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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
IN RE: OPERATION LEAP YEAR
Federal Grand Jury, 07-103
West Palm Beach, Florida
Nay 8, 2007
APPEARANCES:
, ESQUIRE
Assistant United States Attorney
, Foreperson
TESTIMONY
OF
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The sworn testimony of E.
was taken before the Federal Grand Jury, West Palm
Beach Division, West Palm Beach, Palm Beach County,
State of Florida, on the 8th day of may, 2007.
Philip W. may, Court Reporter, was authorized to
6 and did report the sworn testimony.
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
IN RE: OPERATION LEAP YEAR
Federal Grand Jury, 07-103
West Palm Beach, Florida
Nay 8, 2007
APPEARANCES:
, ESQUIRE
Assistant United States Attorney
, Foreperson
TESTIMONY
OF
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1 (The witness entered the grand jury room.)
2
3 having been duly sworn by the grand jury foreperson, I
4 was examined and testified on her oath as follows:
5 EXAMINATION
6 BY
7 Q Could you start by reminding us of your name and
8 where you're employed.
9 A ■
10 I work for the FBI here in West
11 Palm Beach on their violent crimes squad.
12 Q And you are one of the case agents in Operation
13 Leap Year?
14 A Yes, I am.
15 Q Did you recently participate in an interview of
16
17 A Yes.
18 Q Can you tell us date of birth?
19 A was born on
20 Q And you spoke with her recently?
21 A Yes, we did.
22 Q So she was 18 at the time of the interview?
23 A Yes, I believe she was.
24 Who is
25 A was identified by the Palm Beach
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1 Police Department as one of the girls who had frequented
2 Mr. Epstein's house.
3 Q How exactly did the Palm Beach Police Department
4 determine that she was one of those girls?
5 A When they did their search warrant at
6 Mr. Epstein's residence, some message pads were obtained
7 at his residence, and they had several calls from a girl
8 named , and phone numbers. So they were able to
9 track back those messages back to
10 Q Did the Palm Beach Police Department try to
11 interview Miss
12 A They did.
13 • Did she agree to speak with them?
14 A No. She stated that she loved Jeffrey Epstein,
15 and that she would not say anything positive or negative
16 about what occurred.
17 Q After the FBI became involved in this
18 investigation, did you try to interview Miss
19 A We did, as well, with no such luck, as well.
20 Q How long ago was it that you first made contact
21 with Miss
22 A It was back in November of '06.
23 Q Did you try to serve her with a subpoena issued
24 on behalf of this grand jury?
25 A Yes, we did.
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1 Q What happened?
2 A She refused service of the grand jury subpoena.
3 But she was notified of when her appearance was expected
4 here, and a subpoena was left with her.
5 Q After that, did she obtain an attorney?
6 A Yes, she did.
7 Q Who was that?
8 A Jim Eisenberg. He's a well-known defense
9 attorney here in West Palm Beach.
10 Q Who paid for that attorney?
11 A Mr. Epstein is paying for attorney.
12 Q Now once Miss secured the attorney, did
13 she agree to be interviewed?
14 A Yes, she did, after she was granted 6001
15 immunity. She requested immunity.
16 Q Did the justice department authorize that grant
17 of immunity?
18 A Yes, they did.
19 Q After that, did she agree to be interviewed?
20 A Yeah. It was only after she was given that
21 immunity that she would talk with us.
22 Q When did the interview take place?
23 A It took place at the end of April of this year,
24 so just a few weeks ago.
25 Q Who was present at that interview?
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1 A Myself; my partner, agent ; the AUSA,
2 her attorney, Jim Eisenberg, and his
3 investigator; as well as
4 Q what did Miss tell you about Jeffrey
5 Epstein?
6 A She stated that she had met an individual by the
7 name of at a party who had asked her if she
8 wanted to make a few bucks by giving a man a massage. She
9 was told that Mr. Epstein preferred them to be topless,
10 and she agreed to go to his house to give him a massage.
11 Q How old did Miss tell you she was at that
12 time?
13 A She stated she was 16 when she first started
14 giving Mr. Epstein massages.
15 Q Based upon your review of the evidence, is that
16 correct?
17 A No. We have phone records where
18 (phonetic), Mr. Epstein's assistant, is contacting
19 on her cell phone, or using her cell phone to call
20 cell phone starting in April of 2004, which makes
21 15.
22 Q So she said that she was 16, but your evidence
23 shows that she was 15, and she said that she was told she
24 could make a few bucks giving a topless massage?
25 A Yes.
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1 Q What else did Miss MN tell you?
2 A That she went to Mr. Epstein's residence, that
3 took her there the first time, that when she went
4 upstairs she was paid $200 when she first got there by
5 Then she goes upstairs, and Mr. Epstein
6 comes in, he disrobes, puts on a towel, lays down on the
7 massage table and she begins to massage him.
8 She tells Epstein that she heard he likes
9 topless massages, and he told her that he did. And she
10 said, 'who wouldn't?• And she ended up taking off her top
11 during the first massage. But is clear that Mr.
12 Epstein did not at any point touch her during the massage.
13 Q But does she admit that he
14 A Yes. On the second massage, Mr. Epstein asked
15 her to leave her phone number with . Her phone number
16 was left there. On the second massage, she returned the
17 very next day and gave him another massage. This time,
18 Mr. Epstein
19 Q Did Miss admit that
20
21 A Yes, . And I think her term was that
22 meaning that
23 Q How long of a period of time did Miss
24 tell you that she performed massages?
25 A She wasn't able to give us a number of massages,
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1 but just said that it was a lot, and that she had been
2 giving him massages for a year.
3 Q You mentioned to the grand jury that Miss
4 said that Mr. Epstein never touched her, correct?
5 A Yes.
6 Q And she was very adamant about that?
7 A Yes, she was.
Q Were there other things that she was adamant
9 about in her interview with you?
10 A Well, she talked about what she would tell the
11 girls that -- and that she told Mr. Epstein that she was
12 18. I'm sorry, I take that back. She was told to say
13 that she was 18, and she told us that she had a fake I.D.
14 showing that she was 18.
15 So she passed that information along to the
16 other girls when she brought -- eventually she brought
17 other girls to perform massages, and that was one of the
18 things that she told -- she told us first that she brought
19 18- to 20-year old girls. And then she stated that if the
20 girls lied, and they were underage, she told them that
21 they needed to tell Epstein that they were 18.
22 Q Have you been able to identify some of the girls
23 that Miss brought to Mr. Epstein's home?
24 A Yes.
25 Q Were any of those girls over 18?
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1 A No, not that we found so far.
2 Q Have any of the girls told investigators about
3 what Mr. Epstein knew about their ages?
4 A I'm sorry, say that again.
5 0 Have any of the girls who came through
6 been interviewed about what Mr. Epstein knew about
7 their ages?
8 A we did interview them regarding that, and I'm
9 not sure if he asked them. They were all told to say they
10 were 18, but not on every occasion would Mr. Epstein
11 inquire about their age.
12 Q Do you want to check your records on that?
13 A Yes, could I do that?
14 • Yes, please do.
15 A I can tell you that one of the girls that she
16 brought -- this girl told Mr. Epstein that she was in high
17 school, and actually told him her true age, which was
18 under 18.
19 Q So what told you about, that wasn't
20 really the case?
21 A No, that wasn't. Sorry.
22 Q That's all right, I just wanted to make sure
23 it's clear.
24 So Miss told you that she had been told
25 to say she was 18, and she also told you that she had a
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1 fake I.D.?
2 A Yes.
3 Q Did she ever say that Mr. Epstein either asked
4 for her age or asked to see her I.D.?
5 A No, the topic never came up.
6 Q Did you also ask her about how appointments were
7 made?
8 A Yes. She was very clear in the fact that
9 would call her to arrange the appointments, but
10 would call her once Jeffrey was in town.
that
11 Q So she was adamant that the calls only happened
12 when she was already here?
13 A Yes.
14 Q. Were you made aware that Epstein's counsel was
15 informed that he was being investigated for traveling to
16 engage in prostitution, which means that the appointments
1/ would have been made before the traveling?
18 A Yes.
19 Q Was there anything else, besides the issue of
20 age and the issue of when the appointments were made, that
21 sounded coached or that she was especially adamant about?
22 A No, I wouldn't say coached. I mean, we talked
23 about the preferences that Jeffrey discussed, as far as
24 which girls he would like to bring.
25 Once started giving massages to Epstein,
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1 told us that he liked different faces, so he would
2 ask her to bring other girls. We asked her if he ever
3 gave any preferences of what he preferred, and her
4 response was that Epstein liked girls like her, which is
5 thin and blond and attractive.
6 Q And how old was she at the time?
7 A She was 15.
8 Q So thin, blonde, attractive and --
9 A Young, girls like her. I guess we asked if she
10 ever made a mistake, or ever brought somebody that Mr.
11 Epstein didn't take to. She said that she had screwed up
12 and that she had brought a black girl to Mr. Epstein, and
13 that Epstein was not interested in black girls. But he
14 did pay her, and said that he wasn't a racist. He paid
15 her the $200 for her time, but did not want her to perform
16 a massage for him.
17 Q And he didn't allow that girl to perform a
18 massage?
19 A No.
20 Was there anything else that Miss talked
21 about in the interview that you want to share with the
22 grand jury?
23 A I did ask her at the end of the interview if she
24 was in love with Mr. Epstein. She looked into the camera
25 and said that she loved him like a friend. But then she
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1 kind of looked into the camera and gave a wink and a smile
2 and said, "But with your money, I'd marry you any time,
3 Jeffrey."
4 Q Did she also say that she considered him to be
5 an •awesome guy'?
6 A Several times she referred to him as an "awesome
7 guy° • She said that the girls begged her to come and that
8 the girls didn't have a complaint, and the girls would
9 share with her everything that happened after the massage,
10 and that Jeffrey never touched any of the girls. But as I
11 informed you, we did interview some of the girls that she
12 took, and he has touched them.
13 Q In preparation for your testimony today, did you
14 also speak with someone who is considered to be an expert
15 in these cases?
16 A YeS.
17 Q And what is that person's name?
18 A
19 Q Has Mr. been qualified to testify as an
20 expert in federal and state courts in cases that involve
21 what he calls "compliant victims"?
22 A Yes.
23 Q what does he mean by the term "compliant
24 victims"?
25 A A compliant victim is when a victim is not
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1 necessarily forced into the conduct that the offender
2 wants them to engage into, that they actually consent to
3 that kind of activity.
4 Q So that would include minors who are subjected
5 to sexual activity but weren't necessarily kidnapped or
6 forced at gunpoint, or something like that?
7 A Exactly.
8 Q Did he discuss with you the difficulties that
exist when you interview those types of victims?
10 A Yes. He stated that a compliant victim is often
11 times embarrassed that they went along with the behavior.
12 They are also likely to deny the behavior, especially when
13 being interviewed by investigators, that they'll deny it
14 or they'll minimize it. Sometimes it takes two, three or
15 multiple interviews to get compliant victims to either
16 trust their interviewer or realize that their interviewer
17 is not going to be judgemental.
18 Q In this case, have you found that to be the case
19 with some of the interviews?
20 A Yes, I have.
21 Q In addition to being embarrassed, sometimes
22 these victims feel guilty about the fact that they were
23 involved in this type of activity?
24 A Oh, yes.
25 Q Does Mr. also have expertise in sexual
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1 preference of offenders?
2 A Yes, he does.
3 Q Did he explain why an offender would select the
4 types of victims that are involved in this case, girls
5 between 14 and 17-years-old?
6 A This type of offender, the sexual preference he
7 has is for post-pubescent females that are physically
8 developed but not necessarily mentally matured. The girls
9 ranging in this age are sometimes inexperienced, they are
10 possibly naive, not as worldly.
11 An offender of this type could also maybe not
12 feel sexually adequate or feel competent dealing with his
13 own age group. So knowing that these girls are less
14 experienced, may focus on them as well.
15 Q In addition to their emotional immaturity, did I
16 Mr. talk about whether or not younger girls are
17 easier to manipulate than grown women?
18 A Yes.
19 Q Did he talk to you about "grooming"?
20 A Yeah. That's what an offender will use with a
21 compliant victim. He told us that grooming is a technique
22 where you gain the cooperation of those victims by
23 focusing on their interests and playing up to those
24 interests. It's a type of seduction, he cal led it. That
25 was his words for it. And we actually see this in this
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1 case.
2 Can you give us an example of some of the types
3 of grooming that Mr. Epstein used?
4 A With one of the girls we're going to talk about
5 today, , it's very apparent interviewing her how
6 Epstein groomed her. She only went to three or four
7 massages at this time, that she's admitted to. We feel
8 that due to her phone conversations, the multiple calls,
9 that there may be more there. At this point she has
10 stated to us that she has performed three or four massages
11 for Mr. Epstein.
12 what he did is when she first went there he
13 played upon -- she was very shy, and he would play upon
14 that shyness. He told her that she was pretty. He asked
15 her to remove her clothing, and she would not. So he kind
16 of kidded around with her shyness and complimented her,
17 showed interest in her, talked about her boyfriend and
18 different interests she had.
19 At the end of that interview, because she did
20 not take off her clothes, he tells her that if she's
21 willing to do more, she will make more. He also tells her
22 that he would pay her if she would bring other girls. As
23 the massages increased, you can see that the next time she
24 comes he plays again to that shyness, but he gets a little
25 bit more -- I guess he sees that it's not working. This
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1 time she does comply and takes off her -- he asked her to
2 disrobe on the second massage. She takes off her blouse,
3 but she refuses to take off the bra after Mr. Epstein
4 asked her to.
5 So you can see that he tries through showing
6 interest. And then he actually -- when he sees that this
7 isn't working, he takes a more authoritative role with her
8 in the last massage. She said that throughout all of
9 these massages he was very nice, and then at the end he
10 was much more frustrated and irritated. She does get down
11 to her bra and panties on that one, he's just much
12 more authoritative.
13 So he started with the grooming process, tried
14 to get her interest, tried to use that to get her to
15 comply with removing her clothes. But as often happens,
16 at the end of this, he took over and was much more
17 forceful with his requests.
18 Q Have other girls described that same situation
19 where every time they went back, he tried to push it one
20 step further and one step further?
21 A Yes. Several of the girls have said that he
22 would always push for more and more.
23 Q Did Mr. explain why it is that a
24 compliant child victim cannot legally consent to the
25 sexual conduct?
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1 A Yeah. He stated that -- you know, we talked
2 about how the law protects children, and stated that we
3 hold adults accountable. When it comes to adolescents,
4 they go through normal tendencies that mature offenders
5 may try to take advantage of. But the law is in place for
6 that reason, to protect -- in the federal law, to protect
7 those individuals under the age of 18.
8 Q And that's because of the different maturity
9 levels of the --
10 A The offender versus the victims, exactly.
11 Q Did you put together the photographs of the
12 defendants in this case?
13 A Yes, I did.
14 Q Are these photographs of the four human
15 defendants who are named in the proposed indictment?
16 A Yes.
17 Q With their names underneath them?
18 A Yes.
19 Q Agent, who is in the top left-hand corner?
20 A That's Jeffrey Epstein.
21 Q when was this photograph taken?
22 A Recently. There was an article that just came
23 out regarding Mr. Epstein and his connection, or his
24 personal relationship with Prince Andrew, and that was a
25 picture that was in that article.
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1 Q Who is in the top right-hand corner?
2 A That's
3 Q Again, this is a relatively recent photograph?
4 A Yes, that's his personal assistant.
5 Q And the bottom left-hand corner?
6 A Again, that is one of Mr. Epstein's personal
7 assistants, that's (phonetic).
8 Q Has Miss since gotten married?
9 A Yes, her name now is
10 Q And the bottom right-hand corner?
11 A That is . She is, again, a
12 personal assistant to Mr. Epstein. There has been some
13 talk that she is also romantically -- or I should say
14 sexually involved with Mr. Epstein.
15 Q How old are the defendants?
16 A Jeffrey is in his mid-fifties, and the three
17 girls are in their early twenties.
18 Q Do you have a copy of the draft indictment in
19 front of you?
20 A Yes, I do.
21 Q You mentioned when we were looking at the
22 photographs that the three females work as personal
23 assistants for Mr. Epstein, is that correct?
24 A Yes.
25 Q So he is their employer?
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1 A Yes.
2 Q Are you familiar with the property located at
3 3S8 El Brillo Way in Palm Beach?
4 A That's Mr. Epstein residence.
5 Q And he owns that residence?
6 A Yes, he does.
7 Q Are you familiar with Defendant J.E.G.E., Inc.?
8 A Yes. J.E.G.E., Inc. is owned by Jeffrey
9 Epstein. He is the president, the owner, the sole
10 director. It's a business that is solely used for the
11 activities of one of Mr. Epstein's airplanes, which is his
12 Boeing 727. Its tail number is N908JE.
13 And you mentioned that he is the president and
14 the sole director. Is he also the sole shareholder?
15 A Yes, he is.
16 0 Are you familiar with Hyperion Air, Inc.?
17 A Yes. Hyperion Air, Inc. is also a business
18 owned by Mr. Epstein. He is also the president, the
19 director and the sole shareholder of that company as well.
20 That company solely does business with his other aircraft,
21 which is a Gulf Stream G-1159B. It bears a tail number
22 N909JE.
23 Q Is that a smaller aircraft than the Boeing?
24 A Yes.
25 Just to briefly remind the grand jury about
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