UNITED STATES DISTRICT COURT

INFORMATION

The United States Attorney charges that:

Defendant.

i

1. At all times material to this information, the defendant, was a resident of Palm Beach County, in the Southern District of Florida. The defendant was registered as a mortgage broker on December 20, 1996, in the State of Florida.

2. At all times material to this information, Mortgage Express, Inc., (hereinafter “Mortgage Express”) was a Florida corporation. Mortgage Express was incorporated on August 11, 1993 and was licensed as a mortgage brokerage business by the Department of Banking and Finance, State of Florida on September 1, 1993. At all times material to this Information, Mortgage Express maintained offices in Boca Raton, North Palm Beach, Palm Beach Gardens and Palm Beach, all in Palm Beach County, Florida. The

Public Records Request No.: 17-295

defendant worked in the Palm Beach Gardens

Office of Mortgage Express as a mortgage broker.

4

3. Ac all times material to this information, Bank of America was a financial institution whose deposits were insured by the Federal Deposit Insurance Corporation (-role.) .

4. At all times material Co this information, Republic Consumer Lending Group. a subsidiary of Republic National Bank of New York, was a corporation engaged in the business of private mortgage lending. Republic Consumer Lending Group lacer merged with ESBC Bank USA, in the State of New York.

5 At all times material to this information. Ohio Savings Bank was a bank whose deposits were insured by the Federal Deposit Insurance Corporation.

THE SCHEME WO ARTIFICE TO DETRAUR

5 It was the object of the scheme and artifice to defraud that the defendatit would and did obtain mortgage financing for himself and for customers of Mortgage Express by means of false and fraudulent pretenses. As a result, the defendant would obtain non:es and mortgage broker commissions in connection with fraudulently procured loans.

MAMMA AHD nasnantionix 6FP_ARTAFICR TO oRpRADD

8. In order to procure mortgage financing for himself and for customers of Mortgage Express, on various occasions, the defendant did knowingly and willfully submit false and fraudulent Information

2

in one or more mortgage application packages to: Bank of America. Republic Consumer Lending Group, and Ohio Savings Bank.

9. In the various mortgage applications. the defendant knowingly, willfully, and with intent to defraud caused one or more of the following types of fraudulent information to be submitted to the prospective lender: fictitious leases, false verifications of employment, (“vOEK), and false verifications of deposit (“VOD”).

usE Op ZER MAI14

10. Paragraphs 1-9 are realleged and incorporated by reference herein

11. On or about August 26, 1998, in Palm Beach County, in the Southern District of Florida, the defendant,

for the purpose of executing the aforesaid scheme and artifice to defraud and for obtaining money by meohs of false and fraudulent pretenses. did knowingly cause to be delivered according to the directions thereon. by a private or commercial interstate carrier. that is, Airborne Express, from mortgage Express in Palm Beach Gardens, Florida to Republic Consumer Lending Group in hventura. Florida, the mortgage loan application package of Howard and Mary Siira, which application contained one or more false verifications of employment (-Inn”), in violation of Title 18, united States Code, Section 1341 and 2.

’An FRAU

;OMIT 1.1

12. Paragraphs 1-9 are realleged and incorporated by reference herein.

13. On or about May 7, 1999, in Palm Beach County. in the Southern District of Florida, the defendant

knowingly, willfully and with intent to defraud executed a Scheme to obtain monies from a financial institution under false and fraudulent pretenses. that is, to obtain a loan from Bank of America in Fairfax. Virginia. In order to execute this scheme the defendant caused Bank of America to fund a mortgage loan to Jose M. Abejon, under false and fraudulent pretenses, that is, a fictitious lease was submitted with the loan application. which fictitious lease was intended to cause the lender to believe that tne applicant had more assets than was otherwise true, all in violation of Title 18. United States Code, Section 1344 and 2.

count 111

13. Paragraphs 1-9 are realleged and incorporated by reference herein.

14. On or about March 31, 1999, in Palm Beach County, in the Southern District of Florida, the defendant

knowingly, willfully and with intent to defraud executed a scheme

4

07)2617 Page 5 Public Records Request No.: 17-295

P.7/20

to obtain monies from a financial institution under false and fraudulent pretenses, that is, to obtain a loan from Ohio Savings Bank, in Cleveland, Ohio. In order to execute this scheme the defendant committed one or more of the following acts:

(i) The defendant caused Ohio Savings Bank to fund a mortgage loan to the defendant. (International), under false and fraudulent pretenses, that is, the defendant submitted one or more false Verifications of Deposit (“VOD”) with the loan application, which verifications of deposit were intended to cause the lender to believe that the applicant had more assets than was otherwise true,

(ii) The defendant caused Ohio Savings Bank to fund a mortgage loan to the defendant, Constant of Second Second under false and fraudulent pretenses, the defendant misstated the purchase price of the property, leading the bank to believe that the defendant was making a greater down payment than was actually true, all in violation of Title 18. United States Code, Section 1344 and 2.

UNITED STATES ATTORNEY

NANCY VORPE QUINLAN ASSISTANT UNITED STATES ATTORNEY

5

VII. My Boy Shorts Lyrics

41,

(ToiNn iS -We- Scd-PIA: iiedoS

My Boy Shorts by Triple J

My Boy shorts, my boy shorts

I know you want to see me in my boy shorts, my boy shorts my boy shorts I know you want to see me in my boy shorts.

Baby, what you name is?

I know you.

No you don’t know me cause I aint never came here, I got another spot I frequent

Yeah you look good but what I just seen with those big old draws.

Nigger these aint draws.

what they called?

These boy shorts.

Look how they crawl -.little mamma don’t take those off - just walk around in them.

Let me see that boody bounce up and down in them - do it one cheek at a time.

Yeah that’s it let me smell that shit - mmmmm, that pussy aint got no fumes.

That boody done swallowed that little shorts.

Damn its soft, what it costs?

All these hocs got they close off, but look at that girl in the boy shorts

I know they look good, you gotta love em, my ass (Inaudible)

All of these hoes got they close off but look at that girl in the boy shorts

I know they look good, you gotta love em, my ass (Inaudible)

Man I hate when the bitch try to act all snooty, you all act like a nigger can’t slap your boody.

Bitch I’ll leave my hand print on it. Get that nigger you call, he don’t want it. But I know what I want.

What?

A taste of that (inaudible) what, think I don’t? Shit, I’ll flood that twat. (Inaudible) I’ll rub that spot.

O000hhhhhh.

It feel good, don’t it?

Yeahhhh.

Turn around for me, back it up on me. Bring your ass over, touch your toes, bust it open, show me that boody hole.

Just pull them shorts to the side, I aint no trick but if you’ll slip I’ll slide right up in it, but wait one minute you still aint said what it costs, I’ll spend it.

All of these hoes got they close off but look at that girl in the boy shorts.

I know they look good, you gotta love em, my ass (Inaudible).

All of these hoes got they close off but look at that girl in the boy shorts.

I know they look good, you gotta love em, my ass (Inaudible).

Yeah I like g-strings, I like thongs, I like girls with no bras on.

But they nothing like them boy shorts, wedged all up in her ass when she walks,

But you know the butt got to be big it look like a thong no baby don’t dig, be proud of that fat

(that’s right) A nigger don’t want to see no slack in the back. Boody looking like a (inaudible)

But some flat boody holes got fat pussy (inaudible) So I guess I can (inaudible) too, but yours

looks awesome boo.

By the way, my name Triple J, 568 in your face. Palm Beach county, heading straight from the Raw, we take hoes all (inaudible)

All of these hoes got they close off but look at that girl in the boy shorts.

I know they look good, you gotta love em, my ass (Inaudible).

All of these hoes got they close off but look at that girl in the boy shorts.

07/26117 Page 9 Pu0lic Records Request No.: 17.295

I know they look good, you gotta love em, my ass (Inaudible).

My Boy Shorts by Triple

My Boy shorts, my boy shorts

I know you want to see me in my boy shorts, my boy shorts my boy shorts I know you want to see me in my boy shorts.

Baby, what you name is?

I know you.

No you don’t know me cause I aint never came here, I got another spot I frequent

Yeah you look good but what I just seen with those big old draws.

Nigger these aint draws.

what they called?

These boy shorts.

Look how they crawl -, little mamma don’t take those off - just walk around in them.

Let me see that boody bounce up and down in them - do it one cheek at a time.

Yeah that’s it let me smell that shit - mmmmm, that pussy aint got no fumes.

That boody done swallowed that little shorts.

Damn its soft, what it costs?

All these hoes got they close off, but look at that girl in the boy shorts

I know they look good, you gotta love em, my ass (Inaudible)

All of these hoes got they close off but look at that girl in the boy shorts

I know they look good, you gotta love em, my ass (Inaudible)

Man I hate when the bitch try to act all snooty, you all act like a nigger can’t slap your boody.

Bitch I’ll leave my hand print on it. Get that nigger you call, he don’t want it. But I know what I want.

What?

A taste of that (inaudible) what, think I don’t? Shit, I’ll flood that twat. (Inaudible) I’ll rub that spot.

O000hhhhhh.

It feel good, don’t it?

Yeahhhh.

Turn around for me, back it up on me. Bring your ass over, touch your toes, bust it open, show me that boody hole.

Just pull them shorts to the side, I aint no trick but if you’ll slip I’ll slide right up in it, but wait one minute you still aint said what it costs, I’ll spend it.

All of these hoes got they close off but look at that girl in the boy shorts.

I know they look good, you gotta love cm, my ass (Inaudible).

All of these hoes got they close off but look at that girl in the boy shorts.

I know they look good, you gotta love em, my ass (Inaudible).

Yeah I like g-strings, I like thongs, I like girls with no bras on.

But they nothing like them boy shorts, wedged all up in her ass when she walks,

But you know the butt got to be big it look like a thong no baby don’t dig, be proud of that fat

(that’s right) A nigger don’t want to see no slack in the back. Boody looking like a (inaudible)

But some flat boody holes got fat pussy (inaudible) So I guess I can (inaudible) too, but yours

looks awesome boo.

By the way, my name Triple J, 568 in your face. Palm Beach county, heading straight from the Raw, we take hots all (inaudible)

All of these hoes got they close off but look at that girl in the boy shorts.

I know they look good, you gotta love cm, my ass (Inaudible).

All of these hoes got they close off but look at that girl in the boy shorts.

I know they look good, you gotta love em, my ass (Inaudible).

David Patrick Columbia’s NEW YORK SOCIAL DIARY

HOME | PARTY PICTURES | SOCIAL DIARY | SHOPPING DIARY | THE LIST | CALENDAR | ARCHIVES |

A beautiful warm day in New York

Under a canopy of Cherry Blossoms in Central Park. 1:45 PM. Photo: JH.

Some people were beginning to complain about the heat. A good sign. Beauty abounds.

I went to an early dinner over at Swifty’s with some old friends in from out of town. The place was jammed on this early Monday night in New York.

At the table by the open windows was Lee Radziwill with friends. At another table, Jim was dining with Laura Codman, in from Texas on her way to London. Laura is directly descended from Ogden Codman, the gran-pappy of 20th century interior design. Ogden Codman is now the god of interior design. Talk about influence, talk about power in New York! Except he’s dead. Daid. And I’ll bet at least 50% of the design community (sorry, but I’ll bet I’m right) doesn’t have a clue as to WHO Ogden Codman is/was. Or even his collaborator Edith Wharton. That’s okay, that’s show biz.

http://wW26/newyorksocialdiary.com/socialdiary/2004704120\_04/socialdiary042004.php

Michael Bebon, Wendy =. and Woody Heller Nina Shapiro, Alison Schneider, and Dr. Patricia Ca

http://watgwyorksocialdiary.com/socialdiary/20014762110\_04/socialdiaryalibtrAirest

001

ΤY

COMMITTE TO JUSTICE. TRUTH & S.

February 21, 2008

VIA: FACSIMILE & U.S. MAIL Jack A. Goldberger, Esq. Atterbury, Goldberger, et al 250 S Australian Ave Ste 1400 West Palm Beach, FL 33401-5015

Re: Jane Doe v. Epstein

Dear Jack:

This letter is written due to the deep and serious concern about the ethics of your co-counsel. Because your co-counsel refused to provide copies of the documents and photographs used in his direct examination of yesterday to the State Attorney or me, which is the professional and customary thing to do, and the fact that he refused to even allow the court reporter to mark the documents as exhibits I am quite fearful we may never see the exhibits again.

Therefore I am compelled to write this letter to confirm that you have agreed that you will provide the State Attorney and me copies of all the exhibits, properly identified, that were used during the direct examination.

Very truly yours

THEODORE J. LEOPOLD

TJL:ms

ce: Michael Tein, Esq. (via facsimile and regular mail) Lanna Belohlavek, Esq. (via facsimile and regular mail

2925 PGA Boulevard To Suite 200 # Paim Beach Gardens M Florida 33410 # 561.684.6500 # fax 561.697.2383 # ricciaw.com CRASH 107025/10/INESS · INSURANCE BAD FAITH · MANAPED CARE ABUSE · PERSONAL MEDDAS Relations FLA2005 ATH

COMMITTER TO JUSTICE, TRUTH & SAFETY

February 21, 2008

VIA: FACSIMILE & U.S. MAIL Jack A. Goldberger, Esq. Atterbury, Goldberger, et al 250 S Australian Ave Ste 1400 West Palm Beach, FL 33401-5015

Re: Jane Doe v. Epstein

Dear Jack:

This letter is written due to the deep and serious concern about the ethics of your co-counsel. Because your co-counsel refused to provide copies of the documents and photographs used in his direct examination of yesterday to the State Attorney or me, which is the professional and customary thing to do, and the fact that he refused to even allow the court reporter to mark the documents as exhibits I am quite fearful we may never see the exhibits again.

Therefore I am compelled to write this letter to confirm that you have agreed that you will provide the State Attorney and me copies of all the exhibits, properly identified, that were used during the direct examination.

Very truly yours

THEODORE J. LEOPOLD

TJL:ms

c¢:

Michael Tein, Esq. (via facsimile and regular mail) Lanna Belohlavek, Esq. (via facsimile and regular mail

2925 PGA Boulevard ■ Suite 200 ■ Palm Beach Gardens ■ Florida 33410 ■ 561.684.6500 ■ fax 561.697.2383 ■ riccilaw.com CRASHWORTHINESS · INSURANCE BAD FAITH · MANAGED CARE ABUSE · PERSONAL INJURY · WRONGFUL DEATH

2925 PGA Boulevard • Sues 200 Palen Beach Gardens • FL 33410

Ale 0: 080044

049382034925 $ 00.410 02121/2008 Mailed F70/71 33410 US POSTAGE

I

Lanna Belohlavek, Esq. Office of the Florida State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401

Z83ACii+42’77.16 -

HERMAN & MERMELSTEIN PA

ATTORNEYS AT LAW

Tel 305-931-2200 Fax 305-931-0877

18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 www.hermanlaw.com

FAX TRANSMITTAL SHEET

THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL. OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN.INFORMATION THAT IS PRIVILEGED. CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPIJCABLF. LAW. IF THE READEROE THIS MESSAGE IS NCITTHE WENDED RECEPIENTOR THE EMPLOYEEORAGCNT RISPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTWIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF TIILS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED TITS COMMUNICATION IN ERROR, PLEASENOTIFY US IMMEDIATELY BY TELEPHONE, AND RETURN THE ORIGINAL MESSAGE TO US ATTIE ABOVE ADDItEXS VIA THE US. POSTAL SERVICE. THANK YOU

HERMAN & MERMELSTEIN PA

ATTORNEYS AT LAW

Jeffrey Herman Tel 305-931-2200 Fax 305-931-0877 ihorman@hennanlaw.com

18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 vsWW.hermanlaw.com

February 5, 2008

VIA FACSIMILE

Lanna Leigh Belohlavek State Attorney’s Office 401 N. Dixie Hwy West Palm Beach, FL 33401

Re: State of Florida v. Jeffrey Epstein, Case No. 2006CF009454AXX

Dear Ms. Belolavek:

was apparently served with the attached subpoena sometime last week. It is a Subpoena for Deposition who is not presently residing with _ :I. I attempted to contact you today to discuss this matter, unsuccessfully. The deposition is scheduled for February 6 at 9:30 a.m. It is my understanding that is not aware of this subpoena and will not be appearing for the deposition. In addition, I do not know that service of the subpoena on -is sufficient for because she does not reside with him.

Mr. Epstein’s counsel Jack Goldberger is aware that I represent n a civil claim filed on behalf of his daughter - I however, he did not send me a copy of the notice or subpoena for deposition, nor did he contact me to coordinate same. In the future, I would appreciate if your office and Mr. Goldberger’s office would keep me in the loop on the scheduling of the depositions for the

Thank you for your assistance in this regard.

Very truly yours,

g.e6 Net ^{k r} ,

Jeffrey Herman

JMII/Ir cc: Jack Goldberger, Esq. (via facsimile 561-835-8691)

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

CRIMINAL DIVISION “W”

CASE NO.: 06-CF009454AXX

STATE OF FLORIDA,

vs.

JEFFREY EPSTEIN, Defendant.

ORDER DENYING MOTION FOR PROTECTIVE ORDER

THIS CAUSE came before the Court, in , upon receipt of “Response to the Motion for Protective Order” dated February 8, 2008, filed by Jack A. Goldberger, Esquire, received in undersigned on February 11, 2008 (not docketed). The Court has reviewed the “Motion for Protective Order” and said Response. Based upon the Court’s review of the foregoing, it is hereby

ORDERED AND ADJUDGED that the “Motion for Protective Order” dated February 5, 2008, is hereby, DENIED as being moot. There is no need for a hearing on this matter.

DONE AND ORDERED in at WeskiyAreicmletyntruch County, Florida, this the day of Februarfer

FEB 1 2 2008

JUDGE SANDRA K. McSORLEY

SANDRA K. McSORLEY Circuit Judge

copies furnished:

Lana Belohlavek, Assistant State Attorney, 401 N. Dixie Highway, West Palm Beach, FL 33401 Jack A. Goldberger, Esquire. 250 S. Australian Ave., Ste. 1400. West Palm Beach, FL 33401 Theodore J. Leopold. Esquire, 2925 PGA Blvd.. Ste. 200, Palm Beach Gardens, FL 33410

ker/020708

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

CASE NO. 2006CF009454A

STATE OF FLORIDA

VS.

JEFFREY EPSTEIN,

Defendant.

RESPONSE TO MOTION FOR PROTECTIVE ORDER

COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his attorney and files his response to the Motion For Protective Order filed by counsel for State’s witness Jane Doe No. 1.

1. In summary fashion, counsel for Jane Doe No. 1 complains that serving a witness for deposition by the use of a process server and the service of the witness’ parents for the deposition to ensure service, amounts to “continuous and systematic harassment”. ¹

2. The Motion For Protective Order was filed by one of the attorneys purporting to represent Jane Doe No. 1 in a separate civil proceeding.² While disagreeing with the

^<sup>1 Undersigned counsel for the Defendant responds only to the issues in the Motion for Protective Order concerning service of a subpoena for deposition and the date for that deposition. Defendant and undersigned counsel have no knowledge of any agent of the Defendant going to the witness’ place of employment representing “himself as an attorney who needed to contract (sp) her” as alleged “on information and belief” in paragraph 8 of the Motion for Protective Order.

^<sup>2 The Motion for Protective Order was filed by attorney Theodore Leopold. While he purports to represent Jane Doe No.1, attorney Jeffrey Herman also claims to represent the interests of Jane Doe No. 1. In that separate civil proceeding, the two law firms are presently litigating who represents the interests of Jane Doe No. 1.

assertion in the Motion For Protective Order that Mr. Leopold and the undersigned agreed that Mr. Leopold would accept service on behalf of Jane Doe No. 1, and that the undersigned had agreed not to take the disposition on February 6, 2008, the matter has been rendered moot.

3. Prior to filing of a Motion For Protective Order, Mr. Leopold and the undersigned conferred and agreed in writing with the consent of the State Attorney’s Office to the taking of Jane Doe No.1’s deposition on February 20, 2008. The parties have also agreed that Mr. Leopold will accept service for Jane Doe’s No.1’s appearance on that date eliminating the need to use a process server to serve Jane Doe No.1. See Exhibit “A” attached. (Jane Doe No. l’s real name has been redacted from the exhibit.)

WHEREFORE, given the fact that the parties have agreed to a procedure for the taking of Jane Doe’s No.1’s deposition, it is respectfully requested that this Court deny Jane Doe No.1’s Motion for Protective Order as moot.

I HEREBY CERTIFY that a copy of the foregoing has been furnished by mail to Lanna Belohlavek, Esquire, The Office of the State Attorney, 401 North Dixie Highway, West Palm Beach, Florida 33401, Theodore J. Leopold, Esquire, 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida, 33410 and Jeffrey Herman, Esquire, 18205 Biscayne Boulevard, Suite 2218, Miami, Florida, 33160, on this 7th day of February, 2008.

ATTERBURY GOLDBERGER & WEISS, P.A. 250 A traliar venu: South Suit We •rida 33401 (56 CK A. GOLDBERGER, ESQ. lorida Bar No.: 262013

07)26)17 Page 23 Public Records Request No.: 17-295

February 5, 2008

’ 1 JACK A. GOLDBERGER JASON S.WEISS

’ Board Cot-tilted Crarranal Trial AUDI ney oi New Jersey & Honda Ban

VIA FACSIMILE h U.S. MAIL (561)697-2383

Theodore J. Leopold, Esquire Ricci—Leopold 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410

Re: State of Florida vs. Jeffrey Epstein Case No.: 2006CF009454AXX

Dear Ted,

Based on your availability on February 20, 2008, we have scheduled the deposition of on that date beginning at 9:30 a.m. Assistant State Attorney, Lanna Belohlavek, has also committed to that date.

You have indicated to me that you will accept service on behalf of or that date. Accordingly, I am enclosing the notice of deposition and a subpoena for deposition for for February 20, 2008 beginning at 9:30 a.m.

If you are unwilling or unable to produce Ms.l for deposition, please advise me immediately, so I may have her served with a subpoena.

Jack A. Goldberger

JAG/na Enclosure

EFTA02855782

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

CASE NO. 2006CF009454AXX

STATE OF FLORIDA

SUBPOENA FOR DEPOSITION

VS.

JEFFREY EPSTEIN,

Defendant.

TO:

a minor c/o Theodore J. Lepold, Esquire 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410

YOU ARE COMMANDED to appear before a person authorized by law to take depositions on the 4th floor (Rooms 4.2004-4.2010), of the Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida on February 20, 2008 beginning at 9:30 a.m. for the taking of your deposition in this action. If you fail to appear, you may be in contempt of court.

You are subpoenaed to appear by the following attorneys and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed.

WITNESS my hand and seal of said Court on this 5th day of February, 2008.

Jack A. Goldberger, ESQ. For the Court 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 (561) 659-8300

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

CASE NO.: 2006CF009454AXX

STATE OF FLORIDA

NOTICE OF DEPOSITION

JEFFREY EPSTEIN, Defendant.

vs.

TO: Lamm Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on February 20, 2008 beginning at the hour of 9:30 A.M., at the Palm Beach County Courthouse, 4th Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:

before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:

930 A.M.

Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.

This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are permitted under the applicable Statutes or Rules of Court.

I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee and Thedore J. Leopold, Esquire, 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida 33410 by via fax & mail this 5th day of February, 2008.

ATT’ERBURY, GO DBERGER, & WEISS, P.A. 250 Australian A nue South, Suite 1400 Wes aim Beac , Florida 3340] (561 9-8300 fax• 1)835 .691 JA I K A. GOLDBERGER, ESQUIRE 07f26/17 Fl 4 2§ar No. 262013 Public Records Request No.: 17-295

ATTERBURY GOLDBERGER WEISS,

R. ATTERBURY

JACK A. GOLDBERGER

JASON S. WEISS

Board CortiBed Criminal Trial Attorney , Member of New Jersey & Florida Bars

February 8, 2008

The Honorable Sandra McSorley Circuit Court Judge Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401

RE: State of Florida v. Jeffrey Epstein Case No. 2006CF009454A

Dear Judge McSorley:

Enclosed please find a courtesy copy of the Defendant’s Response to the Motion for Protective Order filed by Theodore Leopold.

/y V i I ours,

Jack A Goldberger

JAG/slm Enclosure cc: Lanna Belohlavek, ASA Theodore Leopold

07/266/17 One Clearlake Centre. Suite 1400 250 Austylinvenue South West Purl ruouceach, 1 134 Keque01 Nejat st No.: 17-295

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

CASE NO. 2006CF009454A

STATE OF FLORIDA

VS.

JEFFREY EPSTEIN,

Defendant.

RESPONSE TO MOTION FOR PROTECTIVE ORDER

COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his attorney and files his response to the Motion For Protective Order filed by counsel for State’s witness Jane Doe No. 1.

1. In summary fashion, counsel for Jane Doe No. 1 complains that serving a witness for deposition by the use of a process server and the service of the witness’ parents for the deposition to ensure service, amounts to “continuous and systematic harassment”. ¹

2. The Motion For Protective Order was filed by one of the attorneys purporting to represent Jane Doe No. 1 in a separate civil proceeding.² While disagreeing with the

^<sup>1 Undersigned counsel for the Defendant responds only to the issues in the Motion for Protective Order concerning service of a subpoena for deposition and the date for that deposition. Defendant and undersigned counsel have no knowledge of any agent of the Defendant going to the witness’ place of employment representing “himself as an attorney who needed to contract (sp) her” as alleged “on information and belief” in paragraph 8 of the Motion for Protective Order.

^<sup>2 The Motion for Protective Order was filed by attorney Theodore Leopold. While he purports to represent Jane Doe No.1, attorney Jeffrey Herman also claims to represent the interests of Jane Doe No. 1. In that separate civil proceeding, the two law firms are presently litigating who represents the interests of Jane Doe No. 1.

assertion in the Motion For Protective Order that Mr. Leopold and the undersigned agreed that Mr. Leopold would accept service on behalf of Jane Doe No. 1, and that the undersigned had agreed not to take the disposition on February 6, 2008, the matter has been rendered moot.

3. Prior to filing of a Motion For Protective Order, Mr. Leopold and the undersigned conferred and agreed in writing with the consent of the State Attorney’s Office to the taking of Jane Doe No.1’s deposition on February 20, 2008. The parties have also agreed that Mr. Leopold will accept service for Jane Doe’s No.1’s appearance on that date eliminating the need to use a process server to serve Jane Doe No.1. See Exhibit “A” attached. (Jane Doe No. 1’s real name has been redacted from the exhibit.)

WHEREFORE, given the fact that the parties have agreed to a procedure for the taking of Jane Doe’s No.1’s deposition, it is respectfully requested that this Court deny Jane Doe No.1’s Motion for Protective Order as moot.

I HEREBY CERTIFY that a copy of the foregoing has been furnished by mail to Lanna Belohlavek, Esquire, The Office of the State Attorney, 401 North Dixie Highway, West Palm Beach, Florida 33401, Theodore J. Leopold, Esquire, 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida, 33410 and Jeffrey Herman, Esquire, 18205 Biscayne Boulevard, Suite 2218, Miami, Florida, 33160, on this r day of February, 2008.

ATTERBURY GOLDBERGER & WEISS, P.A. 250 A tralia •venu: South Suit- 00 We- Im ea h. F rida 33401 (56 CK A. GOLDBERGER, ESQ. orida Bar No.: 262013

07:26:17 Page 29 Public Records Request No.: 17-295

ATTERBURY GOLDBERGER . WEISS, IN

* R. ATTERBURY

JASON S.WEISS

* Board Certified Criminal Trial Attorney † Member of New Jersey & Florida Bars

February 5, 2008

VIA FACSIMILE & U.S. MAIL (561)697-2383

Theodore J. Leopold, Esquire Ricci~Leopold 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410

Re: State of Florida vs. Jeffrey Epstein Case No.: 2006CF009454AXX

Dear Ted,

Based on your availability on February 20, 2008, we have scheduled the deposition of on that date beginning at 9:30 a.m. Assistant State Attorney, Lanna Belohlavek, has also committed to that date.

You have indicated to me that you will accept service on behalf of Accordingly, I am enclosing the notice of deposition and a subpoena for deposition for for February 20, 2008 beginning at 9:30 a.m.

If you are unwilling or unable to produce Ms. for deposition, please advise me immediately, so I may have her served with a subpoena.

yours

Jack A. Goldberger

JAG/na Enclosure IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA

CASE NO.: 2006CF009454AXX

STATE OF FLORIDA

NOTICE OF DEPOSITION

vs.

JEFFREY EPSTEIN, Defendant.

TO: Lanna Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401

PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on February 20, 2008 beginning at the hour of 9:30 A.M., at the Palm Beach County Courthouse, 4th Floor. 205 North Dixie Highway. West Palm Beach. Florida 33401:

before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:

9:30 A.M.

Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.

This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are permitted under the applicable Statutes or Rules of Court.

I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee and Thedore J. Leopold, Esquire, 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida 33410 by via fax & mail this 5th day of February, 2008.

ATTERBURY, GO aBERGER, & WEISS, P.A. 250 Australian A nuc South, Suite 1400 Wes Palm Beac , Florida 33401 (561 9-8300 fax• 1)835 .691

JA t K A. GOLDBERGER, ESQUIRE 07/26/17 Fl r rimer No. 262013 Public Records Request No.: 17-295

EFTA02855789

Lanna Belohlavek, Esquire Office of the State Attorney 401 North Dixie Highway West Palm Beach, Florida 33401

33401$4296 CO21

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

CRIMINAL DIVISION “W”

CASE NO.: 06-CF009454AXX

STATE OF FLORIDA,

vs.

JEFFREY EPSTEIN, Defendant.

ORDER DIRECTING ATTORNEY FOR DEFENDANT TO RESPOND TO “MOTION FOR PROTECTIVE ORDER”

THIS CAUSE came before the Court, in upon the submission of a “Motion for Protective Order” dated February 5, 2008, but received in undersigned on February 06, 2008. Said Motion was filed by Theodore Leopold, attorney for a non-party. Based upon the Court’s review of the foregoing Motion, it is hereby

ORDERED AND ADJUDGED that Jack A. Goldberger, Esquire, attorney for the Defendant in the above-captioned case, shall respond in writing to said Motion within five (5) days from the date of this Order. It is further

ORDERED AND ADJUDGED that upon filing of said response, a courtesy copy of same shall be submitted to the undersigned’s

DONE AND ORDERED in at West Palm Beach, Palm Beach County, Florida, this the day of FebrualHartb AND DATED

FEB 0 7 223

s 14A614ifil-LT Circuit Judge

opies furnished:

Lana Belohloavek, Assistant State Attorney, 401 N. Dixie Highway, West Palm Beach, FL 33401 Jack A. Goldberger, Esquire. 250 S. Australian Ave.. Ste. 1400. West Palm Beach, FL 33401 Theodore J. Leopold. Esquire, 2925 PGA Blvd., Ste. 200, Palm Beach Gardens. FL 33410

ker/020708

COMMITTER TO JUSTICE, TRUTH & AFETY

February 5, 2008

VIA HAND DELIVERY

Honorable Sandra K. McSorley Circuit Criminal, Division W Palm Beach County Courthouse 205 N Dixie Highway West Palm Beach, FL 33401

Re: State of Florida v. Jeffrey Epstein Case No. 2006 CF 009454 A

Dear Judge McSorley:

Enclosed please find a copy of Jane Doe’s Motion For Protective Order. The undersigned would request ten (10) minutes of the Court’s time in which to present its motion.

Thank you for your consideration Respectfully submitted THEODORE MEOPOLD TJL:amd Enclosure

cc: Landa Belohlavek, Esq. (via Facsimile & U.S. Mail – w/ enclosure) Jack A. Goldberger, Esq. (via Facsimile & U.S. Mail – w/ enclosure)

2925 7636 Boulevard Suite 200 Palm Beach Gardens Flored 33410 561.684.6500 Public Records Request No.: 17-295 CRASHWORTHINESS · INSURANCE BAD FAITH · MANAGED CARE ABUSE · PERSONAL INJURY · WRONGFUL DEATH

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

STATE OF FLORIDA CASE NO: 2006 CF 009454 A

Plaintiff,

vs.

JEFFREY EPSTEIN

Defendant.

MOTION FOR PROTECTIVE ORDER

Jane Doe No. 1 (“Jane Doe”), by and through her mother and natural guardian, hereby files this Motion for Protective Order. As grounds for said motion, Jane Doe states as follows:

1. On July 19, 2006 the State of Florida filed a criminal Indictment against Jeffrey Epstein (“Epstein”).

2. Jane Doe, a victim of Epstein’s actions, recently filed a civil lawsuit against Epstein. The complaint alleges among other things that Epstein has a sexual preference and obsession for underage minor girls. That he engaged in a scheme in which he gained access to minor girls in his home, sexually assaulted these girls, and then gave them money. Jane Doe was one of Epstein’s victims. She was lured into Epstein’s Palm Beach home under false pretenses and was sexually assaulted by Epstein. As a result, Jane Doe suffered injuries, including intentional infliction of emotional distress damages.

3. After the filing of the civil lawsuit and during the week of January 25, 2008, Epstein’s criminal attorney, Jack Goldberger, Esq., contacted the undersigned to advise that he wished to take the deposition, in the criminal matter, of Jane Doe on February 6, 2008. The undersigned informed Mr. Goldberger that he would accept service on behalf of Jane Doe, but was not available on February 6, 2008. Counsel agreed to use best efforts to schedule the deposition at a mutually convenient date and time.

4. Despite these assurances and understanding, on Friday evening, February 1, 2008, Epstein’s process server served Jane Doe at her place of work for a deposition scheduled to take place on February 6, 2008. I See Subpeona attached as Exhibit “A” (Jane Doe’s real name has been redacted from the exhibit).

5. The undersigned was forced to call Mr. Goldberger on Friday evening and remind him of our earlier conversation and agreement and to insist that the deposition be re-noticed.2

6. After the conversation of Friday evening and with the expressed assurances that the undersigned would accept service for Jane Doe, two days later on Monday morning February 4, 2008, Mr. Goldberger had a process server serve Jane Doe’s mother who resides out of state in

See Subpoena attached as Exhibit “B” (Jane Doe’s mother’s name has been redacted from the exhibit).

7. The service of process on Jane Doe’s mother was defective as an Out of State Commissioner was never appointed and no order was issued by this court authorizing such service. Additionally, Mr. Goldberger had been told not once, but twice that the undersign would accept service on behalf of Jane Doe, yet despite this Epstein and/or his attorney has insisted on

I Mr. Goldberger unilaterally set Jane Doe’s deposition for February 6, 2008 despite knowing that the undersigned was not available on that date.

² Mr. Goldberger has now agreed to postpone the deposition.

having the victim’s privacy repeatedly intruded upon by process servers seeking her out at her employment and then again, intruding upon her mother.

8. Additionally, during this same time period yet another adult male came to Jane Does’ employment and represented himself as an “attorney” who needed to contract her. Upon information and belief that person was also an agent of Mr. Epstein’s.

9. It can only be concluded that Epstein and/or his counsel are purposefully attempting to harass Jane Doe and her mother. These actions are nothing more than a continuous insult to injury upon a young girl who has already been emotionally scarred for life.

WHEREFORE, Jane Doe, by and through Jane Doe’s mother and natural guardian, hereby move the Court for a Protective Order prohibiting Jeffrey Epstein and/or his counsel from continuous and systematic harassment.

I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by Facsimile and U. S. Mail, postage prepaid, this r ✓ day of February 2008 to all counsel on the attached service list.

Respectfully submitted, RICCI—LEOPOLD, P.A. 2925 PGA Blvd. Suite 200 Palm Beac Phone: 5 Fax: 5 . LEOPOLD, Esq. 05608

State of Florida v. Jeffrey Epstein Case No: 2006CF009454A

SERVICE LIST

Lanna Belohlavek, Esq. Attorney For: Party 401 N. Dixie Highway West Palm Beach, FL 33401 Phone: (561) 355-7100 Fax: (561) 355-7379

Jack A. Goldberger, Esq. Attorney For: Jeffrey Epstein 250 S Australian Avenue Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691

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

CASE NO. 2006CF009454AXX

STATE OF FLORIDA

SUBPOENA FOR DEPOSITION

VS.

JEFFREY EPSTEIN,

Defendant.

TO:

YOU ARE COMMANDED to appear before a person authorized by law to take depositions on the 4th floor (Rooms 4.2004-4.2010), of the Palm Beach County Courthouse, 205 North Dixle Highway, West Palm Beach, Florida on February 6, 2008 at 9:30 a.m. for the taking of your deposition in this action. If you fail to appear, you may be in contempt of court.

You are subpoenaed to appear by the following attorneys and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed.

WITNESS my hand and seal of said Court on this 29th day of January, 2008.

Jack A. Goldberger, ESQ. For the Court 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 (561) 659-8300

Page 39

Public Records Request No.: 17-295

272

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

CASE NO. 2006CF009454AXX

STATE OF FLORIDA

SUBPOENA FOR DEPOSITION

VS.

JEFFREY EPSTEIN,

Defendant.

TO:

YOU ARE COMMANDED to appear before a person authorized by law to take depositions on the 4th floor (Rooms 4.2004-4.2010), of the Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida on February 6, 2008, starting at 9:30 a.m. for the taking of your deposition in this action. If you fail to appear, you may be in contempt of court.

You are subpoenaed to appear by the following attorneys and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed.

WITNESS my hand and seal of said Court on this 1st day of February, 2008.

E. P. St. C.N. 1

Jack A. Goldberger, ESQ. For the Court 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 (561) 659-8300

Public Records Request No.: 17-295

HERMAN & MERMELSTEIN PA

WI OHNLYS AT LAW

Stuart S. Mennelstein Tel 305-931-2200 Fax 305-931-0877 ssm8hormanlaw.com

18205 Biscayne Boulevard Suite 2218 Miami. Florida 33160 www.hermanlaw.com

FAX TRANSMITTAL SHEET

MESSAGE:

RE: State of Florida v. Jeffrey Epstein

Please see attached Motion for Protective Order.

THIS MESSAGE IS INTENDED ONLY FOR TIIE USE OF THE INDIVIDUAL OR mritry TO WHICH IT IS ADDRESSED AND MAY CONTAININFORMATION THAT IS PRIVILEGED. CON EIDEKMAL AND EXEMPT FROM DISCWSURE UNDER APPLJOUILE LAW. IF TIIE READER OF THIS MESSAGE. LS NOT THE INTENDED RECIPIENT OR THE EMPLOYEEOR AGE20 RESPONSIBLE FUR DELIVERING THE MESSAGE. TO THE INTENDED RECIPIENT. YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUI1ON OK COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBMED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE. NOTIFY OS IMMEDIATELY BY TELEPHONE, AND RETURN 171E ORIGINAL MESSAGETO US AT THE ABOVE ADDRESS VIA THE U S. POSTAI. SERVICE• THANK YOU.

EFTA02855799

IN THE CIRCUIT COURT OF THE 1511i JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA

Case No.: 502006CF009454AXXXMB

STATE OF FLORIDA

v.

JEFFREY EPSTEIN,

Defendant

MOTION FOR PROTECI’IVE ORDER

COMES NOW, Witness Y. Doe,’ by and through undersigned counsel, respectfully moves for a protective order pursuant to Florida Rule Criminal Procedure 3.220(0(1), requiring that the deposition of Y. Doe be taken in this matter in conjunction with and at the same time with the deposition of Y. Doe in the civil case captioned Jane Doe No. 3 v. Jeffrey Epstein case no. 08-CV-80232-Marra, United States District Court for the Southern District of Florida. As grounds therefore, Witness Y. Doc states as follows:

1. Y. Doe has been subpoenaed for deposition in this case by the Defendant Jeffrey Epstein. The subpoena schedules the deposition for April 2, 2008.

2. Y. Doe is a victim in this matter who alleges that she was sexually assaulted by Defendant Jeffrey Epstein when she was 16 years old. Y. Doe has brought a civil case against Defendant Epstein captioned Jane Doc No. 3 v. Jeffrey Epstein case

The witness is named here anonymously as “Y. Doe” because of the sensitive allegations of sex abuse upon a minor involved in this case.

no. 08-CV-80232-Marra, United States District Court for the Southern District of Florida. This civil case alleges sexual assault against Defendant Epstein.

3. It is anticipated that Y. Doc will be questioned on the same facts and issues regarding her encounter with Jeffrey Epstein in both the civil and criminal cases.

It would protect the victim from harassment, as well as undue and necessary emotional stress and trauma, to have her deposition taken only once by Defendant Epstein, rather than requiring that she unnecessarily revisit the emotional and traumatic facts in separate depositions for each case.

5. It would not prejudice the defense in its investigation or preparation of this case if the depositions in the civil case and the criminal case were conducted at the same time.

6. Florida Rule of Criminal Procedure 3.220(1)0) provides that the Court may issue a protective order “as is appropriate to protect the witness from harassment, unnecessary inconvenience, or invasion of privacy, including prohibiting the taking of the deposition.” Further Fla.R.Crim.P. 3.220(h)(1) contemplates that a witness in Y. Doe’s circumstances will only be subject to one deposition: “In any case, no person shall be deposed more than once except by consent of the parties or by order of the court issued on good cause shown.”

7. This Court has the inherent authority to protect witnesses in a criminal case from potential emotional harm. State v. M, 626 So.2d 1338 (Fla. 1993); State v. ’Farrago 800 So.2d 300 (Fla. 3d DCA 2001). A requirement that a single deposition be taken by Defendant Epstein for both the civil and criminal cases will avoid unnecessary emotional harm to Y. Doe. Finally, the taking of two separate depositions of Y. Doc by

2

Defendant Epstein would be harassment. A protective order under rule 3.220(0O) would prevent this harassment.

8. Counsel for Witness Y. Doe has contacted both the attorneys for the State and for Defendant Epstein regarding this request, and neither has responded.

WHEREFORE, Witness Y. Doe respectfully requests a protective order requiring that the deposition in the criminal case and the civil case captioned Jane Doe No. 3 v. Jeffrey Epstein case no. 08-CV-80232-Marra/Johnson, United States District Court for the Southern District of Florida, be taken at the same time, and for such further relief as this Court deems just and proper.

Dated: March 31, 2008

Respectfully submitted,

HERMAN & MERMELSTETN, P.A. Attorneys for Witness Y. Doe 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877

By:

Jeffrey . Herman jherman@hcrmanlaw.com Florida Bar No. 521647 Stuart S. Mermelstcin ssmAhermanlaw.com Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 ahorowitz@hcnnanlaw.com

CERTIFICATE OF SERVICE

1 hereby certify that a true and correct copy of the foregoing was served by facsimile and U.S. mail on this the day of a-rf-1-,, 2008 to: Jack A. Goldberger, Esq., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401; Lanna Leigh Belohlavek, Esq., State Attorneys Office, 401 N. Dixie Hwy., West Palm Beach, FL 33401-4209.

4

HERMAN & MERMELSTEIN PA

ATTORNEYS AT LAW

Stuart S. Mermelstein Tel 305-931-2200 Fax 305-931-0877 ssm&hermanlaw.com

18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 www.hermanlaw.com

FAX TRANSMITTAL SHEET

MESSAGE:

RE: State of Florida v. Jeffrey Epstein

Please see a copy of the attached correspondence to Judge McSorely.

THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE. THANK YOU.

HERMAN Ex MERMELSTEIN PA

ATTORNEYS AT LAW

Stuart S. Iiikarmelstein Tel 305-931-2200 Fax 305-931A877 ssm@hermanlaw.com

18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 www.hermanlaw.com

March 31, 2008

Via Federal Express Honorable Sandra McSorley Palm Beach County Courthouse 205 North Dixie Highway Courtroom IIF West Palm Beach, Florida 33401

Re: State of Florida v. Jeffrey Epstein Case No.: 502006CF009454AXXXMB

Dear Judge McSorley:

We represent a witness in the above-referenced matter. It is kindly requested that a fifteen (15) minute or less special set hearing he scheduled on the enclosed Motion for Protective Order. Please have your judicial assistant contact my office to schedule said hearing.

Thank you for your attention to this matter

Very trul ours,

Stuart S. Mermelstein

SSM/Ir cc: Jack Goldberger, Esq. Lanna Leigh Belohlavck, Esq.

HERMAN & MERMELSTEIN PA

ATTORNEYS AT LAW

Stuart S. Mermelstein Tel 305-931-2200 Fax 305-931-0877 ssm&hermanlaw.com

18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 www.hermanlaw.com

FAX TRANSMITTAL SHEET

THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE. THANK YOU.

HERMAN & MERMELSTEIN PA

ATTORNEYS AT LAW

Stuart S. Mermelstein Tel 305-931-2200 Fax 305-931-0877 ssrn©hermanlaw.com

18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 www.hermanlaw.com

March 28, 2008

VIA FACSIMILE Lanna Leigh Belohlavek State Attorney’s Office 401 N. Dixie Hwy West Palm Beach, FL 33401

Re: State of Florida v. Jeffrey Epstein, Case No. 2006CF009454AXX

Dear Ms. Bclohlavek:

We have left a number of messages with you to coordinate depositions of our clients in this case, without response. With regard to the depositions of our clients, it is necessary and appropriate for the entry of a court order which would require that one deposition be taken of each of our clients for use in both the criminal case and the civil case. A single deposition is warranted given that the facts of the sexual assault are conunon to both the civil and criminal cases, and the Defendant, Jeffrey Epstein, is the same in both cases. A single deposition is in the best interests of the emotional well being of the victim. In another case we were involved in where both a civil case and a criminal case were pending, the State Attorney’s office filed a motion for protective order in the criminal case pursuant to Fla.R.Crim.P. 3.220(1)O) asking that the depositions in both the criminal and civil case be conducted at the same time.

We would like to coordinate and cooperate with your office with regard to this issue concerning the depositions of our clients. The deposition of is presently scheduled for Wednesday, April 2, 2008. Please let us know how you would like to proceed in this important matter as soon as possible.

Very truly yours,

Stuart S. Mermelstein

SSM/lr

1-Mobile USA

Law Enforcement Relations 4 Sylvan. Parsippany, NJ 07054 Tel 973.2924911 Fax 973 2924697

August 2, 2005

Det Pagan Palm Beach Police Department West Palm Beach, FL

Dear Det Pagan:

This is in response to the Subpoena Duces Tecum, dated July 13, 2005, and served upon T-Mobile USA on August 2, 2005. This subpoena requests customer identification/account information and Call Detail Records for the T-Mobile USA subscriber assigned mobile telephone numbertili

A search of our subscriber database discloses the following information:

Ei Call Detail Records are provided on the pages which follow.

❑ Call Detail Records are presently being compiled.

❑ Original materials follow via US Mail.

Should you have any questions regarding this information please feel free to contact me at your convenience. My direct telephone number is: (973) 292-8841.

Very truly yours,

Andy Dios- Legal Compliance Agent II File: 2005-048776 Law Enforcement Relations

Itemized Details For: Account Number:

Page 6 of 33

Call Type: (A) Call Waiting (B) Call Forward (C) Conference Call (E) Data/Fax (F) Mobile2Mobile (G) Voicemail (H) Free Calls 07/26/17 Page 52 Public Records Request No.: 17-295

Customer Service Number 1-800-937-8997 Feb 05, 2005 Page 7 of 33

Itemized Details For. Account Number .

Customer Service Number 1-800-937-8997

Ma: 06. 2005

Account Service Detail for Subscriber Available Service Bonus 50 Minutes FamTime Unl Nts 1600 Text Message 300 Used Service Bonus Minutes Free Minutes T-Mobile to T-Mobile Use Them Or Lose Them Free Txt Msg Included Plan Minutes T-Mobile to T•Mobile Txl Msg Recd Txt Mso Sent Type WHENEVER Minutes 20 Minutes 1.600 Minutes Unlimited Minutes - Messages 300 Type WHENEVER Minutes - Minutes - Messages 64 Messages 79 Monthly Service Charges $10 Additional Line Bonus 50 Minutes Text Message 300 VM 8 Fax Taxes. Fees and Surcharges Government Fees and Taxes Federal Excise Tax Federal Universal Service Fund State Communication Service Tax Local Communication Service Tax County 911 Regulatory Programs Fee’ S S S $ WEEKEND p.21E(c.4.3 A 6K OFF PEAK WEEKEND I 1t0 4 6 Unlimited 144 Amount Totals 10 00 2 99 S 12.99 3.40 0.03 0.04 1.19 0.78 0.50 0.86

Wee we collect and retain to help cover our costs related to funding and complying with government mandates, programs and obligations.

Total Charges S 16.39

Call Type. (A) Call waiting (B) Call Forward (C) Conference Call (E) Data/Fax (F) mobile2Mobile (6) Voicemail (H) Free Calls

(K) WPS Cal

Page 4 ot 28

Itemized Details PO(’ Account Number:

mar 06.2005 Page 5 of 78

Call Type: (A) Call Wailing (8) Call Forward (C) COnletence Call (E) Data/Fax (F) Molale2Mobile (G) Vo.cemail (H) Free Calls

(K) WPS Call 07/26/17 Page 55 Public Recoils Request No.: 17-295

itemized Details For. Account Number.

Customer Service Number 1.800-937.8997

Mar 06. 2005 Page 6 oi 28

;au Type: (A) Call Waiting (0) Cal Forward (C) Conference Call (E) Data/Fax (F) Mobne2mobile (G) Von:email (H) Free Calls

./C) wPS Cau 07/26/17 Page 56 Public Records Request No.: 17-295

Itemized Details For. Account Number:

Customer Service Number 1 -800- 937 - 8997

Type’ (A) Call Waiting (8) Call Forward (C) Conlerence Call (E) Data/Far (F) Moble2Mobile (6) vocernaz (H) Free Calls

)()WPS Call 07/26/17 Page 57 Public Records Request No.: 17-295

Customer Service Number 1.800.937.8997

LOCAL AIRTIME, LONG DISTANCE and INTERNATIONAL CHARGES - (Continued) Date Call Destination Time Number Called Call Type Minutes Airtime Charges Toll Charges Total 2/11;05 W Palm Bch. FL 2 37 PM 561-267.3548 1 - $ $ 2/11/05 Incoming 3.10 PM 561.333.7190 1 s $ 2/11/05 Incoming 3.13 PM 561-333-7190 • s 2/11/05 W Palm Bch, FL 3:13 PM 561.333.7190 1 S $ $ 2/11/05 W Palm Bch, FL 3:32 PM 561.317.8722 (A) 14 $ $ 2/11/05 Incoming 3:48 PM 561.333.7190 1 S - 5 $ 2/11/05 Incoming 3:48 PM 561-333-7190 3 $ - $ 2/11/05 Incoming 3:51 PM 561-333-7190 1 S $ 2/11/05 W Palm Bch, FL 4:01 PM 561.333.7190 IA) 5 $ $ 2/11/05 W Palm Bch, FL 4:07 PM 561.333.7190 1 S - 2/11/05 W Palm Bch, FL 4:11 PM 561.333.7190 4 E $ • $ 2/11/05 W Palm Bch, FL 4:14 PM 561.951-2830 2 - $ 2/11/05 W Palm Bch. FL 4:16 PM 561.204.3531 1 S $ 2/11/05 W Palm Bch, FL 4:16 PM 561.333.7190 4 - $ $ 2/11/05 W Palm Bch, FL 4:20 PM 561.317.8722 (F) 1 S - S 2/11/05 W Palm Bch, FL 4:21 PM 561.317.8722 (A) 3 S $ 2/11/05 W Palm Bch. FL 4:23 PM 561-793-2403 3 S $ $ 2/11/05 Incoming 4:27PM 561-317-8722 (F) 3 $ - $ $ 2/11/05 W Palm Bch, FL 4:32 PM 561-204-3531 1 $ - $ $ 2/11/05 Incoming 4:47 PM 561.267.3548 (A) 15 $ - $ $ 2/11/05 Incoming 5:00 PM 561-317-8722 (A) 1 $ - $ 5 2/11/05 Incoming 5:12 PM 561.317.8722 (F) 1 S • $ $ 2/11/05 Incoming 5:31 PM 561-512-9522 1 5 - S $ 2/11/05 W Palm Bch, FL 6:29 PM 561-267-3548 1 $ • $ $ 2/11;05 Incoming 6:54 PM 561-383-7542 2 $ - 5 $ 2/11/05 W Palm Bch, FL 6:56 PM 561.267.3548 1 S - S $ 2/11/05 W Palm Bch, FL 6:57 PM 561.204.3531 (A) 1 $ • $ $ 2/11/05 Incoming 6:58 PM 561.951.2830 (A) 10 $ • $ 2/11/05 W Palm Bch, FL 7:08 PM 561.301.6596 1 S $ 2/11/05 W Palm Bch. FL 7:10 PM 561.602.5720 1 S $ 2/11/05 W Palm Etch, FL 7:12 PM 561.602.5720 - S 2/11/05 W Palm Bch, FL 7:12 PM 561-723-7751 2 S $ 2/11/05 W Palm Bch, FL 7:14 PM 561.602.5720 1 $ - S $ 2/11/05 W Palm Bch, FL 7:19 PM 561-602-5720 1 $ - $ $ 2/11/05 W Palm Bch. FL 7:20 PM 561.383.6810 1 $ • $ $ 2/1 1/05 W Palm Bch, FL 7:20 PM 561-602-5720 1 S - $

Cal Type (A) Call Waiting (B) Call Forward (C) Conference Call (E) DaWFax (F) Moble2mobile (G) VOCernail (H) Free Calls

(K) WPS Call 07/26/17 Page 58 Public Records Request No.: 17-295

hernized Details For. Account Number.

Customer Service Number 1.800.937-8997

Mar C . 2005 Page 9 el 28

Call Type (A) Call Wailing (EH Call Forward (C) Conference Call (E) Dam/Fax (F) Mobale2Mobee (G) Voicemail (H) Free Calls

07/26/17 Page 59 Public Records Request No.: 17.295 (K) WPS Call

Itemized Details For: Account Number:

For:

Customer Service Number

Apr 05, 2005

1-800-937-8997

Page 4 of 21

*Fee we collect and retain to help cover our costs related to funding and complying with government mandates, programs and obligations.

S

16.40

Call Type: (A) Call Waiting (B) Call Forward (C) Conterence Call (E) Data/Fax (F) Mobile2Mobile (G) Voicemail (H) Free Calls

(K) WPS Call

07/26/17

Public Records Request No.: 17-295

Itemized Details For Account Number

Customer Service Number 1-800-937-8997

Apr 05. 2005 Page 5 ot 21

Itemized Details For Account Number

Customer Service Number 1-800-937-8997

May 05 2005 Pace 4 of 21

Customer Service Number

Jun 05, 2005

1-800-937-8997

Itemized Details For: Account Number:

Page 4 of 19

*Fee we collect and retain to help cover our costs related to funding and complying with government mandates, programs and obligations.

Total Charges

12.90

$

07/26/17

Page 63

T-Mobile USA Law Enforcement Relations 4 Sylvan, Parsippany, NJ 07054 Tel: 973-2924911 Fax: 973 2924697

August 2, 2005

Oct Pagan Palm Beach Police Department West Palm Beach, FL

Dear Oct Pagan:

This is in response to the Subpoena Duces Tecum, dated July 13, 2005, and served upon T-Mobile USA on August 2, 2005. This subpoena requests customer identification/account information and Call Detail Records for the T-Mobile USA subscriber assigned mobile telephone number

A search of our subscriber database discloses the following information:

2 Call Detail Records are provided on the pages which follow.

❑ Call Detail Records are presently being compiled.

❑ Original materials follow via US Mail.

Should you have any questions regarding this information please feel free to contact me at your convenience. My direct telephone number is: (973) 292-8841.

Very truly yours,

Andy Dios- Legal Compliance Agent II File: 2005-048776 Law Enforcement Relations

Customer Service Number 1-800-937-8997. Feb 05, 2005 Itemized Details For: Account Number:

Page 6 of 33

Call 17pe: (A) Call Waiting (B) Call Forward (C) Conference Call (E) Data/Fax (F) Mobile2Mobile (G) Voicemail (H) Free Calls

(%) WPS Call

Public Records Request No.: 17-295

Customer Service Number 1-800-937-8997

Itemized Details For: Account Number.

Feb 05. 2005 Page 7 of 33

Call Type. (A) Call Waiting (B) Call Forward (C) Conference Call (E) Daia/Fax (F)Mobile2Mobje (G) Voicemail (li) Free Calls

(K) WPS Call

Customer Service Number 1-800-937-8997

Itemized Details For. Account Number.

Mar 06. 2005 Page 4 of 28

’Fee we collect and retain to help cover our costs related to funding and complying with government mandates, programs and obligations.

Can Type: (A) Call Waling (B) Call Fonvard (C) Coherence Call (E) Data/Fax (F)Motme2Moote (G) Unlearned (H) Free Calls

(K)ViiPS Call

07/26/17 Page 67 Public Records Request No.: 17-295

Customer Service Number 1.800-937-8997

Itemized Details For. Account Number.

Mar 06. 2005 Page 5 el 28