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FBI VOL00009
EFTA00230786
1131 sivua
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in PAGE Letter from Jay P. Leflcowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Determinations, dated January 19, 2011 A78 Court Action Sheet - Jeffrey Epstein, No. 30129-2010 A80 Handwritten Notations on Court Jacket - Jeffrey Epstein, No. 30129-2010 M1 Transcript of SORA Hearing, dated January 18, 2011 A82 EFTA00231446
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Al Appellant's Pre-Argument Statement, dated February 9, 2011 [pp. Al-A21 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK PEOPLE OF THE STATE OF NEW YORK, Plaintiff-Respondent, -against- JEFFREY E. EPSTEIN, Defendant-Appellant. Index No.: 30129-2010 PRE-ARGUMENT STATEMENT 1. TITLE OF ACTION: As set forth in caption. 2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES: As set forth in caption. There has been no change in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETTTIONER: Jay P. Leflcowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne 4611 Telephone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYiiii m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJEGF-OF-ThE-C-AUSE-OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the Correction Law. 7. RESULT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW: Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual offender, without additional designation. 8. GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of EFTA00231447
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A2 discretion and constituted reversible legal error based, in part, on the following: (1) the Court improperly relied on untrustworthy double and triple hearsay contained in the recommendation of the Board of Examiners of Sex Offenders, even though the District Attorney, as the party appearing on behalf of the State, rejected much of the Board's recommendation as not constituting clear and convincing evidence to support a Level 3 designation where such hearsay allegations were rejected as a basis for state prosecution; (2) the Court failed to provide the parties with an opportunity to present evidence on contested issues, as required by statute, and instead relied wholesale upon the recommendation of the Board, over the objection of the District Attorney, without any inquiry; (3) the Court did not apply the guidelines established by the Board, as required by statute; and (4) the Court failed to set forth the findings of fact and conclusions of law on which its determinations in support of a Level 3 designation were based, as required by statute. 9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PENDING IN ANY COURT OF THIS OR ANY OTHER JURISDICTION. 10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION. Dated: February 9, 2011 Ja . Leficowitz, P.C. S Lynn Musumeci KIRKLAND t ELLIS LLP 601 Lexington Avenue New York, Neal -4611 Telephone: Facsimile: Attorneys for Defendant-Appellant Jeffrey E. Esptein. -2- EFTA00231448
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A3 Appellant's Notice of Appeal, dated February 9, 2011 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK, Plaintiff, - against - JEFFREY E. EPSTEIN, Defendant. NOTICE OF APPEAL Index No. 30129-2010 CRIMINAL TERM PART 66 JUSTICE RUTH PICKHOLZ PLEASE TAKE NOTICE that the above named defendant, Jeffrey E. Epstein, hereby appeals to the Appellate Division of the New York Supreme Court in and for the First Department, from an order entered in the above entitled action in the office of the Clerk of New York County on the 18th day of January 2011, which order adjudged defendant Jeffrey E. Epstein to be a Level 3 sexual offender pursuant to Article 6-C of the Correction Law, and this appeal is taken from each and every part of that order as well as from the whole thereof. Dated: February 9, 2011 To: Clerk, New York County Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NY Telephone: Lefkowitz, P.C. a Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne Telephone: Faccim; Attorneys for Defendant Jeffrey E. E P'ILED FEB OP SISUPREME COURT NOW YORK COUNTY APPA'ALV: ro.thant.m) EFTA00231449
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A4 Order Appealed From, dated January 18, 2011 with Notice of Entry Ipp. ASUPERVIGINGp.ff.F10ER: -km.. rh•• . '‘ C.; ''g;C: •!. ' §UPERVISING AGE Y, Le NONE ; OFFENDEipp UNS • ,:. ' ttitl'i it0 :" ' 4. ' )ft'i '4'. i - cA: 114aboliii:rekerOnoed,I id . ;o54ntitteistan oflatala amulet midi_ keitaliliihetiesT eh 4Stite:at Ulkaddnisilicsflpikekft tia:lstridethmgned.3_ ' ..r. ,113fit Vender!kri quirad tc1,1". ister''and b.e..W Tak r in„, ... ixeria. a lilt Cave) :lac eacti(Madiga:/ et • ottendeld Hew Y iiii . PtOttigKe e„....a.gurritnary'ind daili410fiximnit aifirfaciellieVeify di 0:.NYS and 0 E*.rlieke.k ion Si attietladVskalsettn" 1 -.. Htnitia i ,-..... -7- war:kW" silence Offen:1476:C 'DJ sexually 68:1420fifi dealt' iitS C°In In' a ' 9' 7' — en nieelit theldelailtiqq. sivUttlYiroA, ifitifinkadosiocesiThipdaatt. .. e. fe alp ',aartheit the offender:,. ,,.. .1.kiiagalabOOffend or ' like fort la Cofrectba LOW Seaton iise-a OM ieViiif t yvitt' gi ld ate '145tal7Puhk - .0' Las;ii.612bOtnied '46 erlid: 2005:. d gild •andJus.4!fil4liiserrameiiiiedi j p.pvtgelhet.the'•Aoari:lhaniiiiidtici the: riskfijoicand,dosignatiOR:pf4a4 oftkier; Savkig.isienlikien Padeelkitdifliittle. Oak:: elti:c and place of the 0 0444),, U!ItiBi_ toflriseit,iiittimit , ' liototattl foltrit4rnninsitts'afemler's risk Iiiimit no Widthtinny nollt.itatIOW6 Li0r . .,b fv.itf . ., :::,....tvIstretiet4'Aysit.trerit,Itira*.;SS. py or, titit'otaat:il t.. ':' ,.. ;level and designation determinations an thdiar.idliveahaton . WhitilialkatclettirminaliOns:aratlatiseditafral Ws. sUbmitted to' the' Divisioff: of "CHmilialrJtiatia6ZSgvial'AV 0tit WI py'llhic.00titC, inf.' ditItin,' please: compete and; attach this ttorni•IndVilitict:Ife7offeh&I'Mrt • natlo P ii.to,thaiark.buler Please distribideNiernainktutcOisiis indicatiiitiajkA2, *014iff•:4 4::I'Tssia44-:, !.t.r)Fri'?- 4.:';4:It t ."Ft:"":\i?'‘‘::wi3;:-.?* 'f.. .",,; W401/sA; OiSit.k1:Inz FINAkRISIC LEVED,DETE iNAllati Miele Calie • ile;Ve4Wr'• bESIGNATIO :4.1leAse,check• h that applir pUrstiantto A • 4.,..tas ' t" t Otipation. ow ts.to.bopomple K", tf-wtet EFTA00231450
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A5 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK, Plaintiff, - against - JEFFREY E. EPSTEIN, Defendant. NOTICE OF ENTRY Index No. 30129-2010 CRIMINAL TERM PART 66 JUSTICE RUTH PICKHOLZ PLEASE TAKE NOTICE that the within is a copy of an order entered in this action on the 18th day of January 2011, in the office of the Clerk of the County of New York. Dated: February 9, 2011 To: Clerk, New York County Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYaili m Telephone: Jar. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Neill -4611 Telephone: Facsimile: Attorneys for Defendant Jeffrey E. Epstein FI LED FEB op 2811 New „ abme cou, ANP `Jr* a cou ev r aAte sr Wiry Dvra,u EFTA00231451
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A6 Palm Beach Police Department - Probable Cause Affidavit of Det. dated May 1, 2006 [pp. A6-A271 Probable Cause Affidavit Palm Beach Police Department Agency OM FLO 500600 - Defendant Police Case#: 05-368 (2) Defendant: Sarah Race/Sex: White Female DOB: Charges: Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts Principal in the 1e1 Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006 the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, a and Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawfbl sexual activity that took place at the residence of Jeffrey stein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein for which at received monetary compensation. During the visit they would be introduced to a, Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstcin's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their ciothin to •rovide the massage. As the victims complied and provided the massages, stein would On occasion, Epstein would introduce a massa et/vibrator and vided the .m o. On three separate occasions, Epstein . At the conclusion of the massages the victims were paid sums of money ranging front $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to est." dob 05/13/1990, and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff" had t while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, ■ stated that-, dab a cousin of SCI's boyfriend and classmate at Ro al Palm Beach High School, worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make money. During the beginning of the month of February 2005 explained that she was first approached by to go with her to Epstein's house, stated that alo with a Hi anic female, later identified at .. her up at her father's house on a Sunday. was not sure of the exact dates but knew it was a Sunday. told her sp fathet that they were going shopping but in reality drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed info a thi " day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida al Beach Signature Date: 05/To 006 Officer Pagc I of 22 EFTA00231452
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Signature of Poli e Officer (F.S.S. 1.1.7.10) A7 Probable Cause Affidavit Palm Beach Police Department Agency ORIM FLO $00400 conversation occurred between and II whereas reportedly toldlihat if tasked her age, she should say she was eighteen. It was later confirmed by the that picked his daughter up on February 6, 2005. According to M father, drove a pick up truck. . described Epstein's house as a two-story pink house with a Cadillac Escalade parke in the driveway. She recalled that . house was on a dead end street. Upon arriving at the house . stated that they walked up a driveway, ast what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to sec Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Short( thereafter, Epstein and his assistant, described as white fe ale vS,I) blond hair and later identified as entered the kitchen. Epstein introduced himself to M.. described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving. alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. . was instructed to follow upstairs: . recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a larlbathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. recalled there al a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told. to take off her clothes.. stated Epstein was stern when he told her to take off her clothes. M said she did not know what to do as she was the onlune there in the room, she took off her shirt leaving her bra on. Epstein had removed his towel and told the. to take off everything. stated Epstein was nude when he took his towel off, placing it on the floor as he laid il down on the table. stated she then removed her pants leaving her thonsjanties on. Epstein then instructed her to give him a massage poirW to a specific lotion for her to use. As IN began to giv ' e, he told her to t on his back. . stated she straddled herself on Epstein's back whereby Epstein's bare buttocks. M said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed. to massage his chest m was now standing on the ground and resumed massaging Epstein's chest area. M stated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then brined to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before rue this in day of May, 2006 by Det Joe Recarcy, wholipersonalfy known to mc. Page 2of 22 Date: 05 006 Slate of Florida Court of Palm B ach Officer EFTA00231453
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A8 Probable Cause Affidavit Palm Beach Police Department Agoney ORIN FLO 500600 stated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with was paid old El said she number. :::1 an were leaving the house, told shc received two hundred from Epstein. Before s surked to leave her phone dollars that y or aging er. During the course of the investigation, parental consent was granted for to assist with the ?stn. At our direction conducted controlled taped phone calls to cellular telephone . dig • II spoke with in an attemaiange another meeting with Epstein.. asked Robson, she need to do to make more ney. stated, "the more you do, the more you get paid." had subs uently called back U and left a voice mail message for her indicating that she had set up an ointment for . to go to Epstcht's house at 11:00 am on April 5, 2005. This message was recorded from voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a message pstcin W which stated -and. name at 11:00 am. This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt and I knocked on the door and met with was told that we were investigatinga claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach was asked if she would accompany us back to the police station for further questioning. She was also told at at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective. Bureau where I obtained a taped, statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turned 17 years of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked iiim anted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to inc. Signature of Police (ricer i.S.S. 117.10) State of Florida County of Palm Beach Officer Signature Date: 05/0 006 Page3of 22 EFTA00231454
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A9 Probable Cause Affidavit Palm Beach Police Department Agency O1U0 FLO 500600 (Unknown last name) and Tony (Unknown last name) picked up and she was taken to Epstcin's house. Upon her arrival to the house she ' uced to Epstein in the kitchen of the house. She wait was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her as Jeff Epstcin's bedroom. arranged the massage table and covered the table with a sheet. She brow t out the massage oils and laid them next to the massage bed. MI, then left the room and informed Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Durnmassage, tried to touch her. stated that Epstein stated "He tried to touch me and I stopped him." I asked how he and she felt uncomfortable. told Epstein, NI massage you but I don't want to he touched, stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brought to see Epstein, each time site was paid $200. stated she had brought the following girls: - ' • - ' , • , M. ( al6 year old female), (a 16 year old female) and :.._.* - . said that at the time she brought these girls to Epstein's house they werea1114 through 16 years of age. ! asked which one was the youngest. =I advised. was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they a ted. They were told they would provide a massage, possibly naked, and allow some touching. I asked her If . was aware. She stated every girl she brought knew what to expect. She ex lamed she knew that. wanted to make money. She approached. and explained about going to work for .. agreed and arrangements were made to bring her to Epstein's house on a weekend. stated that she and .__ (Later identified as -,..:... 71„,. .. . ) picked up. at her house. stated that at that time she was driving a red pickup truck. They traveled 6: Stein's house and entered through the kitchen door. They met with the li eheld Epstein's assistant =.. was introduced to Epstein while they were in the kitchen area. upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing. to Epstein's house. stated. told her she was paid $300.00 for the massage. stated that. was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by =. She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this l w day of May, 2006 by bet Joe Recarey, who is personally known to me. Signature of Police filet (F.S.S. 117.10) State of Florida Coun of Palm Beach Signatur Date: 05/01/2006 g Officer PageSof 22 EFTA00231455
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A10 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 when he was going to travel to Palm Beach. =said when Epstein announces to his assistant, he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein'. stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. further stated that still tries to call Robson.'s house and leaves messages. Sgt . entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstem's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was laced within the vehicle to record NI any conversations within the vehicle. During the drive back to her home, made the co " I'm like a Heidi Plass." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with a sixteen year-old female who was brought to Epstein's residence by . We met with mother at their front door. We explained the ongoing investigation and asked to speak with, as we had information that she had "worked" for Jeff. introduced us to her husband and allowed us entry into the home. tfalgt in the dining room and met with Date of Birth . As she was under the age of eighteen, = was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed,, who denied havi any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with approximately eight months ago and sat in the .was with the house chef, but nothing happened. As the parents were present during the interview, we felt that withholding information from us. She made several comments as to putting the entire incident behind her. I left myarne number and advised should she wish to speak with me again to telephone me. Sgt NI and I thanked for her time and left the area. She stated she would ask, again after we left as to what happened at Epstein's house. I informed her that I had my telephone number and hopefully she would call. On OctoberS2005, Da. and I drove to the — dob . During a sworn taped statement stated approximately a year ago. _ when she was seventeen years old, she was taken to a house by . stated she knows because they both attend Royal Palm Beach High School. She was told she could make money working '• home and met with ' and The foregoing instrument was sworn to or affirmed before me this I" day of May, 2006 by Del who is personally known to me. Signature of Police t7Mcer .5.5. 117.10) State of Florida Date: 05/01/2006 PageSof 22 EFTA00231456
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All Probable Cause Affidavit Palm Beach Police Department Agency OM PLO 500‘00 for Jeff She was told she would have to rovide a massage to Jeff. 7_, stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was alreadyApshe kitchen area. stated would wait for her in the kitchen. I . was introduced to =, Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a , massage. Epstein entered the room wearing only a towel and she provided a massage. - t her clothes on during the massage. She advised sometime during the massage Epstein and pulled her close to him. r said she was uncomfortable by the incident involving Jeff At the conclusion of the massage, she was paid $200.00 for the massage. I asked : ... : . if she has any formal training in massages to which s! hed no. I asked her if received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. ic stated she returned to Epstein's house on another occasion with and another 'z stated she waited in the kitchen with , while was taken upstairs by . stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach *.: via cell phows 4 voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested : to call her back reference the police questioning. T...'t provided the Incoming telephone number as . • . stated she inadvertently told'. ...._ about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Epstein. : asked her what wasgoing on at the house that the police would be asking questions. . • stated . then called Jeff and and asked what was going on reference the ongoing police investigation. According to has since then been trying to contact her to ask about the police questions. I instructed ' ' not to contact and do not provide any more information to as she would notify Jeff Epstein and what was transpiring. On October4, 2005, I made telephone contact with who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She .further advised she did not want to speak of this incident in front of heir )(Aber. At approximately 3:48 pm I made telephone contact with,. During a taped recorded statement ■ stated the following: approximately a year ago, when she was sixteen years of age, stook her time she went• drove to the house. They entered through the kitchen area where she was to Epstein's ho • knows because they both attend Royal Pal Beach High Soho° The first The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by Det • who is personally known to me. Signature of Police facer . 117.10) State of Florida Court otPahn Reach Signatur Date: 05/01/2006 g Officer Page 40122 EFTA00231457
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Al2 Probable Cause Affidavit Palm Beach Police Department Agawy OM PLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the sage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and stein had a verbal disagreement, at which time she left without being paid. She got with who was sittin in the kitchen and told her "let's ga." JS advised she received no money for that day. also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the 'more you do more you get paid. JS advised that several weeks later she agreed to be taken a second time by Haley Once they arrived at the residence, aitobson sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to touch her buttocks. M I was wearing tight Jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and &n. attempted to touch her breasts., then became upset again and told Epstein she didn't want to be touched. discontinued thmage and was paid S200.00. . then went downstairs where for her. She told was waiting she wanted to leave. I said she never returned to the house. stated she is thaw that her friend, _____. : was also at the house and had a problem with Epstein. 1- 1 later researched :, dob IIMS and met with her at her residence. During a sworn taped statement, T• ' ' lowing, on or aboalmember 2004, she was approached at Royal Palm Beach High School by a fellow student M asked - ' ' if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm'Beach. She was brwht into the kitchen area of the house. She further stated that follow Royal Palm Beach High School students MI and ' .) came with them. They were brought into the kitchen where she was introduced to Epstein and other females. _ . : stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told' • Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. . " ' I further stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. .: . ' ' was certain that she stayed in her thong underwear. ' ' continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed hero this 1" day of May, 2006 by p t . who is ersonally known to me. State of Florida of Palm Be h Signatur g Officer Signature of Police Office (F.S.S. 117.10) Date: 0510 12006 Pagel of 22 EFTA00231458
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A13 Probable Cause Affidavit Palm Beach Police Department Agency OWN FLO 500600 table, straddling Epstein to massage his back. While doing this ' was instructed to return to the ground at which time Epstein turned to ve his chest rubbed. : . ' ' : advised she was sure he was masturbating based on his band movements going up and down on his penis area. :... • ' did not want to look at his penis area because she was.uncomfortable. Epstein re v a ' ' was next to the mesas e table and turned it on. :..,..2L L. stated Epstein began . Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked 1_2. ' how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, •_. : was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Dct and I met withSdob at her residence. As. was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted . to cooperate and consented to the interview: During a sworn taped statement, . stated the following: at the age of sixteen,Aring the month of September 2004 she was approached by Haley Robson for a chance to make money. . was friends with associates of and knew the same people, en previously told by her end Royal Palm Beach High School, what did for Epstein. called a person known to as M fsi ifir and scheduled the appointment. picked El up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . Th entered the kitchen area of the house and met with Epstein.. was introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that white going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft mused. Mi exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area Epstein asked her to get comfortable. M advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly e massage, Epstein removed his towel and laid on the massage table naked. As M arca, he attempted to reach down her pan to touch her buttocks area however was unable to due due to the tightness of the jeans and a tight belt. advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this 1" day of May, .21106 by Det , who ispersonally. known to me. Signature of Police dicer .Ss. 111.10) State of Florida Date: 05/01/2006 Page8of 22 EFTA00231459
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A14 Signature of Poli e Office (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency 01W FLO 500600 , attempted to reach up her tank top and touch her breasts. epulled back and Epstein stopped, howev-slie kept masturbating until he climaxed. He cleaned himself wi I he was previously wearing. I. was paid $200.00 for the massage and left the area. She met with who was' waiting in the kitchen area and left the house. then explained she never provided another massage for Epstein. She did however, go to the house with and 1-_______ ;77.....; as they took another friend of Robson's. . advised she was present when . : went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for 1. ' ' ,. . advised while they waited for L • ' the house chef prepared lunch for them as it 'l unchtime when they went. When L.... ' was finished with the mass they left the asked if ever told her what would be expected when she provided a massage.. stated y told her that a massage would be expecte ossibly naked and possibly some touching Involved. ll has no formal training in providinssnassages. . spoke about a third and last time she went to Epstein's house. Robson ye another girl, M, (sixteen years of age) who is. friend, to Epstein's house.. stated . knew that had made money massaging stein and wanted to e oney herself took them in the kitchen i area of the house and introduced to and took . upstairs to the main m. III advised she doesn't know what happened as did not speak about what happened in the room. received $100.00 from for going with her to pstein's house and recommending . On October 6, 2005, at 11:45 am, I met with -. . :, dob a, at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. ...::_,; stated she had previously spoken with . , L.7 .... ' . who told she was interviewed by detectives. During a sworn taped statement, , stated she knew that worked for Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom She met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two ybars. I asked her if she had formal training in providing massages, which stated she had not advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue. - . began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. • explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained The foregoing instrument was sworn to or affirmed before me this ln day of May, 2006 by Bet , who is personally known to me. State of Florida ach Signatur Ing Officer Date: 0510112006 Pagelof 22 EFTA00231460
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A 1 5 Probable Cause Affidavit Palm Beach Police Department Agency OFUN FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "Jeff would try to get away with more and more on each massage". 2:: stateStein would try to touch her more and on one occasion he at tett to use a massager/vibrator on her. dmve to the house for the original massage. LC_ left her cell phone number and every ti e stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and re arc the massage table. 2.: advised stein would ask her questions about herself Epstein knew she was and would be attending . I asked : if Epstein knew her real age. ,.stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked - if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch ber breasts, she would pull away from hint and he would stop. ; was asked if he ev used a vibrator on her. . was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, who informed her that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up. informed ' she would have the car for a month. . stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is • currently parked next to the Gym field. 1 asked her if she ever took any one to the house. . • explained sit. len of hers who attended Royal Palm Beach High School, who has relocated to to attend college. I asked if she ever allowed another female in the room. . :advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of Lynn. University and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September I I, 2005, w/f dob la was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or iffirmed before me this I" day of May, 2006 by Det who is personally known to me. Signature of Pali e Officer (F.S.S. 117.1 State of Florida Date: 05/01/2006 Pagel0of 22 EFTA00231461
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Signature of Police Officer (P.S.S. 117.10) A16 Probable Cause Affidavit Palm Beach Police Department Agency ORD tIA) soda) for misdemeanor possession of marijuana. During the atrest. told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls frcim Epstein's residence, discarded papers were found which contained AH's name and cell phone number. On October. 11, 2005, Det and I met with and obtained a sworn taped statement explained she had been going to Epstein' e since 2002, when she was sixteen years of age. Since then she us has gone to the house hundreds of times. stated she became his "number one girl." She explained that on jafirst visit she was brought to the house by fellow Royal Palm eac chool classmate, . said she was brought through the en area where she met for the first time. Ewes led to the master bedroom, Epstein s room. explained that as she was walkin up the stairs she observed several photographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom, where Sarah prepared the room by setting up the massage table and provided the oils for her to tub on Epstein. IN explained she remembered the steam room area, which contained two large showers. Epstein entered the to from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. IN removed her skid and kept her shirt on. Epstein then instructed her to remove her shirt. removed her shirt and remembered she was not wearing a bra. stated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet All advised he turned over onto his back. Epstein touched her breasts and be an to masturbate. Epsteth ejaculated which meant the 1118S At the conclusion of the massage, was paid 5200.00. They walked thgether downstairs where MIIIM and were waiting. stated ..... received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number, that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back Epstein would toll onto his back and allow her to massase his chest area. stated Epstein would then began to masturbate himself and at with his fingers. •ex lained Epstein the same time would taut this process until he ejaculated. He would then advised that during her frequent visits Epstein asked for her real age, stated she was sixteen. anyone II her real age. advised that thin escalated within the home as Epstein with his female friend . ■ explained the that Epstein had at his disposal. and masturbate himself . Occasionally, Epstein would then join in Epstein advised her no would instruct and pa included Epstein would watch them The (ongoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida County of Palm Beach SIgnatu g Officer Date: 05/01/2006 Pageljof 22 EFTA00231462
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A17 Probable Cause Affidavit Palm Beach Police Department Agency ORD, FLO sonata during ii ale on female intercourse and provide oral sex to bothEland Marcinkova. This occurred during the time r was sixteen years of age. advised this continued to evtalate during two years. The routine became familiar to Il. Epstein's assistant i would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit ork for Epstein. Each timeisiething new was introduced, additional monies were produced and offered for to allow the acts to happen.. consented to perform all these acts but was adamant that there was an understanding with ein that no vaginal penetration would occ . An explained that Epstein's penis was deformed, . explained that his penis was oval shaped. claimed when tut called stein's penis "egg-shaped." . stated Epstein would photo ph Epstein's penis was erect, it was thick ward i the bottom but was thin and siiiiiiithe head and her and proudly display the photographs within the home. in which she provided a massage to Epstein, his•female friend, stated during one visit to Epstein's house was also present • provided the massage in which and her would fondle each others breasts and kiss for Epstein to en o . Towards the end of this massage, Epstein tttabbed and c upset over this. She said her bead was . She screamed "Not" and Epstein stopped. She told him that she did not want to . Epstein did not eSulate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. stated she knows he still displays her photographs through out the house. On October 12, 2005, Det and I met with . , dob who stated during a sworn taped statement, that nothing happened between her and Epstein. , appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. _ , stated on several occasions she provided a massage to Epstein. Sherstated she was brought to the Epstein house in March of 2005. , a classmate at Royal Palm Beach Hi t School, approached her and asked her if she wanted to "work". made the arrangements with Epstein's assistant. , -, who has no formal training in providing massages, stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for Epstein. He identified himself as "Paul". and inquired about the police investigation, and left his telephone number for additional contact. • provided no additional information, as it appeared her responses were almost scripted. The foregoing instrumisvas sworn to or affirmed before me this 1" day 2006 by Act who is personally known to me. Signature of Police Officer I.S.S. 117.10) State of Florida Date: 05/01/2006 Page I 3)f 22 EFTA00231463
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A18 Probable Cause Affidavit Palm Beach Police Department . Agency ORIN PLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with dob-, at the Palm Beach Police Department. 1::. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, .:. • advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approached by a girl, _ .1_, who was dating ' roommate, for an opportunity to make some quick money. 7 ; advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by ... that the massage would have to be done in her underwear. She advised "2. :3 drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and introduced himself as "Jeff" At Epstein's direction, , and , ; removed their clothing down to their panties, Epstein laid on his stomach area and they provided a massage on his legs and feet area. I asked if she had any formal massage training and she replied "no." .... advised she was topless and the panties she wore were the boy shorts lace panties. She and: ' continued the massage until the last ten minutes of the massage, Epstein, told to leave the mom so that' could finish the massage. • got dressed, and left the room as Epstein turned over onto his back. Epstein then removed the towel and laid naked . Epstein requested that . rub his chest S. - -gated as she did this, Epstein, began masturbating. stated Epstein pulled down her boy short panties, and be produced a ler e white vibrator • She stated it was within his reach in a drawer in his master bathroom. advised he never penetrated her vagina with the vibrator. He continued to nib hei vagina with the vibrator as he continued to masturbate. stated she was very uncomfortable during the • incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he bad on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing = • and paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. -irovided her cellular telephone number. was asked if she was recently contacted about this investigation by m the Epstein organization. She replied she was called but it VMS for work. She e was called by for her to return to "work" for Epstein. stated "work" is the term used bslito provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7, 2005, Det Mt and I mct with dob During a sworn taped statement, _ . stated she met Jeffrey Epstein through when ey were still The foregoing instrument was sworn to or affirmed before me this l" day of May, 2006 by Det who is personally knolwn to me. Signature of Police dfficer (F.S.S. 117.40) State of Florida Date: 05/01/2006 tcer Page r3o f 22 EFTA00231464
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Probable Cause Affidavit Palm Beach Police Department Agency ORTN FL O 500600 attending Royal Palm Beach High School. M I would approach females who wished to work for Epstein. • stated she was offered to work for Epstein but declined — - explained that "work" means give massages. She was asked about any formal training in providing massages which she said "no." • said she accompanied and other females who were taken to Epstein's house to provide massages. ' further stated she had been to the house approximate) 4 or 5 times in the past year. She accompanied with M, and. Each time the girls were taken over, they were previously told they woulJ have to provide a massage, possibly naked. They were also told that should Epstein require them to do anything extra, and they were not comfortable just to tell him and he would stop. . .• . stated received $200.00 for each gid she E> ght over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, who was really young, fifteen years old at the most. • further stated each time she went to the house, s e sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught hcr attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pin , I met with ,, dob , at the Palm Beach Police Department. During a sworn taped statemen , a classmate at Royal Palm Beach stated she had met Epstein approximately two ago when she was first approached by School. High approached her about working for Epstein and providing a massage to him for $200.00. bad made the arrangements however was unable to take her the day the arrangements were made. had take , . • also attended Royal Palm Beach High School and was familiar with Epstein. , recalled she was brow t there and entered through the back kitchen door. She had met with an assistant and another assistant . brought her upstairs as she observed several photographs of naked females throughout the house. ;fated Epstein came in the room, wearing only a towel, and laid on the table. stated he picked out the oils he wanted her to use and requested she remove her clothing to provide the massage. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedromn/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein e vibrator which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by Oct . , who is personally known to me. Signature of Police Offieer P.S.S. 31 -1 ) State of Florida Date: 05/01/2006 Pageitiof 22 EFTA00231465