concerned,"
Aker onth investigation, Palm Beach polite said
robable cause to charge. Epstein, 53, with
wful set acts with a minor. and lewd and lascivious.
olestation. They contend that Epstein -.friend of the rich
d 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
S50,000 in campaign.contributions he received from
Epstein, and Mark a candidate to replace Spitzer in
4
CA/AmPlet9599.031 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:04:39 PM
EFTA02735848