EFTA00178967

the computers, and create a privilege log. Any disputes regarding privilege should 
be resolved by the Court prior to access by the government. 
VII. SUBPOENAING PURELY PRIVATE PAPERS VIOLATES THE 
FIFTH AMENDMENT UNDER BOYD. 
In Boyd v. United States, 116 U.S. 616 (1886), the Supreme Court 
condemned the seizure of an individual's private personal papers and their use as 
evidence against him as violative of the Fifth Amendment. While admittedly Boyd 
has been deeply eroded, and language in Hubbell, 530 U.S. at 35-36, would appear 
to be at odds with this portion of Boyd, the relevant portion of Boyd pertaining to 
an individual's private papers has not been directly overruled. 
Indeed, the 
Eleventh Circuit, in a case decided pre-Hubbell, left open the question of the 
continued vitality of Boyd with respect to personal documents. In re Grand Jury 
Investigation, 921 F.2d 1184, 1187 n.6 (11th Cir. 1991). And see Barrett v. 
Acevedo, 169 F.3d 1155, 1167 58th Cir. 1999) ("whether Doe's rationale extends to 
purely personal papers in a defendant's possession is still open to some debate"). 
Permitting the government to compel an individual to turn over to the government 
the entire contents of his computers for the government to do with it as it will, 
including reading all of his most private thoughts and communications, and then 
using those private writings to try him for a crime, "would break the heart of our 
38 
Black. Srebrack. KornspanS• 
2015. Biscayne Boulevard, Suite 1300 • Miami. Florida 33131. Phone: 
• Fax 
• www.RoyBlack.com 
EFTA00179027

sense of privacy". In re Steinberg, 837 F.2d 527, 530 (1st Cir. 1988). It should not 
be permitted under the Fifth Amendment. 
CONCLUSION 
For all these reasons Mr. Epstein's must be permitted to intervene and to 
move to quash the subpoena duces tecum issued to William Riley, and the motion 
to quash the subpoenas should be granted in its entirety. 
Respectfully submitted, 
BLACK, SREBNICK, KORNSPAN & STUMPF, PA. 
201 South Biscayne Boulevard, Suite 1300 
Miam 
1prida 33131 
By 
ROY BLA K, 
Florida Bar No. 
Counsel for Jeffrey Epstein 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on July 17, 2007, a true and correct copy of the 
forging motion was furnished by facsimile 
and U.S. mail to: 
Maria 
, Esq., U.S. Attorney's Office, 500 
uth Australian Avenue, Suite 
400, West Palm Beach, FL 33401. 
By: 
ROY BLACK, ESQ 
Counsel for Jeffrey Epstein 
39 
Black. Srebnick. Kornspan 
aF
n 
201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131. Phone: 
• Fat 
• www.RoyBlack.com 
EFTA00179028

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
GRAND JURY MATTER 
FILED UNDER SEAL 
IN RE GRAND JURY SUBPOENAS 
) 
DUCES TECUM ISSUED TO 
) 
FGJ 07-103 (WPB)/No. OLY -64 
WILLIAM RILEY AND 
) 
RILEY KIRALY 
) 
 
) 
AFFIDAVIT OF ROY BLACK, ESQ., IN SUPPORT OF 
MOTION OF JEFFREY EPSTEIN 
TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS 
STATE OF FLORIDA 
) ss: 
COUNTY OF DADE 
ROY BLACK an attorney at law, duly sworn, deposes and says: 
1. 
I am an attorney at law, duly admitted to practice before the State of Florida and 
the United States District Court for the Southern District of Florida. 
2. 
As detailed further below, I am counsel to Jeffrey Epstein, the movant herein. It 
is my intention herein not to waive the attorney-client, attorney work-product or any other 
privileges, and I have no authority to do so. I make this affidavit solely to provide sufficient 
facts to support Mr. Epstcin's motion to intervene and to quash the subpoenas duces tccum 
issued to William Riley and Riley Kiraly which make identical requests, copies of which are 
annexed hereto as Exhibit "A". 
3. 
In or around September or October 2005, I was consulted and retained by Mr. 
Epstein to represent him in connection with an investigation being conducted by the State 
EFTA00179029

Attorney in Palm Beach County. 
I understood that the State Attorney was investigating 
allegations that Mr. Epstein had paid women to provide him with massages in his home and that 
one or more of the women were alleged to have been under the age of 18 at the time of the 
massage. It was further alleged that during the course of one or more of the massages, sexual 
activity may have occurred. 
4. 
In connection with my representation of Mr. Epstein, in or about September or 
October 2005 I retained the firm of Riley Kiraly, private investigators, to assist me in my 
representation of Mr. Epstein. I began thereafter to work in particular with licensed investigator 
William Riley. Without disclosing any work done by Mr. Riley or his firm on Mr. Epstein's 
behalf and at my direction, any actions thereafter taken by him or the firm were taken in 
connection with the legal representation of Mr. Epstein. 
5. 
On July 17, 2006, Mr. Epstein was charged by a grand jury sitting in Palm Beach 
County with one count of solicitation of a prostitute, a third degree felony. That charge is 
pending. 
6. 
Both prior to the charge being brought and thereafter I and other attorneys 
representing Mr. Epstein were provided with open disclosure of the State's evidence. As a 
result, I have had the opportunity to review all or virtually all of the evidence obtained by the 
State in its investigation. Included in the material I have reviewed are the audio and/or video 
taped sworn statements of 18 witnesses, transcripts of all 18 of those recorded sworn statements, 
the transcript of one additional sworn statement, and over 125 pages of documents prepared by 
the Palm Beach Police Department which detail every sworn statement obtained by detectives, 
every interview conducted by detectives, all their investigative efforts and all the evidence 
gathered. These documents include the entire police file, as well as the probable cause affidavits 
- 2 - 
EFTA00179030

prepared by Palm Beach detectives and the application for a search warrant of Mr. Epstein's 
home. 
7. 
Reviewing these materials has afforded me a thorough understanding of the 
factual bases for any allegations that have been, or could have been, made against Mr. Epstein. 
8. 
In or around January 2007, a federal grand jury in this District began a parallel 
investigation of Mr. Epstein to determine whether any federal laws were broken by Mr. Epstein's 
alleged conduct. We understood the conduct being scrutinized by the federal grand jury was the 
same as the subject of the State prosecution. 
Indeed, during the course of the federal 
investigation, prosecutors asked for and were provided with copies of the 18 recorded sworn 
witness statements, and further asked for copies of the transcripts of those sworn statements. 
9. 
That the two investigations examine the same alleged conduct is also clear from 
the attached letter of the Chief of the Palm Beach Police Department expressing the 
Department's displeasure with the actions of the state grand jury and State Attorney's Office, 
and explaining he was referring the matter to federal authorities in order to initiate a federal 
investigation of the facts. See Letter of Michael S. Reiter, Chief of Police, dated July 24, 2006, 
annexed as Exhibit "B". At the same time, the Palm Beach Police Department both publicly 
released copies of its files, including the 87 page police report and probable cause affidavits 
prepared by its detectives, and publicly announces its intentions to bring the investigation to 
federal authorities due to the Department's dissatisfaction with the State Attorney's handling of 
the matter. See News Articles, annexed as Exhibit "C". 
10. 
As part of that subsequent parallel federal investigation, I and other attorneys 
representing Mr. Epstein have repeatedly met with and spoken to federal prosecutors directing 
- 3 - 
EFTA00179031

the investigation. Again, those discussions have afforded me and other counsel an opportunity to 
understand the factual bases for any charges that could purportedly be brought. 
11. 
I understand from my conversations with federal prosecutors that the federal 
statutes being considered are potential violations of 18 U.S.C. §2423 (travel for the purpose of 
engaging in unlawful sexual activity) and 18 U.S.C. §2422(b), use of the Internet or other means 
of interstate communication to persuade, entice or coerce another to engage in unlawful sexual 
activity. 
12. 
I can state without any hesitation, based on my knowledge of the evidence being 
reviewed, there have been no claims, nor is there any factual support for the making of any 
claims, that Mr. Epstein ever, directly or indirectly, used a computer to locate, to entice, to 
solicit, to coerce, or to persuade any woman to engage in any unlawful sexual activity. Nor is 
there any claim or reference to the use or display of any web based or computer based 
pornography. Further, there are no references whatever to the use of computers in connection 
with the alleged conduct at issue here. 
13. 
In short, I have had a rare opportunity to view at least the whole of the State's 
evidence, which was turned over to federal authorities as part of their grand jury investigation, 
and to discuss any additional federal evidence gathered during the federal grand jury 
investigation. At no time has any potential claimant or any prosecutor ever mentioned the use of 
a computer by Mr. Epstein to engage in any wrongdoing. 
14. 
These subpoenas were not issued in a vacuum. They are simply the most recent 
in a series of highly intrusive and unusual attempts to acquire highly personal and/or privileged 
information concerning Mr. Epstein that can have no relevance whatever to the investigation, 
including Mr. Epstein's personal tax returns (see Letter of 
, Assistant United 
- 4 - 
EFTA00179032

States Attorney, dated November 16, 2006, annexed as Exhibit "D"), medical records including 
treatment notes of Mr. Epstein's treatment by a chiropractor (see Grand Jury Subpoena Duces 
Tecum, dated March 13, 2007, to Dr. Thomas Rofrano annexed as Exhibit "E"), and now, 
invasion of the defense camp by seeking records of the investigative work performed by Mr. 
Riley on behalf of your affiant engaged as Mr. Epstein's counsel in the very same investigation. 
15. 
While the propriety of those other subpoenas is not at issue here, the subpoenas to 
Mr. Riley and to his firm are. When it was pointed out to prosecutors that internal Department of 
Justice rules require, inter alia, that issuance of the subpoenas be predicated on the pre-approval 
of the Assistant Attorney General of the Criminal Division under the United States Attorneys' 
Manual ("USAM"), §9-11.255, the question as to whether such approval had been obtained was 
simply ducked in an exchange of correspondence. See Letter of Roy Black; Esq., to 
Assistant United States Attorney, dated July 13, 2007, and the letter from Ms. 
in response, annexed as Exhibits "F' and "G", respectively. Though such guidelines 
create no third party rights, the fact that the required approval evidently was not obtained 
highlights the continuing overreaching of this investigation. 
16. 
Moreover, quite apart from whether the required steps were taken internally to 
obtain approval before issuing the subpoenas, I also challenge whether, as a substantive matter, 
the government could meet the internal guidelines necessary for issuing a subpoena seeking 
information relating to the representation of a client, as set forth in USAM §9-13.410. 
17. 
I also want to address the matter of attorney-client communications and attorney 
work-product. While, for purposes of this motion, we are not conceding the existence of any 
computers that would be responsive to the subpoena, to the extent there are any such computers, 
they would contain documents that are clearly attorney-client communications and attorney 
- 5 - 
EFTA00179033

work-product. Though for the reasons set forth in the motion the subpoenas should be quashed 
in their entirety, to the extent the Court allows the government to review the contents of the 
computer, I respectfully submit that a procedure must be instituted to allow for the protection of 
Mr. Epstein's attorney-client communications and attorney work-produc 
Sworn to before me this 
• 
17th day of July 2007. 
Notary Public 
STAMP/SEAL 
Personally known 
OY BL CK 
"'
YIN 
WANDA GOMEZ 
• 
MY COMMISSON I DO 240$92 
EXPIRES: Noromber 22, 2007 
?tome 
kohl Tin hist Mrs Sucks; 
OR Produced identification 
Type of Identification Produced: 
- 6 - 
EFTA00179034

EXHIBIT A 
EFTA00179035

JUN-29-200? 11:18 
F. 
WEST PALM BEACH RR 
P.02 
United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
Custodian of Records 
Riley Kiraly 
Commercial Center of Miami 
6135 NW 1676 Street E-26 
Miami, FL 33015 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
Fal 07-103(WPB)/No. OLY-64 
SUBPOENA FOR: 
PERSON 
DOCUMENTS OR OBJECF[M 
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District 
Court at the place, date and time specified below. 
PLACE: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: 
July 10, 2007 
11:00 pm' 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
THE DOCUMENTS AM) OBJECTS LISTED ON ATTACHMENT A. 
*Please coordinate y ur compliance with this subpoena and confirm the date, time, and 
appearance with S/A 
, Federal Bureau of Investigation; Telephone: 
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting 
on behalf of the court. 
CLERK 
(EtY)DEPUTY CLERK 
This subpoena is issued upon application 
elf not applicable, <Ma 'none.' 
Name, Address and Phone Number of Assistant U.S. Attorney 
Assistant U.S. Anorney 
SOO o. Australian
i
 Avenue, Suite 400 
We 
L 33401-6235 
Tcl: 
Pax: 
Toby:Rd lelku ofACIII0 
FORM ORD-227 
JAN.86 
EFTA00179036

JUN -20 -2om 11:19 
WEST PALM REACH RA 
P.03 
ATTACHMENT A 
SUBPOENA TO PAUL A. LAVERY 
1. 
All computer equipment and electronic storage media removed from the 
residence located at 358 El Brillo Way, Palm Beach, Florida, including but not 
limited to central processing units ("CPUs"), laptop computers, keyboards, 
printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, 
DVDs, floppy diskettes, digital cameras, and memory cards. • 
2. 
All computer equipment and electronic storage media that currently belongs 
to, or has ever belonged to, Jeffrey Epstein, including but not limited to central 
processing units ("CPUs"), laptop computers, keyboards, printers, modems, 
routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy 
diskettes, digital cameras, and memory cards. 
3. 
All documents and information related to the nature of the relationship 
between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, 
including, but not limited to, retainer agreements; employment agreements; 
billing statements (whether submitted directly to Mr. Epstein or to a third party 
for reimbursement); records of the dates when services were performed and 
the hours worked; telephone logs or records of dates of communications with 
Mr. Epstein (or with a third party on Mr. Epstein's behalf); appointment 
calendars/datebooks and the like (whether in hard copy or electronic form) for 
any period when work was performed on behalf of Mr. Epstein or when any 
communication was had with Mr. Epstein (or with a third party on Mr. 
Epstein's behalf); and records of fee arrangements and payments received for 
work performed on Mr. Epstein's behalf. 
EFTA00179037

JUN-20-2007 11: 19 
WEST PALM BEACH RA 
P.04 
United States District Court 
SOUTHERN DISTRICT OP FLORIDA 
TO: 
William Riley 
Riley Kiraly 
Commercial Center of Miami 
6135 NW 167' Street E-26 
Miami, FL 33015 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FGJ 07-103(WPB)/No. OLY-63 
SUBPOENA FOR: 
PERSON a DOCUMENTS OR OB3ECT[Sj 
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Juryof the United States District 
Court at the place, date and time specified below. 
PLACE: 
• 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: 
July 10, 2007 
1:00 pm* 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
THE DOCUMENTS AND OB,TECTS LISTED ON ATTACHMENT A. 
'"Please coordinate MIR ROtntiliance with  his subpoena and confirm the date, time, and I 
' 
appearance with S/A I 
 Federal Bureau of Investigation, Telephone: 
This subpoena shall remain in effect until you arc granted leave to depart by the court or by an officer acting 
on behalf of the court. 
DATE: 
June 18, 2007 
This subpoena is issued upon application 
n",. 
nik•A q/Atn Ar A ?twit... 
i
• not appbcoNe. puce "nonc.' 
Name, Addre 
ne Number of Assistant U.S. Attorney 
Assistant U.S. Attorney 
500 So_ Australian Avenue, Suite 400 
Tel: 
33401-623.5 
Fax 
To a used la Ito. of "OI10 
FORM 0RD-227 
JAN.66 
EFTA00179038

JUN-20-2007 11:19 
WEST PALM BEACH RA 
P.05 
ATTACHMENT A 
SUBPOENA TO rA,UL A. LAVERY 
1. 
All computer equipment and electronic storage media removed from the 
residence located at 358 El Brillo Way, Palm Beach, Florida, including but not 
limited to central processing units ("CPUs"), laptop computers, keyboards, 
'printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, 
DVDs, floppy diskettes, digital cameras, and memory cards. 
2. 
All computer equipment and electronic storage media that currently belongs 
to, or has ever belonged to, Jeffrey Epstein, including but not limited to central 
processing units ("CPUs"), laptop computers, keyboards, printers, modems, 
routers, hard drives, flash drives, thumb drives, CD-Toms, DVDs, floppy 
diskettes, digital cameras, and memory cards. 
3. 
All documents and information • related to the nature of the relationship 
between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, 
including, but not limited to, retainer agreements; employment agreements; 
billing statements (whether submitted directly to Mr. Epstein or to a third party 
for reimbursement); records of the dates when services were performed and 
the hours worked; telephone logs or records of dates of communications with 
Mr. Epstein (or with a third party on Mr. Epstein's behalf); appointment 
calendars/datebooks and the like (whether in hard copy or electronic form) for 
any period when work was performed on behalf of Mr. Epstein or when any 
communication was had with Mr. Epstein (or with a third party on Mr. 
Epstein's behalf); and records of fee arrangements and payments received for 
work performed on Mr. Epstein's behalf. 
TOTAL P.05 
EFTA00179039

EXHIBIT B 
EFTA00179040

TOWN OF PALM BEACH 
POLICE DEPARTMENT 
A NATIONAL AND STATE ACCREDITED LAW ENFORCEMENT AGENCY 
July 24, 2006 
HAND DELIVERED 
Dear M Via 
Your daughterawas the victim of a crime which has been investigated by the Palm 
Beach Police Department and subsequently referred for prosecution to the Palm Beach 
County State Attorney's Office. You may be aware that Jeffrey Epstein was indicted on 
charges of solicitation for prostitution by a State of Florida grand jury last week and turned 
himself in at the Palm Beach County jail on July 23; 2006. While I do not speak for them, 
it is my understanding that is the full context in which the Palm Beach County State 
Attorney's Office intends to address the charges that involved the crime in which your 
daughter was victim. 
Please know, that it is the role and responsibility of law enforcement to investigate crime 
and to refer appropriate charges to the prosecutor for consideration. I believe that the 
Palm Beach Police Department has acted competently and responsibly in carrying out this 
role. Should you have any questions concerning the state prosecution of this matter, they 
are best addressed by the Palm Beach County State Attorney's Office. 
I do not feel that justice has been sufficiently served by the indictment that has been 
issued. Therefore, please know that his matter has been referred to the Federal Bureau 
of Investigation to determine if violations of federal law have occurred. In the event that 
the FBI should choose to pursue this matter, the Palm Beach Police Department will assist 
them in their investigation of potential violations of federal law. 
Please feel free to contact me at 
should you have any questions. 
Sincerely, 
Michael S. Reiter 
Chief of Police 
MSR:nt 
345 South County Road • Palm Beach, Florida 33480-4443 • 
- Fax 
• www.palmbeachpolice.com 
EFTA00179041

EXHIBIT C 
EFTA00179042

PB POST 
After long probe, Palm Beach billionaire faces solicitation charge By 
Larry Keller 
Palm Beach Post Staff Writer 
Wednesday, July 26, 2006 
Palm Beach billionaire Jeffrey Epstein paid to have underage girls and 
young women brought to his home, where he received massages and 
sometimes sex, according to an investigation by the Palm Beach Police 
Department. 
Palm Beach police spent months sifting through Epstein's trash and 
'watching his waterfront home and Palm Beach International Airport to 
keep tabs on his private jet. An indictment charging Epstein, 53, was 
unsealed Monday, charging him with one count of felony solicitation of 
prostitution. 
Palm Beach police thought there was probable cause to charge Epstein 
with unlawful sex acts with a minor and lewd and lascivious 
molestation. 
Police Chief Michael Reiter was so angry with State Attorney Barry 
Krischer's handling of the case that he wrote a memo suggesting the 
county's top prosecutor disqualify himself. 
"I must urge you to examine the unusual course that your office's 
handling of this matter has taken and consider if good and sufficient 
reason exists to require your disqualification from the prosecution of 
these cases," Reiter wrote in a May 1 memo to Krischer. 
While not commenting specifically on the Epstein case, Mike Edmondson, 
spokesman for the state attorney, said his office presents cases other 
than murders to a grand jury when there are questions about witnesses' 
credibility and their ability to testify. 
By the nature of their jobs, police officers look at evidence from a 
, "one-sided perspective," Edmondson said. "A prosecutor has to look at 
it in a much broader fashion," weighing the veracity of witnesses and 
how they may fare under defense attorneys' questioning, he said. 
Epstein's attorney, Jack Goldberger, said his client committed no 
crimes. 
"The reports and statements in question refer to false accusations that 
were not charged because the Palm Beach County state attorney 
questioned the credibility of the witnesses," Goldberger said. A county 
grand jury "found the allegations wholly unsubstantiated and not 
credible," and that's why his client was not charged with sexual 
activity with minors, he said. 
Goldberger said Epstein passed a lie detector test administered by a 
reputable polygraph examiner in which he said he did not know the girls 
were minors. Also, a search warrant served on Epstein's home found no 
evidence to corroborate the girls' allegations, Goldberger said. 
EFTA00179043

According to police documents: 
• A Palm Beach Community College student said she gave Epstein a 
massage in the nude, then brought him six girls, ages 14 to 16, for 
massage and sex-tinged sessions at his home. 
* A 27-year-old woman who worked as Epstein's personal assistant also 
facilitated the liaisons, phoning the PBCC student to arrange for girls 
when Epstein was coming to town. And she escorted the girls upstairs 
when they arrived, putting fresh sheets on a massage table and placing 
massage oils nearby. 
* Police took sworn statements from five alleged victims and 17 
witnesses. They contend that on three occasions, Epstein had sex with 
the girls. 
A money manager for the ultra-rich, Epstein was named one of New York's 
most eligible bachelors in 2003 by The New York PoSt. He reportedly 
hobnobs with the likes of former President Clinton, former Harvard 
University President Lawrence 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 
candidate& and organizations, including Sen. John Kerry's presidential 
bid, and the Senate campaigns of Joe Lieberman, Hillary Clinton, 
Christopher Dodd and Charles Schumer. 
Goldberger is one of five attorneys Epstein has retained since he 
became the subject of an investigation, Edmondson said. Among the 
others: Alan Dershowitz, the well-known Harvard law professor and 
author, who is a friend of Epstein. Dershowitz could not be reached for 
comment. 
Police said the woman who enlisted young girls for Epstein was 
20, of Royal Palm Beach. 
has worked at an Olive Mt 
restaurant in Wellington and said she was a journalism major at Palm 
Beach Community College when she was questioned by police last October. 
She has 'an unlisted phone number and could not be reached for comment. 
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 five-bedroom, 7 1/2 -bath home on the Intracoastal Waterway, 
then escorted upstairs to a bedroom with a massage table and oils. 
Epstein and 
were both naked during the massage, she said, but 
when he grabbed her buttocks, she said she didn't want to be touched. 
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. Theillitl knew 
what to expect when they were taken to Epstein's home, 
said. 
Give a massage * maybe naked * and allow some touching. 
EFTA00179044

One 14-year-old girl 
took to meet Epstein led police to start 
the investigation of him in March 2005. A relative of the girl called 
to say she thought the child had recently engaged in sex with a Palm 
Beach man. The girl then got into a fight with a classmate who accused 
her of being a prostitute, and she couldn't explain why she had $300 in 
her purse. 
The girl gave police this account of her meeting with Epstein: 
She accompanied 
and a second girl to Epstein's house on a Sunday 
in February 2005. Once there, a woman she thought was Epstein's 
assistant told the girl to follow her upstairs to a room featuring a 
mural of a naked woman, several photographs of naked women on a shelf, 
a hot pink and green sofa and a massage table. 
She stripped to -her bra and panties and gave him a massage. 
Epstein gave the 14-year-old $300 and she and the other girls left, she 
said.' She said 
told her that Epstein paid her 8200 that day. 
' 
Other girls told similar stories. In most accounts, Epstein's personal 
assistant at the time, 
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 890,000 to the department for the purchase of a firearms 
simulator, said Jane Struder, town finance director. The purchase was 
never made. The money was returned to Epstein on Monday, she said. 
EFTA00179045

I. 
Palm Beach Police Chief Says Justice Wasn't Served in Teen Sex Scandal 
July 26, 2006 6:47 PM 
Maddy Sauer Reports: 
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do not feel that justice has been sufficiently served," wrote 
Palm Beach Police Chief Michael Reiter in a letter he sent to the parents of young girls that he 
believes are victims of sex crimes committed by New York financier Jeffrey Epstein. 
The police chief is angry that despite his department's lengthy probe of Epstein's alleged illegal 
sexual activity with underagesirls, Epstein was indicted on a much lesser charge of soliciting a 
prostitute. The probable causeaffidavit for Epstein's arrest alleges much more serious acts. 
Epstein is alleged to have repeatedly paid young, and some underage girls, to come to his house, 
massage him and on a few occasions have sex with him, according to the affidavit. 
Meanwhile, the Palm Beach police have referred the matter to the FBI. 
Today, Epstein's attorney called the allegations untrue and said that the witnesses' credibility had 
been called into question. 
"The reports and statements in question refer to false accusations that were not charged because 
the Palm Beach County State Attorney's office questioned the credibility of the witnesses, and a 
Palm Beach County grand jury decided not to believe the allegations," said Jack Goldberger. 
"Consequently, the grand jury chose not to accuse Mr. Epstein of anything beyond the 
solicitation of a prostitute." - 
Calls seeking comment from the Palm Beach County State Attorney Barry Krischer were not 
returned today. 
Chief Reiter has not been happy with lCrischer's handling of the matter for some time. He wrote 
an angry letter to him in May urging him to consider disqualifying himself from the prosecution 
of the case saying: "I must renew my prior observation to you that 1 continue to find your 
office's treatment of these cases highly unusual." wrote Reiter. He urged Krischer to 
"consider if good and sufficient reason exists to require your disqualification from the 
prosecution of these cases." The police believed they had probable cause to arrest Epstein on 
four counts of unlawful sex acts with minors and one count of lewd and lascivious molestation. 
EFTA00179046