Epstein motion for return of property seized in 2005 Palm Beach search

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

STATE OF FLORIDA¶

vs.¶

JEFFREY EPSTEIN,¶

Defendant.¶

CASE NO.: 2006CF009454AXX DIVISON: “W”¶

DEFENDANT’S MOTION FOR RETURN OF PR¶

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COMES NOW the Defendant, JEFFREY EPSTEIN, by ugh hig undefiigned attorney, and moves this Honorable Court to enter an O turn of property seized on October 20, 2005 during execution of a search a *e I endant’s residence. In support thereof the Defendant states as follows:¶

1. On October 20, 2005, the Palm the Defendant’s residence. Durin Defendant’s personal property NPo ite Department executed a search warrant at ution of the warrant, numerous items of the zed and impounded by the Palm Beach Police Department. A copy of the se rrant return is attached to this motion (Exhibit A).

2. On June 0, 20 e criminal charges arising from the search warrant were resolved through a nego agreement.

3. le I justification exists for the continued impoundment of the Defendant’s personal .perry. The Defendant is entitled to the return of all personal property listed in Exhibit A.

WHEREFORE, the Defendant, JEFFREY EPSTEIN, respectfully requests this Honorable Court to enter an Order for the return of his personal property.¶

CERTIFICATE OF SERVICE¶

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion was sent via FAX and U.S. MAIL to Lanna Belohlavek, Esq., Assistant State Attorney, 401 North Dixie Highway, West Palm Beach, Florida 33401, this 2\ s”k”day of July, 2008.¶

ATTERBURY, GOLDBERGER & WEISS, P.A. 250 ustralian Avenue South, Suite 1400 (56 65 -8300 O ‘4S’ W Palm Beac Florida 33401 C . LBERGER, ESQ Bar Number 262013,,),, CiS”1¶

Pg 1 of 6¶

PROPERTY	FOUND	DECEASED (Probated)	PERSONAL	CONFISCATED	DESTROY
EVIDENCE	TRIAL	LABORATORY	STOLEN/RECOVERED	OTHER
INCIDENT/CITATION NUMBER 05-368	DATE/TIME RECOVERED 10-20-2005	PROPERTY NUMBER (Leave Blank) 05-1024	BIN NUMBER (Leave Blank)
ADDRESS WHERE PROPERTY IMPOUNDED 258 FL Brillo
DISCOVERED BY / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
OWNER / VICTIM’S NAME / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
SUSPECT’S NAME / D.O.B. Eostein Seff	ADDRESS	Street	City	Zip	PHONE
ADDT NL SUSPECT / D.O.B.	ADDRESS	Street	City	Zip	PHONE
SPECIAL INSTRUCTIONS			FOUND PROPERTY CLAIM 90 DAYS NOT CLAIM

| -------- | ---------- | ------- | --------------------------------------------------------- | | 1 | 1 | | Phone message book (kitchen) | | 2 | 3 | | Phone message book (office off kitchen) | | 3 | 3 | | file folder (massaged) w/ 2 mire files (Purk Box) | | 4 | 1 | | Shreddered paper marked on for + check | | 15 | 1 | | orange file folder marked message massage | | | | | * Items 2-5 from office off kitchen | | 16 | ✓ | | Birge massage table off from c/o 5-5 to THE OFF | | 7 | ✓ | | Brown massage table foreyer | | 8 | 1 | | Black framed photo of nude girl | | 9 | 99 | | pictures in frame to item 6-8 from the off | | 10 | | | D from yellow/blue room off kitchen off foreyer | | 11 | 8 | | Photos from office off pool area | | 12 | 2 | | Photos from table on left to Helling Room off pool area | | | 2 | | Photos table on right to pool area |¶

TOTAL PACKAGE WEIGHT¶

I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.¶

I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer.¶

SIGNATURE¶

DATE¶

SIGNATURE¶

7915 D2 ID# UNIT¶

RECEIVED BY¶

REASON¶

DATE/TIME RECEIVED¶

I, Joseph Recarey, the officer by whom this warrant was executed, do swear that the above inventory contains a true and detailed account of all the property taken by me, under the authority of this warrant. Sworn to and subscribed before me this 21 day of October 2005.¶

Joseph Recarey J 7915¶

Joseph A. Burns¶

PROPERTY	FOUND	DECEASED (Probated)	PERSONAL	CONFISCATED	DESTROY
EVIDENCE	TRIAL	LABORATORY	STOLEN/RECOVERED	OTHER
INCIDENT/CITATION NUMBER 05-368	DATE/TIME RECOVERED 10:20-05	PROPERTY NUMBER (Leave Blank) 05-1024	BIN NUMBER (Leave Blank)

ADDRESS WHERE PROPERTY IMPOUNDED 358 EL-Brillo
DISCOVERED BY / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
OWNER / VICTIM’S NAME / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
SUSPECT’S NAME / D.O.B. Fostin Jeff	ADDRESS 358 EL Brillo	Street	City	Zip	PHONE NUMBER
ADDITNL. SUSPECT / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
SPECIAL INSTRUCTIONS				FOUND PROPERTY 90 DAYS	CLAIM NOT CLAIM

ITEM-#	QUANTITY	VALUE	DESCRIPTION
13	2	✓	VHS trapes from Cridge By coul
14	2	*	CD’s marked Happy Brinder ↑ Cridge By coul
15	3		Photos framed from Cabana
16	1	✓	message book 1st floor S/W corner (top air)
17	1	✓	message book (from inside)
18	3		CD’s from desk
19	1	*	DV from desk (Xms # 1 at 7:20 am)
20	informed		Photos from desk from 1st floor S.W.
21	2		framed Photos from desk
22	2	✓	framed Photos from table in S/W corner of circle
23	3		Soap on Rope (NE Bedroom) (wh. to cog)
24	2		tub in Torpedo in Brown box
25	2		Soap in Rope (middle Bedroom) (wh. to cog)
			large framed Picture (from foyer into Missile Bedroom)
TOTAL PACKAGE WEIGHT

I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.		I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer.
SIGNATURE	DATE	SIGNATURE	ID# 7 915 D2 UNIT

PROPERTY	FOUND	DECEASED (Probated)	PERSONAL	CONFISCATED	DESTROY
EVIDENCE	TRIAL	LABORATORY	STOLEN/RECOVERED	OTHER	(ab)
INCIDENT/CITATION NUMBER 05-368	DATE/TIME RECOVERED 10-20-05	PROPERTY NUMBER (Leave Blank) 05-1024	BIN NUMBER (Leave Blank)

| ADDRESS WHERE PROPERTY IMPOUNDED¶

258 El Brillo
DISCOVERED BY / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
OWNER / VICTIM’S NAME / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
SUSPECT’S NAME / D.O.B. Eustacia Joff	ADDRESS	Street	City	Zip	PHONE NUMBER
ADDITIONAL SUSPECT / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
SPECIAL INSTRUCTIONS				FOUND PROPERTY	CLAIM
				90 DAYS	NOT CLAIM

| ---------------------- | ---------- | ------- | -------------------------------------------------------------------------- | | 27 | 1 | NCV | School TRANSCRIPT, [REDACTED] MASTER BOX FORM DC SK | | 28 | 1 | MAX | BOTTLE OF TOY TAIL, MASTER BOX FORM CR & COUZA MASTER BOX FORM (2) | | 29 | 3 | NCV | VIDEOTAPES 1/2” SEXIN CITY, EASTIN JANINE, HOUSE LE SBIANS FOUR, Return | | 30 | 6 | NCV | FRAMED PHOTOS FROM MEN’S BOMB FORM - MASTER BOX FORM | | 31 | 1 | NCV | GREEN MASSACE TABLE, MEN’S BOMB FORM - MASTER BOX FORM → DNA test 3 Greg | | 32 | 1 | NCV | THRIFTY RENTAL AGREEMENT FROM CHEVROLET SUBURBAN (COPIED) | | 33 | 1 | MAX | NOTE FROM [REDACTED] FROM CHEVROLET SUBURBAN. | | 34 | WKB | 11 | CD’S from office of P.K. Lichen | | 35 | 6 | | ZIP CD’S from Book case RETURN | | 36 | 2 | | 8 MM Video top ps from Book case RETURN | | 37 | 4 | | Compact flash cards from Book case RETURN | | 38 | 1 | | Flash card from Camera on book case - RETURN TO OWNER | | 39 | 3 | | ZIP CD’S from Book case RETURN | | 40 | 30 | | CD’S from Book case (it is 35-40 from Eustacia house) RETURN | | TOTAL PACKAGE WEIGHT | | | |¶

I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.¶

I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer.¶

SIGNATURE	DATE	SIGNATURE	ID#	UNIT
		[Signature]	AIS D2

SEARCH WARRANT RECTION¶

PROPERTY		FOUND	DECEASED (Probated)	PERSONAL	CONFISCATED	DESTROY
EVIDENCE		TRIAL	LABORATORY	STOLEN/RECOVERED	OTHER	lah
INCIDENT/CITATION NUMBER 05-368		DATE/TIME RECOVERED 10-20-05		PROPERTY NUMBER (Leave Blank) 05-1024		BIN NUMBER (Leave Blank)
ADDRESS WHERE PROPERTY IMPOUNDED 258 El Brillo
DISCOVERED BY / D.O.B.		ADDRESS		Street	City	Zip	PHONE NUMBER
OWNER’S NAME / D.O.B.		ADDRESS		Street	City	Zip	PHONE NUMBER
SUSPECT’S NAME / D.O.B. Epstein, Jeff 01-20-05		ADDRESS 358 El Brillo		Street	City	Zip	PHONE NUMBER
ADDTNL SUSPECT / D.O.B.		ADDRESS		Street	City	Zip	PHONE NUMBER
SPECIAL INSTRUCTIONS						FOUND PROPERTY 80 DAYS	CLAIM
						NOT CLAIM

| -------- | ---------- | ------- | ------------------------------------------------------- | | #41 | 1 | ✓ | Floppy disks from desk middle Shelf Return | | #42 | 1 | * | 2 IP drive disk from Guest room Return | | #43 | 1 | | Power Cord for CPU from Guest room | | #44 | 1 | ✓ | CPU from Guest Bedroom | | #45 | 10 | ✓ | 8 mm video Tapes in Guest Bedroom Return | | #46 | 1 | ✓ | Max 11 CD-R in Guest bedroom Return (COPIED) | | #47 | 10 | * | Disks in clear Box Return | | #48 | 7 | | ZIP DISKS from Guest room Return | | | | | Items # 35-48 from Guest bedroom | | #49 | 1 | | Message book from Guest house office Return | | #50 | 1 | | message book Return | | #51 | 2 | | Compact flash cards from | | #52 | 6 | | CD’s return #49-5 from Guest house office Return | | #53 | 1 | | CPU from Guest house office Return |¶

TOTAL PACKAGE WEIGHT¶

I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.¶

I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer.¶

SIGNATURE _____¶

DATE _____¶

SIGNATURE _____¶

7915 D2 ID# _____ UNIT _____¶

SEARCH WARRANT RETURN¶

PROPERTY	FOUND	DECEASED (Probated)	PERSONAL	CONFISCATED	DESTROY
EVIDENCE	TRIAL	LABORATORY	STOLEN/RECOVERED	OTHER	Cab
INCIDENT/CITATION NUMBER 05-368		DATE/TIME RECOVERED 10-20-05	PROPERTY NUMBER (Leave Blank) 05-1024		BIN NUMBER (Leave Blank)

ADDRESS WHERE PROPERTY IMPOUNDED 358 EL Brillo Palm Beach¶

DISCOVERED BY / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
------------------------	---------	--------	------	-----	--------------

OWNER’S NAME / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
-----------------------	---------	--------	------	-----	--------------

| SUSPECT’S NAME / D.O.B.¶

Epstein, Jeff 01-20-5	ADDRESS	Street	City	Zip	PHONE NUMBER
---------------------------------------------------------	---------	--------	------	-----	--------------

ADDT NL SUSPECT / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
--------------------------	---------	--------	------	-----	--------------

SPECIAL INSTRUCTIONS			FOUND PROPERTY	CLAIM
			90 DAYS	NOT CLAIM

| -------- | ---------- | ------- | -------------------------------------------- | | 54 | 1 | ✓ | Power cord to CPU #53 | | 55 | 1 | * | CPU from office off kitchen | | 56 | 1 | | Power cord to item #55 | | 57 | 3 | ✓ | CD’s return #55-57 from office off kitchen | | 58 | 1 | ✓ | Peach message table upstays (PENDEN) | | | | | (PENDEN) | | | | | (PENDEN) |¶

TOTAL PACKAGE WEIGHT¶

I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.¶

I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer.¶

SIGNATURE	DATE	SIGNATURE	ID#	UNIT
		[Signature]	7 915 DR

PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT¶

PROPERTY	FOUND	DECEASED (Probated)	PERSONAL	CONFISCATED	DESTROY
EVIDENCE	TRIAL	LABORATORY	STOLEN/RECOVERED	OTHER	(ab)
INCIDENT/CITATION NUMBER 05-	DATE/TIME RECOVERED 10 2005 14/0	PROPERTY NUMBER (Leave Blank) 05-1024	BIN NUMBER (Leave Blank)

ADDRESS WHERE PROPERTY IMPOUNDED 358 FL Bullo¶

DISCOVERED BY / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
OWNER’S NAME / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
SUSPECT’S NAME / D.O.B. RETURN JEF	ADDRESS 358 FL Bullo	Street	City	Zip	PHONE NUMBER
ADDTNL SUSPECT / D.O.B.	ADDRESS	Street	City	Zip	PHONE NUMBER
SPECIAL INSTRUCTIONS					FOUND PROPERTY 90 DAYS	CLAIM NOT CLAIM

ITEM	QUANTITY	VALUE	DESCRIPTION	RETURN
	1	*	GREEN DITO TO FLAVIE with DAKED GIRL	Return

TOTAL PACKAGE WEIGHT¶

I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt.	I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer.
SIGNATURE	DATE

| AB P 332 | 6 | 10-20-05 1500kg |¶