IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CA FLORIDA HOLDINGS, LLC, Publisher of THE PALM BEACH POST, CASE NO.: 50-2019-CA-014681-XXXX-MB Div.: AG Plaintiff, v. ABRUZZO, as Clerk and Comptroller of Palm Beach County, Florida, Defendant. # SECOND AMENDED COMP A Cos CA Florida Holdings, LLC, publisher of The P ea r Post, for its Second Amended Complaint against Abruzzo, the Clerk rt and Comptroller for Palm Beach County, Florida, in his official capacity ("C qc Cle ), alleges as follows: # ICTION - I. This is an action}r4tlI jE exclusive jurisdiction of the Circuit Court pursuant to Fla. Stat. Sections 26.012(2Xa) .011 et seq. # PARTIES - 2. Beach Post is a daily community newspaper published by Plaintiff CA Florida ,.H . C, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida. - 3. Defendant Abruzzo is the duly elected Clerk and Comptroller of Palm Beach County, Florida. He is sued herein in his official capacity as his office is in possession and/or control of documents that are the subject of this action. # INTRODUCTION 4. In what is now widely if belatedly recognized as a colossal miscarriage of justice which led to the further needless victimization of countless young girls and women — a wealthy, politically connected, and powerful financier was not held accountable for, nor even forced to confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein's 2008 deal with the State of Florida was not consistent with the evidence gathered a im, what remains shrouded in mystery is how that evidence was presented — and the o which it was presented — to the grand jury that returned an indictment far more li pe than expected and deserved. 5. Through this action, The Palm Beach Pos lic access to the testimony, minutes, and other evidence presented in 2006 to Ils e ch County grand jury empaneled during the first Epstein sex abuse investigatio , access to such materials is limited, for example, in order to prevent the flight o ability to conceal or destroy evide accused who is later exonerate expressly authorizes the • losure of grand jury proceedings under certain circumstances, including, as here furthe ng justice, which can encompass furthering a public interest. Fla. Stat. § 905.27(1)( se indictment may be contemplated and their re jurors' candor in deliberations; and to protect an er, these factors are inapplicable here. Also, Florida law t 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 with the solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those who chose to give Epstein favorable — "unusual," in the words of the Town of Pa h Police Chief — treatment, are exposed and held accountable. From what limited inf is now in the public domain, the State Attorney's referral of Epstein's case to the out of the ordinary for this type of case — gives rise to a i) s in'T nce of favoritism and corresponding disregard for the rights of the minor victim 's sex trafficking. Access to the grand jury materials will allow the public to dete inner the grand jury process, and the secrecy that comes with it, was used to furthe s Ste• e , instead, operated to shield Epstein and his co-conspirators from the conseque of it criminal activities. Accordingly, Fla. Stat. Section 905.27 authorizes the disci yb pstein's 2006 grand jury proceedings. which would be # FACTUAL BACKGROUND 7. The folio acts were gathered, in large part, from documents obtained by The Palm Beach Post ugh rious Florida Public Records Law requests, documents unsealed or publicly ava ther related judicial proceedings, and information and documents in the public # A. First Epstein Sex Crimes Investigation, Indictment, and Plea tut-cement: 2005-2008. 8. The investigation into Epstein's sex crimes began more than fourteen years ago, when a 14-year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid \$300. Epstein was 52 years old at the time. 9. 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. 10. Both the victim/witness interviews, as well as evidence retri owing a search of Epstein's home, showed that some of the girls involved were un of 18. The police search of Epstein's residence also found two hidden cameras O ghout the house, large numbers of nude photos of girls, including victims who Ae e had not interviewed in the course of their investigation. 11. In March 2006, a State grand s• 84c eeduled at which all of the victims were expected to testify. The proceeding was tpon , however, due to meetings between the State ( od Attorney's office and Epstein's pr4pjn minal defense lawyer and personal friend, Alan Dershowitz. 12. Another gr> jyljy was convened in April 2006, but canceled the day before it was to begin receivin # (1) Police Chief Reiter's Letter to the State Attorney. n May I, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a "personal and confidential" letter to then Palm Beach County State Attorney, Barry Krischer, stating: I must renew my prior observation to you that I continue to find your office's treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to communicate in this manner, but my most recent telephone calls to you and those of the lead detective to your assigned attorneys have been unanswered and messages remain unreturned. After giving this much thought and consideration, 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. (Emphasis supplied) 14. 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 ini against him, which would be public. charges # (2) The July 2006 State Grand Jun Presentati 15. Instead, State Attorney Krischer elected to refer cas'itit4 grand jury, which is mandatory for capital cases but rarely used for all of c . According to an official spokesperson, this was the first time that a sex crime, presented to a grand jury in Palm Beach County. 16. In July 2006, after State ine aischer presented testimony and evidence from one victim, the grand jury return n n ent on a sole count of solicitation of prostitution. There is no mention in the indi en the victim being a minor. 17. On info mic• and i belief, a second of Epstein's victims was supposed to testify before the grand j , but z unable to attend because of a school exam. 18. m asbnable explanation has been provided as to why the numerous other known victim t presented as witnesses and crime victims to the grand jury convened in July 2006. Nor has an reasonable explanation been provided as to why State Attorney Krischer, who was initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do so. 19. On information and belief, during the grand jury appearance of the single victim who testified, the State Attorney presented evidence that vilified the victim and attacked her credibility, including soliciting testimony regarding underage drinking and questionable personal behavior that was unrelated to the charges against Epstein. Further upon information and belief, this information was initially brought to the attention of the State Attorney's office by Epstein's defense counsel. # (3) The FBI's Investigation and Epstein's Non-Prosecution Agreement With Federal Authorities. 20. On information and belief, following the deficient July 2006 i and with Chief Reiter's encouragement, the FBI began its own investigation of E 21. Records unsealed in 2015 revealed that the FBI comp rts on "34 confirmed minors" that were victims of Epstein's sexual predations. B idence gathered by the FBI, a 53-page indictment was prepared by the U.S. Attorn \ in June 2007. However, at the request of Epstein's lawyers, the indictment was \ CCIth,,re nted to a federal grand jury. 22. Instead, then U.S. Attorney e So ern District of Florida, Alexander Acosta, negotiated a plea deal with Epstein's wyers to grant immunity to Epstein (along with four named co-conspirators and ed potential co-conspirators) from all federal criminal charges. 23. Thro remainder of 2007 and through the first half of 2008, Epstein's lawyers and th mey continued negotiating the plea arrangement. Upon information and belief, E wyers insisted that (I) the victims not be notified, (2) the deal be kept confidentt d under seal, and (3) all grand jury subpoenas (including one that had already been issued for Epstein's computers) be withdrawn. 24. On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was sentenced to 18 months in jail, followed by a year of community control or house arrest, and was adjudicated as a convicted sex offender required to register twice a year in Florida. 25. 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 conlmtunicated with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's 26. Indeed, Epstein was not incarcerated in a Florida prison f IO to crimes for which he was convicted. Instead, he was placed in a private wing m Beach County Stockade, where, after 3 la months, he was allowed to leave t' ork release" for up to 12 hours a day, 6 days a week. His private driver provide 3( t )l b 'nation to and from "work." 27. Epstein was released five months ear t . i 28. Upon information and belief, c, 14s t , lated the terms of his probation, but was not prosecuted. # (4) The Ctj P.V,hims' Rights Act I itioatioti. 29. Epstein's victin4onlylldarned after the fact about his plea in State court and filed an emergency petition to il federal prosecutors to comply with the Crime Victims' Rights Act (18 U.S.C. § 377 VRA , which mandates certain rights for crime victims, including the right to be inform lea agreements and the right to appear at sentencing. U.S. District Judge Kenne recently ruled that federal prosecutors violated the CVRA by failing to notify Epstein's victims before allowing him to plead guilty to only the two State offenses. 30. The prosecution's failure to keep the victims apprised, among other things, also contravenes the Florida Constitution, Article I, § 16(b) and Fla. Stat. § 960.001. 31. Following publicity exposing the extraordinary leniency of the plea deal, dozens of civil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court. 32. 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." 33. 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 wl vestigated the case against Epstein. AS 34. Upon information and belief, Epstein's victims were t with law enforcement and told that they would be compensated if did not cooperate with law enforcement. Qainst cooperating # B. Second Epstein Sex Crimes Investin S i ment. Suicide: 2019. 35. On July 6, 2019, Epstein was a ederal sex trafficking charges. 36. Upon information and be ited States government's investigation of new allegations and charges stemmed, • continued press investigations into and reporting on the mishandling of the 2006 harg and the civil suits that followed. 37. In a July r,9, letter to the federal district court by the U.S. Attorney for the Southern District ew rk, Epstein was described as "a serial sexual predator who preyed on dozens of mi or g s over a period of years." The letter emphasized that "the Government has real conce nded in past experience with this defendant — that if allowed to remain out on bail, the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case, including victims and their families, and otherwise attempt to obstruct justice." It also described the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex trafficking in the form of "hundreds — and perhaps thousands - of sexually suggestive photographs of fully- or partially-nude females," including underage females. In a locked safe, compact discs were found with handwritten labels including the descriptions: "Young [Name] + [Name]," "Misc nudes 1," and "Girl pies nude." 38. 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 underag girls were brought into Epstein's mansions for sexual encounters. A few days later, owin lic outcry over the NPA with Epstein entered into by the U.S. Attorney for the Sout I j ct of Florida, Alexander Acosta, who by then was serving as U.S. Secre r in the Trump administration, resigned from office. 39. Epstein was denied bail and was place IC In o ,) ial detention at the federal Metropolitan Correction Center in lower Manhatta t 40. On or about August 6, 2019, F S n Ssr , . Ron DeSantis ordered a state criminal probe into the actions of the Palm B hen and former State Attorney Krischer for their handling of the Epstein underage s ng case. 41. On August 10, pstein was found dead in his cell at the Metropolitan Correctional Center. His f death was determined to be suicide. # C. The st 27. 019. SDNY Hearing: Epstein's Victims Speak. 42. On ccount of his death, prosecutors sought to dismiss the indictment against Epstei aintaining that they would continue to investigate his co-conspirators. 43. United States Senior District Judge Richard M. Berman ordered a hearing on August 27, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to speak at the hearing. 44. 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. 45. 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 [thy] preferred vehicle of resolution," emphasizing that "public hearings are exactly what jud Hearings promote transparency and they provide the court with insights and info ich the court may not otherwise be aware of." Indeed, even Epstein's defense laµ t the hearing that the court "is the institution that most people have confidence in ' e ery troubled times." 46. At the August 27th hearing, the girls, now o e ke about their "exploitation and coercion," and to the fact that many of them "we 'nive S ulnerable situations and in extreme Av poverty, circumstances where [they] didn't ne on [their] side, to speak on [their] behalf...." One victim lamented that " icti she] never got to see what the agreement was or why the special treatment got n the Florida case years earlier. Another noted how "completely different" the inv tiga leading to the 2019 federal indictment were from the prosecutors in the Flori g , both in their treatment of her and their investigation of her victimization by em. 47. er federal judge in attendance at the August 27th hearing emphasized that "trans one of the overriding objectives in our criminal justice system." 48. Nearly all of the victims expressed the conviction that the secrecy that shielded Epstein has caused them "irreparable harm" and that an opportunity to address his criminal wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for at least some measure of justice to be served after his death. Indeed, one victim stated: "Any efforts made to protect Epstein's 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 tjre criminal justice system. # D. The Palm Beach Post's Standing and the Public Interest. # (1) The Palm Beach Post Has Reported ENO's'0 1n Epstein's Crimes For Nearly 15 Years.14. / ) 49. Plaintiff, The Palm Beach Post, is a communi aper serving readers in Palm Beach County and the Treasure Coast vicinity. 50. The Palm Beach Post has been a three other times. Er P ie winner and nominated as a finalist 51. Beginning in 2004, The ch Post has extensively investigated and reported on the allegations against, the I ment investigation of, and the crimes committed by, Epstein and his co-conspirato e Newspaper's reportage has included publication of the following articles: - "Th- 4 o Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends a gators Say, Underage Girls.," published on August 14, 2006, reporting that: Aik obson, a local community college student, admitted in a sworn statement to \*ce that "she had taken at least six girls to visit Epstein, all between the ages of 14 d 16;" Palm Beach Police "interviewed five alleged victims and 17 witnesses;" Dershowitz, the Harvard law professor, traveled to West Palm Beach with information about the girls," including social media discussions about "their use of alcohol and marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their decision to take the case to a grand jury;" Palm Beach Police subsequently "received complaints that two of the victims or their families had been harassed or threatened;" "relations between police and prosecutors were fraying" as the investigation continued; and "one girl who was subpoenaed — the one who said she had sexual intercourse with Epstein — never showed up" to testify before the grand jury. - "Trump Snags Gosman Estate for \$41 Million" published on November 16, 2004, reporting on the bidding war between Donald Trump and Jeffrey Epstein for the purchase of a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along the storied 'Raider's Row' " in Palm Beach. - "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 suspect rostitution johns are usually charged with a misdemeanor, and even a felony ch typically made in a criminal information — an alternative to an indictment ch n with the commission of a crime." - "After Long Probe, Billionaire Faces Solicitation Charge" n July 26, 2006, reporting that "Palm Beach police thought there was prob le c use to charge Epstein with unlawful sex acts with a minor and lewd and las estation." The article further reported that "Police Chief Michael Reit • angry with State Attorney Barry Krischer's handling of the case that he mo suggesting the county's top prosecutor disqualify himself," and ide year-old on-the-record female source who said "she gave Epstein a nude, then brought him six girls, ages 14 to 16, for massage and sex-ting st s at his home." - "Police Say Lawyer Tried to D nage Girls" published on July 29, 2006, reporting that "[f]amed Harv: fessor Alan Dershowitz met with the Palm Beach County State Atto ice and provided damaging information about teenage girls who say his client, Palm Beach billionaire Jeffrey Epstein, sexually charged mas that "[t]he state attorney's office said it presented the Epstein case to a c' d jury this month rather than directly charging Epstein because of concerns the girls' credibility." - rye f Age Isn't Defense In Sex Cases" published on August 5, 2006, at ather than file charges, the state attorney's office presented the case grand jury" which "indicted Epstein last week on a single, less serious f ony solicitation of prostitution," and that "[t]he case raised eyebrows he state attorney's office rarely, if ever, kicks such charges to a grand jury." "Expert: Igno reporti to a u tein Camp Calls Female Accusers Liars" published on August 8, 2006, reporting at "[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 I, 2008, reporti t "Epstein, 55, pleaded guilty ... to felony solicitation of prostitution and procu r a pe n under the age of 18 for prostitution," resulting in "a lifelong obligati offender," and that "[a]s part of the plea deal, federal investiga investigation of Epstein, which they had taken to a grand j - "Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit J ycoon" published on August 13 2008 reporting that "[d]uring his first f confinement" Epstein was visited by , who allegedly escort pon their arrival at his Palm Beach waterfront home to an upstairs room, repared the masse e table and provided the oils for their encounters" p n, and by "a young woman whom Epstein purport as his Yugoslavian sex slave." gister as a sex to drop their - "Billionaire Sex Offender Leave ays a Week For Work" published on July I, 2008, reporting that Epstein' a ed to leave the Palm Beach County Stockade six days a week on a work- - "Women Want Epste\* al Unsealed" published on June 10, 2009, reporting that attorneys for w ens g Epstein in various courts "want his [non-prosecution] agreement [NPA] f eral prosecutors unsealed" and were moving to unseal the agreement in 'rcuit ourt of the Fifteenth Judicial Circuit, and that "Epstein now faces at least a doze lawsuits in federal and state courts filed by young women who said they'had s with him and now are seeking damages." On that date, The Palm Beach Past moved to intervene in the matter for the purpose of obtaining public access toc N PA. which was ordered disclosed by this Court on June 25, 2009. - stein's Secret Pact With Feds Reveals 'Highly Unusual' Terms" published on ember 19, 2009, reporting that, owing to Epstein's non-prosecution agreement, eral prosecutors backed down and agreed to recall grand jury subpoenas if Epstein pleaded guilty to prostitution-related felonies in state court" and "also a reed not to charge any of E stein's ssible co-conspirators: ==, Lesley Groff and " 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 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." - "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 Law published on October 4, 2017, reporting that, according to court documents, "yelled out \$5.5 million to settle lawsuits with three of more than two dozen ho sued him." - "Judge Rules Feds' Agreement With Jeffrey Epstein Pa Teen Victims' Rights" published on February 22, 2019, reporting on a ling y U.S. District Judge Kenneth Marra that "Federal prosecutors violated the of Jeffrey Epstein's teenage victims [under the Crime Victims' Right .y failing to reveal they had dropped plans to prosecute the billionaire on d decal charges in connection with the girls' claims that he paid them for s m Beach mansion." - "Epstein Indicted On Sex Charges/P i Beacher Pleads Not Guilty to Sex Trafficking, Conspiracy Charges In a ourt In Manhattan" published on July 9, 2019, reporting on Epstein's ap ce .S. District Court for the Southern District of New York in which he "plea n ilty to charges accusing him of creating a vast network of girls as young at e exploited for his sexual pleasure at his homes in Palm Beach and A true and correct copy of the a articles, in either the computerized format in which they are maintained in The P r Beac z Post's electronic archives or the news print edition in which originally publishe ann ed hereto as Exhibit 1. 52. e filing of the initial Complaint in this matter, The Palm Beach Post — along with m is ide — has continued to report on Epstein's crimes and the ongoing official proceeding resulting from those crimes. # (2) The Palm Beach Post's Standing and the Public Interest. 53. The press has a constitutional right of access to criminal proceedings, see, e.g., Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal proceedings. v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the integrity of the judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Publ. Co. v. M, 426 So. 2d 1,6-7 (Ha. 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 protecti Th orded [by the First Amendment] is to the communication, to its source and to its reci • h."); Pittman v. M, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme ognized that the First Amendment offers protection to both speakers and those receive speech."); see also Stephens v. Cry. ofAlbemarle, Va., 524 F.3d 485,492 t C 1 08) (providing that a plaintiff has "standing to assert a right to receive speech" by ' S o 4c, that there exists a speaker willing to convey the information to her"). 54. Because of the unique ro rfo by the press as a "public surrogate" (M, 426 So. 2d at 6-7) in protecting t ccess and its interest in reporting information about criminal proceedings, news or s "presumptively have a right to access judicial records," Comm ir, Ala. Dep't of C 0,74,dvance Local Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019), and "standing to lion t e validity of an order restricting publicity because its ability to gather news is dire 'red or curtailed." 426 So. 2d at 4; see also Carlson v. United States, 837 F. 57-58 (7th Cir. 2016) ("[a]s a member of the public, [the Reporters Committee] has standing to assert [its] claim" to grand jury materials because such materials are "public records to which the public may seek access, even if that effort is ultimately unsuccessful"). 55. Here, the continued denial of access to information The Palm Beach Post seeks on behalf of its journalists and the public it serves "unquestionably constitutes irreparable injury." Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also Zerilli v. 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). 56. The Palm Beach Post has the right to maintain this private right o • because the furtherance of justice, an express legislative exception to grand jury intended for the public benefit, and The Palm Beach Post seeks access on be Ct, public. Fla. Stat. § 905.27(1Xc). It is further expressed in Fla. Stat. § 905.27 the 1 ature in amending Fla. release of the Jeffrey Epstein Stat. § 905.27(1)(c) and (2)(c) in 2024, intended for this t e Jeffrey Epstein grand jury materials. In other words, the legislature cleared all grand July materials. # K e\- (3) The Court's Jurisdiction "I o Declare Rights And Constru }times. ," 57. This Court has C• to declare rights, status, and other equitable or legal relations whether or not further • is or could be claimed. Florida Stat. Section 86.011. 58. Flori a law pe ifically provides that a declaration may be sought from the Court concerning a rights under a statute. Florida Stat. Section 86.021 ("Any person...whose rights, sta er equitable or legal relations are affected by a statute, or any regulation made under sta ry 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."). 59. The Court's exercise of its power to declare rights "is to be liberally administered and construed." Florida Stat. Section 86.101. # COUNT I (Declaratory Relief - Florida Stat. Sections 86.011 et seq.) 60. The allegations set forth in paragraphs 1 through 59 are incorporated by reference as if fully set forth herein. 61. This is an action for Declaratory Relief pursuant to Chapter 86. Florida Statutes, and other supplemental relief. Ailk" 62. The Palm Beach Post respectfully requests that the Court uant to Fla. Stat. Sections 905.27(1) and (2)(c) that it is entitled access to the t tmo mutes, and other evidence presented in 2006 to the Palm Beach County grand c' b to se such disclosure and access would be furthering justice in the public interest. F ta 5.27(1)(c). 63. The Palm Beach Post has sought o7fhe testimony, minutes, and other evidence presented in 2006 to the Palm Beac nd jury. A good-faith dispute exists. 64. Through this Complaint, Pal each Post presently has a justiciable question concerning its rights to obtain t 905.27(1) (c) and (2Xc). nd jury materials pursuant to Fla. Stat. Sections 65. In an appe the final judgment entered on December 21, 2022 in this case, the Fourth Distri Appeal reversed the trial court's decision that Florida courts lack authority to e release of grand jury materials. Rejecting the trial court's determination, the appell eld that trial courts have inherent authority over grand juries and have the right to order release of grand jury materials if such would further justice as defined in Fla. Stat. section 905.27. CA Fla. Holdings, LLC v. Aronberg, 360 So. 3d 1149 (Fla. 4th DCA 2023). Therefore, this court has inherent authority to release the Epstein grand jury materials in addition to the statutory authority granted by the 2024 amendments to Fla. Stat. section 905.27. 66. A bona fide, actual, present, and practical need for the declaration exists in order to further justice in the public interest by the release of the 2006 Epstein grand jury materials. WHEREFORE, The Palm Beach Post respectfully requests that the Court determine the rights and obligations of the parties by declaring that pursuant to Fla. Stat. Sections 905.27(1)(c) and (2)(c). The Palm Beach Post and the public may gain access to the testimony. # COUNT II, atk" (Florida Stat. Section 905.27) 67. The allegations set forth in paragraphs I through 66 a i gr ted by reference as if fully set forth herein. 68. Based on information learned by The Pal t a ost through its Florida Public Records Law requests, law enforcement sources wit /SS, i owledge of the grand jury evidence and proceedings, judicial documents obtained • endent but related court proceedings, and , S documents otherwise available in the \*c rd, the 2006 State Attorney for Palm Beach t o County, Barry Krischer, present t evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manne luded Epstein's indictment for the serious crimes he committed, including sex ing and sexual assault. 69. t to lorida Stat. Section 905.27, as amended in 2024, in order to further justice for E u tein victims and the public, and to provide public disclosure to illuminate whether Epstei unjustifiably lenient treatment based on the available evidence, The Palm Beach Post requests that it and the public be granted immediate access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury. 70. In 2024, the Florida legislature amended Fla. Stat. Sections 905.27 (1)(c) and (2Xc) for the express purpose of removing all legal impediments to the release of the Jeffrey Epstein grand jury materials. Therefore, other than for limited redactions to protect witness and victim identities, Fla. Stat. Sections 905.27 (1)(c) and (2Xc) compel disclosure of the Epstein 2006 grand jury materials. WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla. Stat. Sections 905.27(1)(c) and (2)(c), as amended, order the Clerk of the Court to provide copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beaty grand jury during the first Epstein sex abuse investigation so that, following a . a inspection, these materials are immediately disclosed to the newspaper, and C an 0 other and further equitable or legal relief the Court deems just and proper. Dated: May 17, 2024 Respectfid s b , RAURIG, P.A. f CA Florida Holdings, LLC, of The Palm Beach Post hen A. Mendelsohn, Esq. 5100 Town Center Circle, Suite 400 oca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099 /s/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 mendelsohns law.com FLService@gtlaw.com By: /s/ Michael J Grygiel MICHAEL J GRYGIEL (Pro Hac Vice application forthcoming) 54 State Street, 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518) 689-1499 grygielm@gtlaw.corn Nina D. Boyajian NINA D. BOYAJIAN (Pro Hac Vice application forthcoming) 1840 Century Park East, Suite 1900 Los Angeles CA 90067 Telephone: (310) 586 -7700 Facsimile: (310) 586 -7800 boyajiatm®gtlaw.com riveraal@gtlaw.corn Go # EXHIBIT 1 # The Palm Beach Post REAL NEWS STARTS HERE # The Man Who Had Everything: Jeffrey Epstein craved big homes, elite friends and underage girls By Andrew Marra Posted Jul 17, 2019 at 6:02 AM From the archives: When Palm Beach detectives start skmg questions and teenage girls started talking, a wave followed. resistance Editor's Note: This article appeared in The Palm Beach Post on , 2006, three weeks after Jeffrey Epstein's arrest in Palm Beach County on a charge olicitation of prostitution. WINGED GARGOYLES guarded the gate at Palm Beach mansion. Inside, hidden cameras trolled two rooms, while t Is me and went. For the police detectives who siftedfotTie garbage outside and kept records of visitors, it was the lair of a troubling targe Epstein, one of the most teriot s of the country's mega-rich, was known as much for his secrecy as for his love of fi t ngs: magnificent homes, private jets, beautiful women, friendships with ttk orld's elite. But at Palm regular a favors. lice headquarters, he was becoming known for something else: the teenage girls he hired to give him massages and, police say, perform sexual Epstein was different from most sexual abuse suspects; he was far more powerful. He counted among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along with some of the most prominent legal, scientific and business minds in the country. When detectives started asking questions and teenage girls started talking, a wave of legal resistance followed. # » NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during workrelease If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough. Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends quietly, always in the background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman e was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robe In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Se , the British Mail on Sunday tabloid laid out speculative stories that the socialit s beap was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?" the newspaper won cl%e A4c)a e Maxwell, Epstein is both flamboyant and intensely private." 'rJee ter. lIn September 2002, Epstein was The media frenzy did not begin in full until flung into the limelight when he flew CI' Africa on his private jet. actors Kevin Spacey and Chris Tucker to Suddenly everyone wanted to published lengthy profiles. The bachelors and began descr and "reclusive." Epstein was. New York magazine and Vanity Fair ork Post listed him as one of the city's most eligible im in its gossip columns with adjectives such as "mysterious" Although E s a no interviews, the broad strokes of his past started to come into focus. # Building e of extravagance He was born blue-collar in 1953, the son of a New York City department employee, and raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree but became a math teacher at the prestigious Dalton School in Manhattan. The story goes that the father of one of Epstein's students was so impressed with the man that he put him in touch with a senior partner at Bear Stearns, the global investment bank and securities firm. In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J. Epstein and Co. That is when he began making his millions in earnest. Little is known or said about Epstein's business except this: He manages money for the extremely wealthy. He is said to handle accounts only of \$1 billion or greater. It has been estimated he has roughly 15 clients, but their identities are the subject of only speculation. All except for one: Leslie Wexner, founder of The Limited retail chai A and , a former Palm Beacher who is said to have been a mentor to Epstein. Wexner sold Epstein one of his most lavish residences: a massive townh block on Manhattan's Upper East Side. It is reported to have, amon c • s) circuit television and a heated sidewalk to melt away fallen snow. at dominates a eatures, closed- That townhouse, thought to be the largest private residen hattan, is only a piece of the extravagant world Epstein built over time. In New Mexico, he constructed a 27,000-square iltbp mansion on a 10,000-acre ranch outside Santa Fe. Many believed it to be the e in the state. In Palm Beach, he bought a waterfrontito n El Brillo Way. And he owns a 100-acre private island in the Virgin Islands. # » PHOTOS: The players in t frey Epstein saga Perhaps as remarkab the highest echelo media moguls funds. lavish homes is his extensive network of friends and associates at ower. This includes not only socialites but also business tycoons, ans, royalty and Nobel Prize-winning scientists whose research he often 'Just like other people collect art, he collects scientists," said Nowak, who directs the Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of a \$30 million research donation from Epstein. Epstein is said to have befriended former Harvard President Larry Summers, prominent law Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher 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 rich. "I wasn't even aware of him," except for a Vanity Fair article. Epstein's friendship with Clinton has attracted the most attention. Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to in him at an intimate fund-raising dinner in Palm Beach. But from all appearances, the i become close friends until after Clinton left the Oval Office and moved to New Y Epstein has donated more than \$100,000 to Democratic candidates' igns, including John Kerry's presidential bid, the reelection campaign of New Mexico Go 1 and the Senate bids of Joe Schumer. Hillary Rodham Clinton, Dodd and Charles # Powerful friends and enemies A Vanity Fair profile found cracks in the ve left Bear Stearns in the wake of a fede Commission violation. It also poi million loan. Ia)oofEpstein's life story. The 2003 article said he nd a possible Securities and Exchange at Citibank once sued him for defaulting on a \$20 The article suggested that phis business mentors and previous employers was Steven Hoffenberg, now se g n term after "bilking investors out of more than \$450 million in one of the lar i schemes in American history." As he amasse man who i ealth, Epstein made enemies in disputes both large and small. He sued the 90 sold him his multimillion-dollar Palm Beach home over a dispute about less than \$16,000 in furnishings. A former friend claimed Epstein backed out of a promise to reimburse him hundreds of thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein owed him nothing. » Jeffrey Epstein: Model prisoner who swept, mopped floors, official says "It's a bad memory. I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the retired former president of Electronics and Sega Corp. "Suffice it to say I have nothing good to say about him." Among the characteristics most attributed to Epstein is a penchant for women. He has been linked to Maxwell, a fixture on the high-society party circuits in both New York and London. Previous girlfriends are said to include a former Ms. Sweden and a R manian Aik model. "He's a lot of fun to be with," Donald Trump told New York magazine i that he likes beautiful women as much as I do, and many of them are doubt about it, Jeffrey enjoys his social life." c It is even said unger side. No t Although he was not a frequenter of the Palm Beac e'Ca:ifi m49;eea, Beach Police made his presence felt. and Among his charitable donations, he gave 390,0\ q v \$100,000 to Ballet Florida. # Investigation leads to Epstein In Palm Beach, he lived in luxury. Th ercedes sat in his garage, alongside a Harley-Davidson. His jet waited a at Palm Beach International Airport. At home, a private chef and a small staff st d at e ready. From a window in his mansion, he could look out on the Intracoastal W sterwa ii", nd the West Palm Beach skyline. lie seemed to be a man who had everything. But extraordin 0 eaah can fuel extraordinary desires. # » Epste to leave jail for mansion in sex-trafficking case In March 2005, a worried mother contacted Palm Beach police. She said another parent had overheard a conversation between their children. Now the mother was afraid her 14-year-old daughter had been molested by a man on the island. The phone call triggered an extensive investigation, one that would lead detectives to Epstein but leave them frustrated. Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm Beach police report detailing the criminal probe offers a window into what detectives faced as they sought to close in on Epstein. Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to perform a massage. She said the friend told her to say she was 18 if asked. At the house, she said she was paid \$300 after stripping to her panties and massaging the man while he masturbated. # Police interview 5 alleged victims The investigation began in full after the girl identified Epstein in a p paid her. Police arranged for garbage trucks to set aside Epstein's t through it. They set up a video camera to record the coming coings at his home. They monitored an airport hangar for signs of his private jet's NT d departures. e man who had police could sift a d" They quickly learned that the woman who took t 4 old girl to Epstein's house was a Palm Beach Community Coll t from Loxahatchee. In a sworn statement at police headquarters, 18, mitted she had taken at least six girls to visit Epstein, all between the ages of 14 l6. pstein paid her for each visit, she said. During the drive back to her ho n told detectives, "I'm like a Heidi Fleiss." c ot) v Police interviewed five all ed ic ms and 17 witnesses. Their report shows some of the girls said they had been in/ss~ttruct t ave sex with another woman in front of Epstein, and one said she had direct inteplaurse ith him. In October,tp. rched the Palm Beach mansion. They discovered photos of naked, younglooking found in the garage area and inside a clock on Epstein's desk, alongside a girl's high school transcript. just as several of the girls had described in interviews. Hidden cameras were Two of Epstein's former employees told investigators that young-looking girls showed up to perform massages two or three times a day when Epstein was in town. They said the girls were permitted many indulgences. A chef cooked for them. Workers gave them rides and handed out hundreds of dollars at a time. One employee told detectives he was told to send a dozen roses to one teenage girl after a high school drama performance. Others were given rental cars. One, according to police, received a \$200 Christmas bonus. The cops moved to cement their case. But as they tried to tighten the noose, they encountered other forces at work. In Orlando they interviewed a possible victim who told them nothing inappropriate had happened between her and Epstein. They asked her whether she had spoken toj j pne else. She said yes, a private investigator had asked her the same questions. » Jeffrey Epstein: Acosta, Krischer trade barbs over sweethea t c t When they subpoenaed one of Epstein's former employees, he and a private eye had met at a restaurant days earlier to go investigators. ld the same thing. He at the man would tell Detectives received complaints that private eyes Epstein's local attorney, Guy Fronstin, he sa high-powered Miami lawyer who has d Kennedy "\ ng as police officers. When they told stigators worked for Roy Black, the likes of Rush Limbaugh and William While the private eyes were co professor, traveled to West Palm profiles on the popular W their use of alcoho a parallel investigation, Dershowitz, the Harvard law ach with information about the girls. From their own MySpace.com, he obtained copies of their discussions about He took his doubt o o a meeting with prosecutors in early 2006, where he sought to cast s' reliability. The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only did some of the girls have issues with drugs or alcohol but also some had criminal records and other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she told police she was younger than 18 when she started performing massages for Epstein. After the meeting, prosecutors postponed their decision to take the case to a grand jury. In the following weeks, police received complaints that two of the victims or their families had been harassed or threatened. Epstein's legal team maintains that its private investigators did nothing illegal or unethical during their research. By then, relations between police and prosecutors were fraying. At a key meeting with prosecutors and the defense, Detective Recarey, the lead investigator, was a no-show, according to Epstein's attorney. "The embarrassment on the prosecutor's face was evident when the police offi ver showed up for the meeting," attorney Jack Goldberger said. AS' Later in April, Recarey walked into a prosecutor's office at the state ca office and learned the case was taking an unexpected turn. The prosecutor, Lanna Belohlavek, told Recarey the state j s office had offered Epstein a plea deal that would not require him to serve jail tim e a felony conviction. Recarey told her he disapproved of the plea offe . Acc The deal never came to pass, however. ?S' # Future unclear after charge On May 1, the department aske ecutors to approve warrants to arrest Epstein on four counts of unlawful sexual =, now 27, for alle ed role in arranging the visits. Police officials also wanted to charge MB th s -described Heidi Fleiss, with lewd and lascivious acts. yity with a minor and to charge his personal assistant, By then, th case. On t ent was frustrated with the way the state attorney's office had handled the same day the warrants were requested, Palm Beach Police Chief Michael Reiter wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if he would not act. Two weeks later, Recarey was told that prosecutors had decided once again to take the case to the grand jury. It is not known how many of the girls testified before the grand jury. But Epstein's defense team said one girl who was subpoenaed - the one who said she had sexual intercourse with Epstein - never showed up. The grand jury's indictment was handed down in July. It was not the one the police department had wanted. Instead of being slapped with a charge of unlawful sexual activity with a minor, Ep tein was charged with one count of felony solicitation of prostitution, which carries a tt um penalty of five years in prison. He was booked into the Palm Beach County Jail ear 23 nd released hours later. O Epstein's legal team "doesn't dispute that he had girls over for mass oldberger said. But he said their claims that they had sexual encounters with hi cre ibility. "They are incapable of being believed," he said. "They accusations of theft made against them by their e some of them." al records. They had ere was evidence of drug use by What remains for Epstein is yet to be se t (ame S , The Palm Beach Police Departme d the FBI to investigate the case. It also has returned the \$90,000 Epstein d 2004. In New York, candidates f gyernor and state attorney general have vowed to return a total of at least \$60,000 i mpa n contributions from Epstein. Meanwhile, Epstein's powerful friends have re ent as tabloids and Internet blogs feast on the public details of the police inves Goldberge intains Epstein's innocence but says the legal team has not ruled out a future plea deal. He insists Epstein will emerge in the end with his reputation untarnished. "He will recover from this," he said. Staff writer Larry and staff researchers Bridget Bulger, Angelica Corte; Amy Hanaway and Melanie Mena contributed to this story. THE MOST **INTELLIGENT GRID** IN AMERICA LEARN MORE Section: A SECTION Page: IA Source: By PAUL OWERS Palm Beach Post Staff Writer Illustration: PHOTO (C & 2 B&W) & MAP (B&W) Memo: Ran all editions. Dateline: WEST PALM BEACH # TRUMP SNAGS GOSMAN ESTATE FOR \$41 MILLION When it came time to bid Monday for the palatial Palm Beach digs of Donald was not about to be trumped. %gran, The "Nobody was going to outbid me," the brash developer-turned- ality said from his New York office. Trump bested two other bidders with a \$41.35 million off or 43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along the s rderts Row." But Trump, 58, proud possessor of Mar-a-Lago, has o o live in the Gosman home at 513 N. County Road. He wants to - what else? - s it • ake more money. The star of the mega-hit The Apprentice said r s o redevelop the site into a "super luxury house" that would be the "finest an e United States." He might build another house before flipping the entire p "I've known about this house for quite of land in Florida - and probably ," Trump said. "It's probably the best piece for luxury real estate." Althoutirump said he could s Lesly said zoning regul said she's not worried about T w for only two houses - and maybe a third. e property into nine lots, Palm Beach Ma. plans. "He's been a very good projects very well. He's a rty owner in the town of Palm Beach," she said. "He does his ctionist." Monday's auctionjdbk pl Gosman's Chat distribution at U.S. Bankruptcy Court in West Palm Beach as part of ankruptcy case. Proceeds from the sale will go into escrow for eventual ito The aucti an atto that T t exactly noon after Judge Steven dismissed an objection from resenting money manager Jeffrey Epstein. The lawyer argued unsuccessfully as not a qualified bidder because his contract stipulated that he would not close on the sale unless title insurance was in place beforehand. With Trump listening via conference call, Epstein began the bidding at \$37.25 million - \$250,000 higher than Trump's initial offer. Mark Pulte, son of the founder of home-building giant Pulte Homes, passed when his turn came, letting lawyers for Trump and Esptein bid against each other until the price hit \$38.85 million. Pulte then bid \$39.1 million, briefly raising the ire of Trump, who believed that Pulte had given up his right to bid by passing the first time. ,0 4.4c But allowed the offer to stand, and Pulte and Trump went back and forth until Puke dropped out at \$41.1 million. Epstein, a part-time Palm Beach resident, bowed out at \$38.6 million. closed the bidding 10 minutes after it started, leaving Trump with the right to buy the 29,000-square-foot home (a typical Palm Beach County single-family house is about 2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service quarters. The closing could take place within a week but probably won't happen until next month. Trustee Joe Luzinski and creditors said they were pleased with the outcome. "We knew we were dealing with some substantial people . .. who were going it up a bit," Luzinski said. "The system worked," said Charles Tatelbaum, a lawyer for creditor JPM Chase Bank. "In bankruptcy court, the idea is to get the most for creditors, and that' pened." The auction proved to be a bonanza for creditors, Luzinski said, no e highest offer former listing agent Sotheby's International Realty received was \$ million. Sotheby's won't receive a commission, he said. Pulte, 42, of Boca Raton, said he figured Trump wouldn't Monday. "I got the feeling he was willing to go a lot higher, and t to chase it," Pulte said. Pulte said Gosman asked him before the auction wh uld be willing to let him stay in the mansion after the closing until he decides w is to move. Trump and Luzinski said they have had no such discussio man. Gosman, 75, had the house built after payin I lion for the land in 1986. The former health-care magnate declined • t ie requests before and after the auction Monday. He was at the courthouse but befo the auction took place. The \$41.35 million price tag eclips 5 million sale of Lowell "Bud" Paxson's Palm Beach home and guest house but of the \$45 million that Virginia home builder Dwight Schar paid for Ron Pe 6,000-square-foot estate, Casa Apava, a designated landmark. Schar also paid \$18.6 m" ion for lakefront lot across the street from the main house, for a total of \$63.6 million. In y Schar spent a total of \$70 million for his new property, making it the price res tial sale in U.S. history. Gosman once ha rtune that Forbes magazine estimated at \$480 million. He voluntarily filed for Chat bikruptcy protection in 2001, listing assets of \$250 million and liabilities c million. When ed that Gosman had to give up all of his exempt assets to creditors if he wanted to organize under Chapter 11, Gosman converted the case to Chapter 7 liquidation. Last year, .S. Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is invalid because Florida law does not recognize a Dominican Republic divorce that Lin Gosman tried to obtain from another man, Michael Castre. The judge's decision was a huge victory for creditors because it prevents Abe Gosman from protecting assets by claiming joint ownership with his wife. Gosman's assets, which include an extensive collection of artwork, could total as much as \$70 million and will be sold later. Without Lessen's ruling, Luzinski would have had a much harder time selling Gosman's estate, said David Cimo, special counsel for the trustee. "We would have been thwarted . .. or at least substantially impaired," Cimo said. 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 amounS o money like Donald Trump." CoS paul\_owers@pbpost.com # The Palm Beach Post REAL NEWS STARTS HERE # Indictment: Billionaire Solicited 3 Times Updated Oct 2, 2019 at 2:30 PM (EDITORS NOTE: This story originally published in The Palm Beach Post on July 25, 2006) Billionaire money manager and Palm Beach part-time resident Jeffre solicited or procured prostitutes three or more times between n3 Oct. 31 of last year, according to an indictment charging him with lony so icitation of prostitution. Epstein, 53, was booked at the Palm Beach Cou t :45 a.m. Sunday. He was released on \$3,000 bond. Ai l'S o r, I 'tution johns are usually charged ge is typically made in a criminal ment charging a person with the Epstein's case is unusual in that suspe with a misdemeanor, and even a fel information - an alternative t commission of a crime. His attorney, Jack Goldb , declined to discuss the charge. State attorneys offi spokesman Mike Edmondson also had little to say. "Gener ea ng, there is a case that has a number of different aspects to it," aid of a prostitution-related charge being submitted to a grand jury. became aware of the case months ago by Palm Beach police." Prosecutors and police worked together to bring the case to the grand jury, he said. Palm Beach police confirmed that and said the department will release a report today regarding its investigation. Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot h ith a pool and a boat dock on the Intracoastal Waterway since 1990, n to property records. A man answering the door there Monday pstein wasn't home. A Cadillac Escalade registered to him was ark the driveway, which is flanked by two massive gargoyles. Epstein sued Property Appraiser Gary Nikoli sis ci , contending that the assessment of his home exceeded its fair va e. He dismissed his lawsuit in December 2002. (ES' A profile of Epstein in Vanity F fine said he owns what are believed to be the largest private home attan - 51,000 square feet - and in New Mexico - a 7,500-acre r ch. se are in addition to his 70-acre island in the U.S. Virgin Islands and f aircraft. Epstein's Erie dmirers, according to the magazine, include prominent businessm demics and scientists and famed Harvard law professor Alan Ders lar er@pbpostcom # 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 o 26, 2086) Palm Beach billionaire Jeffrey Epstein paid to have underage oung women brought to his home, where he received massages a so etimes sex, according to an investigation by the Palm Beach Poli rtment. Palm Beach police spent months sifting throu tet s trash and watching his waterfront home and Palm Beach Internat port to keep tabs on his private jet. An indictment charging Ep a was unsealed Monday, charging him with one count of felony solicit of rostitution. Palm Beach police thought t probable cause to charge Epstein with unlawful sex acts with a lewd and lascivious molestation. Police Chief Mich Reiter was so angry with State Attorney Barry Krischer's handling of the case a prosecutor ualify himself. e wrote a memo suggesting the county's top ou to examine the unusual course that your office's handling of this taken and consider if good and sufficient reason exists to require your disqualification from the prosecution of these cases," Reiter wrote in a May I memo to Krischer. While not commenting specifically on the Epstein case, Mike Edmondson, spokesman for the state attorney, said his office presents cases other than murders to a grand jury when there are questions about witnesses' credibility and their ability to testify. By the nature of their jobs, police officers look at evidence from a "one-sided perspective," Edmondson said. "A prosecutor has to look at it in a much broader fashion," weighing the veracity of witnesses and how they may fare under defense attorneys' questioning, he said. Epstein's attorney, Jack Goldberger, said his client committed no crimes. "The reports and statements in question refer to false accusations that were not charged because the Palm Beach County state attorney questioned the credibility of the witnesses," Goldberger said. A county grand jury "found the alleg s wholly unsubstantiated and not credible," and that's why his client w,t di t charged with sexual activity with minors, he said. O Goldberger said Epstein passed a lie detector test administe d by reputable polygraph examiner in which he said he did not know tr s were minors. Also, a search warrant served on Epstein's home f9en. . vidence to corroborate the girls' allegations, Goldberger s According to police documents: - A Palm Beach Community Coll the nude, then brought him s sessions at his home. t said she gave Epstein a massage in es 14 to 16, for massage and sex-tinged - A 27-year-old woman worked as Epstein's personal assistant also facilitated the liaiso oning the PBCC student to arrange for girls when Epstein was ming town. And she escorted the girls upstairs when they arrived,c ) n esh sheets on a massage table and placing massage oils nearby. o sworn statements from five alleged victims and 17 witnesses. They cont7gd that on three occasions, Epstein had sex with the girls. A money manager for the ultra-rich, Epstein was named one of New York's most eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with the likes of former President Clinton, former Harvard University President Summers and Donald Trump, and has lavish homes in Manhattan, New Mexico and the Virgin Islands. He has contributed tens of thousands of dollars to Democratic Party candidates and organizations, including Sen. John Kerry's presidential bid, and the Senate campaigns of Joe , Hillary Clinton, Dodd and Charles Schumer. 4 7 Goldberger is one of five attorneys Ep t i etained since he became the subject of an investigation, Edmond id. Among the others: Alan Dershowitz, the well-known H w professor and author, who is a friend of Epstein. Dershowitz could hle eached for comment. Police said the woman 20, of Palm Wellington a College w phon sted young girls for Epstein was has worked at an Olive Garden restaurant in e was a journalism major at Palm Beach Community was questioned by police last October. She has an unlisted r and could not be reached for comment. Rob3pn said she met Epstein when, at age 17, a friend asked her if she would like to make money giving him a massage. She said she was driven to his fivebedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs to a bedroom with a massage table and oils. Epstein and were both naked during the massage, she said, but when he grabbed her buttocks, she said she didn't want to be touched. Epstein said he'd pay her to bring him more girls - the younger the better, told police. When she tried once to bring a 23-year-old woman to him, Epstein said she was too old, said. who has not been charged in the case, said she eventually brought six girls to Epstein who were paid \$200 each time, said. "I'm like a Heidi Fleiss," police quoted her as saying. The girls knew what to expect when they were taken to Epstein's home, said. Give a massage - maybe naked - and allow some touching. One 14-year-old girl took to meet Epstein led police to start investigation of him in March 2005. A relative of the girl called t thought the child had recently engaged in sex with a Palm B he girl then got into a fight with a classmate who accused her of be a rostitute, and she couldn't explain why she had \$300 in her purse. The girl gave police this account of her meetin stein: She accompanied and a second t stein's house on a Sunday in February 2005. Once there, a woma e th ght was Epstein's assistant told the girl to follow her upstairs to a ro ng a mural of a naked woman, several photographs of naked wome elf, a hot pink and sofa and a massage table. She stripped to her ra and panties and gave him a massage. Epstein gav ar-old \$300 and she and the other girls left, she said. She said Ro 0 to er that Epstein paid her \$200 that day. O ' s old similar stories. In most accounts, Epstein's personal assistant at the ti e, now 27, escorted the girls to Epstein's bedroom. whose most recent known address is in North Carolina, has not been charged in the case. Palm Beach police often conducted surveillance of Epstein's home, and at Palm Beach International Airport to see if his private jet was there, so they would know when he was in town. Police also arranged repeatedly to receive his trash from Palm Beach sanitation workers, collecting papers with names and phone numbers, sex toys and female hygiene products. One note stated that a female could not come over at 7 p.m. because of soccer. Another said a girl had to work Sunday - "Monday after school?" And still another note contained the work hours of a girl, saying she leaves school at 11:30 a.m. and would come over the next day at 10:30 a.m. Only three months before the police department probe began, Epstein donated \$90,000 to the department for the purchase of a firearms simulator, sai Struder, town finance director. The purchase was never made. The y w s CO returned to Epstein on Monday, she said. # Palm Beach Daily News # Police say lawyer tried to discredit teenage girls Posted Jul 29, 2006 at 12:01 AM Updated Oct 3, 2019 at 2:00 PM (EDITOR'S NOTE: This story originally was published in The Palm Beach P July 29, 2000 S Famed Harvard law professor Alan Dershowitz met with the 0 ch County State Attorney's Office and provided damaging information ou teenage girls who say they gave his client, Palm Beach billionaire J=y y pstein, sexually charged massages, according to police reports. The reports also state that another Epstein would have allowed Epstein to have no denies this happened. greed to a plea bargain that record. His current attorney And the documents also reve private investigators agg chased off visitors. e father of at least one girl complained that Bowed his car, photographed his home and Police also talked to ody who said she was offered money if she refused to cooperate '(the P Im Beach Police Department probe of Epstein. The a ney's office said it presented the Epstein case to a county grand ju onth rather than directly charging Epstein because of concerns about the gi s' credibility. The grand jury indicted Epstein, 53, on a single count of felony solicitation of prostitution, which carries a maximum penalty of five years in prison. Police believed there was probable cause to charge Epstein with the more serious crimes of unlawful sex acts with a minor and lewd and lascivious molestation. Police Chief Michael Reiter was so angry that he wrote State Attorney Barry Krischer a memo in May suggesting he disqualify himself from the case. The case originally was going to be presented to the grand jury in February, but was postponed after Dershowitz produced information gleaned from the Web site myspace.com showing some of the alleged victims commenting on alcohol and marijuana use, according to the police report prepared by Detective Recarey. a 20-year-old Palm Beach woman who told police she recruited girls for Epstein, also is profiled on myspace.com. Her page includes photos of her and her friends, including one using the name "Pimpin' Mad EZ." , who was not charged in the case, is a potential prosecution wi According to Recarey, prosecutor Lanna Belohlavek offered Eps eys Dershowitz and Guy Fronstin a plea deal in April. Fronstin, ing with Epstein, accepted the deal, in which Epstein would plead gu tt one count of aggravated assault with intent to commit a felony, be on five years' probation and have no criminal record. The deal s c. , for Epstein to submit to a psychiatric and sexual evaluation and hav o pervised visits with minors, according to Recarey's report. T b gain was made in connection with only one of the five alleged victit t r on states. Fronstin - who declined to co veteran defense attorney Ja agreement by any of Ep e case - was subsequently fired and rger was hired. He denies there was any neys to a plea deal. "We absolutely di a ree to a plea in this case," he said. Neither Belohlavek nor a state at rney pokesman could be reached for comment. The pa p rents of alleged victims who complained of being harassed by priva igators provided license tag numbers of two of the men. Police fou t e vehicles were registered to a private eye in West Palm Beach and another in Jupiter, according to Recarey's report. "I have no knowledge of it," defense attorney Goldberger said. The report also says a woman connected to the Epstein case was contacted by somebody who was still in touch with Epstein. That person told her she would be compensated if she didn't cooperate with police, Recarey's report says. Those who did talk "will be dealt with," the woman said she was told. Phone records show the woman talked with the person who allegedly intimidated her around the time she said, Recarey reported. Phone records also show that the person said to have made the threat then placed a call to Epstein's personal assistant, who in turn called a New York corporation affiliated with Epstein, the report states. The issue in the Epstein case is not whether females came to his waterfr2 .....\, nt home, but whether he knew their ages. "He's never denied girls came to the house," Goldberger said. Bu SI pstein was given a polygraph test, "he passed on knowledge of age, rney said. After the indictment against Epstein was unsealed t Police Chief Reiter referred the matter to the FBI. "We've received t and we're reviewing it," said FBI spokeswoman Judy Orihuela in The chief himself has come under atta m stein's lawyers and friends in New York, where he has a home. T work Post quoted Epstein's prominent New York lawyer, court, as saying his client was indicted only "because of the crazin olice chief." Reiter has declined to cobunedit on the case. Prosecutors h ve nd4'pfesented a sex-related case like Epstein's to a grand jury before, sai ' e Edmondson, spokesman for the state attorney's office. "That's what y te vit a case that falls into a gray area," he said. TR attorney's office did not recommend a particular criminal charge on whit to indict Epstein, Edmondson said. The grand jury was presented with a list of charges from highest to lowest, then deliberated with the prosecutor out of the room, he said. "People are surprised at the grand jury proceeding," West Palm Beach defense attorney Richard Tendler said. "It's a way for the prosecutor's office to not take the full responsibility for not filing the (charge), and not doing what the Palm Beach Police Department wanted. I think something fell apart with those underage witnesses." Defense attorney Robert Gershman was a prosecutor for six years. "Those girls must have been incredible or untrustworthy, I don't know," he said. Other attorneys said Epstein's case raises the issue of whether wealthy, connected defendants like Epstein - whose friends include former President Clinton and Donald Trump - are treated differently from others. Once he knew he was the subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as Dershowitz and Lefcourt, who is a past president of the National Association of Criminal Defense Lawyers. Miami lawyer Roy Black - who became nationally known when he s litfu defended William Kennedy on a rape charge in Palm Bea involved at one point. as Said defense attorney Suskauer: "I think it's u get the perception that with power, you may be tr e average Joe." una e the public may ently than the # Expert: Ignorance of age isn't defense in sex cases Posted Aug 5, 2006 at 12:01 AM Updated Oct 3, 2019 at 1:38 PM (EDITOR'S NOTE: This story originally published in The Palm Beach Post on Aug. 5, 2W6) Even if Palm Beach money manager Jeffrey Epstein di know that girls who police say gave him sexual m his Intracoastal home were under the legal age, t wouldn't have exempted him from crimin :es of sexual activity with minors. "Ignorance is not a valid defense skills professor who was a 30 years, half of that time p children. 'S But where there is a large gap in ages - and especially in cases of teachers with students - there is a public interest in prosecuting, he said. Likewise if the accused has a track record of sex with minors. 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 "S y drug abuse. 0 Some of the alleged victims in the Epstein case re me to his home multiple times for the massage se an the \$200 to \$300 he typically paid them per ( Ini id at would be a definite problem for the prosec o sa Betty Resch, who prosecuted crimes against dcjFe •n Palm Beach County for five years and sn e ivate practice in Lake Worth. "The victim beco "But she's a vi pathetic" to a jury, Resch said. heless. She's a kid." Most m nor al, charged with sex crimes against minors look said. A jury expecting to see a monster will. And the victims' ages work against them and in r 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." # Epstein camp calls female accusers liars Posted Aug 8, 2006 at 12:01 AM Updated Oct 3, 2019 at 3:35 PM (EDITOR'S NOTE: This story originally published in The Palm Beach Post on Aug. 8, 2006) Attorneys and publicists for Palm Beach financier Jeff Epstein went on the offensive Monday, contendi teenage girls who have accused Epstein of sexual shenanigans at his waterfront home are li saying that the Palm Beach Police Departmen sh." "There never was any sex betwe SV pstein and any underage women," his lead e ack Goldberger, said from Idaho where he wa no mg with his family. Epstein did have y men come to his house to give him massages 1 er said. "Mr. Epstein absolutely insisted anyb w o came to his house be over the age of 18. Ho erified that, I don't know. The question is, did anything gal occur. The law was not violated here." ha8 no explanation as to why Epstein would pay girls or + men with no massage training - as the alleged victims said was the case - \$200 to \$300 for their visits. "The credibility of these witnesses has been seriously questioned," Goldberger said. > Epstein, 53, was indicted by a county grand jury last month on a charge of felony solicitation of prostitution. After an 11-month investigation that included sifting through Epstein's trash and surveilling his home, Palm Beach police concluded there was enough evidence to charge him with sexual activity with minors. When the grand jury indicted Epstein on the less serious charge, Police Chief Michael Reiter referred the case to the FBI to determine whether there were federal law violations. After a spate of stories about the case last week, New York publicist Dan Klores - whose client list has included Paris Hilton and Jennifer - said on Saturday that Epstein's camp was ready "to get their story out." They did that Monday via Goldberger and a Los Angeles publicist for Miami criminal defense attorney Roy Black, who also has represented Epstein in the case. 7% "We just think there has been a distorted view of in the media presented by the Palm Beach police, Goldberger said. Reiter has consistently declined to a do the case and did not respond to a requester nt Monday. The implication that State Attorney Barry Krischer was easy on Epstein by presenting the case to a grand jury rather than filing charges directly against him is wrong, Goldberger said. The Palm Beach Police Department was "happy and ecstatic" that the panel was going to review the evidence. "I think what happened is they weren't happy with the result. They decided to use the press to embarrass Mr. Epstein." But records show that Reiter wrote Krischer on May 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 prosecution of these cases." Rather than flat-out decline to charge Epstein, Krischer referred the case to the grand jury to "appease" the ch' Goldberger said. A state attorney's spokesman would say on refers cases to the grand jury when they viability of the evidence or witness t e office s with the Both the state attorney and t r d jury concluded there was not sufficient eviden at tein had sex with minors, according to t , ber r. "It was just a childish performance by t etPil t each Police Department," Goldberger s The def e attorney said one of the alleged victims who clai ed s e as a minor was in fact over the age of 18. er alleged victim who was subpoenaed to testify to g and jury failed to do so. Epstein's accusers, he added, ve histories of drug abuse and thefts. "These women are liars. We've established that." But why would they all invent their stories about meeting Epstein for sexual massages? "I don't have an answer as to what was the motivation for these women to come forward and make these allegations," Goldberger said. # Palm Beach chief focus of fire in Epstein case By LARRY PALM BEACH In the [REDACTED] of Palm Beach financier Jeffrey Epstein, a brother, at first, on E two ears are accused of servicing Epstein and Palm Beach Police Chief Michael Reiter. Epstein, 33, was indicted last month on a charge of likery substitution of provisionality leaver of Reiter's "criminals" one of Epstein's [REDACTED] held. His department disseminated [REDACTED] and view of the case, and behaved in a "violent" manner when the grand jery didn't inflict Epstein on the charges if sought, another Epstein lawyer complained. To hear the Epstein campel it, Reiter, 68, is a headquarters letter asked to be the silent of Mayberry. They whaper that he's endorsed in a merey direct. Reiter did in fact file for discover from his wife, Jill, last year, after 24 years of marriage. They have a not, 15, and a daughter, H. The couple is scheduled to go to mediation next week, Aug. 16. Nothing in the court file may avota their self is particularly right. Reiter incurred the wrack of the Epstein camp as well as the state attorney's office for two reasons. First, he prosecuted Epstein to be charged with the more serious crimes of sexual activity with menstres because he sincerely state Attorney Rarry Kriecher in what language wishes used by one law enforcement official with another because of what he perceived as that officer smokehaving of the case. In a letter to Kriecher written May 1, Reiter called his actions in the Epstein case "highly unreasonable," he added. "I must target you to . . . consider if good and well test reason exists to require your disqualification from the prosecution of these cases." In short, Reiter told the county's top prosecutor for the part 13 years that he ought to get off the case. "I help like a department provisionalism," Miami Dade State Attorney Katherine Pernsonez Ranfie said of Reiter's letter. Following Epstein's indictment, Reiter referred the case to the FBI to determine if the miserick, supervision of defendant has [REDACTED] or federal law. Reiter was discussed the case in the bromatistic situation at home. But others already unikemently use one word to describe the chief provisionalism. "I have shapes been improved by Miller's provisionalism and his brothers," said Lincoln, chief of the Lawsuit Police Department and a Palm Beach County cop for 22 years. "The town of Palm Beach has a very provisional police department. We all consider Miller to be our peer and a man of integrity." June Beach Police Chief H.C. Clark II agreed While he doesn't know Reiter will be has not with him on countrywide law enforcement issues. "Yes never seen him lose his coal. For never was anything but a provisional demander from him." Reiter joined the Palm Beach Police Department in 1981, braining a \$20,000-year patrol job at the University of Pittsburgh. His personal packet shows commentarily excellent job evaluations. Pash Palm Beach is no bother of crime, and in his first year on the job, a resident confined to his home with a sick child charged Reiter for driving a few Cokes to the boats. Reiter arbanded pornout for the beverages. Another resident charged Reiter for shotting off his car's headlights in his driveway, saying a raker must have been at fact. Reiter worked everywhere from mad jobs to examined crime, sire and misericia. And he's an invice at investigations involving the Island's rich and faccion. He was the lead detective presiding the drag overdue death of Lavid Kennedy in 1984. He also was one of the officers who worked the investigation of William Kennedy Smith, who was charged in 1991 — and later acquired — with raping a woman at the Kennedy family component in Palm Beach. Reiter, who has a master's degree in her mass resource development from Palm Beach Atlantic University, also has attended the FBI National Academy in Quartica Blvd., and management courses at Harvard Long Island active in countrywide interpreter his approximate organizations and has a "top score" indictment security stationer. "He has a perspective, the performer has just addressed the problem of the town," said Lower Manager Person Lowell, who provided Reiter from one court chief to chief for March 2001. Reiter finally made his \$144,000 as the lawyer's cop. He did that high worth it. "I feel very happiestly, very straightforward, there's no change against or throughout being out devoted," Lowell said. "I think that he should be a chief has been outstanding in his policy party." © 2006 Newspapers.com # Reiter focus of fire in Epstein case Clipped By: **reiter\_m** Sat., Apr 22, 2017 # Delays in Epstein case unusual, lawyers say Posted Mar 13, 2007 al 12:01 AM Updated Oct 3, 2019 at 3:48 PM (EDITORS NOTE: This story originally published in The Palm Beach Post March 13, 2007) A federal probe or a plea deal could explain the wait ii1'tlI\ Palm Beacher's solicitation case. Nearly eight months after Palm Beach tyco. ffci Epstein was charged with felony solicit o ostitution, there has been no discernible progr s t case. No witnesses deposed. No trial date ng, save for routine court hearings reset xplanation. "Usually that would b attorney Glenn case. said criminal defense o has no involvement in the "As a ge ral rule, it would be unusual for nothing to have hap ene a Michael Dutko, a criminal defense ey in Fort Lauderdale. He represents o Palm Beach, potentially a key witness in the A routine hearing for Epstein was pulled from the court docket last week and reset for May 16. The delays and inaction could be due to a potential federal probe of Epstein or because a plea deal is in the works, attorneys say. Unusual is the word that best describes everything about the case against Epstein, 54, an enigmatic money manager in New York City who counts Bill Clinton and Donald Trump among his friends. "Highly unusual" is how Palm Beach Police Chief Michael Reiter described State Attorney Barry Krischer's handling of the case in a bluntly critical letter to Krischer last year before Epstein was indicted. Reiter referred the matter to the FBI to determine whether any federal laws had been violated. Epstein's allies countered by attacking the chief personally and professionally. Reiter's department investigated Epstein for 11 months. Police sifted repeatedly through his trash and conducted surveillance on his five-bedroom, 7 1/2-bath, 7,234-s foot home on the Intracoastal Waterway. Police said Epstein paid women and girls as g as 14 to give him erotic massages at his home. P ght there was probable cause to charge him / w' ul sex acts with a minor and lewd and lasc. ous estation. Epstein responded by hiri h mc of lawyers. One of them, Harvard law pr d author Alan Dershowitz, provided the scat tt rn 's office with information about alcohol and m lua se by some of the girls who said they were wit eM. Pro ut s then referred the case to the grand jury rather de charges directly against Epstein. + ein's attorneys deny he had sex with underage girls. The lawyers say the girls' stories are not credible. But if the court file is any indicator, they've made no effort to depose the girls. > Neither prosecutors nor defense attorneys have sought to question , said Dutko, her attorney. She recruited teenage girls to visit Epstein for massages and sexual activity, Palm Beach police said, and presumably would be a key witness. Epstein's attorney Jack Goldberger did not return phone messages. A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it to federal prosecutors. "We still have a pending case," FBI spokeswoman Judy Orihuela said Monday. State Attorney Krischer did not return a call for comment. His spokesman, Mike Edmondson, declined to say whether federal investigators are delaying the Epstein case. But, added, "if another agency is looking at something wouldn't want to step on their toes." Attorneys say inertia in a criminal case o\_ s to a pending plea deal. "It would not surprise me if so not reflected in the court fi agreement that will be \ as happened that's utko, such as an later. Defense attorne ner said defense attorneys sometimes pu off o ly conducting discovery -- deposing witnesses, requ g documents and the like -- because doing so more work for harried prosecutors who beco e angry and not offer a plea deal. etimes defense lawyers, knowing that, will try and do iscovery without taking depositions," said Shiner, a former prosecutor for 13 years. Instead, they may conduct a below-the-radar probe such as having a private investigator check out leads, he said. Shiner and others say a plea deal for Epstein probably would result in pretrial intervention, in which a defendant may be ordered to undergo a psychological evaluation, counseling or other conditions in return for dropping the charge. Edmondson, spokesman for State Attorney Krischer, said there is no plea offer and no request for the prosecution to show its cards. "To my knowledge, it's never happened before on a filed case," he said. Section: LOCAL Page: 5B Source: The Associated Press Illustration: PHOTO (B&W) Memo: Ran all editions. Dateline: NEW YORK # WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN. WAS 16 A billionaire investor, already facing jail in Palm Beach County on charges of ingbnderage prostitutes, is being sued by a young woman who says he had sex with her syhi was 16 and had sought his help becoming a model. The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, sa finlhei€r Jeffrey Epstein had the teen perform a sex act when she brought photographs of herself for review in his Upper East Side mansion sometime in 2000. Epstein, 54, a money manager, told the teen he managed fin ictoria's Secret and "could get you into the catalog" if she were "nice" to him, court pape a papers say being "nice" included massages and other favors. When the girl told Epstein, "I am 16 years old and ju odel," he replied, "Don't worry, I won't tell anybody," court papers say. Epstein, said by London's Mail on Sunday to end of England's Prince Andrew, has been indicted in Palm Beach on charges of solici e prostitutes. That case is pending. The girl visited Epstein "several times ov a ral months and engaged in bizarre and unnatural sex acts" while she was a minor, the la Epstein "repeatedly requested that with her 14-, 15-, and 16-year-old girlfriends, stating, 'Come by with your frien young e next time. Don't bring Sherrie (a mutual friend in her 40s). I love girls your age.' " The young woman, now 23, returning to Epstein because she has "mental issues," said her lawyer, William J. U • h. H eised to elaborate, but court papers say she was "disabled as a result of severe mental dise and d ect." Epstein's lawyer read a newspape k, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can cognize the word 'rich.'" Lefcourt also and will a to of limitations has expired for the woman's case criminally and civilly, ainly be dismissed. He refused to c ment on Epstein's Florida charges. Meanwhile, Unroch, 57, also acknowledged that his client was living with him and was at the center of a \$10 million lawsuit he filed last year against a neighbor who said he was having sex with underage girls. That case is pending. "What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve the case out of court. # Palm Beacher pleads in sex case Updated Oct 3, 2019 at 1:47 PM (EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 1, 2008) Jeffrey Epstein will serve 1 1/2 years on teen solicitation charges. He lives in a Palm Beach waterfront mansion and C as company with the likes of President Clinton, Prin Andrew and Donald Trump, but investm t ba er Jeffrey Epstein will call the Palm Beach Coutut a for the next 18 months. < 46\ felony solicitation of Epstein, 55, pleaded guilty prostitution and procur son under the age of 18 for prostitution. After months in jail, he will be under house arr ear. And he will have a lifelong obligation to gist r as a sex offender. He must submit to an HIV st wit in 48 hours, with the results being provided s victims or their parents. of the plea deal, federal investigators agreed to drop + ir investigation of Epstein, which they had taken to a grand jury, two law enforcement sources said. Epstein was indicted two years ago after an 11-month investigation by Palm Beach police. They received a complaint from a relative of a 14-year-old girl who had given Epstein a naked massage at his five-bedroom, 7,234 square-foot, S8.5 million Intracoastal home. Police concluded that there were several other girls brought in 2004 and 2005 to an upstairs room at the home for similar massages and sexual touching. The indictment charged Epstein only with felony solicitation of prostitution. The state attorney's office later added the charge of procuring underage girls for that purpose. Prosecutor Lanna Belohlavek said of the plea: "I took into consideration the length the trial would have been and witnesses having to testify" about sometimes embarrassing incidents. Epstein may have made a serious mistake soon after he was S charged. He rejected an offer to plead guilty to one count aggravated assault with intent to commit a felony, according to police documents. He would have go years' probation, had no criminal record and not registered sex offender, the documents in Epstein arrived in court Monday w' three attorneys. He wore a blue blaze e 'rt, blue jeans and and gray sneakers. A Judge Deborah Dale Pucillo accepted the plea, ngerprinted. Epstein then removed his bla jail while his atto photographe as handcuffed for the trip to d to shield him from When h tually is released to house arrest, Epstein will h. too rve a 10 p.m. to 6 a.m. curfew, have no used contact with anyone younger than 18 and her own nor possess pornographic or sexual materials that are relevant to your deviant behavior," the judge said. Epstein will be allowed to leave home for work. The New York-based money manager told the judge he has formed the not-for-profit Florida Science Foundation to finance scientific research. "I'm there every day," Epstein said. The foundation was incorporated in November. Epstein said he already has awarded money to Harvard and MIT. When he is released from jail, there is a chance that Epstein will be forced to move. Sex offenders are not allowed to live within 1,000 feet of a school, park or other areas where children may gather. No determination has been made as to whether Epstein's home complies, but attorneys said it likely does. Sex offenders also typically must attend counseling sessions. Belohlavek said that was waived for Epstein because his private psychiatrist is working with him. The judge was A skeptical but agreed to it. Epstein's legal woes don't end with Monday's plea. T AS. are four pending federal civil lawsuits and one in related to his behavior. At least one woman has st d hi4n in New York, where he owns a 51,000-squar ,V M anhattan mansion. "It's validation of what we're sa 'SACS? civil cases," said Miami attorney Jeffrey He w represents the alleged victims in the federal law i W st Palm Beach attorney Ted Leopold represe eged victim in a civil suit in state court. He a cipates amending that lawsuit to add "a few other s as well. In the case, police went so far as to scour Epstein's tr and nduct surveillance at Palm Beach International where they watched for his private jet so they uld know when he was in town. They concluded that + pstein paid girls \$200 to \$300 each after the massage sessions. > "I'm like a Heidi Fleiss," now 22, told police about her efforts in recruiting girls for Epstein. > There was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation, police concluded. The state attorney's office said questions about the girls' credibility led it to take the unprecedented step of presenting the evidence against Epstein to a grand jury, rather than directly charging him. Palm Beach Police Chief Michael Reiter was furious with State Attorney Barry Krischer, saying in a May 2006 letter that the prosecutor should disqualify himself. "I continue to find your office's treatment of these cases highly unusual," he wrote. He then asked for and got a federal investigation. A Epstein hired a phalanx of high-priced lawyers - includin Harvard law professor and author Alan Dershowitz public relations people who questioned Reiter's c and the victims' truthfulness. In addition to mansions in Palm Beach d r attan, Epstein owns homes in New Mexic Q a irgin Islands. He's a frequent contributor to D cid,k Party candidates. He also donated \$30 million.tooa rd in 2003. Former New York G Spitzer returned a \$50,000 campaign contrib t Epstein after his indictment, then resigned t y wring his own sex scandal. And the same Palm Be lice Department that vigorously investig returned his \$90,000 donation for the a firearms simulator. f writer Eliot Kleinberg and former staff researcher ichelle Quigley contributed to this story. # Jeffrey Epstein: Scientist, stuntman, `sex slave' visit jailed tycoon By LARRY / Palm Beach Post Staff Writer Posted Aug 13, 2008 at 12:01 AM Updated Jul 16, 2019 at 4:54 PM Tycoon Jeffrey Epstein mingled with an eclectic mix of {sup}`4041` people, including beautiful young women, before he into trouble for paying teenage girls to give him s xualb% massages at his Palm Beach mansion. Not much has changed, even though h n vdlys1des in a dorm at the Palm Beach County 4 S ce's 17-acre, 967-bed stockade near the fair\ During his first month of by the female assistan them to the roo naked massag ne ent, Epstein was visited rls told police, had escorted nsion where they gave him Also tre ptisite to the jail was a young woman whom Epstein described as his Yugoslavian sex slave. ealthy financier and science wonk also has been + ited by an expert on artificial intelligence, as well as a man who is a mixed martial arts aficionado and sometime movie stuntman. > The only other people to visit him at the jail, according to records, are a Island man and an individual who listed Epstein's Palm Beach address as his own. > Epstein, 55, pleaded guilty on June 30 to two prostitutionrelated charges and was sentenced to 18 months in jail, followed by a year of house arrest. Epstein paid teenage girls \$200 to \$300 in 2004 and 2005 for massages in his home that sometimes included sexual touching, Palm Beach police said. His jail visitors in July included: 29, who some of the teen masseuses said phoned them when Epstein was in town and escorted them upon their arrival at his Palm Beach waterfront home to an upstairs room, where she prepared the massage table and provided the oils for their encounters with him. visited Epstein three times in July, according to a jail visitor's log. lists a Manhattan home address. Reached by telephone, she declined to discuss Eps 23, whose family in Y avia Epstein paid money to so that he could in to the United States to be his "sex slave," o n e girls told police. One girl told police that s i • structed and her to kiss a sex while he watched and masturbated. Anothe s engaged in sex with at Epste g. visited Epstein in jail four time s. She lists her address as on the Upper East si a of hattan, not far from Epstein's enormous apar nt. er S ank, 62, founder of the Institute for Learning e at Northwestern University and an expert on ficial intelligence, paid one visit to Epstein. Schank has written numerous books on that subject and has a doctorate degree from Yale University in linguistics. He was one of 19 people who applied to be president of Florida Atlantic University in 2003. He became "chief learning officer" at the online Trump University in 2005. Schank listed his address as being in Stuart, and records show he also owns a home in Lake Worth. Epstein has financed a number of scientists over the years, including Nobel Prize winners. He gave \$30 million to Harvard University in 2003. In November, he formed the not-for-profit Florida Science Foundation, which he said finances scientific research. - Igor Zinoviev, a Russian mixed martial arts fighter, who coaches a Chicago team in the International Fight League. He also has worked as a personal trainer, celebrity bodyguard and movie stuntman, according to the league's Web site. The New Jersey resident visited Epstein seven times in July. (S S Zinoviev, Schank and comment. could not be r Staff researcher Niels Heimeriks contri s story. # Palm Beach Daily News # Billionaire sex offender leaves jail six days a week for work Updated Oct 4, 2019 at 9:27 AM Palm Beach billionaire Jeffrey Epstein, who's serving 18 months in jail for soliciting an underage girl for prostitution, is allowed to leave the Palm Beach County Stockade six days a week on a work-release program. Teri Barbera, spokeswoman for the Palm Beach Sheriffs Office, confirmed that Epstein, 55 Veen ee m the work-release program since Oct. 10. "He works six days a week: Frida ASeS4/ 4? i t ednesday 10 a.m. to 10 p.m.," Barbera said ' ai . "(He) works at his local West Palm Beach of1mo tored on an active GPS system (he wears an permit deputy, at workplace du et). Mr. Epstein hires a se, for his own security at his e he is out." Miami a rney Jeffrey Herman represents six young women io 1 e sued Epstein, claiming he sexually abused at his Palm Beach home when they were minors. + Or man said he received a letter about the work-release pro= from the U.S. Attorney's Office within the past few days. But Herman says Epstein had been out on workrelease for several weeks before the notification. > "My clients expressed shock and disappointment," Herman said. "I find it incredible that he's on work-release in the community and my clients aren't notified of this and we get this letter weeks after the fact." "He goes to work every single day and goes back to jail at night, just like everybody else (in the program)," Goldberger said. Epstein pleaded guilty June 30 to two felony counts: soliciting prostitution and procuring a person under 18 for prostitution. As part of the plea agreement, Epstein must serve one year of house arrest and register as a lifelong sex offender. # Women want Epstein sex plea deal unsealed Updated Oct 2, 2019 at 2:23 PM (EDITOR'S NOTE: This story originally published in The Palm Beach Post June 10, 2W9) Their attorneys will ask a judge to open Jeffrey Epstei 0' records. When wealthy money manager Jeffrey Eps f Beach pleaded guilty last year to procur 4 for prostitution, his case detoured arou \ nd state rules regarding the sealing of court d qt e , At a plea conference on t ate arges, a judge, a defense lawyer and a prosecut udd at the bench and decided that a deal Epstei c with federal prosecutors to avoid chargesylfau sealed, according to a transcript of the hearing. And so it t l rida rules of judicial administration, as well as rules + of he Palm Beach County court system, require public notification that a court document has been or will be sealed, meaning kept from public view. The rules also require a judge to find a significant reason to seal, such as protecting a trade secret or a compelling government interest. > Yet no notification or reason occurred in Epstein's case, according to court records. Epstein's own attorneys, in federal filings, have referred to his confidential deferred prosecution agreement with the U.S. attorney's office, struck in September 2007, as "unprecedented" and "highly unusual." And it was "a significant inducement" for Epstein to accept the state's deal, observed the state judge who accepted his plea, County Judge Deborah Dale Pucillo. Epstein now faces at least a dozen civil lawsuits in federal and state courts filed by young women who said they had A sex with him and now are seeking damages. Attorneys for some of those women want his agreem with federal prosecutors unsealed and will ask Cir Jeffrey Colbath to do so today. "It is against public policy for these doc a be have been sealed and hidden from public r y s a member of the public, E.W. has a right t a ey¢se documents unsealed," wrote former Cir Bill Berger, now in private practice and repre en 1 g one of the women. The Palm Beac agreement. P will ask Colbath to unseal the rney Deanna Shullman will argue that the publi as a right to know the specifics of Epstein's deal. ding fo various media accounts, Epstein moved in le at included President Clinton, Donald Trump and + ce Andrew. "International Moneyman of Mystery," declared a 2002 New York magazine profile of Epstein. Epstein, 56, is in the Palm Beach County Stockade, serving an 18-month sentence after pleading guilty nearly a year ago to felony solicitation of prostitution and procuring teenagers for prostitution. He is allowed out from 7 a.m. to 11 p.m., escorted by a deputy, said Palm Beach County Sheriffs Office spokeswoman Teri Barbera. During a Palm Beach Police Department investigation, five victims and 17 witnesses gave statements. They told of young women brought by his assistants to Epstein's mansion on El Brillo Way for massages and sexual activity, and then being paid afterward. At Epstein's plea conference last year, his attorney, Jack Goldberger, and then-Assistant State Attorney Lanna Belohlavek approached Pucillo in a sidebar conference. Pucillo, who had left the bench nine years earlier, was filling in temporarily as a senior judge. According to a transcript, Goldberger told Pucillo tha Epstein had entered a confidential agreement wit riti attorney's office in which federal prosecutors broktacOnot pursuing charges against him if he pleade in state court. Pucillo then said she wanted a s of the agreement filed in his case, and G concurred that he wanted it sealed. Belohlave\fsiehed off on it. The Florida Supreme Co s e pressed "serious concern" and launched an all- ry into sealing procedures across the state edia reports in 2006 of entire cases being s led ap disappearing from court records. "The pu nstitutional right of access to court records mySt rem n inviolate, and this court is fully committed to rding this right," justices wrote in their final report. Ad÷ office on Tuesday referred any questions to Goldberger, who declined to comment. Pucillo also has declined to comment. # Epstein secret pact with Feds reveals "highly unusual" terms Posted Jun 10, 2009 at 12:01 AM Updated Oct 4, 2019 at 9:23 AM (EDITOR'S NOTE: This story originally published in The Palm Beach Post on September 19, 2009) A secret non-prosecution agreement multimillionaire financier Jeffrey Epstein struck with federal prose being called "highly unusual" by former federal p and downright outrageous by attorneys no resenting young women who serviced him. The deal reveals that the FBI an ASS Attorney's Office investigated him for several a rimes, including engaging minors in com e I s . The crimes are punishable by anywhe 0 years to life in prison. But federal pr backed down and agreed to recall grand jury su s if Epstein pleaded guilty to prostitu -related felonies in state court, which he ul atel id. He received an 18-month jail sentence, of he served 13 months. + e U.S. Attorney's Office also agreed not to charge any of Epstein's possible co-conspirators: ==, , Lesley Groff and > The deal was negotiated in part by heavyweight New York criminal defense attorney Gerald Lefcourt. Unsealed on Friday after attorneys for some of Epstein's victims and The Palm Beach Post sought its release, it offers the first public look at the deal Epstein's high-powered legal counsel brokered on his behalf. Mark of Stuart, a former federal prosecutor, described the disparity in potential sentences as unusual, but even more so a provision on attorney payment. The first draft of the agreement in September 2007 required that Epstein pay an attorney -- tapped by the U.S. Attorney's Office and approved by Epstein -- to represent some of the victims. That attorney is prominent Miami lawyer Bob Josefsberg. But an addendum to the agreement signed the following month struck Epstein's duty to pay Josefsberg if he and th AS victims did not accept settlements -- capped at \$150,0 and instead pursued lawsuits. said it appears the government w. ct ) balance the lesser sentence for Epstein ering \$150,000 for each victim. "I've neve e s n anything like that in my life," he said. "It's usual." The deal does not say wh andvictims were contacted or consulted before t made. Attorney Brad three of the y f Fort Lauderdale, who represents omen, believes that none of the 30 to 40 wom identified as victims in the federal investigation werE told of time. said his clients received from the U.S. Attorney's Office months after the deal O signed, assuring them Epstein would be prosecuted. "Never consulting the victims is probably the most outrageous aspect of it," said. "It taught them that someone with money can buy his way out of anything. It's outrageous and embarrassing for United States Attorney's Office and the State Attorney's Office." Epstein now faces many civil lawsuits filed by the women, who are represented by a variety of attorneys. In many, the allegations are the same: that Epstein had a predilection for teenage girls, identified poor, vulnerable ones and used other young women to lure them to his Palm Beach mansion. They walked away with between \$200 and \$1,000. Former Circuit Judge Bill Berger, also representing victims, called the agreement a "sweetheart deal." "Why was it so important for the government to make this deal?" Berger asked rhetorically. "We have not yet had an honest explanation by any public official as to why it was made ... and why the victims were sold down the river." 4,4 1 Former federal prosecutor Ryon McCabe described th agreement as "very unorthodox." Such agreements are usually reserved for corporations, not individ "It's very, very rare. I've never seen or h procedure that was set up here," said who has no involvement in any Epstein litig "He's essentially avoiding f eralkdsecution because he can afford to pay that y la ers to help those victims review their cases. on has no money, he couldn't be able to stri e this and avoid federal prosecution. The ba deal with federal prosecutors is all the more in light of the legal powerhouses who have C)rk for Epstein, including Harvard professor Alan + rshowitz and Bill Clinton investigator Kenneth Starr. Lefcourt is a past president of the National Association of Criminal Defense Lawyers. > Epstein's local defense attorney, Jack Goldberger, issued a statement Friday saying he had fought the release of the sealed agreement to protect the third parties named there. "Mr. Epstein has fully abided by all of its terms and conditions. He is looking forward to putting this difficult period in his life behind him. He is continuing his longstanding history of science philanthropy." The investigation triggered tensions between police and prosecutors, with then-Palm Beach Chief Michael Reiter saying in a May 2006 letter to then-State Attorney Barry Krischer that the chief prosecutor should disqualify himself. "I continue to find your office's treatment of these cases highly unusual," Reiter wrote. He then asked for and got the federal investigation that ended in the sealed deal. "The Jeffrey Epstein matter was an experience of what a many-million-dollar defense can accomplish," Reiter told A the Palm Beach Daily News upon his retirement. COS 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 righ Tuesday gave lawyers representing multimillionaire sex offender Jeffrey T n the right to subpoena abortion records from women who are seeking millions in m the parttime Palm Beach resident. Palm Beach County Circuit Judge Donald Hafele said the records uld elp Epstein rebut the women's claims that they suffered psychological ills after ng to give him sexually-charged massages at his Palm Beach mansion w were as young as 14. Hafele told Epstein's attorneys they couldn't go on a fis ition. The medical records, he said, can't be sought until the women are asked w have ever had an abortion, how many and where. Further, he said, the recor be made public and might not be admissible during trial. But, he said, since the women claim Epste s responsible for their emotional distress, his attorneys can explore the impdo o er events. Medical records, Hafele said, are a better source of information th rson memory. Attorney Louis Silver, who represe idential Women's Health Center, a West Palm Beach clinic where abortions , warned Hafele that he was stepping on shaky constitutional grounds. "These records are protected b onstitutional right of privacy," he said, referring to the Florida Constitution. After the hearing, Silver jiur appeal won't be necessary until Epstein attorneys seek the records. In another rulin can't be rel complain becam Critton b esday, Hafele also said that videos from depositions in the state cases 'th t a court order. The ruling came after Epstein attorney Robert Critton deo of Epstein being asked whether he had an "egg-shaped" penis .com sensation. It first appeared on The Palm Beach Post Web site. ed attorney Spencer Kuvin for releasing it. Kuvin said it was public record. The civil stfits 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 # Epstein Journal's Findings Could Resurrect Case Posted Sep 17, 2019 at 12:01 AM Updated Oct 1, 2019 at 10:51 AM 464' (EDITOR'S NOTE: This story originally published in The Palm Beach Post on March 20, 2010) A purloined journal that is said to contain the nam "hundreds" of victims of convicted sex offender Epstein could be used to reopen the invest into the multi-millionaire's appetite for teenage~girl ttorney representing seven of the victims s New details about the conte t fl journal were released this week when Alfredo l gu , who worked as a property manager fo It......, Pal Beach resident, pleaded guilty to obstruct n f tice for lying to federal agents when asked if e a y information about his former boss' criminal ty. He later tried to sell the journal he stole fro apfrtein for \$50,000 to an unidentified person, alerttauthorities, according to court records. part of the plea agreement, federal prosecutors said the urnal "contains information material to the Epstein investigation, including the names of material witnesses and additional victims." "Had the items been produced in response to the inquiries of state or federal authorities ... the materials would have been presented to the federal grand jury," federal prosecutors wrote. Instead, prosecutors short-circuited the grand jury investigation and cut a deal with Epstein. They agreed not to pursue federal charges if he didn't contest prostitutionrelated felonies in state court. The money manager pleaded guilty in July 2008 to procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18 month sentence. Attorney Adam Horowitz, who represents seven of the roughly 18 women who have filed civil suits against Epstein, said the new information could trump the socalled non-prosecution agreement. The multifaceted agreement, he said, deals only w, list of victims that the U.S. Attorney's Of ew about when it penned the deal in 2007. If al victims are listed in the journal Rodriguez sto or. tz said federal prosecutors could reopen t ation. "It opens the door for furth p se tion," he said. In addition to turning the'journal to federal agents, Rodriguez told th e ew his former boss was having sex with unde g g hen he worked for him in 2004 and 2005. He en naked girls, who looked like minors, in the p pstein's \$8.6 million mansion. He had seen pcyftogra lc images of young girls on Epstein's computer, to court records. Neither Epstein's criminal defense attorney, Jack Goldberger, nor attorney Robert Critton, who represents Epstein in the civil lawsuits, could be reached. Federal prosecutors have consistently declined comment. The wording of the controversial agreement is unclear. It says federal prosecutors would provide Epstein's attorneys "with a list of individuals whom it has identified as victims." Miami attorney Robert Josefsberg was appointed to represent any of the victims on the list who wanted to pursue Epstein in civil court. As part of the agreement, Epstein is to pay for Josefsberg to represent the women. Some of the women, most identified as Jane Doe in lawsuits, had already hired attorneys to represent them. Some have since settled their suits with Epstein, although terms were not disclosed. Horowitz said he has filed court papers to get the journal that Rodriguez stole. "It's another piece of evidence that shows our clients were at Epstein's mansion: he said. Rodriguez told prosecutors he didn't turn over the' when both FBI and Palm Beach police asked for i eca se he wanted money for it. He also said he w d Epstein would make him "disappear." The infogttah e told investigators, was his "insurance p He faces a maximum 20 yea when he is sentenced on June 18. jane\_musgrave@p @pbpcourts .1 1141"i # The Palm Beach Post REAL NEWS STARTS HERE # Epstein paid three women \$5.5 million to end underagesex lawsuits Posted Oct 3, 2017 at 12:01 AM Updated Oct 4, 2017 at 12:46 AM Ending years of speculation about how much Palm Beach billionaire Jef women who claimed he used them as sex toys, court documents file out \$5.5 million to settle lawsuits with three of more than two do tein paid young k show he shelled s who sued him. Responding to requests from Epstein's attorneys in a corn sex scandal, attorney said the politi offender paid more than \$1 million to each of the uit that was spawned by the ed 64-year-old convicted sex represented. Identified in court papers only by their initi allegations and their youthful ages, L.M \$2.5 million, said of the se is or \lip donyms because of the nature of the \$1 million, E.W. \$2 million and Jane Doe e negotiated with Epstein to end the lawsuits. Jack Goldberger, one of Epstei s c al defense attorneys, on Tuesday declined comment on the revelations, citing co identia agreements that were part of the settlements. For the same reason, he declined t a hether Epstein paid similar amounts to settle roughly two dozen lawsuits fil y othe young women against Epstein, claiming he paid them for sex when some w=ems otlftg as 14 years old. Attorne arola, who is representing , said his client was compelled to divulge the confiders 'al settlements to answer questions posed by Epstein's attorneys. "Brilliant move on their part," he said. Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have likely come out. He says the information will help him undermine Epstein's claims that "ginned up" the allegations to help his former law partner, imprisoned and disbarred Fort Lauderdale lawyer Scott Rothstein, perpetuate a \$1.2 billion Ponzi scheme. The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute between Epstein and Rothstein, both billionaires. A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a minor for prostitution, he sued Rothstein and , claiming they trumped up the allegations of sexual molestation to perpetuate the Ponzi scheme. Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly successful law firm by forging the names of federal judges and others to persua it vestors he had negotiated settlements in lawsuits against high-profile people. Investor ,,ill By then, it was too late. A deal had already been cut with then-South Florida U.S. Attorney Alex Acosta and Epstein's attorneys to shelve a 52-page federal indictment against Epstein, a former math teacher turned money manager who counts Presidents Donald Trump and Bill Clinton among his friends. Prosecutors' failure to alert the young women about the deal violated the Crime Victims' Rights Act, Marra ruled. "At a bare minimum the (act) required the government to inform (the young women) that it intended to enter into an agreement not to prosecute Epstein," he wrote. Still, Marra said he wasn't second-guessing prosecutors' decision not to pursue Epstein on federal charges if he pleaded guilty to minor state prostitution charges and agreed to compensate his victims for the trauma he caused. "The court is not ruling that the decision not to prosecut cS , was improper," Marra wrote. "The court is simply rul. that, under the facts of this case, there was a viola the CVRA." Further, he made no decision about w edy should be. He gave prosecutors and tt representing the young women 15 days to m ide how to unravel the complex legal web that anging over Epstein and his young victims fo an a decade. The chances an a be reached are slim, said attorney Jack ca o 11 ho is representing the two Jane Does who cha pd the prosecutors' actions. Fu er, e said, there is no road map to follow. The it attorney filed on behalf of the two dentified young women, claiming prosecutors violated e federal act, is unique, he said. "We are treading on virgin ground, to use what is probably an inappropriate phrase in this situation," he said. Scarola said he and will ask that the nonprosecution agreement be thrown out. That would open the possibility that the long-shelved federal indictment could be dusted off and filed against the 66-year-old Epstein, who spends most of his time on a private island he owns in the U.S. Virgin Islands. "I don't see the government conceding to that remedy," Scarola admitted. Further, he said, it is likely Epstein will be allowed to weigh in. Miami attorney Roy Black years ago filed papers asking to intervene on Epstein's behalf. The U.S. Attorney's Office said it wouldn't comment on Marra's ruling. Neither Black nor New York City attorney Jay Lefkowitz, who led efforts to bury the federal indictment, responded to emails or phone calls for comment. West Palm Beach attorney Jack Goldberger, who A represents Epstein, also didn't respond. Scarola said it is likely Epstein's star-studded legal tea argue that Epstein fully complied with the terms L fth agreement he made in 2007 with federal prosecut s a d therefore the agreement can't be undone. As he promised, Epstein pleaded g e 2008 to state charges of soliciting a minor fo r ti on and soliciting prostitution. He served 13 an 18-month jail term in a vacant wing of the con tockade that he was allowed to leave 12 hours a cja ys week. Further, as ag who sued him. court re in aid settlements to the young women le the settlements were confidential, ow he paid three women a total of \$5.5 eturn, federal prosecutors held up their end of the rgain. Their investigation ceased. Having done all that prosecutors asked of him, Scarola said Epstein will make a simple argument: "You can't turn around and deprive me of the benefits I bargained for." However, Scarola said, using Marra's ruling, he will counter that the contract Epstein signed was illegal and therefore unenforceable. Even if Marra agrees to toss out the non-prosecution agreement, Scarola conceded that doesn't mean Epstein will face federal charges. "The contract can be set aside and the federal government can attempt to enter into the same agreement," he said. "Except the spotlight of public attention will be on them and the 40 victims will be able to explain to the court why this sweetheart deal should not be approved." Scarola said that prosecutors may have had good reason not to pursue Epstein. 'There may be a reasonable explanatioS but we don't know what that reason may have been, said. In court papers, federal prosecutors have s t many of the young women were afraid to cross ful, politically connected money manag a si ply refused to testify against him. In other cases, they said, t i\ om changed their stories. Jane Doe 2, who is t ry' it....., to h e the non-prosecution agreement throw o t, \*tially described Epstein as "an awesome ma prosecutors she hoped "nothing ) happens" to hi hile she later agreed to testify against Epstein, tutors said they feared Epstein's attorneys wQQld us er words to destroy her if she ever took the stand. Ad÷ arra, however, said the young woman's comments didn't mean she wasn't entitled to know about the prosecutors' plans to drop the charges. "There is no dispute that Epstein sexually abused Jane Doe 2 while she was a minor," he wrote. "Therefore, regardless of her comments to the prosecutor, she was a victim." > Before the case is finally resolved, Scarola predicted that "a lot of people are going to have to answer a lot of questions." In his ruling, Marra detailed what appeared to be a cozy relationship between Acosta, his line prosecutors and Epstein's team of lawyers. His phalanx of lawyers included noted Harvard law professor Alan Dershowitz and Kenneth Starr, the former U.S. solicitor general whose investigation led to the impeachment of President Clinton. Marra describes an October 2007 breakfast meeting between Acosta, who is now U.S. labor secretary, and Lefkowitz shortly after the non-prosecution agreement was A inked. After the meeting, Lefkowitz sent Acosta a note than • AS him for "the commitment you made to me durin October 12 meeting in which you assured me tha Office would not ... contact any of the ide individuals, potential witnesses, or po claimants and their respective counsel in thi Marra quoted an equally ple najte then-Palm Beach County State Attorney Bali ris her sent to Assistant U.S. Attorney Vill o was the lead prosecutor in Epstein's case. uld get this worked out for reasons I wo riting," Krischer wrote, shortly after the non-p cution agreement was signed. "After this is resolve uld love to buy you a cup at Starbucks and a con ersation." y of the notes that were exchanged dealt with ,..÷prosecutors' and Epstein's lawyers' shared desire to keep the deal secret from Epstein's accusers. In a September email, Villafana asked Lefkowitz for guidance about what she should reveal. "And can we have a conference call to discuss what I may disclose to ... the girls regarding the Agreement," she asked. Such cooperation between prosecutors and defense attorneys is unusual, Marra said. "It was a deviation from the government's standard practice to negotiate with defense counsel about the extent of crime victim notifications," he wrote. Further, he noted, that when and his two young clients asked for information, they were repeatedly misled. "The CRVA was designed to protect victims' right and ensure their involvement in the criminal justice process," Marra wrote. "When the government gives information to victims it cannot be misleading." AS Ultimately, the terms of the non-prosecution agr were revealed only after and attorneys f press successfully sued to make them publ' jmusgrave@pbpost.com iS ) @pbpcourts 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 se , trafficking, conspiracy charges in federal cj in Manhattan Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on to charges accusing him of creating a vast network of girls for his sexual pleasure at his homes in Palm Beach and pleaded not guilty g as 14 that he exploited The 66-year-old money manager's appearance in U.S capped more than a decade of recriminations by y claimed Epstein used his money and political i ourt in New York City n and their attorneys who avoid federal prosecution. Epstein's attorney Reid Weingarten dismisse charges as "essentially a do-over" of alleg County Jail for 13 months more than a o. ount indictment on sex trafficking anded Epstein in the Palm Beach However, unlike in 2007 when then shelve a 53-page federal indictm prostitution charges, prosecute, now U.S. labor secretary. rida U.S. Attorney Alex Acosta agreed to stein agreed to plead guilty to two state ork indicated they aren't willing to deal. Acosta is "The alleged behavior shocks Berman said at a nscience," New York City U.S. Attorney Geoffrey morning news con is still profound( deserve their And while the charged conduct is from a number of years ago, it rtant to many of the alleged victims, now young women. They At a deten keep E tel commit icking. Epstein paid dozens of young women to give him nude massages that, for m t, led to sex, he said. scheduled for Monday, Berman said he will ask a federal judge to d bars until he is tried on charges of sex trafficking and conspiracy to If convicted of exploitiiirens 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 Gunfire, who has accused Epstein of turning her into his sex slave and forcing her to have sex with others, including Dershowitz and Prince Andrew, praised Berman. He showed the case is "being taken in a serious ay," she told the Associated Press. Dershowitz has vehemently denied Guiffre's claims. New York prosecutors were able to ignore the controversial nonprosecutio because it contained some significant fine print, said former federal Jude Cassell, who for years has fought to get the agreement thrown out. It says only that could be filed against Epstein in South Florida, he said. Berman agreed. "That agreement only binds, by its terms, only bi Southern District of Florida," he said. "The Southern District of New York is not min at agreement and wasn't a signatory of it." That means the sordid allegations that have been level a federal indictment. n for years are now part of Contrary to Epstein's claims, he knew the women Palm Beach were minors because they told hi Epstein preyed on young girls because he prosecutors added. to his homes in New York and according to the indictment. ere "vulnerable to exploitation," As part of a carefully orchestrated sex he was in New York so they would indictment says. The employees "Employee-2" and "Employe Ep in or his associates would call girls while e for sex once he returned to Palm Beach, the ed. They were identified only as "Employee-1," To ensure he had a steady str recruiters. He would pa hem to ring new girls to his home on El Brillo Way along the Intracoastal Waterway In Beach or to his palatial townhouse on New York's Upper East Side. young girls, Epstein would turn some victims into "This allowed E to create an ever-expanding web of new victims," Berman said. In both New o alm Beach, the lurid operation was similar. Unidentified employees of Epstei scort the teens into a room. They were told to take off all or most of their cloth wing the naked billionaire massages, according to the indictment. "Epstein ould 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 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 wars 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 : oche federal government could have been involved in a conspiracy to violate law," Scarola said of his interest in continuing the legal battle over the nonprosecutio ent. When Acosta agreed to drop the federal investigation, Epstein in 2 guilty to two prostitution charges and served 13 months of an 18-month senten to a acant wing of the Palm Beach County Jail - a cell he was allowed to leave 12 h , six days a week. He was also forced to register as a sex offender and settle civi more than 30 young women filed against him. U.S. Rep. Lois Frankel, D-West Palm Beach, said s s carola's interest in finding out how the agreement came to be."I am especially m ed in why Epstein got the deal he got," Frankel said. "We need to know why h i n such an easy sentence. While she has asked the House Oversight C o investigate Acosta, Frankel said she is not sure that will happen. "It just seems as a travesty that this guy got off the way he did and, without pre-judging i ha a proper court case," Frankel said. Former Palm Beach Police Chief ter was inflamed in 2006 when then-State Attorney Barry Krischer refused pstein with serious crimes. Reiter took the information his officers had g ie m dozens of Epstein's victims to Acosta, believing he would prosecute Epstein. t. Reiter said he was heart 3 years later, Epstein will finally face justice. "Thankfully, U. S. Attom judgment to inves kte an Florida over a de an and the other authorities in New York have the good prosecute Epstein in the way that should have occurred in o," Reiter said in a statement. And, Scarola are signals that Berman's investigation is far from over. Berman d friends investigat answer questions about whether others, such as Epstein's high-powered be charged. He brushed off questions about the significance that the was being handled by the Public Corruption Unit. 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 Co SA iS)/49