# IN THE CIRCUIT !COURT OF THE FIFTEENTH JUDICIAI, CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HQLDINOS, LLC, Publisher of THE PALM BEACH POST,

Plaintiff,

v.

DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida,

Defendants.

CASE NO,: 50-2019-CA4014681,X=C-MB Div.: AO

# FIRST AMENDED COM 4PLA),\_ILNT ,
CA Florida Holdings, LLC, publisher o IlicalA Beach Post, for, its First Amended to 14rney / Complaint against Dave Aronberg, the S for Palm Beach County, Florida, in his official capacity ("State Attorney"), . Bock, the Clerk of the Court for Palm Beach County, Florida, in her official a 9. ourt Clerk"), alleges as follows:

# JURISDICTION
- within the exclusive jurisdiction of the Circuit Court pursuant to
- Xi) and 86.011 et seq.
- 1. This is Fla. Stat. Secti TS '6.012 ,

# PARTIES
- 0 The Palm Beach Post is a daily community newspaper published by Plaintiff:CA Florida.I1oldings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.
- 3. Defendant Dave .Aronberg is the duly elected State Atkiiney for the Fifteenth Judicial Circuit in and for Palm :Beach County, Florida, pursuant to Ha. Shat. Section 27.01 and has .authority in grand jury proceedings pursuant toPla. Stat. Section 27.04. He is sued herein in

Party JOINT

his official capacity as his office is in possession and/or control of documents that are the subject of this action.

Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach County, Florida. She is sued herein in her official capacity as her office is in possession and/or control of documents that are the subject of this action.

# INTRODUCTION
AA' 5. In what is now widely if belatedly recognized as a colossal mis e of justice which led to the further needless victimization of countless young girl C r) n — a wealthy, politically connected, and powerful financier was not held accountab , nor even forced to confront, allegations of serious sex trafficking crimes. Whil that Jeffrey Epstein's 2008 deal with the State of Florida was not consistent with ce gathered against him, what remains shrouded in mystery is how that eviden w resented — and the extent to which it was presented — to the grand jury that returned a ict nt far more limited in scope than expected ./-=== and deserved.

.7' ' 8ty Through this ac L .0Yi, e ahn Beach Post seeks public access to the testimony, minutes, and other evidence pr d in 2006 to the Palm Beach County grand jury empaneled during the first Epstein s apse investigation. Typically, access to such materials is limited, for example, in ord revent the flight of those whose indictment may be contemplated and their ability t r destroy evidence; to ensure jurors' candor in deliberations; and to protect an accuse s later exonerated. However, these factors are inapplicable here. Also, Florida law expressly authorizes the disclosure of grand jury proceedings under certain circumstances, including, as here, in the furtherance of justice. Fla. Stat. § 905.27(I)(c).

7. It can no longer credibly be maintained that continued blanket secrecy over the proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law.

To the contrary, transparency is required to promote public understanding of the criminal justice system and public confidence in the fair administration of justice. As detailed below, Epstein was accused of sexually abusing and trafficking dozens of women and girls in south Florida (among other locations) over a period of several years while exploiting his wealth and political connections to obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury proceedings will shed light on the extent to which those in our government entrusted-IVth the solemn responsibility of enforcing our criminal laws equally as to all citizens their duties in this instance. Justice will be furthered where it is either (I) demonstrated'th ein was treated like others accused of similar heinous crimes, or (2) as appears more I key/to be the case, those who chose to give Epstein favorable - "unusual," in the words own of Palm Beach Police Chief - treatment, are exposed and held accountable. From Wimited information is now in the public domain, the State Attomey's referral of Epsteiif s case to the grand jury — which would be > out of the ordinary for this type of case rise to a strong inference of favoritism and corresponding disregard for the right / 9 inor victims of Epstein's sex trafficking. Access to the grand jury materials will all theprutil c to determine whether the grand jury process, and the .( secrecy that comes with it, was to further justice or, instead, operated to shield Epstein and his co-conspirators from e nsequences of their criminal activities. Accordingly, Fla. Stat. Section 905.27 ut zes the disclosure of Epstein's 2006 grand jury proceedings

in the absence of such a statutory basis, this Court is empowered to order public sc osure pursuant to its inherent authority and supervisory powers over the grand jury. Indeed, courts throughout the country in the past several decades have ordered the disclosure of high-profile grand jury proceedings pursuant to their inherent authority where the public's interest in those proceedings has outweighed the general need for secrecy. This is particularly so where,

as here, many of the details of Epstein's criminal misdeeds have already been made available in the public domain through extensive news reporting by, among others, The Palm Beach Post; by the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves.

9. In recognition of the sensitivity of the materials being sought, and in the interest of protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach' County = , grand jury first being submitted to this Court for in camera review, where t be redacted, as appropriate, to protect those who deserve such protection.

# FACTUAL BACKGROUND
10. The following facts were gathered, in large part, from documents obtained by The Palm Beach Post through various Florida Public Records Law requests, documents unsealed or publicly available in other related judicial proceedings, and information and documents in the public record.

# A. First Epstein Sex Crimes investigation, Indictment, and Plea Agreement: 200.5-2008.
11. The investigation into Epstein's sex crimes began more than fourteen years ago, when a 14-year-old girl' tepmother reported to police in the Town of Palm Beach, Florida, that Epstein and othe ho wprked for him arranged for her to give Epstein a "massage." Epstein required th stlrp, exposed himself, and masturbated while touching her. The girl was paid \$300. Ep~t@i1R4as 52 years old at the time.

Following this initial report in 2005, the Town of Palm Beach Police, and later, in 2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with disturbingly similar details, with each of the other victims.

13. Both the victim/witness interviews, as well as evidence retrieved following a search of Epstein's home, showed that some of the girls involved were under the age of 18. The police search of Epstein's residence also found two hidden cameras and, throughout the house, large numbers of nude photos of girls, including victims whom the police had not interviewed in the course of their investigation.

14. In March 2006, a State grand jury was scheduled at which all of th s were expected to testify. The proceeding was postponed, however, due to meetinc re een the State Attorney's office and Epstein's prominent criminal defense lawyer n!!• .1 friend, Alan Dershowitz.

15. Another grand jury was convened in April 2 'ow canceled the day before it was to begin receiving evidence. z1-k,

# (1) Police Chief Reiter's Letter to the State Attorney.
16. On May I, 2006, Town of(Pairtt Bach Police Chief Michael Reiter wrote a "personal and confidential" letter toA 61; e1m Beach County State Attorney, Barry Krischer, stating:

I must renew my pno rvation to you that I continue to find your office's treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to communicate in this manner, but my most recent telephone calls to you and those of the lead- detective to your assigned attorneys have been unanswered and messages remain unreturned. After giving this much thought and consideration, I must urge you to era mine the unusual course that your office's handling of this matter has taken and consider if good and sufficient reason exists to require your disqualification from the prosecution of these cases (Emphasis supplied)

17. Chief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach Police Department's probable cause affidavits charging Epstein and two of his assistants with multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested

that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges against him, which would be public.

# (2) The July 2006 State Grand Jury Presentation.
18. Instead, State Attorney Krischer elected to refer the case to a grand jury, which is mandatory for capital cases but rarely used for all other crimes. According to an official spokesperson, this was the first time that a sex crimes case was presented to a gran n Palm Beach County

19. In July 2006, after State Attorney Krischer presented tes C• evidence from one victim, the grand jury returned an indictment on a sole count of • ',Lion of prostitution. There is no mention in the indictment of the victim being a

20. On information and belief, a second of st ictims was supposed to testify before the grand jury, but was unable to attend b st \ a of a school exam.

21. No reasonable explanation h a's n ,provided as to why the numerous other known victims were not presented as witness daime victims to the grand jury convened in July 2006. Nor has any reasonable explan tton initially eager to investigate an ct \_proSecute Epstein for his crimes, over time lost the desire to do trprovided as to why State Attorney Krischer, who was so.

22. who tes • ormation and belief, during the grand jury appearance of the single victim State Attorney presented evidence that vilified the victim and attacked her credibila,yRcluding soliciting testimony regarding underage drinking and questionable personal behavior that was unrelated to the charges against Epstein. Further upon information and belief, this information was initially brought to the attention of the State Attorney's office by Epstein's defense counsel.

charges. 25. Instead, then U.S. Attorney for the Southern District of lorida, exander Acosta, V negotiated a plea deal with Epstein's team of lawyers to gran nity to Epstein (along with four named co-conspirators and any unnamed potential c pt ors) from all federal criminal

# (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 Ai; the FBI, a 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. ever, at the request of Epstein's lawyers, the indictment was never presented to a feder 1 fy•

26. Throughout the remainder oft c Sltr rough the first half of 2008, Epstein's lawyers and the U.S. Attorney continu otia g the plea arrangement. Upon information and belief, Epstein's lawyers insist h the victims not be notified, (2) the deal be kept confidential and under seal, a rand jury subpoenas (including one that had already been issued for Epstein's co it 40t. as) be withdrawn.

7 27. O ne 30 2008, Epstein pled guilty to State charges: one count of solicitation of prostitutio e hunt of solicitation of prostitution with a minor under the age of 18. He was sente ce onths in jail, followed by a year of community control or house arrest, and was adjudicat as a convicted sex offender required to register twice a year in Florida.

28. The plea deal, called a non-prosecution agreement (`NPA"), allowed Epstein to receive immunity from federal sex-trafficking charges that could have sent him to prison for life.

On information and belief, based on public records, former State Attorney Krischer communicated with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers.

29. Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for which he was convicted. instead, he was placed in a private wing of the Palm Beach County Stockade, where, after 3 12 months, he was allowed to leave the jail on "work release" for up to 12 hours a day, 6 days a week. His private driver provided his transportation to and kornicwork."

ze—NI

30. Epstein was released five months early.

31. Upon information and belief, Epstein violated the terms:of his\_probation, but was not prosecuted

# (4) The Crime Victims' Rights A5.1 Litigation.
32. Epstein's victims only learned after the fact about his plea in State court and filed an emergency petition to force federal prosecutors toceimply with the Crime Victims' Rights Act /- \\ (18 U.S.C. § 3771, "CVRA"), which mandattieertainc\*rights for crime victims, including the right to be informed about plea agreements inclitheyright to appear at sentencing. U.S. District Judge < 1/.. "), Kenneth A. Marra recently ruleditha e ral prosecutors violated the CVRA by failing to notify Epstein's victims before allowkhith to plead guilty to only the two State offenses.

33. The pros s failure to keep the victims apprised, among other things, also contravenes th da Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001.

34 owing publicity exposing the extraordinary leniency of the plea deal, dozens of civil Hsatril4i re brought against Epstein, most of which Epstein's lawyers settled out-of-court.

35. In 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense) sex offender in New York, a lifelong designation. In 2011, the New York County District Attorney's office unsuccessfully sought to lower his registration to low-risk "level one."

36. Upon information and belief, during the course of the Town of Palm Beach and FBI investigations, Epstein retained private investigators to follow, harass, and photograph his victims and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated the case against Epstein.

37. Upon information and belief, Epstein's victims were threatened against c perating with law enforcement and told that they would be compensated only if they did not e te with law enforcement.

# B. Second Epstein Sex Crimes Investigation, Indictment. Si
38. On July 6, 2019, Epstein was arrested on federal sex tra%14/ 142g charges.

39. Upon information and belief, the United Stat allegations and charges stemmed, in part, from contin ent's investigation of new nvestigations into and reporting on the mishandling of the 2006 charges and the \ ' i its that followed

40. In a July 8, 2019, letter to t era district court by the U.S. Attorney for the Southern District of New York, Epst cribed as "a serial sexual predator who preyed on dozens of minor girls over ape ." The letter emphasized that "the Government has real concerns — grounded in past ex ce with this defendant — that if allowed to remain out on bail, the defendant could atter t pressure and intimidate witnesses and potential witnesses in this case, including s and their families, and otherwise attempt to obstruct justice." It also described the res Its of the FBI's search of Epstein's Manhattan townhouse: evidence of sex \ trafficking in-the form of "hundreds — and perhaps thousands — of sexually suggestive photographs of fully- or partially-nude females," including underage females. In a locked safe, compact discs were found with handwritten labels including the descriptions: "Young [Name] + [Name]," "Misc nudes 1," and "Girl pits nude."

41. On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's office for the Southern District of New York charged Epstein with sex trafficking and conspiracy to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were brought into Epstein's mansions for sexual encounters. A few days later, owing to public outcry over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida, Alexander Acosta, who by then was serving as U.S. Secretary of Labor ir&tiwi Trump administration, resigned from office.

42. Epstein was denied bail and was placed into pretrial/detettio at the federal Metropolitan Correction Center in lower Manhattan

43. On or about August 6, 2019, Florida Gov. Sadtis ordered a state criminal / probe into the actions of the Palm Beach Sheriff andforr4ezAiate Attorney Krischer for their handling of the Epstein underage sex trafficking easeX\

44. On August 10, 2019, Epstein was found dead in his cell at the Metropolitan Correctional Center. His cause of d'IliM -determined to be suicide.

# C. The August 27, 20O.-SDhirilearine: Epstein's Victims Speak.
45. On account of Ais,death, prosecutors sought to dismiss the indictment against Epstein, while maintaini they would continue to investigate his co-conspirators.

46. nt States Senior District Judge Richard M. Berman ordered a hearing on August on the prosecutors' decision to dismiss the indictment and allowed victims to spec tt e caring

47. In the course of the hearing, more than two dozen victims delivered their personal stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of violent rape by Epstein. Many more victims were present in the courtroom but did not testify.

; 48. While some questioned the reasoning behind the court's decision to give the victims voice after Epstein's death, District Judge Berman noted that "a public hearing is [the] preferred vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings promote transparency and they provide the court with insights and information which the court may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that the court "is the institution that most people have confidence in, in these very troub

49. At the August 27th hearing, the girls, now women, spoke abo "exploitation d\*e to speak on [their) and coercion," and to the fact that many of them "were in very vulnerabl C and in extreme 11 poverty, circumstances where [they] didn't have anyone on [their] behalf...." One victim lamented that "as a victim, [she] nev .ee what the agreement was or why the special treatment got approved" in the Fl ears earlier. Another noted how "completely different" the investigators leadin 9\ o 2019 federal indictment were from the prosecutors in the Florida case, both in then rea ent of her and their investigation of her /--- , victimization by Z Epstein. \----

50. A former federCjb - Attendance at the August 27th hearing emphasized that "transparency is one of the oveiTidi4 objectives in our criminal justice system."

51. Nearly all t e victims expressed the conviction that the secrecy that shielded Epstein has ca islfriem "irreparable harm" and that an opportunity to address his criminal wrongd those of the individuals who enabled his sexual racketeering, would allow for at leaiticime measure of justice to be served after his death. Indeed, one victim stated: "Any efforts made to protect Epstein's name and legacy send a message to the victims that he wins and that he is untouchable." Another victim expressed fear that this is a world "where there are predators in power, a world where people can avoid justice if their pockets run deep enough." In short, the

"unusual" treatment Epstein received in Florida in 2006 based on his wealth, social status, and connections severely eroded the public's faith in the integrity and impartiality of the criminal justice system.

# D. The Palm Beach Post's Standing and the Public Interest.
# (1) The Palm Beach Post Has Reported Extensively On Epstein's Crimes For Nearly 15 Years.
52. Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm Beach County and the Treasure Coast vicinity.

53. The Palm Beach Post has been a Pulitzer Prize winner and noniinated as a finalist y, three other times. \_7` \ -- , -"..\ 1,4/ i)

54. Beginning in 2004, The Palm Beach Post hace:atensively investigated and reported on the allegations against, the law enforcement in s ig ,c of, and the crimes committed by, Epstein and his co-conspirators. The News p ilfils " ortage has included publication of the following articles:

- "The Man Who Had Eycyjiii Jeffrey Epstein Craved Big Homes, Elite Friends and Investi ators Say, Underage Girls.," published on August 14, 2006, reporting that: a local community college student, admitted in a sworn statement to police that "she had taken at least six girls to visit Epstein, all between the ages of 14 and 16;" Palm Beach Police "interviewed five alleged victims and 17 witnesses;" "Dershowitz, the Harvard law professor, traveled to West Palm Beach with information about the girls," including social media discussions about "their use of alcohol and Eirijuana," . after meeting with Epstein's legal team, "prosecutors postponed their decision lo- take the case to a grand jury;" Palm Beach Police subsequently "received A semplaints that two of the victims or their families had been harassed or threatened;" "\*Iations between police and prosecutors were fraying" as the investigation continued; ditd "one girl who was subpoenaed — the one who said she had sexual intercourse with Epstein — never showed up" to testify before the grand jury.
  - "Trump Snags Gosman Estate for 541 Million" published on November 16, 2004, reporting on the bidding war between Donald Trump and Jeffrey Epstein for the purchase of a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along the storied `Raider's Row' " in Palm Beach.

- “Indictment: Billionaire Solicited 3 Times” published on July 25, 2006, reporting that “Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 of last year, according to an indictment charging him with felony solicitation of prostitution.” The article further reported that “Epstein’s case is unusual in that suspected prostitution johns are usually charged with a misdemeanor, and even a felony charge is typically made in a criminal information – an alternative to an indictment charging a person with the commission of a crime.”
- “After Long Probe, Billionaire Faces Solicitation Charge” published on July 26, 2006, reporting that “Palm Beach police thought there was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation.” The article further reported that “Police Chief Michael Reiter was so angry with State Attorney Barry Krischer’s handling of the case that he wrote a memo suggesting the county’s top prosecutor disqualify himself,” and identified a 20-year-old on-the-record female source who said “she gave Epstein a massage in the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged sessions at his home.”
- “Police Say Lawyer Tried to Discredit Teenage Girls” published on July 29, 2006, reporting that “[f]amed 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 “[t]he 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 “[r]ather 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]he 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 issues with the viability of the evidence or witnesses’ credibility.”
- “Palm Beach Chief Focus of Fire In Epstein Case” published on August 14, 2006, reporting that Chief Reiter “pressed for Epstein to be charged with the more serious crimes of sexual activity with minors” and “slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that office’s mishandling of the case.”
- “Delays In Epstein Case Unusual, Lawyers Say” published on March 13, 2007, reporting that “[n]early eight months after Palm Beach tycoon Jeffrey Epstein was charged with felony solicitation of prostitution, there has been no discernible progress in his case.”

- “Woman Sues Billionaire Investor, Says They Had Sex When She Was 16” published on October 18, 2007, reporting on a lawsuit brought in New York State court against Epstein “by a young woman who says he had sex with her when she was 16 and had sought his help becoming a model.”
- “Palm Beacher Pleads In Sex Case” published on July 1, 2008, reporting that “Epstein, 55, pleaded guilty . . . to felony solicitation of prostitution and procuring a person under the age of 18 for prostitution,” resulting in “a lifelong obligation to register as a sex offender,” and that “[a]s part of the plea deal, federal investigators agreed to drop their investigation of Epstein, which they had taken to a grand jury.”
- “Jeffrey Epstein: Scientist, Stuntman, ‘Sex Slave’ Visit Jailed Tycoon” published on August 13, 2008, reporting that “[d]uring his first month of confinement” Epstein was visited by [REDACTED], who allegedly escorted victims “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 Epstein, and by [REDACTED], “a young woman whom Epstein purportedly described as his Yugoslavian sex slave.”
- “Billionaire Sex Offender Leaves Jail Six Days a Week For Work” published on 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 Feds 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 agreed not to charge any of Epstein’s possible co-conspirators: [REDACTED], [REDACTED], Lesley Groff and [REDACTED].” 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 Epstein Attorneys Can Subpoena Abortion Records” published on January 27, 2010, reporting that “a judge . . . gave lawyers representing multi-millionaire sex offender Jeffrey Epstein the right to subpoena abortion records from women who are seeking millions in damages from the part-time Palm Beach resident.”

- "Epstein Journal's Findings Could Resurrect Abuse Case" published on March 20, 2010, reporting that "[a] purloined journal that is said to contain the names of `hundreds' of victims of convicted sex offender Jeffrey Epstein could be used to reopen the investigation into the multi-millionaire's appetite for teenage girls."
- "Epstein Paid Three Women \$5.5 Million to End Underage Sex Lawsuits" published on October 4, 2017, reporting that, according to court documents, Epstein "shelled out \$5.5 million to settle lawsuits with three of more than two dozen teens who sued him."
- "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen', Victims' Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's teenage victims (under the Crime Victims' Rights Act] by failing to"\tpVeal they had dropped plans to prosecute the billionaire on dozens of federal char\* in connection with the girls' claims that he paid them for sex at his Palm Bcackmanyiion."
- "Epstein Indicted On Sex Charges/Pan-Time Palm Reacher Pleads Not Guilty to Sex Trafficking, Conspiracy Charges In Federal Court lrytvlanhattan" published on July 9, 2019, reporting on Epstein's appearance in U.S. District Court for the Southern District of New York in which he "pleaded not guilty to/ciargesaceusing him of creating a vast network of girls as young as 14 that he exptjII <for is sexual pleasure at his homes in Palm Beach and Manhattan." A \

A true and correct copy of the above news ani,es-,N r the computerized format in which they are maintained in The Palm Beach Pose lect c archives or the news print edition in which originally published, is annexed her ibit 1.

55. Since the filing fthe al Complaint in this matter, The Palm Beach Post - along with media worldwide {sup}`7` zhas con nued to report on Epstein's crimes and the ongoing official ci-\_has proceedings resullog result frofirthose crimes.

# 2) The Palm Beach Post's Standing and the Public Interest.
Oe press has a constitutional right of access to criminal proceedings, see, e.g., Richinoi Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal proceedings. v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the integrity of the judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Publ.

Comm'r, Ala. Dept of Corr. v. Adva and "standing to question the v fi'di news is directly impaired or cu le(i ' c 837 F.3d 753, 757-58 ( 57. Because of the unique role performed by-we pre,ss as a "public surrogate" (=, 426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about At criminal proceedings, news organizations "pre'sumptively have a right to access judicial records," Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019), order restricting publicity because its ability to gather 426 So. 2d at 4; see also Carlson v. United States, 2016) ("[a]s a member of the public, [the Reporters Committee] has standing to its] claim" to grand jury materials because such materials are "public records to whicb4h may seek access, even if that effort is ultimately unsuccessful").

Co. 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate" in matters concerning the closure of judicial proceedings). The press also has a First Amendment interest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer Council, 425 U.S. 748, 756-57 (1976) ("Where a speaker exists . . . the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both."); Pittman v.., 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme Court has recd, First Amendment offers protection to both speakers and those wishing to r Cr 8 also Stephens v. Cry. of Albemarle, Va., 524 F.3d 485, 492 (4th Cir. 200 has "standing to assert a right to receive speech" by "show[ing] that the exists a speaker willing that the h."); see that a plaintiff to convey the information to her")

Here, the continued denial of access to information The Palm Beach Post seeks on behalf of its journalists and the public it serves "unquestionably constitutes irreparable injury." Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Ha. 2017); see also Zerilli v. IM, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press' function as a vital

source of information is weakened whenever the ability of journalists to. gather information is impaired," as it is by Attorney General's refusal to disclose unredacted report and underlying grand jury materials).

59. The Palm Reach Post has the right to maintain this private right of action because the furtherance of justice, an express legislative exception to grand jury secrecy, is intended for the public benefit, and The Palm Beach Post seeks access on behalf of the pub! a. Stat. § 905.27(1)(c). It is further express in Fla. Stat. § 905.27 that the legislature i for rara a court to be the party to make the determination of disclosure. Fla. Stat. § 905( 21( ther words, the legislature intended for recourse to the courts in considering and determining the propriety and scope of grand jury secrecy.

# E. The Court's Jurisdiction And Authority.
# (1) The Court's Supervision of the Grand Jury Process and Its Authority to Order Public Disclosure of the Epstein Evidence.
60. The Florida Supreme Co it has noted that "in states such as Florida, where the grand jury is preserved, it is an im act t endage of the court which impanels it. At the same time it should not be forgotten hat the dge of that court is equally important and he is generally charged with the supervi n of the grand jury's activities .It is, therefore, of vital importance to maintain the digs and e integrity of both the grand jury and the presiding judge." State v. Clemons, 15O 2d`231, 233-34 (Fla 1963).

apter 905 of the Florida Statutes governs the empanelment and conduct of Florid:4rand juries. The court gives the grand jury its initial charge and advises the grand jury about its legal duties. Fla. Stat. § 905.18.

62. Florida Stat. Section 905.27(1) provides that "the testimony of a witness examined before the grand jury or other evidence received by it" may be disclosed "when required by a court . . for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by the witness before the court; (b) Determining whether the witness is guilty of perjury; or (c) Furthering justice." Fla. Stat. § 905.27(1)(a)-(c).

63. Further, disclosure is appropriate pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency. Carlson v. United States, 837 F.3d at 766 ("t-itisuict court has the inherent power to disclose [grand jury] materials in exceptional cir ces and . historic importance can be a sufficient reason when there is little counte ttilit'igngcl for secrecy").

64. The Florida Supreme Court has confirmed that grand ju t'crecy is not absolute and that any "potential harm to public officeholders" from disc( will be the product of their own conduct, and not the consequence of an unrestr d di of misguided citizens." Miami Herald Pub. Co. v. Marko, 352 So. 2d 518 (197il("The benefits to be derived from this •'-'7 extraordinary exercise in citizen participati the grand jury] would be severely limited if the fruits of that activity were not avails le blic on whose behalf it is undertaken. Implicit in the power of the grand jury to Li ?esti k) veld expose official misconduct is the right of the people to be informed of its findings. • public disclosure of grand jury findings inevitably entails the risk of reputational da ge, the legislature has ensured that any potential harm to public officeholders w I he product of their own conduct, and not the consequence of an unrestrained body ofrQl citizens.").

# (2) The Court's Jurisdiction To Declare Rights And Construe Statutes.,
65. This Court has jurisdiction to declare rights, status, and other equitable or legal relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011.

as if fully set forth herein. .k/ 68. The allegations set forth in paragraphs 14throttgb47 are incorporated by reference fit

66. Florida law specifically provides that a declaration may be sought from the Court conceming a petitioner's rights under a statute. Florida Stat. Section 86.021 ("Any person whose rights, status, or other equitable or legal relations are affected by a statute, or any regulation made under statutory authority, may have determined any question of construction or validity arising under such statute,... or any part thereof, and obtain a declaration of rights, status, or other equitable or legal relations thereunder.").

67. The Court's exercise of its power to declare rights "is to be Ii administered and construed." Florida Stat. Section 86.101.

# COUNTS
(Declaratory Relief - Florida Stat. Sections 816.01 f es seq.)

69. This is an action for Declar4Reli f pursuant to Chapter 86, Florida Statutes, and other supplemental relief. )--,,

70. The Pahn Beat t-fros tfully requests that the Court declare that pursuant to Fla. Stat. Section 905.27(1), it ts.eititled access to the testimony, minutes, and other evidence presented in 2006 to the tA uteach County grand jury because such disclosure and access would be in the furthe of justice. Fla. Stat. § 905.27(1)(c). Because The Palm Beach Post is not seeking t e ma rials in connection with either a civil or criminal case, it seeks a declaration that the sco o its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2).

71. The Palm Beach Post further seeks a declaration that disclosure of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency.

72. The Palm Beach Post has sought from Defendants, but Defendants have refused to provide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint and the relief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith dispute el'istei' etween i the parties.

AS' 73. Through this Complaint, The Palm Beach Post presently has ciable question concerning its rights to obtain the 2006 grand jury materials pursuant to Fla. Stat Section 905.27( I ) zr S- \ ,^i il l and the Court's inherent authority.

74. A bona fide, actual, present, and practi or the declaration exists in that Defendants have denied to The Palm Beach P —God to the public at large — the grand jury materials sought to be disclosed. The relief s u fro the Court is therefore not merely the giving of legal advice or to answer hypothe ns.

WHEREFORE, The P ost respectfully requests that the Court determine the rights and obligations of the pC 'e B ili:iy declaring that pursuant to Fla. Stat. Section 905.27(1)(c) and the Court's inheren ut ority, The Palm Beach Post may gain access to the testimony, minutes, and of er 'dente presented in 2006 to the Palm Beach County grand jury and use those material ÷ 'f rpose of informing the public.

# COUNT H
YYY

(Florida Stat. Section 905.27)

75. The allegations set forth in paragraphs 1 through 74 are incorporated by reference as if fully set forth herein.

76. Based on information learned by The Palm Beach Post through its Florida Public Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence and proceedings, judicial documents obtained from independent but related court proceedings, and documents otherwise available in the public record, the State Attorney for Palm Beach County presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner that precluded his indictment for the serious crimes he committed, including sex trafficking and sexual assault.

77. Pursuant to Florida Stat. Section 905.27, in order to furtheilystiee for Epstein's victims and the public, and to provide public disclosure to illuminatewhether Epstein received unreasonably lenient treatment based on the available evi,denerk,791Palm Beach Post requests immediate access to the testimony, minutes, and othereviderwe presented in 2006 to the Palm Beach County grand jury.

78. In a case of this magnitude a d t ortTnce where the accused is dead and so many of his crimes, as well as the identiti a es of his co-conspirators, and the identities of the victims have already been exp , t 7 for grand jury secrecy is no more. See United States v. Socony-Vacuum Oil Co., 3 . . 150, 234 (1940) ("[A]fter the grand jury's functions are ended, disclosure is whol p per where the ends ofjustice require it.").

W HERD, The Palm Beach Past respectfully requests that this Court, pursuant to Fla. Stat. Se 7(1) and the Court's inherent authority, order the State Attorney and the Clerk of the urto Co file with this Court copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so that, following an in camera inspection, it can be made available to The Palm Beach Post and the

public on an expedited basis, and grant any other and further equitable or legal relief the Court deems just and proper.

Dated: January 17, 2020

Respectfully submitted,

GREENBERG TRAURIG, P.A.
Attorneys for CA Florida Holdings, LLC,
Publisher of *The Palm Beach Post*

Stephen A. Mendelsohn, Esq.
5100 Town Center Circle, Suite 400
Boca Raton, Florida 33486
Telephone: (561) 955-7629
Facsimile: (561) 338-7099

By: /s/ Stephen A. Mendelsohn
STEPHEN A. MENDELSOHN
Florida Bar No. 849324
mendelsohns@gtlaw.com
hasenh@gtlaw.com
FLService@gtlaw.com

By: /s/ Michael J Grygiel
MICHAEL J GRYGIEL
(Admitted Pro Hac Vice)
54 State St., 6th Floor
Albany, New York 12207
Telephone: (518) 689-1400
Facsimile: (518) 689-1499
grygielm@gtlaw.com

By: /s/ Nina D. Boyajian
NINA D. BOYAJIAN
(Pro Hac Vice application pending)
1840 Century Park East, Suite 1900
Los Angeles CA 90067
Telephone: (310) 586 -7700
Facsimile: (310) 586 -7800
boyajiann@gtlaw.com
riveraal@gtlaw.com

# CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.

/s/ Stephen A. Mendelsohn

STEPHEN A. MENDELSOHN CO 'S

# IT 1
The Newspaper's Reportage on Jeffrey Epstein

C)

# The Palm Beach Post REAL NEWS STARTS HERE
# The Man Who ;Had Everything: Jeffrey Epstein craved big homes, elite friends and underage girls
By Andrew Marra

Posted 1u112,2019 at 6:02 AM

From the archives: `When Palm Beach detectives starte kin questions and teenage girls started talking, a wave o esistance followed,

Bditor'sNote: This article appeared in The Palm Beach Post on A Jeffrey Epstein's arrest iti Patin Beach County a charge 6\ % 2(X\$, three weeks after ahem ofprostitution.

WINGED GARGOYLES guarded:the gate atje Is. Palm Beach mansion. Inside, hidden cameras trolled'two rooms, while th and went.

:For the police detectives who sifted garbage outside. and kepi reeonis.cavisitors, it was the lair of a troubling target

EpSteit, one of the mitt 11.1ft the country's mega-.rich, was known. as much for his secrecy as for his love of e tehings: magnificent hppaes,.priVate jets, beautiful women, friendships with th s worl ee . e te.

But at Palm o headquarters, he was becoming: known for something else: the regular ar nage girls he-hired to give:him massages and, police say, perform sexual favors

Epstein was differenrfrom most sexual abuse suspects; he was far more powerful. He anuited among his friends' former President Bill.Clittot, Donald Trump and PrinceAndrew, along with some of the most prorninegr legal, scientific and business minds in the country. .

When detectives started asking questions and teenage girls started talking, a wave of legal resistance, followed.

1

•» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work-FeleaSq

11Palm Beach,p0lice didn't know quite who Jeffrey Epstein was, they found out soon enough.

Epstein, now 53, was a quintessential man of mystery. He amassed his.fortune and friends quietly, always in the background as he .navigated New York high society.

When he first attracted notice in the early 1990s, it was on account.of the wo h a; dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert'

In .a lengthy artide, headlinedithe Mystery of Ghislaine Maxwell's Seer e British Mail on Sunday tabloid laid out speculative stories that the tOcialite' au1 . aCIA spook, a math. teacher,a concertpignist or a corporate headhunter:

"But whatis the truth about him?' the newspaper wonde axwell, Epstein, is both flamboyant and intensely private;

The media:frenzy did not begin in full until a dek t ii, er. lb September 2002, Epstein was flung into the limelight when he flew Clin tek dilttors Kevin Spacey and Chris Tucker to Africa.on his private let.

Suddenly everyone wanted to publishedlengthY proilte.t. Th pstein was. New York magazine and Vanity Fair tit Post listed him as one of the city's theist:eligible \*bachelors andbegan des ibing its gossipcolumnsWith adjectivessuch gemysterious" 'and.arectusivet

Although Eiist t j no interviews, the. broad strokes of his past started to come into focus:

# Buildin asof extravagance
He was bo blue-collar in 1953, the son of a New York City department employee, and raised in Brooklyn's. Coney Island neighborhood. Re left college without. a bachelor's degree but b'e'came a math teacher at the prestigious Dalton School. Manhattan,

The story goes that the father of one of Epstein's studentsviaSSo impressed with the than that he puthim in touch with: a seniorpartner at•Bearr. Stearns; the 'global investment bank and securities firm.

10.1976, Epstein:left Dalton fora job at Bear. Stearns,:By the early 1980s, he had started). Epstein and CO. That is when he began makinglis millions in earnest.

Little is known or said about Epstein's businessexcept this: He manages money for the extremely wealthy. He is taidto handle:aacninta only:O1Si billion or greater.

It has:been estimated he has roughly 15 clients, but their identities are the subject of only speculation. All except for one: Leslie Wexner, founder of The Limited retail chain apd a farmer Palm Beadier who is said to have been a mentorto Epstein.

WO:hens:11d Epstein One of hitinciat lavish residences: a'magive &Mike doiniitatesa block on Manhattan's Upper. East Side. Itisteported to have, among.i res, closed, circuit television and a heated sidewalk to melt.a.w.artallen snow.

That townhouse, thought to be the largest privatesesidence A ' c i b anan, is only a piece of the extravagant world Epstein. built over tithe.

In New Mexico; he constructed a 17,000-square- il&l nansion on a 10,000-acre ranch outside Santa Fe. Many believed.it to.be the I e in the state.

1

private island inthe Virgin Islands. {sup}`4` In Palm Beach, he bought a waterfront g e ar,o I Brillo Way. And he owns a 100-acre

# >> PHOTOS:The players in ey..SpAtehisaga ; -
Perhaps as remarkable As 'sh homes is his extensive network of friends and associates at the highest echeto fpo r. This includes not only socialites but also business tycoons, media moguls royalty and Nobel Prize-winning Scientists whose research he often

lust. 11. people collect art, he collects scientists; said Nowak, who directs the Program f r Evolutionary Dynamics. at Harvard University and was reportedly the recipientof a S30 million research donation from. Epstein.

.EpStein is said to have befriended former Harvard President Laryy \$nmm!ers,prominent law Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort Zuckerman.

And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely photographed.

'The odd thing is I never met him; said Dominick Dunne, the famous chronicler of the trials and tribulations of the very rick wl wasn't even, aware of him," except for a Vanity Fair article..

Epstein's friendship with Clinton has.:attracted: the most. attention.

Epstein met Clinton as early as 19505, when he paid tens of thousands of dollars to j him.at an intimate fund-raising dinner in PIIMBeach. But from all appearances they ome close friends until after Clinton left the Oval Office and moved to NewYor

.Epstein has donated more than \$100,006 toiDemocratiecandidates' including Jean Kerry's presidential bid, the reelection.tampaign of New Mexico GO sthartheh and the Senate bids of Joe Lieberman, Hillary Rodhatfi Clinton, Chri Dodd and Charles SChumer.

# Powerful friends and enemies
A Vanity Fair profilefound cracks.in the ve teas life story. The1003 article said he left Bear Stearns in the wake of a:feder be a possible Seturitiesend:Exchange Commission. violation.. It also point Citibank once sued Itim for defaulting on a \$20 million loan.

The article suggested that onedtthwtusiness inentors and previous employers was Steven Hoffenberg,, now' serving n terra after "bilking investors out:of more than \$450 million in one of tbelarge . ernes in .American history?

As he exam e4th, Epstein made enemies in disputes. both large and small., He sues:1111e man who.' : ' old limn his intiltimillidii-dollar Pala Beath hOthe over a dispute about:less than t1 in furnishings.

A former Mend claimed Epstein backed out of a. promise to reimburse him hundreds.of thousands of dollars. after their failed investment in Texas oil wells. A judge decided Epstein Owed hilt tiothilig.

» Jeffrey Epsteip:tmocKprisoner who\_ssfept, moppeli,floors42(fisialsays

les a, bad. memory. I would rather not have ever ?net Jeffrey Epstein," said Michael Stroll; the retired forrner president of Electronics and Sega Corp. "Suffice\* to say I have nothing: good to say about him."

Among the characteristics most attributed to Epstein is a penchant for \*Women.

He has been linked to Maxwell, a fixture on the high-society party, circuits in both New York and London. Previous:girlfriends are said to include aformerMs. Sweden and,a.Roipanian. model.

"He's a lot of fun to be with," Donald Trump told New York.magazine in 2 t, t t is even said that he likes beautiful women as much as I do, and many of them are o ger side. No doubt about it, Jeffrey enjoys his social life?

# Investigation leads to Epstein
c Although he wasnot:a frequenterof the.Palm Beach. • e A'tvie , he made presence felt. ,\* \in Among his charitable donations, he gave S90,0.00 . e Beach.Police:Department and S100,000 to Ballet Florida:

( ck ce\ I-Cedes sat in his garage; alongside a - .Palm Beach International Airport. Athome, a eady..Prom a window in his mansion, he could look. the West Palm Beach skyline. He seemed to be:a man. In Palm Beach, he lived in luxury. Thr Harley-DaVidson. His jet waited at private'chef and a small staff st out on the Intracoastal Wate who had everything.

But extraordin ealtb c>rn fuel extraordinary desires.

# » Epstein eave ma for mansion in sex-trafficking case
In March 20 a worried mother contacted Palm Beach police. She said another parent had overheard a conversation between their children.

Now the mother was afraid her l4-year-Old daughter had been. molested,by a maxi on, the island.

The phone call triggered an extensive investigation, one that would lead detectives to Epstein. but leave theiri frustrated.

Palm Beach police and the state attorney's office have declined to discuss fhecase..But a Palm Beach police report detailing the criminal probe offers awindow into whardetectives fated as they sought to close in on Epstein.

Detectives interviewed the girl, who told them a friend had invited her tin rich man's house to perform a massage. She said thefriend.told her to say she was 1\$ if asked; At the house, she said she was paid SSWalter stripping to her parities and massaging' the man while he masturbated.

# Police interview 5 alleged victims
The investigation began, in Hill after the girl identified Epstein in a ph paid her. Police arranged for garbage trucks to set, aside Epstein's t through it. They set up a video-camera to record the comings monitored an airport hangar for signs of his private jes,ar man.who had ce could sift at his home.,They departures.

They quickly learnecf that the woman who took the Palm Beach Coiriniiiiiity Coll statement at police headquarters, visit Epstein, all between the ages of IA 4c(140/ trr Loxahatthee. In a Math fitted she had taken at least six girls to paid her for each visit, she said. girl to Epstein's house was:

During the drive back to her hots oIcl detectives, "I'm like a Heidi Pleiss."

Police interviewed five alleged arid 17 witnesses, Their reportshows some of the girls said they.had been ins to have sex with another woman in front of Epstein, and one said she fiad direct intercourse him.

In October looking found transcript. ed the Palm Beach mansion: They discovered photos of:naked, youngas several of the girls had described in interviews. Hidden cameraswere age area'and inside a:cloCk on Epstein's desk, alongside :a ,girl's, high school

Two of Epstein"sformer employees told investigators that young-looking girls showed up to perform massages two or three times a day When Epstein: Was in town.

They said the girls were permitted many indulgences. A:chel cooked for them, Wqrkers gave them rides andlancied out hundreds of dollars ar atime.

One employee told detectives he was.told to send a.dozen roses to-one. teenage girl after .1 high ; school drama performance. Others weregiv.en rental can. One; according to polite:, received a \$200 Christmas bongs.

The cops moved to cement their case. But as they tried to tighten the noose, they encountered. other forces at work.

In Orlando they interviewed a potsibletictitn who told them nothing. inappropriate ¢ad happenedbetween her:and Epstein. They asked her wheth:er she: had spoken to. ease. She said yes, a private investigator had asked her the same questioris.

1

1


Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart d

When they subpoenaed one of Epstein's former employeesthetold e same thing. He ands private eye had.met.at a.restapra:nt:days earlier to go.o the mgt.would tell investigators.

Detectives received :toniplaintstliatprivate eyes vi as polite officers. When they told Epstein's local attorney,. Guy Fronstin, he said gators worked for Roy Black, the highspowered,Miami lawyer who has defendC te Alves ofRush Limbaugh and William Kennedy

S ale' While the private eyes were. to •itallel investigation, Dershowitt, .dietiattard law professor, traveled to WettP. -with information- about the girls. From iheir own profiles on the popular b site ySpace.com, he obtiined copies of their discusSions about their use of alcohol and

He took: his r h meeting with prosecutors in early 2006 \*where he sought to cast doubt on e ns eliability,

The, priybeyes had: dog up enough dirt on the girls to makeprosecutors skeptical. Not only did some of the girls have issues with drugs or alcohol but afro some had triniinal records and other troubles, Epstein's legal team claimed. And.at least one of them, they said, lied when she told police she was younger than I\$ when she stsrted performing massages for Epstein.

-After the meeting? prosecutors :po.s.tponed their decision to tamale case to a. grand jury:;


In the' ollouting weeks, police receivedeor.nplaints. that two of the victirtis or their families had. been harassed Or threatened. Epsteitt'S legal team .ntaiiitainsthat its private investigators did .nothing illegal or unethicalduring their research.

By then, relations between:police and.prosecutors were fraying. At a key meeting with prosecutors and the defense, Detective Recarey, the lead investigator, was a:no-showt according to EPSteith ittatity.

"The embarrassment on the prosecutor's,face was evident whorl the. police (Ater : • r showed up for the meeting; attorney Jack Q0:illy:ger said.

Later in April, Recarey walked into a prcise\_cutor's.office at the state at. .. . ce and learned .the case Was taking an Unexpected turn,

The prosecutor, Lanna Belohlavek, told.Recattythettate a Office had offered Epstein a plea deal that would not require: him to serve jail tinag felony conviction..

Recarey told her he disapproved of the plea offer.

The deal never came to pass, however, ( S \ y

# Future unclear after charge.
Qn May-1,.the department ask \* tors' to approve Watitants to arrest Epstein on four counts ofunlawful sexualact\* a:minor-and to charge his personalassistant, now 27, for heral role.in arranging.thevisits. Police .officials ilsowanted to charge Robtbnith Ifad bed Heidi.Fleisenvith.lew.d and lastiViotts acts.

By then, the t was :frustrated with the way the state attorney's office had handled the case On ay the warrants were retwestetk, Palm Beach Police Chief Michael Reiter wrote a. tt r °State AttomerBarry Ki'ischer suggesting he disqualify:himself from the case if' he would of act.

Two weeks later, Recarey was, told that prosecutors had decided .once again to take the case to the grand jury.


1

It is notknownhow many of the girls testified before the grand jury: Buc Epstein's defense team said one girl who was subpoenaed - the Cafe who said she had sexii0 intercourse: With Epstein - never showed.up.

The grand jury's indictmentwas handed down in July. It was not the one the police department had wanted.

,Instead of;being slapped with a. charge of unlawful sexual activity with a minor; Epst charged With one count of felony solilitation of prostitution, Which carries a m of five years in prison; He was booked into the Palm Beach County Jail earlyJ Z3, released hours. later. in was penalty

Epstein's legal teami'doesn't disputethat he had girls over for ma he said their claims that they had sexual encounters with him 1 creåfHfity.. erger said. But.

"They are incapable of being believed," he said. "They h accusations of theft made: gainst them.by their emplo 4' s. , some of them." records.. They had re: was evidence of drug use.by

Wliatreznairis for Epstein is yet to be seen <S ,

The Palm Beach Police Departmen the FBI to investigate the case. It also has returned the. \$90,000 Epstein d

lb New York, candidates for go'llet or and state attorney general have vowed to return å total of at least \$60;000 in tam contributions from Epstein. Meanwhile, Epstein's powerful bends have rem ?S' ed sileåt " as tabloids and Internet blogs feast on the public details of the police investig • n.

Goldbe ins Epstein's innocence but says the legal team has riot ruled out a future plea dea e insists. Epstein will emerge in the end with his reputation untarnished,

"He will recover from this: he' said.

Staffwriter Lerry and staff researchersBridget Bulger, Angelica Corter,,Amy Hanaway and Mink Mena contributtd to this story.

amarra@pbpost.com

THE MOST
**INTELLIGENT GRID**
IN AMERICA

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273 / 278 - Tuesday, November 16, 2004


Section: A SECTION

Page: 1A

Source: By PAUL OWERS Palm Beach Post Staff Writer

Illustration: PHOTO (C & 2 B&W) & MAP (B&W)

Memo: Ran all editions.

Dateline: WEST PALM BEACH

# TRUMP SNAGS GOSMAN ESTATE FOR \$41 MILLION
When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, 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 make 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 time," Trump said. "It's probably the best piece of land in Florida - and probably the country - for luxury real estate."

Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor Lesly [REDACTED] said zoning regulations allow for only two houses - and maybe a third. [REDACTED] said she's not worried about Trump'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 place at U.S. Bankruptcy Court in West Palm Beach as part of Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual distribution to creditors.

The auction began at exactly noon after Judge Steven [REDACTED] 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 - \$250,000 higher than Trump's initial offer.

Mark Pulte, son of the founder of home-building giant Pulte Homes, passed when his turn came, letting lawyers for Trump and Epstein bid against each other until the price hit \$38.85 million.

Pulte then bid \$39.1 million, briefly raising the ire of Trump, who believed that Pulte had given up his right to bid by passing the first time.

But [REDACTED] allowed the offer to stand, and Pulte and Trump went back and forth until Pulte dropped out at \$41.1 million. Epstein, a part-time Palm Beach resident, bowed out at \$38.6 million.

[REDACTED] closed the bidding 10 minutes after it started, leaving Trump with the right to buy the 29,000-square-foot home (a typical Palm Beach County single-family house is about 2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service quarters.

The closing could take place within a week but probably won't happen until next month. Trustee Joe Luzinski and creditors said they were pleased with the outcome.

"We knew we were dealing with some substantial people . . . who were going to bid it up a bit," Luzinski said.

"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.

"In bankruptcy court, the idea is to get the most for creditors, and that's what happened."

The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer former listing agent Sotheby's International Realty received was \$32 million. Sotheby's won't receive a commission, he said.

Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday.

"I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said.

Pulte said Gosman asked him before the auction whether he would be willing to let him stay in the mansion after the closing until he decides where he wants to move. Trump and Luzinski said they have had no such discussions with Gosman.

Gosman, 75, had the house built after paying \$12.1 million for the land in 1986.

The former health-care magnate declined interview requests before and after the auction Monday. He was at the courthouse but left before the auction took place.

The \$41.35 million price tag eclipses the \$30.35 million sale of Lowell "Bud" Paxson's Palm Beach home and guest house but falls short of the \$45 million that Virginia home builder Dwight Schar paid for Ron Perelman's 26,000-square-foot estate, Casa Apava, a designated landmark.

Schar also paid \$18.6 million for a lakefront lot across the street from the main house, for a total of \$63.6 million. Insiders say Schar spent a total of \$70 million for his new property, making it the priciest residential sale in U.S. history.

Gosman once had a fortune that Forbes magazine estimated at \$480 million. He voluntarily filed for Chapter 11 bankruptcy protection in 2001, listing assets of \$250 million and liabilities of \$233.6 million.

When a judge ruled that Gosman had to give up all of his exempt assets to creditors if he wanted to reorganize under Chapter 11, Gosman converted the case to Chapter 7 liquidation. Last year, U.S. Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is invalid because Florida law does not recognize a Dominican Republic divorce that Lin Gosman tried to obtain from another man, Michael Castre.

The judge's decision was a huge victory for creditors because it prevents Abe Gosman from protecting assets by claiming joint ownership with his wife. Gosman's assets, which include an extensive collection of artwork, could total as much as \$70 million and will be sold later. Without Lessen's ruling, Luzinski would have had a much harder time selling Gosman's estate, said David Cimo, special counsel for the trustee.

"We would have been thwarted . . . or at least substantially impaired," Cimo said.

The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife an ownership interest in his home and other belongings only to avoid losing them in bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in 1999, well before he filed for bankruptcy.

Lessen is expected to rule in the next two months whether Gosman made improper transfers, a decision that will affect how much money will be available to creditors.

Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were willing to move forward, in part because the upkeep of the estate now exceeds their means. "This is not a happy occasion for them, but at least we're moving to the next level," Cimo said. "That's not a house you want to live in unless you're making large amounts of money like Donald Trump."

paul\_owers@pbpost.com


# .., ..h. . . <sup>I</sup> e Palnr~ each ost REAL NEWS STARTS HERE I
# Indictment: Billionaire Solicited 3 Times
Posted Jul 1, 2008 at 12:01 AM

Updated Oct 2, 2019 at:2:80 PM

(EINTOR\$ PIQTE: This story originally published in The Palm Beath Post on July 25, 2a)6)

Billionaire money manager and Palm Beach part-time resident Jeffte solicited.or procured prostitutes 'three or more times: between A d • ct. M of last year, according to an indiCtment charging him with fey ation of prostitution.

Epstein, 53, was booked at the Palm.Beach County 5 a.m. Stuiday. He was released.on \$3,000 bond.

Epstein's case is unutualin that stiSpett N 114 • - et\-tu 'on.johris7 are usually charged with a misdemeanor,. and even a fel Rai- &a is. typically iriade in a criminal information - an alternative to A' l% di my nt charging a person with the commission of a crime.

His attorney, Jack Qicil tge " , dined to discuss the charge:

State attorney's o s olcesman. Mike:Edmondson also had little to says

'Gene ealcip , there is •a case that has'a number of different'aspects to It; Edm of a prostitution-related charge.being submitted to a grand jury. came aware of the case months ago. by Palm Beach police.\*

Pt utors and police worked together to being the case to the grand int% he said.

Palm Beach police confirmed that and-said the department will release a report today regarding its investigation.

Epstein has owned .a five-.bedroom, 7 1/2-bath, 7,234-square-foothoni ith a pOol arid boat dock oti• the Intracoastal Waterway since 1990) ac property records. A man answering the door there Monday s wasn't home. A Cadillac Escalade registered bhp was parke e driVeway, which is flanked by two massive gargoyles,

Epstein sued Property Appraiser Gary Rikglit; ntending that the assessment. of his home exceeded its fair mvket He dismissed his lawsuit in December 2002.

A prOfile of Epstein in Vanity-F— e said he owns what are believed to be-the largest-private homes n - 51,000 square feet azid.in New Mexico - a 7,500-acre ra are in addition.to his.70-acre itlandin•the U.S. 'Virgin. Islands. and "craft.

Epstein's friends a era, according to the magazine, include prominent. businessme S,. cade , ics and.scientists and famed. Harvard law prcifessor Alan. Dersho .

@pbpost.com


# The Palm Beach Post
REAL NEWS STARTS HERE

---

# After long probe, billionaire faces solicitation charge
Posted Jul 27, 2006 at 12:01 AM

Updated Oct 3, 2019 at 3:11 PM

(EDITOR'S NOTE: *This story originally published in The Palm Beach Post on July 26, 2006*)

Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young women brought to his home, where he received massages and sometimes sex, according to an investigation by the Palm Beach Police Department.

Palm Beach police spent months sifting through Epstein's trash and watching his waterfront home and Palm Beach International Airport to keep tabs █ 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 there was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation.

Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's handling of the case that he wrote a memo suggesting the county's top prosecutor disqualify himself.

"I must urge you to examine the unusual course that your office's handling of this matter has taken and consider if good and sufficient reason exists to require your disqualification from the prosecution of these cases," Reiter wrote in a May 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.

By the nature of their jobs, polite officers look at evideritefrom one-sided perspective,' .Edmondson said. "A prosecutor has to look at it in apnuch broader fashion,' weighing the veracity of witnesses and how they may fare under defense attorneys' questioning, he said.

Epstein's attorney, ack Goldberger, said his client committed no crimes.

"The reports andstatements in question refer to false accusations that were not charged because the Palm Beach County state attorney questioned the credibility of the Witnesses, Goldberger said., A county grand jury "found the allegations wholly unsubstantiated:and not credible, and that's why his client was AS - -1 Charged with sexual activity-with minors, he said.

Goldberger said Epstein passed aliedetector test administere utable polygraph examiner in which he said he did notimow e minors. Also, a starch warrant served on Epstein's home fou dente to corroborate: he girls' allegations; Goldberger sal

According to police documents:.

- -.A Palm BeathCormiinity.Colleg the nude, then brought him six Acc., t ag 4 to 16, for massage and sex-tinged sessions. at his home, ent id.she:gaVe Epstein-a massage in.
- A 27-year-old woma ho rked as .Epstein's personal assistant also facilitated the liai ons p g the PBCC student to arrange for girls when Epstein was rpm wn. And she escorted the girls upstairs when they arrived, pytlng fre sheets on a massage table and placing massage oils nearby.
- Pali sworn statements'from five allesed victims and 17Wittiesses. They at on three occasions, Epstein had sex with the girls.

A nfoney manager for the ultra-rich, Epstein was •named one of New York's most eligible bachelors in 2003 by The New York Post, Be reportedly hobnobs with. the likes of former President Clinton, former Harvard UniversityPresident Summers and Donald Trump, andhas lavish homes in Manhattan, New Mexico and the-Virgin Islands.

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1

He has contributed tens of thousands of dollars to Democratic Party candidates and organizations, including Sen. John Kerry's presidential bid, and the Senate campaigns of Joe.Lieberman, Hillary Clinton, Dodd and Charles Schumer.

Goldberger is one of five attorneys Ept subject of an investigation, Edmon saz fnong thenthers: Alan Dershowitz, the well-known Ha rofesso.r and author.; who is a friend of Epstein. Dershowitz could notched for comment. ASr CICed Since he became the

Police said the woman 20, of Palm Beach' Wellington and. CollegeWh tslie phone ed young girls forEpstein was on has worked at an Olive Garden restaurant in Was a journalism major at Palm Beach Community questioned by polite last October. She.has an unlisted d could not be reached. for comment.

To .she met Epstein wtien,atage- Vita friend asked her if she wouldlike e money giving him a massage. She said she was driven to his. fivebedroom, 71/2-bath hiamenn. the Intracoastal Waterway; then \*stoned upstairs. to a:bedroom with a Massage table and oils. Epstein and were both naked doting the massage, she said, but when he grabbed her bottocks,..shesaid.she dichetwent, to be touched.

CO ASHA

Epstein said he'd pay her to bring him more girls - the.youngerthe better, told police, When she tried once to bring a 23-year.-old woman to him, Epstein said she was too old, said.

who has.not been charged in the case, said she eventually brought six girls to Epstein who were paid \$200:each time;-:'I'm like a Heidi. Reiss,' police quoted her as' aying. The girlsktiew what to expect-When they were taken to Epstein's home, said. Give a tnattagt - maybe:naked -.and allow. some touching.

Ong 4-year-old. girl took to meetEpstein led police to start investigation of him in March:2003. A relative of the girl called to thought the: child had recently engaged in\_sex with •a.Palm Bea rl t egirl then. got into a. fight with. a classmate who accused.her of be stitute, and shecouldn't explain Why she had \$300 in.her purse..

Thesirl gaye policethis account of her meeting ect)n:

She accompanied and a second' gir .Febrtia.ry. 2005.. Once• there,. a woman girl to follow her upstairs to. a room photographs of naked women o E, a hot pink and i) table. "C r s.house on a Sunday in was Epstein's assistant told the mural of a naked woman, several 'sofa massage

She stripped to herbra ties and gave him a massage.

Epstein gave the I l ecWillY-old \$300 and:she and the.other. irls left, she said. She said Robs Old he that Epstein paid her \$200' that day;

d similar stories. In most accounts, Epstein's personal assistant at rah =, now 27, escorted the as to Epstein's bedroom.

iwhostmost recent known addressisia North Carolina,.bas 4ot been charged in. the case.

Palm BeaCh:police often conducted surveillance of Epstein's home) and 'at Palm Beach International Aifpoitto get if hiS pi-if/ate jet Was tildte; to-they Would Icnow when he was in town. Police also arranged repeatedly-to receive his trash from Palm Beach sanitation workers, collecting papers with names 4nd phone numbers, sex toys and female hygiene prodtKIS•

One note stated that a female could not come over at 7 p.m. because of soccer. Another said a girl had to work Sunday -'Monday after school?' And still another note contained the work hours of a girl, saying she leaves: school at 11:30 a.m. and would come over the next day at 10:10 a.m.

Only three months before the police department probe began, Epstein donate S90;000 to the department for the purchase of a firearms simulator, saidJ Strudgr, town finance director.:the purchase was never made. Them was

returned to Epstein on Monday, slie said. CO "C(5) 6)\* \?\*

# ;Palm Beach Daily .News
# Police say lawyer tried to discredit teenage girls
Posted Jul 29, 2006 at 17:01 AM

Updated Oct 3, 2019 at 2:00 PM

(EDITORS NOTE: TRU nary originally was published in The Palm Beach Po ly • 2g 2066).

AS" Famed Harvard laWprofessor Alan DershOwitz met with the P County. State Attorney's Office and provided damaginginformation.a out t enage girls who say they gave his client,.Palm.Beachhillionaireje gel!), sexually charged massages, according.to:police reports..

The reports also state that another Epstein a eed to a plea bargain that would have allowed Epstein to have no 4 {sup}`N`4.. {sup}`e` .; ord. His current attorney denies this happened.,

And the documents also reveal private investigators aggre chased off visitors. her of at least one girl complained that wed his car,:phestographerthis.home and.

Police also talked lioar otiiebody Who said the was offered money if she refused to cooperate with the Beach Police Department probe of Epstein.

Theist state said it presented the.:Epstein Case to a county'grand th rather than directly charging Epstein because. of concerns about credibility. The grandjury indicted Epstein, .53i On a single. count of felob solicitation ofprogfitutiort, which carries a maximum penaltyof five years in prison.

Police believed there was probable cause to charge Epstein with the more serious crimes of unlawful sex acts with a minor and lewd and lascivious molestation. Police Chief Michael Reiter was so angry that he wrote State Attorney Barry Krischer a. memo in May suggesting'he disqualify himself from the tate:


The case originally was. going to be presented to the. grand hiry i February, but Wit postponed after Dershowitz produced intontiation.gleaned horn the Web, site myspace.com showing some of the alleged victims commentinton alcohol and maAiltian.a ttse, according to the police report prepared by Detective Recarey.

a 20-year-old Palm Beach woman who told police she recruited girls f6r Epstein, also is profiled on.tnyspace.corn. Her page includes photos of her and her friends, including one using the name "Pimpin' Made "who was. not charged in the case, is a potential prosecution with

According to Recarey, prosecutor tanna Belohlavek offered Epste ys Dershowitz and Guy Fronstin a plea deal in April. Fronstin, a g with Epstein, accepted the deal, in which Epstein wouldplead guil too e count of aggravated assault with intent to commit a felony; be p on\_we year's' probation and have ho criminal record. The deal a or EPstbin to submit tea psychiatric and sekual evaluation and have. rvited.vitits with. minors, according. o Itecarey's report. The nwas made in connection. with only one of the five alleged vicpim e restates,

Fronstin - who declined to corn i oii a case was subsequently fired and veteran defense attorney Ja r was hired. He denies there was any agreement by any of Eps ors to a plea deal.

abtblUtelydid not l o a plea in this.casef he said. Neither Belohlavek nor a state .attom Icesirian Could be. reached for comment.

The pate t arents of alleged victims who complained of being.harassed.by priva in sti ators provided license tag nutnbers of two of the. men.. Police to • ehicles were registered to a private eye in West Palm Beach and in Jupiter, according to Recareis report.

"I have no knowledge ofictdefense.attorney Goldberger said.

The report also says a Vernati connected to the Epstein case was contacted by somebody who was still in touch with Epstein. That person told her she would be compensated if she -didn't cooperate with police; Itecarey's report says. Those 1


The chief himself has come tinder atta' clS ib ps eiret laWyert and friends in New York, where he has a home. TIr S ew ou Post quoted Epstein's, prominent New York lawyer, G Le rt, as sayinghisclientwas indicted only 'because of the craclnes ice chief.'

Reiter has declined.to c n the case..

Prosecutors have beforetsaid ike F mo'ndson, spokesman for the' tate attorney's offite. "Thaes Whity6u ith a ate that falls into a gray area,' he: said. resented a sex-relatedcaselike Epstein's to &grand jury

°they's office did notrecommend a particularcriminal charge on. indict Epstein, Edmondson said. The grand jury was presented with a. list . charges from highest to lowest; then deliberated with the prosecutor out of the room, he said.

'People:are surprised at the grand jury proceeding,' West. Palm Beach defense attorney Richard Tendler said. "Ws away for theprosecutOes'offite t6 not take the full responsibility for not filing the (charge), and not doing what the Palm Beach Police Department wanted. I think something fell apart with. those underage witnesses:

who did.tilk "will be dealt with: the woman said she was told. Phone records show the woman talked with the person who allegedlyintimidated her around the time she said, Recarey reported.

Phone records also show that the person said to have made the threat, then placed a call to Epstein's personal assistant, who'in turn called a New York corporation affiliated With Epstein;the report states.

The issue in the Epstein case is not vyhether females came to his waterfroA home, but whether he knew their ;get.

1

S

"He's neverdenied girls came, to the; ouse: Goldberger said, But he Mein was given a polygraph test, 'he.p.assed on knovileclge of age;' y said.

Afterdie indictment against Epstein was unsealed this Po Ce. Chief Reiter referred the matter'to the FBI. 'We'Ve received th tid\*E'te reviewing it,' said FBI spokeiWciman Judy Orihuela in M' { g iS {sup}`e`

> I i i i # i

Defense attorney Robert Gershman was a prosecutor for sixx years. "Those girls must have been.incredible or untrustsv.orthy, I dotift know; he said.

Other attorneys said Epstein'S case: raises the issue of whether wealthy, connected defendants like Epstein --whose friends include former President Clinton.and Donald.TrumP - are treated differently from, others. Once he knew hewas the subject of a criminal probe, Epstein hired .a phalanx of powerful attorneys such as Dershowitt and Lefcourt, who is a past president of the National Association of Criminal Defense Lawyers.

Miami lawyer Ray Black -'wIMbecame nationally known when he sixA • ;AIh defended William Kennedy Smith on a rape charge in PAM Beach involved at. one point.

Said defense attorney Sushauers-1 thimk.it's e public may get the: perception that with power, you:may be treat ently than the s average Joe?

# The. Palm Beach. Post
REAL NEWS STARTS NM

# Expert: Ignorance of age isn't defense in sex, cases
Posted Aug 5, 2006 at 12:01 AM

Updated, Opt 0, 2019 at, 1:38 PM

(EDITOR'S NOTE: This story originally pubjishg(tin The

Palm Beath. Poston Aug. .,2006)

Even if Palm Beach money manager Jeffrey Epstein di know that, girls who police say.gayg him sexual mass his Intracoastal home were under the legal age, th wouldn't have exempted hint from criminal A4c45 es sexual activity with,minors.

"Ignorance is not a valicfclefense ACC o I1 ekle, a legal skills professor who was a r ecutor for nearly 30 years, half of that tune in sex crimes against children.

'Them is'no concerned; ment as far as the age is

After a -month investigation, Palm Beach police said obable cause to charge Epstein, S3, with wful sex acts with a minor and lewd and lascivious O CA station. They contend that Epstein -.friend of the rich 4 famous and financial patron of Democratic. Party organizations and candidates - committed those acts with five underage girls.

In the past week, New York Attorney General and gubernatorial candidate Eliot Spitzer has returned about 550,000 in campaign contribution's he received from Epstein, and Math a candidate to replace Spitzer in his current job, has returned. S10,000 to him because of the Palin Beach standal, the New York Daily News has reported.

Rather than fileCharges, the state attorney's officepresented, the case to a county grand jury, The panel indicted'Epstein last.week.on single, less.serious chargeof felonysolicitation of prostitution.

The case raised eyebrows because the state attorney's office rarely, if ever, kicks such charges to a grand jury. And it increases the diffictilty ofprosettiting child sex abuse cases;,S . especially when the defendant is enormously wealthy,a.0 can hire high-priced, top-tier lawyers.

At least One of Epstein's alleged victims told 'ce' eV., shelvat underage when the two of them for massages and sexual activity. She was at the time'and said' Epstein asked her ut her high school, according to police re As ,

A girl who said she &let East en. she was 15 said he told her VA? 93.14 n hn. happened at his. house,. bad' things caul e police reports:state,

Epstein's you leged victim was 14 when she says she gave hi massage that included some sexual activity. She is 9w e girl's .father says he doesn't know whether old Epstein her age.

rdatighter has kept a lot .of What happened from me because ofSheer embarrassment," he said.. "But she very much looked 14. Any prudent.man would have had second thoughts about that.'

Defense attomey.JacItGoldberger maintains that not only did Epstein pass a polygraph test showing he did not know the girls were minors, but their stories weren't credible: The state attorney's office also implied that their credibility was an issue when it decided not to Charge Epstein directly, but instead give the case to the grand jury.

"A prosecutor has to look at.it.in a much.broader fashidn, a state attorney's spokesman said last'week.



Epstein hired Harvard. law Professor Alan. tz when he became aware he was under a n, and Dershowitzgave prosecutors info t some of the alleged victims had \*spoke of ' h and marijuana on a popular Web site, actor ' g:to in Beath.police report.

Prosecutorstyp' 1 der two things in deciding 'whether to c arge s ebody with sex-related offenses against min° ether there is sufficient evidence and whethe sLfl is a public interest:in doing so, Dekie said.

o teens are in asexual relationship and the`:buy turns b fore the girl, he could be chilled with a sex crime if e.sex continues. There would: be no public interest in pursuing that, Delde said.

a

But where There is a large gap. ages and especially in cases of teachers with students - there is a public interettin prosecuting, h.e said. Likewise if the accused has a track record of sex with minors.

z

Still there is a "universal constant" in prosecuting these cases, Dekle said. Men who exploit underage children for sex often carefully choose their victims in ways that will minimize the risk to them, he said.

Victims usually are from a lower social status, and they may suffer from psychological problems, Dekle said.

"Lots of child sexual abuse victims have been victimized by multiple people over a period of time. Then the act of abuse produces behavior in the victims that further damages their credibility." Examples include promiscuous behavior and drug abuse.

Some of the alleged victims in the Epstein case returned to his home multiple times for the massage sessions and the \$200 to \$300 he typically paid them per visit. "That would be a definite problem for the prosecutor," said Betty Resch, who prosecuted crimes against children in Palm Beach County for five years and now is in private practice in Lake Worth.

"The victim becomes less sympathetic" to a jury, Resch said. "But she's a victim nevertheless. She's a kid."

Most men charged 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.

If a child and an adult tell different stories and both swear they're telling the truth, adult jurors are more likely to believe the adult, Dekle said.

"You have all these things working against you in a child sex abuse case. Prosecutors normally try to be very careful in filing those cases because they know what they're getting into. There is no such thing as an iron-clad child sexual abuse case."

# The Palm Beach Pok REAL NEWS STARTS HERE
# Epstein camp galls female accusers liars
Posted Aug 8, 2006 at 12:.01 AM.

Updated Oct 8,2019 at 3:35 PM

(EDITOR'S NOTE: This story originally publish(d in The

Palm Beach Pak dh Aug. 8, 2006)

Attorneys and publicists for Palm. Beach financier Jeffre Epstein went:on the offensive Monday, contending teenage girls who have accused: Epstein of sexual Shenanigans at his waterfront home ire hart say g that the Palm Beach Police Department

"There never was annex betwee and any underage WOmenrhis.lead at ac • Gtildberget, said from Idaho where he was with his family.

Sintejn.dfd have yo ta en eornem his house to give him massages, 0 t . said. "Mr.. Epstein absolutely insisted anyb dy w e to his house be over theoge of 18. How hey that, I don't know. The question is; did. anYthi occur. The law was net violated here.'

ad no explanation as to why Epstein would-paygirls.or o en with ho massage training - is the illegetvictinit el was'the case - \$200 to 330() fortheir visits. 'The credibility of these witnesses has been seriously questioned;" Goldberger said.

Epstein, 53, was indicted by ocounty grand jury lastmonth on a charge.of felony solicitation of prostitution. After-an 1 I-month investigation that include.d sifting through Epsteitfs trash and surveilling his home, Palm Beach police concluded there was enough .evislence to charge him with sexual activitywith minors. When the. grand juryindicted

1

Epstein on the less serious chargei.Pol ice Chief Michael Reiter referred theicase to the FBI to determine Whether there Were federal law violations:

After a spate of stories about the case last week, New York publicist Dan Klores - whose client list harinduded Paris Hilton and Jennifer - said on.Saturday that Epstein's camp was ready to get their story out.a

They did that Monday via Goldberger and a LOS Angela publicist for Miami criminal defense attorney Roy. Black, who also has represen'ted Epstein in the case.

"We just,think there has been a distorted view of this irt the media presentedby the Palm Beach police.," Goldberger said.

Reiter has consistently declined to cons egtd j6e case and did not respond to..1 request for m Monday.

( S 4

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The. implication that State Attorney Barry ICristher was easy on Epstein by presenting the case to a grand jury . rather than filing charges directly against him.is wrong, Goldberger said.

1


The Palm Beach Police Department was 'happy and I ecstatic" that the panel was going to review the evidenCe. °I think what happened is they weren't happy with the. res ult. They decided to use the press to embarrass Mr. EpStein."

But records show that Reiter wrote Krischer on May I well before the case went to the grand jury - suggesting that Krischer "consider if good and sufficient reason exists to require your disqualification from the prosetution of these cases!

Rather than flat-.out decline to charge Epitein, ICrischer referred the case tothe grand jury. to `appease the chiefO Goldberger said.

A state attorneys spokesman would say only t i t th\_ fhee refers cases to the grand jury when there with the viability:of the evidence or witnesses'

Both the state attorney and the concluded there was not sufficient evidence n had sex with minors, according to Gol t was just a childith performance by the Polite Department," Goldberger said

The defense or eysaid one of the alleged victims who dame was a minor was in fact over the: age of 18. A they eged victim who was subpoenaed:to testify to t so grand jury failed to do so. Epstein's accusers, he added, ve histories of drug. abuse and thefts. "These women are ars. We've established that!

But why would they ill invent their stories about meeting Epstein rot sexual massages?

1 don't:have an Answer is to'wharwas the motivation for these women to come forward and make these allegations," Goldberger said.



# Reiter focus of fire in Epstein case
Clipped By:



reiter\_m
Sat, Apr 22, 2017

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# The Palm Beach Post
REAL NEWS STARTS HERE

# Delays in Epstein case unusual, lawyers say
Posted Mar 13, 2007 at 12:01 AM

Updated Oct 3,2019 at 3:48 PM

(EDITORSTIOTE This story originally published in The Palm

Reach Post March 13, XX)

A federal probe or a plea deal could• explain the wait in Palm Beacher's solicitation cast

Nearly eight months after Palm Beach tycoon Epstein was charged with felony solicitati stitution, there has been no discernible progres No. Witnesses deposed. No trial date , save:for routine court hearings reset anation.

"Usually that would be urlcu R said criminal defense attorney Glenn Mit no involvement in the case.

"As a generA C e ) t would be unusual for nothing to have happe k" agreed Michael Dutko, a criminal defense a me , ort Lauderdale: He represents:

Af2 Palm Beach, potentially a key witness in the

O se A routine hearing for Epstein was pulled frail:that:Mitt dodketlatt week and reSetfor May 16. The delays and inaction. could he: doeto a potential federal probe of Swain or because a plea dealt is in the works, attorneys say. '

Unusual is: the word that best describes everything about the case against Epstein, 54, an. enigmatic money manager in New York City who counts Bill Clinton and.Donald: Trump among his friends:

'Highly unusual'? is how Palm Beach Police Chief Michael Reiter described Ssate Attorney Barry krischer's handling of the cast in:a bluntly critical letter to Krischer last year before Epstein was indicted:

Reiter Wetted the Witter-CO the•FBI to determine whether any federal laws had been violated. Epstein's allies countered by attacking the chief personally and professionally.

Reiter% department investigated Epstein for 11 months. Paige sifted repeatedly through his trash and conductea surveillance on.his fivepbedro-om, 7 1/2gbath, 7;234-squ foot home on the Intratoattal Waterway. O

Police said Epstein paid women and girls as y give him•erotic massages athis home. Pot ht there was probable cause to charge him wi sex acts withn minor and lewd and lascivious~l don.

Epstein responded by hiring4p oflawyers. One of them, Harvard law professor ay author Man Dershowitz, provided the state a ffice with infortnatiOn about alcohol and:Atari y some of the girls who said they were wi

Prosect> en referred the case to the. grand jury rather file. arges directly against Epstein.

st &attorneys deny he had sex with.underage e: lawyers say the.girls.' stories' are not credible. Bptif 'the court file is any indicatorv.they'vemadeno effort rollepoSe the girls.

1

Neither proseeptors, nor defense atto\_rneystape.sought to question , said Dutko, her attorney. She 'recruited teenage gilt to visit Epstein for massages and sexual activity,. Palm Beach police. said, and presumably would be a key witness.

Epstein 's attorney jack Goldberger did not return phorie messages:

A source close, to the case \*suggested iris languishing pending a decision by the FBI citi\*lietherto refer itto. federal prosecutors.

'We still have a:pending:case," FBI spokeswoman Judy• Orihuela said Monday.

State Attorney Krischerdid not return a call for comment. His spokesman, Mike Edmondson, declined to say whether federal investigators. are:delaying;the Ep-stein case: But; hi added, "if another agency it looking at sbiliething,'W wouldn't want to step on their toes."

Attorneys say inertia in a criminal case oft s to •a pending plea deal,

"It would not:surprise the if som appened that's not reflected in the .court file such as an agreement that will be fo zed ter.

Defense attorney sometimes put Witnesses, re esd g"documents and thelike -- because doing s creates more work for harried prosecutors who may bee ngryand not offer a plea deal. said defense attorneys conducting discovery -- deposing

es defense lawyers, knowing that, will try and.do covery without taking depositions," said. Shiner, a former prosecutor for 13 years.

Instead, they may conduct a belbw'the-radar probe such as haVing aprivate investigator check out leads, he said,

Shiner and others say'a pleadeal far Epstein probably • would.result in pretrial intervention, in.which a:defendant may be ordered to undergo a psychological evaluation, counseling or .other conditions in return for dropping, the charge.

}

Edmondson, spokesman for State Attorney Krischer, said there is no plea offer and no .request for the prosecution to show its Cards.

-pa my knoviledge, it's never happened before on a filed case; he said.

Cos


Section: LOCAL

Page: 5B

Source: The Associated Press

Illustration: PHOTO (B&W)

Memo: Ran all editions.

Dateline: NEW YORK

# WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16
A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had sought his help becoming a model.

The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had the teen perform a sex act when she brought photographs of herself for him to review in his Upper East Side mansion sometime in 2000.

Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice" included massages and other favors.

When the girl told Epstein, "I am 16 years old and just want to model," he replied, "Don't worry, I won't tell anybody," court papers say.

Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been indicted in Palm Beach on charges of soliciting underage prostitutes. That case is pending.

The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural sex acts" while she was a minor, the lawsuit says.

Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends, stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her 40s). I love girls your age.'"

The young woman, now 23, kept returning to Epstein because she has "mental issues," said her lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result of severe mental disease and defect."

Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can read a newspaper and recognize the word 'rich.'"

Lefcourt also said the statute of limitations has expired for the woman's case criminally and civilly, and will almost certainly be dismissed.

He refused to comment on Epstein's Florida charges.

Meanwhile, Unroch, 57, also acknowledged that his client was living with him and was at the center of a \$10 million lawsuit he filed last year against a neighbor who said he was having sex with underage girls. That case is pending.

"What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve the case out of court.

# The Palm \_ Beath Post
REAL NEWS SHIRTS HERE

# Palm Reacher pleads in sex ;mei
Posled Jul 1, 2008 at 12:01 AM

Updated Oct 3, 2019 at 1:47 PM

(EDITOR'S NOTE; This story originally published in Th&

Palm Beach. Post on fuly.l, 2008)

Jeffrey Epstein will serve 1 1/2 years on teen solicitation charges.

t ic

He lives:in a Palm Eleach waterfront mansion and has kO company with the likes of President Clinton, Prink.) .Andrew and Donald Trump;but ihvestine V eriefftey Epstein will call the Palm Beach'Coun ' .for the nett I& months.

j Epstein, 55) pleaded guilty MAta o felony solicitation of prostitution and procuri aft under the age of 18 for prostitution. After se oaths in jail, he will be under house acre r e . And. hewill have a lifelong. obligation to a sex Offender: He must submit to an HIV test in hours, with the results being provid ? ivs victims or their parents.

( c part mto the plea deal, federal investigators agreed to drop l i.anet • vestigation of Epstein; which they had takensto a d jury, two law enforcement sources said.

Epstein was indicted two years ago after an 11-month investigation by Patin Beach ptiliCe. They received a complaint from a. relative of a.14-year-old girl who had given Epstein a naked massage at his five-bedroom, 7424 square-foot, 8845 million Intracoastal home.

Police concluded thartherc were several other girls brought in 2004 and 2005 to an upstairs room at the home for similar massages and sexual touching.

The indictment charged:Epstein only with felony solicitation of .pmstinition. The state attorney's office later added the charge of procuring underagegirls for that purpose.

Prosecutor Lannal3e1Ohlavelt said of tbcpleci tOOk into consideration the: lesigthithe trial would have been and witnesses havingto testify\* about sometimes embarrassing .incidents.

Epstein may have made a.serious mistake soon after he was charged. He rejected an offer to plead gniltyto one count of aggravateda.ssaultwithiptent to-commit a felony, according to police documents. 'HI would have god years' probation, had ho criminal secord and not b registered sex offender, the:documents Indic-

Epstein arrived in court Monday vn attorneys. He: wore a blue blazer, lue. jeans and and gray sneakers. Afte dge Deborah.Date Pucillo accepted the plea, was erprinted. Epstein then removed. his bl d s handcuffed for-the trip to jail while hfsattd di shield him from photographer

When he eveiAta2ly is released-to house arrest,. Epstein.will have to e a.1..0 p.m, to '6 a.m.:curfew:Kanto pe ed contact with anyone wungerthan 18: and O1.e r own nor. possess pornographic or sexual materials at: are relevant to your deviant behavior/.theittdge said.

Epstein will be allowed to leave home forwork. The New York-based money manager. told the judge he has formed the tot-for-p.mot.Floritla.Seience FollThclatIP.n. to finance scientific research. I'm. there every day)? Epstein said.

The foundation was incorporated in November. Epstein said he already has awarded money to Harvard and MIT.

When he is release& from jail, there is a chance that Epitein will be forced tcrtriov.e. Self offendersare not allowed to live within 1.,000 feet of a school', parls.Or other areas where children may gather. No determination has been made as to whether Epstein's home compliet, but attorneys. said it likely does.

Sea offenders also typicallyatistattend counseling sesslions. Belohlavek said that was waived for Epstein because his private psychiatrist is working' with him. The judge was skeptical but agreed to it.

Epstein's legal woes don't end with MOnday's plea, The are four pending federal civil lawsuits. and one in s related to. his behavior. At least:one woman has su New York,. where.he owns a.\$1,900-square- an mansion. in attain

"les validation of wharWoesa Miami .attomeyleffrey Henn victims in the federal 'Avis Ted LeopOld.represen state court. He sal add' "a few oth I Caseti'said d represents the alleged aIm. Beach attorney ed victim in. a Civil suit in ates amending that lawsuit to 'as well,

In the crimin ate, police' went so far as to scow Epstein's trash a ticusurveillance at Palm Beach International here they watched for his private. jet to they know When.he was in town. They concluded that 'paid girls \$200 to \$3.00 each after the massage sessions.

"I'm like.a.Heidi. now 22, told Slice abouther efforts. in recruiting girts.for Epstein.

Th'erewas probable cause to charge Epstein with unlawful sex acts with a Ennio,. arid lewd and lascivious molestation, police concluded.

The state attorney's office. said.questions about the girls credibility led it to take the unprecedented step of ; presenting the evidence against Epstein to a!graud jury rather than -directly charging him.

Palm Beath Police Chief Michael Reiter wasfurimis with State Attorney'Barry Krischer, saying in a May 2006 letter that the prosecutor should disqualify himself; "I continue to find your office's treatment of these cases highly unusual; he wrote. He then asked forind got a federal investigation.

Epstein hired a phalanx of high-priced lawyers - Including Harvard law professor and author Alan Ders.1.19Writx - a public relations people who questionedReiter% go and the v,ictims' truthfulness.

In addition to mansions in Palm Beach. an ttan, Epstein ownshomes in New Mexico. gin Islands, He's a ftettue-nttorittibittor to De- rty candidates-, lie also.donated \$30 milliontgg ard n.2003.

Former New York Gov. returned A 550,000 campaign contribu pstein after his indictment, then resigned di mg:his own sex scandal. And the same Palm B Department that vigorously investigated returned his S90,000 donation for the parch rearms simulator.

writer Eliot Kleinberg and forther.staffresearcher elle Quigley contributed to this story.


I . •

# The ,PalmBeach Post REAL NEWS STARTS HERE
# Jeffrey Epstein: Scientist, stuntman, lstit slave' visit jailed tycoon
•

By LARRY / Palm Beach Post Staff Writer

Petted Aug 13, 201 at 12:01 AM

Updated Jul 16, 2019 at 4:54 PM

Tycoon Jeffrey Epstein mingled with an eclectic MU of people, including beautiful young women, before he go into. trouble for paying: teenage:giils to give him s massages at his Paint Beach Mansion:

Not Muth hat changed; even. thciugh.he • in a dorm at the Palm Beach County\$lt 17-acre, 967-bed stockade near-the fairgr.

During his first menth.of t; Epstein was visited by the female assistant o, told polite, had escorted them. to the wpm. ton where theygave him naked massagec •ki

Also•treldting •' jail was .a youngwoman whom Epstein purpo scribed as his YugoslavianSeX Slate.

wealthy financier 445:1 science word; also.has. been 'sit d'by an expert on artificial intelligence, as well as a an who is a mixed martial arts aficionado and sometime movie stuntman.

The only other people to visit.him at the jail, according to records, are a Island man and an individual who listed Epstein's Palm Beach. address as his own.

Epstein, 55, pleaded guilty on June 30.to.two prostitutionrelated charges and was sentenced to 18 months In jail, followed by a year of house arrest: Epstein paid teenage

girls 3200 to.\$300 in 2004 and 2005 for massages in hiS home. that sometimes included sexual touching, Palm Beach police said.

His jail visitors injuly'lucluded:

- 29, who some of the teen masseuses said phoned them when Epstein was in town and escorted them upon their arrivalat his:Palm Beach waterfront home town. upstairs.room, where she prepared.the massage table and provided the oils for their encounters with him: visited Epstein three times in July; according to a jail visitors iog. list.sa Manhattan home address.. Reached by telephone, she declined to discuss Epste' c

i - Nadia Marcirikova,- 23; whose family in av Epstein paid money to so that he could b • the United States to be his "sex slave;\*tw iris tad police. One. girl told police that E cted Mareirikova and her to kiss a while he Wattled and masturbated. Another gaged in sex with. at Epste\* j visited Epstein in jail four times.' e- lists her address as on the. Upper'East sidpp ar3hattan, not far from Epstein 's enormous a

- Roge e mp k, 62, founder of the Institute.fOr Learning ncest Northwestern University and au expert on al intelligence, paid. one visit to Epstein. Schank has tten numerous books owthat subject and has a doctorate degree from Yale Universityin linguistics. He'vms one of 19 .people who applied to be president of Florida. Atlantic University in 2003. He became chief learning officer' at the online Trump University in 2005..Schanklisted his address as being in Stuart, and records show he also owns a,home in Lake Worth.


Epstein has financed a number of scientists over the years, including Nobel Prize winners. He gave 830 million to Harvard University in 2003. In November, he: formed the not-for-profit Florida Science Foundation, which he said finances scientific research.

- Igor Zinoviev, a Russian. mixed:martial arts.fighter, who coaches a Chicago team in the International Fight League, He also has -waked as a personal titter,. celebrity bodyguard and movie stuntman, according to-the leagues Web site. the •Nevaersey. resident visited. Epstein seven. times iti.july.

Zinoviev, Sthank arid comme,nt, could not be tea

Staff researcher Niels Heimeriks contribu s story:.

Teri fiarb.era, spokeswoman forthe Palm Beach Sheriffs'Office, confirmed that Epstein, 55) h work-release program since Oct. 10.

# Palm Beach Daily News
# Billionaire sex. offender "eaves jail six days a week for work.
Posted Jul 1, 2008 at 12:01 AM

Updated Oct 4,2019 at 9:27 AM

Palm beach billionaire Jeffrey gpstein, who's serving 18 months. in jail for soliciting an underage girl for prostitution, is allowed to leave the Palm Beach County Stockade six days a week on a work-release program. O

"He works six days a week: Frid.ay. u ednesday 10 a.m. to 10 p.m.: Barbera said vi He) works at his local West Palm Beach off ed on an active GPS system (he wears an ankl br Mr. Epstein hires a perm itdeputy, at h for his own security at his workplace autin he is outs

Miami attorli fiey Herman represents siit young wome eye sued Epstein, claiming:be sexually abused. aim Beach home when they were minors.

O .e an said he received a letter about the work-release Ograra from the U.S. Attorney's Office within the pait few days. But Herman says Epstein haelbeen gut on,workrelease for several weeks beforelhe notification.


"My clients expressed shockand disappointment," Herman said. "I find itincredible that he's on work-release in the community and my clients aren't notified of this and we get this letter weeks after the fact.'

lie goes to work every single day slid goes back to jail at night, just like'everybody else (in the program)," Goldberger said.

Epstein pleaded guilty June 30 to two felony counts: soliciting prostitution and procuring a. person under 18 for prostitution. As part of the plea agreement, Epstein must serve one year of house arrest and register as a lifelong sex

offender. 04

# Palm Beach Post REAL NEWS STARTS HERE
# Woman want Epstein sex plea deal unsealed
Posted Jul 1, 2008a112:01 AM

Updated Oct Z 2019 at 223 PM

(EDITOR'S NOTE: This story originally published in The

Palm Beath Pott June 10, 2009)

Their attorneys will ask a judge to open Jeffrey Epstein's AS, records.

When wealthy money manager Jeffrey Epstein of CH Beach pleaded guilty last year to proeurin prostitution, his case detoured around regarding the sealing of court documents. r tate rules

At a plea conference on the lawyer and .a prosecutor that a deal Epstein h avoid cliarges s the hearing. es, a judge, a defense d of the bench and decided with federal prosecutors to ed, according to a transcript of

Ands

i t Flopriaima rulaes of.judicityalcoadmartinis.: mati,on, asuirweeplal baslicrules sealed,. thi .ngtkaacpoturt trQdmocurn publeicntvi.heasw,beeneor wesilail beso require a judge to find a significant reason, to seal, such as protecting a trade secret dr a compelling gbvehtment interest.

0

Yet no notification or reason occurred in Epsteiri!s case, according to court records.


i

•

Epstein's own attorneys,•in federal filings, have referred to his confidential deferred prosecution agreement with the U.S. attorney's office, struck in Septeniber 2007, as unprecedented" and "highly unusual." And it was 'a significant inducement" for Epstein to accept the state's deal, observed the state judge who accepted his plea, CatintyJudge Deborah Dale Pucillo.

Epstein.now faces at least a dozerhcivil lawsuits in federal and state courts 'filed by young women who said they had sex with him and now are seeking dainages.

Attorneys for some of those women want his agreemen with federal prosecutors unsealed and will ask Cir Jeffrey Colbath to do so today.

It.is against public polity for these dettlft e have been sealed.and hidden• from public sc a member of tlieptiblic, E.\117..has a right to Ocuments unsealed"' wrote former Cirt e Berger) now in private practice and repres44ng of the women.

The Palm Beach. s iviU ask Colbath to unseal the agreement..P tt Deanna.Shullmati will argue that the public ha i t to know the specifics of Epstein's OW

Accor arious.media.accotints, Epstein movedin les that includecl:President Clinton, Donald Trump and Andrew. "International Moneyman of Mystery," ared a 2002 New York magazine profiltof Epstein..

Epstein, 50, is in. the Palm Beach Countratockade, serving an 1/1-month.sentenct.after pleading guilty nearly a year ago to felony solicitation of prostitution and procuring teenagers for prostitution.

He is allowed out from 7 a.m. to 1.1 p.m., escorted by a deputy, said 'Palm Beach County. Sheriffs Office• spokeswoman Teri Barbera.

During a Palm Beach.Police Department investigation; five victims and.17 witnesses gave statements, They told of young women brought by his assistants. to Epstein's mansion on'El Brillo Way for massages and sexual activity, and then being. paid afterward.

At Epstein's plea conference last year, his attorney, Jack Goldberger, and then-Assistant State. Attorney Lanna Belohlavek•approached Pucillo in a sidebar conference. Pucillo, who had left the bench nine years earlier,, was filling in temporarily as a. senior judge.

According to a transcript, Goldberger told. Pucillo. that Epstein. had entered a confidential agreement with attorney's office in which federal prosecutors 12r° pursuing charges against him if he pleaded state court. Putill0theii skid slieWatited te f the agreement filed in his case, and Gol e r c ncurred that hewantedit sealed. Belohlavek14kst off on it.

The Florida Supreme Cot ias iessed "serious concern" and launched an all-o to sealing procedures across the state fo dia reports in 2006 of entire cases being sew disappearing from court records.

"The public's tutional right of access to court records must re riviolate, and this court is fully committed to guar \*ng.this right; justices wrote in their final report..

office on Tuesday referred any questions to oldberger, who declined to comment. Pucillo also has declined to comment.

# The Palm Beach Pc•st REAL NEWS STARTS HERE
# Epstein secret pan with Feds reveals "highly mastiff" terms
Posted Jun 10, 2009 at 12:01 AM

Updated Oct 4, 2019 at9:23 AM

(EDITOR'S NOTE: This story originally pubtisbe.d in lift

Palm Beath Poston Septenibee 19, 21709)

A secret non-prosecution agreement multimillionaire financier JeffreyEpstein struck with federal prose being called'ahighly unusual' by former federal pi-, rs and downright outrageous by attorneys now ese • rig young wornenwho:serviced him,

The deal reveals that the FBl and. AS2S. orney's Office investigated hint for several fee - s, incluthil engaging minors iin CQMM e crimes are punishable by anywhe om years to life in prison.

But federal prose) ked down and agreed to recall grand jury t poen Epstein pleaded guilty to prostitution- felonies in state.court; which he ultimat He received .arr 18-month jail sentence, of S eh h rued 13 months.

C)he .S. Attorney's Office ebb !agreed Mit to 601;040 of . pstein's possible co-conspirators: ==,


In Lesley Grdff and Nadia .Martinkova.

The deal was .negotiated in part by heavyweight New York criminal defense attorney Qerald Lefcourt,

Unsealed on Friday after attorneys forsome of Epstein's victims and The Palm Beath Postsought its.release, it offers the firstpubliclook at the deal. Epstein's highfrpOWered legal counsel brokered on. his behalf.

Mark of Stuart, a former federal. prosecutor., described the. disparity in:potential sentences as Manual,: but even more so :a priniiiion an attorney payment.

The first draft of the agreement in September 1007 required that Epstein pay an attorney --tapped by the 11,S, Attorney's Office and approved by Epstein -- to represent some of the victims. That attorney is prominent Miami lawyer Bob Josefsberg.

But an addendum to the agreement signed the following' month struck Epstein's duty to pay Josefsberg if he tithe victims did not accept settlements.-- capped at S150,00O AS, and instead pursued lawsuits.

said it appears the government was balance the lesser sentence for Epstein:1i S150,000 for each victim. -I've never, like that in my life; he said. /es h' ring. ything

The deal does not say whe ., or totistilted before the d tl. - •5 ide. s were contacted

Attorney Brad dsJF.ort Lauderdale, who represents three of they, g. .en, believer that none of the 39 to 40 woman d as victims in the federal investigation were tdldahead.bf time. said.his.elients received leeters m the U.S. Attorney's. Office months after the deal signed, assuring them Epstein would be prosecuted.

'Never consulting thevictims is probably-the most outrageous aspect, of said. It taught them that someone with money can buy Iris Way out of anything: It's outrageous and embarrassing. for United States Attorney's. Office and the State Attorney'S Office.'

Epstein now faces:many civillawsuits filed by the women, who are represented by a variety of attorneys. Jn many, the allegations are the same: that Epstein had a,predilection for teenage girls, identifiecipoor, vulnerable'ones and used

1

other young women to lure them to his Palm Beach mansion. They walked away with between \$200 and S11000.

Forme'. titalit judge Bill Berger; also representing victims, called the agreementa "sweetheart deal."

"Why was itso important for the government to make this dealt Berger asked. rhetorically: Ve have not yet had an honest explanation hyany public:official as to why itwas made .....:and why the victims were sold down the. river."

Former federal prosecutor Ryon McCabe described the agreement is"very unorthodox:" Such agreements, h are. usually reserved for corporations, not individ

/4 very, very rare. I've never seen or hear procedure that was setup here," said involvement in any Epstein iitigati o has no

"He's essentially avoiding f ecutionbecausebe can afford to pay that e to help those victims review their cases..., rso has nOtnonoy,te couldn't be able to strike.4e3l, h is and avoid federal prosecution.

The ba eal with federal prosecutors is all the more inwresei i light ciftlit legal powerhouses who have ed or. Epstein, including Harvard professor Alan O ee ... owitx and Bill Clinton investigator Kenneth Starr. . (court is a past president of theVational Association of -Criminal Defense Lawyers.


Epstein'S local. defense attorney, ack Goldberger, issued a statement Friday saying he:had fought.the release of the sealed agreement to'protett the third parties named there. "Mr. Epstein has fully abided by all of its terms and conditions. He is looking forward to putting this difficult. period. in his behind him. He is continuing:his:longstanding history of science philanthropy."

i

The investigation triggered tensions between police and prosecutors, with then-Palm I3each Chief Michael. Reqr saying is a May 2006 letter to then-State Attorney Bariy Krischer that the chief prosecutor should disqualify hiniselfi

coMinue to find your qffice's treatment of these cases highly unusual," Reiter wrote. He then asked for and got the federal investigation that ended in the sealed deal.

'The Jeffrey Epstein.matter was an experience ofwhat a

many-million-dollar defense can accomplish,' Reiter told the Palm Beach. Daily News upon his retirement. 46s CO S

187 / 278 - Wednesday, January 27, 2010


Section: LOCAL & BUSINESS

Page: 3B

Source: By JANE MUSGRAVE Palm Beach Post Staff Writer

Dateline: WEST PALM BEACH

# JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS
In a decision that could spark a constitutional showdown over privacy rights, a judge Tuesday gave lawyers representing multimillionaire 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.

Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut the women's claims that they suffered psychological ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as young as 14. Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records, he said, can't be sought until the women are asked whether they have ever had an abortion, how many and where. Further, he said, the records would not be made public and might not be admissible during trial.

But, he said, since the women claim Epstein, now 57, is responsible for their emotional distress, his attorneys can explore the impact of other events. Medical records, Hafele said, are a better source of information than a person's memory.

Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky constitutional grounds.

"These records are protected by our constitutional right of privacy," he said, referring to the Florida Constitution.

After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the records.

In another ruling Wednesday, Hafele also said that videos from depositions in the state cases can't be released without a court order. The ruling came after Epstein attorney Robert Critton complained that a video of Epstein being asked whether he had an "egg-shaped" penis became a youtube.com sensation. It first appeared on The Palm Beach Post Web site. Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was public record. The civil suits began mounting after Epstein agreed to plead guilty to two state charges: procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18-month sentence. As part of the deal brokered with federal prosecutors, he agreed not to contest the accusations in the civil lawsuits. He can argue the women don't deserve the millions they are seeking.

~jane\_musgrave@pbpost.com

# The Pihn each Post REAL NEWS STARTS HERE
# Epstein Journal's Findings Could Resurrect Case
By Jane Musgrave

Posted Sep 17, 2019 at 12:01 AM

Updated Oct 1, 2019 et 10:51 AM

(EDITOR'S NOTE: This story originally published in The

Palm Beath Post on March20, 2010)

A purloined journal that is said to contain the 'faille. di "hundreds" of victims of convicted sex offender. Je Epstein could be used toreopen the investiga in multi-millionaire's appetite for teenage gi orney representing men of.the victims, said

' New detailsabout dig contents o£ the journal were released this week when.Alfredo Ro who worked as a property manager fcirthe ath resident pleaded guilty to obstructio for lying to federal agents, when asked if. reformation about.his former boss' crimin activi e later tried to. sell the journal he stole from Ep for \$50,000 to an unidentified person, who afe uthotities, according to, court records..

art orthe plea agreement,. federal prosecutors said the urnal'contaiiis.infOrmatibri Material to the Epstein nvestigation, incjugling the names, of material witnesses aridadditional victims,'

"Had the items been produced in response to the inquiries of state or federal authorities ... the materials would hate been presented to the federal grand jury," federal prosecutors wrote.

Instead, prosecutors short-circuited the grand jury investigation and. cut a deal with Epstein. They agreed hot to pursue federal charges ifhe didn't contest prostitutionrelated felonies in state court. The. money:manager pleaded guilty injuly. 2008.to procuringa minor for prostitution. and soliCiting prostitution. He served .1.3 months of an. 18 month sentence.

Attorney Adam Horowitz, who represents seven of the roughly 18 Women who have filed civil suits:against Epstein, said the new information could trump the socalled non-prosecution agreement.

Tie multifaceted agreement, he said, deals only WI specific list.of victims that the U.S. Attorney's Offi about when it penned the deal in 2Ci071.1.fad al victims are listed in the journal Rodriguez stole, said, federal prosecutors could reopen the \\*ti on. knelt'

It opens the door for further pis eutio he said.

A

in additign.to.turping.a tit urnal to federal agents, Rodriguez told the is former boss was having sex with undera en he worked for him In 2004 and 2005. H ad. s naked.giris, who looked likeminors,. in theppol o ins \$8.6 million mansion. He had seen pornog, images of young girls on Epstein's computer, tdin o court records.

°either Epstein's criminal defense attorney;:lack Goldberger, riot attorney Robert Ctittoniwho represents Epstein in the civil lawsuits, couldbe reached. Federal prosecutors have consistently declined comment.

The wording of the controversialegreement is unclear..lt sayafederalprosecutOrs would provide .Epstein's attorneys "with a. list ofindivicluals whom it has identified:as yictims," .Miami attorney Robert josefsberg was appointed to


represent any of the victims on the list who wanted to ti pursue Epstein in civil court As !Art of the agreement; Epstein is to pay for JoSefsberg to represent the women.

> Some of the women, most identified as Jane Doe in lawsuits, had:already hired attorneys to represent them. Some have since settled their suits with Epstein, although terms were not disclosed.

Horowitz said he has filed courtpapers to get the journal that Rodriguez stole. 'lt's another piece of evidence that shows our clients were at EpsteirA mansion,' he said.

Rodriguez told'prosetutort he didn't turn over the jo when both.FBI and pain:II:leach polite zslted.for it he wanted money for it. He also said.he.was would make hito uclisappear.a.The infor • told investigators, was his "insurance poli

Helaces a maximum 20'yezrs igjQnalten he is sentenced on June 18.

jane\_inusgtave@pb


# r ale Palm each Post REAL NEWS. STARTS HERE
# Epstein paidthree women \$5.5 million to end underagesex lawsuits
fly Jane:Mtiagraige

Posted Ca 3, 2017 at 12:01 AM

Updated Oct 4, 2017 at 12:46 AM

:Ending years of speculation about how Muth Palm Beach billionaire Jeffs' in paid yOUng women whq claimed he used them as sertoys, court documents filed las wee show he shelled out \$5.5 million to settle lawsuits with three of more than two dozen teens who sued'bim.

N."

Responding to requests from Epstein's attorneys in a compl = it that was spawned by the sex scandal, attorney said:the polititall 64-year-old tthivicted sex offender paid more than S 1, maim to each of the thgg. o Edwards represented.

Identified in court papers only by their initial nyms ;because of the nature of the allegations.and their youthful.ages, L.M. d S million, E.W. \$2 million and Jane Doe S2.5 million, said of the settl negotiated with Epstein to end the lawsuits.

•ere—rgeie

Jack Goldberger, one of Epste defense. attorneys, on Tuesday declined comment on the revelations, citing confide agreementrtharwere part of the settlements. For the .tame=, he decline say tv ether Epstein paid similar anti:aunts to settle roughly two dozen lawsuits filedJby of r Dung women against Epstein, claiming hepaid, them for sex Mr. revere. when some wereyoung as 14 years.old.

Attorney la, who is representing was compelled to divulge the co ' + , said his client I settlements to answer questions posed by'Epstein't• attorneys. "Brilliant move on their p ," he said.

Even if Epstein's attorneys hadn'topened the door, Scarpla said the information would have likely come out: He says the information will.help him undermine Epstein's claims that 'ginned up' the allegations to help his former law partner, imprisoned and disbarred Fort Lauderdale lawyer Scott Rothstein, perpetuate a11.2 billion Ponzi scheme.

successful law firm by forging the names of federal judges and others to persuade had negotiated, settlements in lawsuits against high.profile people. Investors ' tol could get a cut of the cash. Rothstein was sentenced to 50 years in prison in 2010 after admitting hehad bulk his wildly stors he ey

The revelations of the settlements came as part of an ongoing.lawstiitthat started as a dispute between Epstein and Rothstein, both billionaires.

A year after Epstein in 200gpleadecl guilty to-solicitation of prostitution. and procuring a minor for prostitution, he sued Rothstein and claiming they trumped up the allegations bisexual indlestation to-perpetuate the Ponzi scheme.

One of the high-profile people Rothstein used to lure investors was .ccording to a lawsuit Vest Palm Beach attorney Robert Critton filed on Epstein's According to the lawsuit, Rothstein told investors. Epstein, a money manager, had -Ned to settle, the lawsuits with the teens for S200 million — a claim Ctitton descri s "a complete fabrication."

After Epstein dropped the lawsuit in 2012; Edwa t eJtlte tables on him. accused Epstein of filing thelawsuit malicitmilym p r representing the young women. Although was a partner in Rothst defunct firm, Scatolaclaiins Epstein had no evidence was involved in scheme. Federal prosecutors successfully charged other attorneys and mem firm, but was never implicated, Scarola said in the malicious prosecuti

The revelations about th \*hey Epstein paid to three of the young woman came last:week in documents filed four ? s , g uesday -in preparation far a Decernhertrial on the lawsuit.

Attonry a addad Coleman) who represents. Epstein; on Tuesday sought a delay of the trial, itl p because she claimed she has been unable to talk to her client since his estate on his private island in the U.S. Virgin. Islands was. devastated last month:by Hurricane Irma. I've had no ability to communicate with Mr. Epstein; she said.

Pointing out Epsteip's enormous wealth aritthis private jet, Paint Beach County Circuit Judge Donald Hafele rejected her request While saying he didn't want to appear insensitive to those victimized by the Storm that hammered the Caribbean and roared through.South Florida, he said Coleman offered:no proof, such as an affidavit front Epstein, to shore up her claims.

Still,,Hatele.gave Coleman extra.time to respond to various motions that he will have to decide before the case goes to trial:.

Despite Statolis insistence tha W.:nothing to .do with.Rothstein's P0 erne, Coleman. said theevidenceln\_diCates Otherwise. Why else would he. try to de Tinton s wennoWn friends, such as now President Donald Trump, former Presi Hilton and illusionist David Copperfield, she asked. He used the celebrities as a d.

'The Epstein cases were used to.fieece money and defraud inv said.

Edward's:malicious prosecution case has been diffieultio ibecause both.Epstein and have refused to answer questions: As he di lawstiits;Epstein has invoked his.Fifth.Amendment right against Self-incritnin .questionedby Scarola... has claimed that much of the information Ep c' 'xi ng is protected by attorney-client privilege,.

The malicious prosecution lawsuit against Epstein. Edwa the federal Crime Victims Righ Epstein. o hotly-contestedlawsuitsthat continue to pit suing the LILL attorney's office, claiming it violated when it 'negotiated a.nom-prosectition agreement with

Only after fede secut rs agreed to drop their investigation of Epstein, did he agree to plead guiltyl thtion.charges in Palm Beach. County Circuit .Court, In federal court records, p claim one of the key reasons they agreed to drop their case was Epstein's agree tap lawsuits filed against him.by dozens of his underage victims,

# Palm Beach Daily News
# Judge rules Ms' agreement with Jeffrey Epstet pot violated teen victims' rights
By Jane Musgrave

Postated Sep 17, 2019 at at1:62 PM 4

ed Oct 8, 2019 2:31 PM Upd

(EDITOR'S NOTE: nig story originally published in The4•Assa\' Palm Sega Post on ?Omar)! 4 2010)

C) .' Federal prosecutors violated the rights of Jeffrey E C tein's teenage victims by failing to reveal they had dropped plans to prosecute the billionaire on dozens :o connection with the girls' claims at hit Palm Beach mansion,.U:S Marra ruled on.Thursday. arges in em for sex dge Kenneth

Ina blistering 33-pa (sly methodically de prosecutors t young worn they w e:l as iryoung as 14. ng arra. Meticulously and umerous steps federal, the agreement from. more than 40 airn.Epstein paid them. for sex when.

l :: goveroment'spent ontolclhours negotiating the and implications. ofthe NPA with Epstein's attorneys,. ant information was shared with the victims,7.Marra wroteethistead,:the victims weretold to.be.'patient! while the investigation proceeded."

By then, it was too late. A deal had already been. ut with then-South Florida U.S. Attorney Alex Acosta and.Epstein's• attorneys to shelve a.52-page federal indictment against Epstein, a former math teacher netted money manager who counts Presidents Donald Trump and Bill Clinton. among his friends.

Prosecutors failure to alert the young women about the deal violateC1 the Crime Victim? Rights Act, Marra ruled. -At a bare minimum the (act) respired the government; to inform (the young women) that it intended to enter i\* an agreement not. o prosecute Epstein,? he. wrote.

+"We are.treading on virgin ground, to use what is prObably an inappropriate. phrase in this situation," he said.

Still, Marra said he wasn't second-guessing prosecutors decision not to pursue Epstein on.federal.c.harges if he pleacletiguilty tominorstate prostitution charges. and agteed.to cOtripensate his victims for the trauma he-caused.

"The court isnot:Whig that the decision not to prosecute was improper," Marra wrote: `The court is simply ruli that; under the facts of this case, there was a violation. the CVRA.". U

Further, he made no: decision.ahout wha dy should be. He gave prosecutors and a presenting the y.oungw0znert.15 days to inee ct oW to unravel the complex. legal.web that ging over Epstein and his young victims for i e a decade.

The c.hances. an ac reached are slim, said attorneyfack St is representing the two Jane Does Who ct Ilan e prosecutors' actions,

Furthe said, there is no road map to follow, The ly+ttsuit orney filed on behalf of the "MO entified young women., claiiningpintetutbil violated e edgral ant, is. unique, he

Scarola said he and will ask that the non: prosecution agreement be thrown out:That would open the pnssibilitythat the long-shelved federal indictment could be dusted offend filed against rhe 66-yen-old • Epstein, who spends most of his time on .a private island he owns in thell..5. Virgin Islands.

f

"I don't seethe government 'conceding to thatremedy,": Scarola admitted. Further, he said, it is likely:Epstein. will be allowed to weigh in.. Miami attorrity'Roy Slack years ago filed papers asking to intervene on Epstein's behalf.

The U.S. Attorney's Office said it wouldn't continent Marra's ruling. Neither Black .norNew.. York City attorney Jay Lefkowitz,who led efforts to. bury the federal indictment, responded to ernaile or phone tails for continent. WestPalm Beach attorney Jack Goldberger, who represents •Epetein,:ajw didn't respond.

Scarola said it is likely Epstein 'S stamstudded legal team argue that Epstein fully complied with the .terms of agreement he made in 2007 with federal prosecut therefore the agreement can't beundone,

As he promised,. Epstein pleaded gull 'SI: 8 w state charges of soliciting a minor'for p and soliciting prostitution. He served 18- mo an 18-month jail term in a vacant wing of the co de that he was allowed to leave 12 hours a da eek.

4

Further, as ag settlements to the young women who sued h' e settlements were confidential, court records heinidthree women a total of \$5.5

turn, federal prosecutors held up their end of the ;gain. Their investigation ceased.

Having done all that prosecutors asked of him, Scarola said Epstein will make a simple argument: "You can't turn around and deprive me of the benefits I bargained for.."

However? Scarola said, using Marra's ruling, he will counter that the contract Epstein signed was illegal and therefore unenforceable.

Even if Marra agrees tb toss dutthemon-prosecution ! agreement, Scarola conceded that doesn't mean Epstein; will face federal charges.

"The contact can be set asideAnd:the federal governmnt ari attempt to enter into the same ,agreetottehe

Tacceptthe spotlight of public attention:will be on them and the 40 victims will be. able to explain to the:court. why this sweetheart deal should not be .approved.'

Scarola said that ptosecuton May have had good teasbh not to pursue• Epstein. 'There pay be a reasonable explanation but we don't:know whatthatreason may have' been," h said.

In court papers) federal prosecutor's have said rat Cri - of the young women were• afraid to cross•tbe I, politically connected money'manager. refusedto testify against hint.

In other cases; they said, tli hanged. their 'stories:: Jane Doe 2, who .is tryin non-prosecution agreement thrown y described Epstein as 'an awesome -man" osecutors she hoped "nothing happens` to e she later agreed to testify against Epstein"pr said they feared Epstein's attorneys would t r words to destroy her if she ever took the

Ot a,. however, said the yogrtg..W4M.414 comments didn't can she wasn't entitled to know about the prosecutors' plans to drop the charges. "mete is no dispute that:Epstein sexually abused Jane Doe 2 while she wan. minor? he wrote: 'Therefore, regardless of her:comments to the proSetutot, she was a -victim!'

Before: he case is finally resolved, Scarola predicted that "a lot of people.are going to have to answer a lot of questions."

In his ruling, Marra detailed whatappeared to be.a cozy relationship between Acosta, his line prosecutors and Epstein's team of lawyers.: His phalanx of lawyers included noted Harvard law professor Alan Dershowitz and Kenneth Starr, the former U.S. solicitor general whose investigation led to: the impeachment of President Clinton.

Marra describes. an October 200Y breiktast meeting between Acosta, who.is now US. labor secretary;.and Lefkowitz shortly. after the non-prosecution•agreeinent was inked,

After the meeting, Lefkowitz sent Acosta .a note than .him for "the -commitment you made to me duringo October 12 meetingin which you assured me that Office weuld not .., contaCtany of the Men individuals, potential witnesses, or pote and their respettiVe counsel in this

Mutt quotedan equally pleas County State Attorney.Ba Attorney Villaf Epsteiti's Case. t reasontl won' CI .. after the non ros • to en-Palm 5eaCh r sent to Assistant U.S. as the lead prosecutor in get this worked out for Ong," •Kriseher wrote, shortly ion agreement was signed. "After this itresol ettl wo love to. buy you a tupit Starbutks and have a c sation.'

f the notes that were exchanged dealtwith osecutors' and Epstein's lawyers shared desire to keep the deal secret from Epstein's accusers. In a September email, Villafana asked Lefkowitz; for guidance about what she should reveal. And tart we- have a conference call to discuss. what I may disclose to ... the girls regarding. the Agreement," she asked.

Such cooperation between prosecutors and defense , attorneys. is unusual, Marra said. It was a deviation from • the government's standard practice to negotiate with defense counsel about the extent of crime victim. notifications: he wrote.

Ftirther;he noted, that when and his two young clients:asked.for information, they were repeatedly misled: "The.CRVA. was designed to ptOtettcrictirhe tight and ensure their involvement in the criminal justice process; Marra wrote. "When the government gives information to vittiint it Cubit& be misleading.'

Ultimately; the terms of the non-protectition agree were revealed only after and attorneys fo press successfully sued to make them public.

jthusgrave@pbpost.corti

iS )

@pbpeourts

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 manager's appearance in U.S. District Court in New York City capped more than a decade of recriminations by young women 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 traffic. Epstein paid dozens of young women to give him nude massages that, for most, led to sex, he said.

If convicted of exploiting dozens 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.

"We think he's a significant flight risk," Berman said of the man who ferried Britain's Prince Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former President Bill Clinton on his jet, dubbed the Lolita Express.

Berman's hard-line stance was welcomed by young women who for years have been told that Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement, promising not to charge Epstein in federal court.

Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning her into his sex slave and forcing her to have sex with others, including Dershowitz and Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she told the Associated Press. Dershowitz has vehemently denied Guiffre's claims.

New York prosecutors were able to ignore the controversial nonprosecution agreement because it contained some significant fine print, said former federal Judge Paul Cassell, who for years has fought to get the agreement thrown out. It says only that no charges could be filed against Epstein in South Florida, he said.

Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of Florida," he said. "The Southern District of New York is not bound by that agreement and wasn't a signatory of it."

That means the sordid allegations that have been leveled at Epstein for years are now part of a federal indictment.

Contrary to Epstein's claims, he knew the women who came to his homes in New York and Palm Beach were minors because they told him their ages, according to the indictment. Epstein preyed on young girls because he knew they were "vulnerable to exploitation," prosecutors added.

As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while he was in New York so they would be available for sex once he returned to Palm Beach, the indictment says. The employees weren't named. They were identified only as "Employee-1," "Employee-2" and "Employee-3."

To ensure he had a steady stream of young girls, Epstein would turn some victims into recruiters. He would pay them to bring new girls to his home on El Brillo Way along the Intracoastal Waterway in Palm Beach or to his palatial townhouse on New York's Upper East Side.

"This allowed Epstein to create an ever-expanding web of new victims," Berman said.

In both New York and Palm Beach, the lurid operation was similar. Unidentified employees of Epstein's would escort the teens into a room. They were told to take off all or most of their clothes before giving the naked billionaire massages, according to the indictment.

"Epstein would also typically masturbate during these encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys," the indictment says.

As part of the criminal complaint, prosecutors are asking that Epstein be forced to turn over his multimillion-dollar townhouse on East 71st Street. The complaint does not seek forfeiture of Epstein's house in Palm Beach.

While heartened that Epstein now faces serious criminal charges in New York, Cassell said he would continue to push a West Palm Beach-based federal judge to throw out the nonprosecution agreement that Acosta forged with Epstein's star-studded legal team.

U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked. Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight Monday, explaining what action Marra should take to redress that wrong.

Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein's victims with attorneys [REDACTED] 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 wants to know how and why the agreement was reached.

"There's been no explanation as to how a deal like this could have been cut and how the federal government could have been involved in a conspiracy to violate federal law," Scarola said of his interest in continuing the legal battle over the nonprosecution agreement.

When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He was also forced to register as a sex offender and settle civil lawsuits more than 30 young women filed against him.

U.S. Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out how the agreement came to be. "I am especially more interested in why Epstein got the deal he got," Frankel said. "We need to know why he was given such an easy sentence.

While she has asked the House Oversight Committee to investigate Acosta, Frankel said she is not sure that will happen. "It just seems to me it was a travesty that this guy got off the way he did and, without pre-judging it, let's have a proper court case," Frankel said.

Former Palm Beach Police Chief Michael Reiter was inflamed in 2006 when then-State Attorney Barry Krischer refused to charge Epstein with serious crimes. Reiter took the information his officers had gathered from dozens of Epstein's victims to Acosta, believing he would prosecute Epstein. He didn't.

Reiter said he was heartened that 13 years later, Epstein will finally face justice.

"Thankfully, U. S. Attorney Berman and the other authorities in New York have the good judgment to investigate and prosecute Epstein in the way that should have occurred in Florida over a decade ago," Reiter said in a statement.

And, Scarola said, there are signals that Berman's investigation is far from over. Berman declined to answer questions about whether others, such as Epstein's high-powered friends, would be charged. He brushed off questions about the significance that the investigation was being handled by the Public Corruption Unit.

While agents on Saturday were arresting Epstein aboard his private jet at the Teterboro Airport in New Jersey after returning from Paris, other officers were searching his New York City townhouse. Agents seized nude photos of young girls who appeared to be minors, Berman said.

He said his focus was on finding more women who were exploited and abused by Epstein. Turning to a poster, detailing the charges that had been filed against Epstein, he pointed a finger at a photo of the convicted sex offender who was once described as "a man of mystery."

"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you,"

Berman said. A special number, 1-800-CALLFBI, will link victims of authorities.

Bill Sweeney, assistant director of the FBI's New York office, said after years of being ignored by federal agents, the victims' voices will be heard.

"The Jeffrey Epstein matter is No. 1 on the major case list in the country," Sweeney said.

Turning to address Epstein's victims directly, he said: "Your bravery may empower others to speak out against crimes against them."

jmusgrave@pbpost.com