EFTA00176235

LAW OFF ICC* OF 
GERALD B. Lirraytrat, P.C. 
( 
e. 
Min
. 
Esq., Assistant United States Attorney 
Esq., Deputy Chief, Northern Region 
Office o 
e United States Attorney 
Southern District of Florida 
February 1, 2007 
Page 20 
investigators discovered and turned over to the PBPD during the course of the 
investigation. 
served 21 months in federal prison for his offense. 
statements of 
While the Police Report and Probable Cause Affidavit ar
an 
step-mother, omitted is 
state conviction for identity fraud (annexed at Tab 12). This 
information, uncovered by defense investigators, was also turned over to the 
PBPD during the course of the investigation. 
IV. 
The Facts of This Case Militate Against Bringing a Federal Prosecution 
A. 
Declining To Prosecute as an Exercise of Discretion 
Epstein is being prosecuted by state authorities in Florida. Even if we assume arguendo 
that Epstein's conduct constitutes a federal crime that can be proven, nevertheless no "substantial 
Federal interest" would be served by prosecuting him. On this question, the United States 
Attorney's Manual (USAM) itself gives specific guidance. Section 9-27.230 provides: 
In determining whether prosecution should be 
declined because no substantial Federal interest 
would be served by prosecution, the attorney for the 
government 
should 
weigh 
all 
relevant 
considerations, including: Federal law enforcement 
priorities; the nature and seriousness of the offense; 
the deterrent effect of prosecution; the person's 
culpability in connection with the offense; the 
person's history with respect to criminal activity; 
the person's willingness to cooperate in the 
investigation or prosecution of others; and the 
probable sentence or other consequences if the 
person is convicted.I7
Each of these factors militates against prosecution. As indicated, federal law enforcement 
priorities focus on particular phenomena involving the sexual abuse of minors, the use of the 
" Each of these factors is discussed in greater detail in USAM 9-27.230(B). 
EFTA00176255

LAW Off IVES Cr 
GERALD B. Laarcatarr, P.G. 
Mr
Esq., Assistant United States Attorney 
Esq., Deputy Chief, Northern Region 
Office of the United States Attorney 
Southern District of Florida 
February I, 2007 
Page 21 
internet to lure minors to engage in prohibited sexual activity, child pornography, or trafficking. 
The conduct in which Epstein is alleged to have engaged fits nowhere in these categories. Given 
its essentially sui generis character, its prosecution would have little or no general deterrent 
effect. 
If prosecuted under statutes designed to address far more serious conduct and far more 
dangerous offenders, he would be subject to punishment that is grossly disproportionate to his 
alleged behavior. Even though society has a legitimate interest in preventing and punishing 
sexual exploitation of minors, under our federal system, that interest is one that is shared 
between the federal government and the states, and one in which there is a division of 
responsibility. Under our system of federalism, the states, and only the states, act where the 
concern is local, and the federal government only where there is a federal interest at stake. This 
is just as true with respect to sexual activity involving minors as it is with respect to murder, 
which can be prosecuted, federally, only in special circumstances where there is a genuine 
federal interest to be served. 
Most importantly, there is no identifiable federal interest to be served by prosecuting the 
conduct at issue in this case. The federal interest lies in addressing the problem of Internet 
predators, a problem of uniquely federal interest. As the Director of the Office for Victims of 
Crime of the DOJ has stated, "...the nature of Internet crimes presents complex new challenges 
for law enforcement agencies and victim service providers with regard to investigating crimes, 
collecting evidence, identifying and apprehending offenders, and assisting child victims and their 
families." U.S.D.O.J., Office of Justice Programs, OVC Bulletin, Internet Crimes Against 
Children, December 2001. Federal lawmakers recognized that while the internet presents 
wonderful opportunities for young people, at the same time "criminals are also using modern 
technology - to prey on innocent victims." Id 
That should be sufficient to end the matter, as Epstein's case has nothing whatever to do 
with internet predation, or the type of predators to which the legislation is addressed. 
After all, it is a first principle that the Constitution creates a federal government of 
enumerated powers. See United States v.= 
514 U.S. 549, 552 (1995) ("Just as the 
separation and independence of the coordinate branches of the Federal Government serve to 
prevent the accumulation of excessive power in any one branch, a healthy balance of power 
between the States and the Federal Government will reduce the risk of tyranny and abuse from 
either front.") (quoting Gregory v. Ashcroft, 501 U.S. 452, 458 (1997 
Thus, Congress's power 
to legislate in this area is constrained by the Commerce Clause. As 
demonstrates, the 
EFTA00176256

LAW OFFIC[30F 
GERALD 13. Larcotrirr, P.C. 
...
Esq., Assistant United States Attorney 
sq., Deputy Chief, Northern Region 
Office of the United States Attorney 
Southern District of Florida 
February 1, 2007 
Page 22 
Clause imposes real limitations on Congress's power to criminalize essentially local behavior. 
See United States v. Morrison, 529 U.S. 598 (2000) (Violence Against Women Act exceeded 
Congressional power under the Commerce Clause or § 5 of the Fourteenth Amendment). 
M
, of course, recognizes Congress's power to regulate "the use of the channels of 
interstate commeind "to keep the channels of interstate commerce free from immoral and 
injurious uses." 
514 U.S. at 558. But this confirms that the legitimate federal interest is 
in the misuse of instrumentalities or channels of interstate commerce. This suggests that, in 
defining and weighing the federal interest, the focus should be on the use of interstate travel, and 
not upon the sexual conduct itself. Clearly, Epstein's interstate travel can be of no legitimate or 
significant federal interest. He spent a great deal of his time in Florida because he has owned a 
home there for seventeen years and has many professional, social and personal interests centered 
there, none of which has anything to do with sexual conduct. Given the attenuated relationship 
between sexual conduct with any person under 18 and interstate travel, the federal interest in this 
matter is negligible. 
The conduct at issue is not an example of a widespread or growing phenomenon that in 
general crosses state or international lines (like intemet sexual predators or sex tourism) that is 
difficult to police or prosecute and that the United States has a special interest in eliminating. It 
does not involve the special targeting of children. It does not involve organized prostitution, sex 
trafficking, or organized crime. It does.not involve violence or the threat of violence, nor 
physical harm or threat of harm. It does not involve child pornography. Indeed, the 
circumstances of this case are so idiosyncratic that its pursuit would not significantly advance the 
protection of minors. Instead, the conduct at issue here is precisely the conduct that is primary 
interest to the state. And it is the state that has the authority, and the right, to establish and rely 
on reasonable criteria for deciding which cases to bring and which to forego. 
To the extent that the federal statutes in this area are broadly drafted, this is to confer on 
the authorities sufficient leeway to exercise their discretion and "get the bad guys" who do 
exploit minors, often on a massive scale or for financial rewards. The very breadth of the 
statutory language places on federal prosecutors the weighty responsibility of insuring that their 
discretion is exercised thoughtfully. Certainly, the fact that conduct arguably falls within the 
broad scope of a broadly worded federal criminal statute cannot itself establish that a substantial 
federal interest is at stake. 
Nor does the statutory breadth mean that prosecutors should strive to test the statutes' 
outer boundaries. This is particularly true here, where private conduct is at issue; where the 
EFTA00176257

LAW OIVICILS a 
GERALD J3. Linrcarrirr, P.V. 
Milii
. 
Esq., Assistant United States Attorney 
Esq., Deputy Chief, Northern Region 
Office o 
e United States Attorney 
Southern District of Florida 
February 1, 2007 
Page 23 
federal statutes, broadly read, would criminalize sexual conduct that state law may permit; and 
where the question of whether federal le
 in this area exceeds Commerce Clause 
authority, in light of United States v. 
supra, remains unresolved by the Supreme Court. It 
is well to remember that hard cases make bad law — for the government as well as for its citizens. 
Indeed, if the use of a handgun that traveled in interstate commerce does not allow a federal 
prosecution by invocation of the Commerce Clause, as the Supreme Court ruled in 
then 
surely purely local sexual activity would not, either. 
B. 
Petite Policy 
In addition to the factors discussed above, the Petite Policy (regarding dual and 
successive prosecutions), a limitation on prosecutorial authority, may also stand as a bar to 
federal prosecution. If it is arguable whether the policy applies, the policy itself may require that 
Justice Department authorization to proceed be obtained. 
The Policy, which takes its name from Petite v. United States, 361 U.S. 529 (1960), is set 
forth in the USAM at 9-2.031. The Petite Policy "establishes guidelines for the exercise of 
discretion by appropriate officers of the Department of Justice in determining whether to bring a 
federal prosecution based on substantially the same act(s) or transactions involved in a prior state 
or federal proceeding." 
The purpose of the policy "is to vindicate substantial federal interests through appropriate 
federal prosecutions, to protect persons charged with criminal conduct from the burdens 
associated with multiple prosecutions and punishments for substantially the same acts or 
transactions, to promote efficient utilization of Department resources, and to promote 
coordination and cooperation between federal and state prosecutors." USAM 9-2.031(A). 
Though the Policy does not create any substantive or procedural rights enforceable by law, see, 
e.g., United States v. Snell, 592 F.2d 1083 (9th Cir. 1979), it nevertheless provides a valid basis 
for arguing against the institution of charges in this matter. 
The crux of the Policy is this: 
This policy precludes the initiation or continuation 
of a federal prosecution, following a prior state or 
federal prosecution based on substantially the same 
act(s) or transaction(s) unless three substantive 
prerequisites are satisfied: first, the matter must 
EFTA00176258

LAW OFFICCH OF 
GERALD B. LEFOOURT, P.C. 
Esq., Assistant United States Attorney 
Esq., Deputy Chief, Northern Region 
Office of the United States Attorney 
Southern District of Florida 
February 1, 2007 
Page 24 
involve a substantial federal interest; second, the 
prior prosecution must have left that interest 
demonstrably unvindicated; and third, applying the 
same test that is applicable to all federal 
prosecutions, the government must believe that the 
defendant's conduct constitutes a federal offense, 
and that the admissible evidence probably will be 
sufficient to obtain and sustain a conviction by an 
unbiased trier of fact. 
In addition, there is a 
procedural prerequisite to be satisfied, that is, the 
prosecution must be approved by the appropriate 
Assistant Attorney General. 
Satisfaction of the three substantive prerequisites 
does not mean that a proposed prosecution must be 
approved or brought. The traditional elements of 
federal prosecutorial discretion continue to apply. 
Whether the matter involves a substantial federal interest is a determination to be made 
on a case-by-case basis, applying the considerations applicable to all federal prosecutions. The 
second prerequisite is that the prior prosecution must have left that substantial federal interest 
"demonstrably unvindicated." "In general, the Department will presume that a prior prosecution, 
regardless of result, has vindicated the relevant federal interest." USAM 9-2.031(D)28
The presumption may be overcome when the prior prosecution resulted in a conviction if 
the prior sentence was manifestly inadequate in light of the federal interest involved or if the 
choice of charges in the prior prosecution was affected by certain inappropriate or irrelevant 
factor such as "incompetence, corruption, intimidation, or undue influence." 
No such factors operated here. The negotiations between the State Attorney were 
conducted at arms length, and at times in an atmosphere of mutual hostility. At no point was 
Epstein granted any sort of break in his case due to his wealth, his political affiliations, or the 
prominence of his lawyers. If anything, those factors worked against him. The state prosecutors 
devoted enormous resources to a lengthy investigation, refused to reveal the nature of the charges 
1s All three substantive pre-requisites for approval of a prosecution governed by the Petite Policy are 
discussed in greater detail in USAM 9-2.031(D). 
EFTA00176259

LAW ()MCC, OF 
GERALD B. LiarcovEr, P.C. 
( 
( 
I 
( 
( 
( 
( 
Esq., Assistant United States Attorney 
Esq., Deputy Chief, Northern Region 
Office of the United States Attorney 
Southern District of Florida 
February 1, 2007 
Page 25 
they were considering, refused to speak with Epstein's attorney of choice, and tried to strong-arm 
Epstein to plead guilty to a violent felony by threatening to place witnesses, whom the State 
knew were not credible, on the stand before a grand jury. 
In determining the charges, the State Attorney took into account the fact that both of the 
principal victims - 
and 
- have serious credibility problems, 
including damaging histories of lies, illegal drug use, and crime. The State Attorney, quite 
appropriately, took into account the substantial possibility that, with witnesses of their ilk, it 
might not be able to make any case against Epstein at all. In fact, according to Barry ICrischer, 
the State Attorney for Palm Beach County, his reason to take the case to the grand jury, rather 
than proceed by information, was to determine whether his witnesses would testify under oath, 
even without being lS&
eeted to cross-examination. Tellingly, though subpoenaed to testify at 
the grand jury, Ms. M 
failed even to appear. 
The charging decision was not an act of favoritism, but a rather harsh exercise of the 
State Attorney's discretion. The State Attorney had never before prosecuted a case involving 
erotic touching unless the victim was exceedingly young, vulnerable, or in a trust relationship 
with the perpetrator. Cases brought by the State Attorney previously involved far more 
egregious conduct, including the videotaping of sexual activity, multiple rapes, and keeping 
minors as sex slaves, including tattooing them to indicate ownership and control over them. Any 
suggestion that Epstein received preferential treatment - or that the State prosecutors were 
corrupt - would be utterly without merit. 
For all of these reasons, we submit that no prosecution can or should be brought against 
Jeffrey Epstein. We would like to reserve the opportunity to make a further submission in which 
we address more specifically the applicable law once we have had the benefit of narrowing the 
focus at our meeting. 
cc: Roy Black, Esq. 
Lilly Ann Sanchez, Esq. 
ri 
Gerald B. 
( 
EFTA00176260

C 
C. 
c 
C 
c 
c 
t 
EFTA00176261

Date: 2/17/06 
PALM BEACH POLICE DEPARTMENT 
Page: 
1 
Time: 11:36:35 
Incident Report 
Program: CMS301L 
Case No 
SPECIAL NOTES : 
Occur To Date : 
Day Of Week 
Street Number : 
City  
Location Type : 
Beat Assignment: 
Dept Class . . 
Case Status . : 
Supervisory Dt.: 
Entry Date . . : 
Names/ 
Vehicles? 
Narrative? 
. . : 
. 
: 
1-05-000368 
DO NOT RELEASE 
1/27/05 0000 
Thursday 
358 EL BRILLO WY 
PALM BEACH, FL 
RESIDENCE-SINGLE 
DETECTIVE BUREAU 
SEXUAL BATTERY 
OPEN 
ACTIVE 
Occur From Date: 1/27/05 0000 
Report Date . : 3/14/05 1600 
FAMILY 
Map Reference 
Report Officer 
Case Status Dt 
: 10 
: 111105 
Property? . . : 
Offenses? . . : 
Related Cases? : 
****** ***VEHICLE 
Case number . : 1-05-000368 
State Veh Type : 
Make  
Model Name . . : 
Style 
 
Color - Bottom : 
N F ORMATION
# 
Category . 
Year  
Model 
 
Permit Number 
Color - Top . 
License # . . 
1 
•
 
• 
******** ****** ******* 
0 
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Stolen value . 
0 
Disposition . : 
Insured . . . 
Insured by . . : 
Keys in car . 
Vehicle locked : 
Lein holder . 
Date recovered : 0/00/00 
Recovery value 
0 
Street number : 
City  
Recovery code : 
NCIC number . : 
Be On Look Out?: 
 
 PERSON 
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Case Number . : 1-05-000368 
Street Number : 
City 
Birth Date/Age : 
Occupation . . 
Home Phone No. : 
Sex 
 
 Female 
Weight  
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Street Number : 
City  
Birth Date . . 
Employer? . . . 
Oper Lic No. . : 
Other Phone Nbr: 
Sex 
 
• 
Minimum Weight : 
SUSPECT 
1-05-000368 
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INFO 
Last Name . . : 
# 1 ********* 
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. 
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Race
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INFORMATION- 
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valid in: 
Female 
0 
Prompt 
Maximum Age . : 
Occupation . . : 
Home Phone No. : 
Race  
• White 
Minimum Height : 0 
Maximum Height : 0 
EFTA00176262

Date: 2/17/06 
Time: 11:36:35 
Case No 
Maximum Weight 
Aliases? . . . 
: 
: 
PALM BEACH POLICE DEPARTMENT 
Incident Report 
1-05-000368 
0 
Misc. ID# . . 
MO/Crime Spec? 
Hair Color . . : 
Hair Length 
Hair Style . . : 
Eye Color 
Glasses . . . : 
Complexion 
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Build 
 
Teeth 
 
Speech  
Hat 
 
Coat  
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Pants 
 
Shoes 
 
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Body Marks #2 : 
Body Marks #3 : 
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Status  
• 
Arrest Case No.: 
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S 
Case Number . : 
Street Number : 
City  
• 
Birth Date . . : 
Employer? . . : 
Oper Lic No. . : 
Other Phone Nbr: 
Sex 
 
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Minimum Weight : 0 
Maximum Weight : 0 
Aliases' 
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Glasses .  
Facial Hair 
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Hat 
 
Shirt 
 
Shoes 
 
Body Marks #2 : 
Body Marks #4 : 
Arrest Case No.: 
************** 
Case Number . 
Street Number 
S USPECT/ARRESTEE 
INFO 
RMATION- 
# 3 ** 
: 1-05-000368 
Prompt valid in: EPSTEIN, JEFFREY 
: 358 EL BRILLO WY 
City  
• PALM BEACH, FL 000033480 
Birth Date . . : 1/20/1953 52 
Maximum Age . : 52 
Employer? . . : 
Occupation . . 
Oper Lic No. . : E123425530200 FL 
Home Phone No. 
Other Phone Nbr: 
Race  
White 
Sex 
 
• Male 
Minimum Height : 0 
Minimum Weight : 0 
Maximum Height : 0 
Maximum Weight
0 
Misc. ID# . . 
Aliases' 
MO/Crime Spec? 
Hair Color 
Hair Length . 
Hair Style 
. : 
Eye Color . . 
USPECT/ARR 
1-05-000368 
358 EL BRILLO WY 
PALM BEACH, FL 000033480 
25 
Maximum Age . 
Occupation . . 
241534676 HA 
Home Phone No 
Race  
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Minimum Height 
Maximum Height 
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MO/Crime Spec? 
Hair Length 
Eye Color 
Complexion 
Build 
 
Speech  
Coat  
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Body Marks #1 : 
Body Marks #3 : 
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Page: 
2 
Program: CMS301L 
ESTEE 
INF O 
Prompt valid in: 
(Continued) 
STILL SUSPECT 
RMATTON- 
4 2 ** 
: 25 
PERSONAL ASST/EPSTEIN 
: 0 
: 0 
EFTA00176263

Date: 2/17/06 
Time: 11:36:35 
PALM BEACH POLICE DEPARTMENT 
Page: 
3 
Incident Report 
Program: CMS301L 
Case No 
• 1-05-000368 
Glasses . . . 
Facial Hair . 
Teeth 
 
Hat 
 
Shirt 
 
Shoes 
 
Body Marks #2 : 
Body Marks #4 : 
Arrest Case No.: 
************** 
Case Number . : 
Prompt valid in: 
Street Number : 
City  
• WEST ALM BEA 
Birth Date/Age : 
Occupation . . : STUDENT 
Home Phone No. : 
Sex 
 
• Fema e 
Weight  
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Be On Look Out?: 
ICTIM 
1-05-000368 
Victim Type . 
JUVENILE 
Residency Sts : 
Can Identify . : 
Injury Extent : 
Injury Type 2 : 
Med Treatment : 
Phys Last Name : 
************** 
Case Number . : 
Street Number : 
City  
Birth Date/Age : 
Occupation . . 
Home Phone No. : 
Sex 
 
Weight 
Be On Look Out?: 
ViCtim Type . : ADULT 
Residency Sts : 
Can Identify . 
Injury Extent : 
Injury Type 2 : 
Med Treatment : 
Phys Last Name : 
V ICTIM 
1-05-000368 
PALM BEACH 
Female 
 
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• 
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1-05-000368 
PALM BEACH, 
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Pants 
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Status  
Additional 
. . : 
UCR?: 
INFORMATIO 
H, FL 33412 
FL 
(Continued) 
STILL SUSPECT 
N - # 1 ******************** 
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Oper Lic No. 
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Height  
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: 
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INFORMATION 
- # 3
Prompt valid in: • 
FL 000033480 
Employer? 
******************** 
EFTA00176264

Date: 2/17/06 
Time: 11:36:35 
PALM BEACH POLICE DEPARTMENT 
Page: 
5 
Incident Report 
Program: CMS301L 
Case No 
Street Number : 
City  
• 
Birth Date/Age : 
Occupation . . : 
Home Phone No. : 
Sex 
Weight  
Be On Look Out?: 
Victim Type . : 
Residency Sts : 
Can Identify . 
Injury Extent : 
Injury Type 2 
Med Treatment : 
Phys Last Name : 
************** 
Case Number . : 1-05-000368 
Street Number : 
City  
• 
Birth Date/Age : 
Occupation . . : 
Home Phone No. : 
Sex 
 
 Female 
Weight  
 0 
Be On Look Out?: 
Victim Type . : 
Residency Sts : 
Can Identify . : 
Injury Extent : 
Injury Type 2 
Med Treatment : 
Phys Last Name : 
1-05-000368 
PALM BEACH, FL 000033480 
Employer? . . 
Oper Lic No. . : 
Race  
• White 
Height  
• 0 
Misc. ID# . . : 
Other Phone Nbr: 
JUVENILE 
Residency Type : 
File Charges . : 
Victim Sobriety: 
Injury Type 1 : 
Hospital ID . : 
Phys First Name: 
 
 Female 
0 
ICTIM 
************** 
Case Number 
 
Street Number 
City  
Birth Date/Age 
Occupation 
Home Phone No. 
Sex 
INFORMATION 
- # 
Prompt valid in: 
PALM BEACH, FL 000033480 
17 
Employer? . . 
Oper Lic No. . : 
Race  
• White 
Height  
• 0 
Misc. ID# . . : 
Other Phone Nbr: 
JUVENILE 
Residency Type : 
File Charges . : 
Victim Sobriety: 
Injury Type 1 : 
Hospital ID . : 
Phys First Name: 
VICTIM 
: 1-05-000368 
PALM BEACH 
 
 Female 
Weight  
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Be On Look Out?: 
Victim Type . : JUVENILE 
Residency Sts : 
Can Identify . : 
Injury Extent : 
Injury Type 2 : 
Med Treatment : 
Phys Last Name : 
***** ******* 
** 
FL 
(Continued) 
7 ******************** 
NICOLE 
INFORMATION 
- # 8 
Prompt valid in: 
000033480 
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Employer? 
Oper Lic No. 
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Height  
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ICTIM 
INFORMATION 
- # 9 
EFTA00176265

Date: 2/17/06 
Time: 11:36:35 
PALM BEACH POLICE DEPARTMENT 
Page: 
4 
Incident Report 
Program: CMS301L 
Case No 
• 1-05-000368 
Occupation 
Home Phone No. : 
Sex 
 
 Female 
Weight  
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Be On Look Out?: 
Victim Type . : JUVENILE 
Residency Sts : 
Can Identify . 
Injury Extent : 
Injury Type 2 : 
Med Treatment : 
Phys Last Name : 
************** 
VICTIM 
Case Number . : 1-05-000368 
Street Number : 
City  
• PALM BEACH, 
Birth Date/Age : 
OCcupation . . 
Home Phone No. : 
Sex 
 
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Weight  
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Victim Type . 
Residency Sts 
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Injury Extent 
Injury Type 2 
Med Treatment 
Phys Last Name 
************** 
Case Number . 
Street Number 
City 
Birth Date/Age : 
Occupation . . 
Home Phone No. : 
Sex 
Weight  
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Victim Type . 
Residency Sts 
Can Identify . 
Injury Extent 
Injury Type 2 
Med Treatment 
Phys Last Name 
: JUVENILE 
VICTIM 
: 1-05-000368 
 
• PALM 
************** 
BEACH,
 
 Female 
0 
: ADULT 
VICTIM 
Case Number . : 1-05-000368 
Prompt valid in: 
Oper Lic No. . : 
Race  
• white 
Height  
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Misc. ID# . . : 
Other Phone Nbr: 
Residency Type : 
File Charges . : 
Victim Sobriety: 
Injury Type 1 : 
Hospital ID . : 
Phys First Name: 
INFORMATION 
-# 
Prompt valid in: 
FL 000033480 
FL 
(Continued) 
4 ******************** 
Employer? . . : 
Oper Lic No. . : 
Race  
• white 
Height  
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Misc. ID# 
Other Phone Nbr: 
Residency Type : 
File Charges . : 
Victim Sobriety: 
Injury Type 1 : 
Hospital ID . : 
Phys First Name: 
INFORMATION 
-# 
Prompt valid in: 
000033480 
Employer? . 
Oper Lic No. 
Race  
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Height  
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5 ******************** 
A 
. : 
. : 
INFORMATION 
-# 6******************** 
EFTA00176266

Date: 2/17/06 
Time: 11:36:35 
PALM BEACH POLICE DEPARTMENT 
Page: 
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Incident Report 
Program: CMS301L 
Case No 
Case Number . : 
Street Number : 
City  
• 
Birth Date/Age : 
Occupation . . : 
Home Phone No. : 
Sex 
 
• 
Weight  
Be On Look Out?: 
Victim Type . : 
Residency Sts : 
Can Identify . : 
Injury Extent : 
Injury Type 2 : 
Med Treatment : 
Phys Last Name : 
***** ****** *** 
Case Number . : 
Prompt valid in: 
Street Number : 
City 
Birth Date/Age : 
Occupation . . : 
Home Phone No. : 
Sex 
Weight  
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Victim Type . : 
Residency Sts : 
Can Identify . : 
Injury Extent : 
Injury Type 2 : 
Med Treatment : 
Phys Last Name : 
1-05-000368 
1-05-000368 
PALM BEACH, FL 
Female 
0 
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1-05-000368 
Prompt valid in: 
000033480 
Employer? . . : 
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: 
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INFORMATION 
 
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************** 
Case Number . : 
Street Number : 
City  
Birth Date/Age : 
Occupation . . 
Home Phone No. : 
Sex 
Weight  
Be On Look Out?: 
Victim Type . : 
Residency Sts : 
Can Identify . : 
Injury Extent : 
Injury Type 2 : 
Med Treatment : 
 
 Female 
0 
JUVENILE 
ICTIM 
1-05-000368 
PALM BEACH, FL 
 
 Female 
0 
ADULT 
GERALDINE 
000033480 
INFO 
(Continued) 
White 
0 
# 10 ******************* 
Employer? . 
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Race  
 White 
Height  
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Misc. ID# .
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File Charges . : 
Victim Sobriety: 
Injury Type 1 : 
Hospital ID . : 
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RMATION 
- 
# 
11 
****** 
**** ***** **** 
Prompt valid in: 
000033480 
Employer? . . : 
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Race  
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Height  
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Victim Sobriety: 
Injury Type 1 : 
Hospital ID . 
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0 
NICOLE 
EFTA00176267

Date: 2/17/06 
PALM BEACH POLICE DEPARTMENT 
Page: 
7 
Time: 11:36:35 
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Program: CMS301L 
Case No 
• 
Phys Last Name : 
******* ******* 
V 
Case Number . : 
Street Number : 
City  
• 
Birth Date/Age : 
Occupation . . 
Home Phone No. : 
Sex 
 
Weight  
Be On Look Out?: 
1-05-000368 
ICTIM 
1-05-000368 
PALM BEACH, 
INFORMATION 
- # 
Prompt valid in: 
FL 000033480 
Employer? . . : 
Oper Lic No. . : 
Race  
• 
Height  
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(Continued) 
12 ******************* 
White 
0 
Female 
0 
Victim Type . : ADULT 
Residency Type : 
Residency Sts : 
File Charges . : 
Can Identify . : 
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Injury Extent : 
Injury Type 1 : 
Injury Type 2 : 
Hospital ID . : 
Med Treatment : 
Phys First Name: 
Phys Last Name : 
 
 VICTIM 
NFORMAT/ON 
13 ******************* 
Case Number . : 1-05-000368 
Prompt valid in: 
Street Number 
City  
Birth Date/Age : 
PALM BEACH, FL 000033480 
Employer? . . : 
Occupation . . : 
Oper Lic No. . : 
Home Phone No. : 
Race  
• White 
Sex 
 
 Female 
Height  
0 
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Misc. ID# . . : 
Be On Look Out?: 
Other Phone Nbr: 
Victim Type . 
Residency Sts 
Can Identify . 
Injury Extent 
Injury Type 2 
Med Treatment 
Phys Last Name 
************** 
Case Number . : 1-05-000368 
Street Number : 
City  
Birth Date/Age : 
Occupation . 
Home Phone No. : 
SeX 
 
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Weight  
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Victim Type . : JUVENILE 
Residency Sts : 
Can Identify . : 
Injury Extent : 
: JUVENILE 
VICTIM 
I N 
Residency Type : 
File Charges . : 
Victim Sobriety: 
Injury Type 1 : 
Hospital ID . : 
Phys First Name: 
FORMATION
-
Prompt valid in: 
PALM BEACH, FL 000033480 
Employer? 
. 
Oper Lic No. 
Race  
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Other Phone Nbr: 
Residency Type : 
File Charges . : 
Victim Sobriety: 
Injury Type 1 : 
is ******* ***** 
* ****** 
. : 
EFTA00176268

Date: 2/17/06 
Time: 11:36:35 
PALM BEACH POLICE DEPARTMENT 
Incident Report 
Page: 
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Program: CMS301L 
Case No. . . . : 
Injury Type 2 : 
Med Treatment : 
1-05-000368 
Hospital ID . 
Phys First Name: 
(Continued) 
Phys Last Name : 
4ii.************* 
ICTIM 
INFORMATIO 
N - # 15 ******************* 
Case Number . 
1-05-000368 
Prompt valid in: 
Street Number : 
City  
• PALM BEACH, FL 000033480 
Employer?
Birth Date/Age : 
Occupation . . : 
Oper Lic No. .
Home Phone No. : 
Race 
• White 
Sex 
 
Weight  
Female 
0 
Height  
Misc. ID# . . 
0 
Be On Look Out?: 
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Victim Type . : ADULT 
Residency Sts : 
Can Identify . : 
Injury Extent : 
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Med Treatment : 
Phys Last Name : 
Residency Type : 
File Charges . : 
Victim Sobriety: 
Injury Type 1 : 
Hospital ID . : 
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************** 
V,7 ICTIM 
INFORMATION. 
- # 16 ******************* 
Case Number . : 1-05-000368 
Prompt valid in: 
Street Number : 
City  
• 
Birth Date/Age
PALM BEACH, FL 000033480 
Employer? . . : 
Occupation . . : 
Oper Lic No. . : 
Home Phone No. : 
Sex 
 
Weight  
Female 
0 
Race . . . . . : 
Height  
• 
Misc. ID# . . : 
White 
0 
Be On Look Out?: 
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Victim Type . : JUVENILE 
Residency Type : 
Residency Sts : 
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Can Identify . : 
Victim Sobriety: 
Injury Extent : 
Injury Type 1 : 
Injury Type 2 : 
Hospital ID . : 
Med Treatment : 
Phys First Name: 
Phys Last Name : 
************** I ICTIM 
INFORMATION 
- # 17 **** ***** ********** 
Case Number . : 1-05-000368 
Prompt valid in: 
Street Number : 
City  
• PALM BEACH, FL 000033480 
Birth Date/Age : 
Employer? . . : 
Occupation . . : 
Oper Lic No. . : 
Home Phone No. : 
Race  
• White 
Sex 
 
• Female 
Weight  
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Be On Look Out?: 
Height  
Misc. ID# . 
Other Phone Nbr: 
0 
Victim Type . : JUVENILE 
Residency Type : 
Residency Sts : 
File Charges . : 
EFTA00176269

Date: 2/17/06 
Time: 11:36:35 
PALM BEACH POLICE DEPARTMENT 
Page: 
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Incident Report 
Program: CMS301L 
Case No 
• 1-05-000368 
Can Identify . : 
Injury Extent : 
Injury Type 2 : 
Med Treatment : 
Phys Last Name : 
********* OTHER 
Case Number . 
1-05-000368 
Street Number : 
City 
Birth Date/Age : 
Occupation . . : STUDENT 
Home Phone No. : 
Sex 
 
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Weight  
• 0 
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********* 
0 
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T H 
P E R 
(Continued) 
Victim Sobriety: 
Injury Type 1 : 
Hospital ID . 
Phys First Name: 
S 0 N 
INFORMATION 
- #1********* 
Last Name . . : 
E R 
PERSON 
1-05-000368 
358 EL BRILLO WY 
PALM BEACH, FL 000033480 
 
 Female 
0 
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Oper Lic No. 
Race 
foyer? . . : 
Oper Lic No. . : 
Rade  
• White 
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• 0 
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/NFORMATION
 -# 2 ********* 
Last Name . . : 
. : 
. : M625620855610 FL 
 
 White 
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 510 
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: OTHER PERSON 
********* OTHER 
P E R S 0 N 
INFORMATION 
-# 3 ********* 
Case Number . : 1-05-000368 
Last Name . . : 
Street Number : 
City  
Birth Date/Age : ilingliMi 
Employer? . . : 
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Oper Lic No. . : 
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• White 
Sex 
 
• Female 
Height  
• 0 
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Person Type . : OTHER PERSON 
Other Phone Nbr: 
***** * * * * OTHER 
PERSON 
INFORMATION 
- # 4 
Case Number . : 1-05-000368 
Last Name . . : 
Street Number
City  
Birth Date/Age
Occupation 
: PAINTER 
Home Phone No. : 
Sex 
 
 Ma e 
Weight  
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********* 0 T H 
Case Number . : 
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PERSON 
1-05-000368 
Employer? . 
: 
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• White 
Height  
• 0 
Person Type . : OTHER PERSON 
INFORMATION 
-# 5 ********* 
Last Name . . : BACK, KATHY 
EFTA00176270

Date: 2/17/06 
Time: 11:36:35 
PALM BEACH POLICE DEPARTMENT 
Incident Report 
Page: 
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Program: CMS301L 
Case No 
Street Number : 
1-05-000368 
(Continued) 
City  
Birth Date/Age : 0/00/0000 0 
Employer? . . : 
Occupation . . : FAMILY THERAPIST 
Oper Lic No. . : 
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Race  
White 
Sex 
 
Weight  
• Female 
0 
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0 
OTHER PERSON 
Other Phone Nbr: 
Case Number . : 
***EMPLOYER INFORMATION*** 
1-05-000368 
Employer Name : PBC DIVISON OF YOUTH AFFAIRS 
Address . . . : 4200 N AUSTRALIAN AV 
City/State/Zip 
Phone Number . 
: 
: 
WEST PALM BEACH, FL 33407 
****** *** OTHER 
P E R S 
Case Number . : 1-05-000368 
Street Number : 
City 
Birth Date/Age : 
Occupation . . : STUDENT 
Home Phone No. : 
Sex 
 
• Ma e 
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ON 
INFORMATION 
- # 6 ********* 
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 White 
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Person Type . : OTHER PERSON 
***EMPLOYER INFORMATION*** 
Case Number . 
Address . . . 
City/State/Zip : 
Phone Number . : 
1-05-000368 
Employer Name : SUMMIT CHRISTIAN SCHOOL 
4900 SUMMIT BV 
WEST PALM BEACH, YL 33415 
*********OTHER 
P E R 
Case Number . : 1-05-000368 
Street Number : 
City  
• 
Birth Date/Age : 
Occupation . . : 
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Sex 
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WEST PALM 
0/00/0000 
 
 Male 
0 
S O N 
INFORMATION
 -#
Last Name . .
BEACH, FL 33412 
0 
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• White 
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• 0 
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: OTHER PERSON 
********* 
0 THER 
P E R S 0 N 
Case Number . : 1-05-000368 
Street Number : 
City  
Birth Date/Age : 0 00 0000 0 
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• Female 
7 ********* 
A 
IN
 - # 8 *********
Last Name . . : 
Employer? . . : 
Oper Lic No. . : 
Race  
• 
Height  
• 0 
EFTA00176271

Date: 2/17/06 
PALM BEACH POLICE DEPARTMENT 
Page: 
11 
Time: 11:36:35 
Incident Report 
Program: CMS301L 
Case No 
 1-05-000368 
Weight  
• 0 
Other Phone Nbr: 
(Continued) 
Person Type . : OTHER PERSON 
********* OTHER 
PERSO 
N 
INFORMATION 
-# 9 ********* 
Case Number . : 1-05-000368 
Last Name . . : 
Street Number 
City  
Birth Date/Age : 
Occupation . . :  
Home Phone No.
Sex 
 
• Female 
Weight  
• 0 
Other Phone Nbr: 
Employer? 
. . : 
Oper Lic No. . : M460812887661 FL 
Race  
 White 
Height  
 0 
Person Type . : OTHER PERSON 
****************************NARRATIV 
Original Report 
LO 
Reported By: 
Entered By.: 
E 
# 1 *** ***** ********** 
* * *** **** 
9/20/05 
9/20/05 
On 03/14/2005, I received a call from a woman who did not wish to 
identify herself. (Later identified as  
) She stated that 
her fourteen year old step daughter (later identitied as 
possibly ma have been molested in Palm Beach by a wealthy 
man. According to 
, she learned of the possible molestation 
by a third party. S e exp ained that she had received a call from the 
mother of her stepdaughter's friend. The mother claimed to have 
overheard a conversation between her daughter and a male friend; they 
were talking about 
. The conversation was about how 
had met 
with a 45- ear-old man and had sex with him and was paid or it. I 
advised 
that I would like to meet with her to obtain a more 
detailed statement and facts. 
stated she did not know what 
do and had to discuss the matter wi 
her husband. At this point 
did not provide me with a call back number or any other 
information. She stated that she would contact me once she had spoken 
with her husband and 
mother. 
On 03/14/2005 received a call from Mr. & Mrs. 
. The stated 
it was okay to speak to their daughter IIII via ce 
phone 
Her mother 
had beenErde aware of the case. 
ey 
a reed to meet me at t e po ice department later this date. 
On 03 14/2005, Mr.  
 accompanied by his wife 
came to the Palm Beach Police Department were they all!! me 
that they believe their fourteen year old daughter may have had some 
type of sexual relationship with an older male who resided in Palm 
Beach. Neither knew the suspect s name or address. Both stated that 
their daughter did not talk to them about the incident, nor would she 
admit to it. 
identified his daughter as 
05 13 1990; resides with her biologics mot er 
at 
is a twin, 
EFTA00176272

Date: 2/17/06 
PALM BEACH POLICE DEPARTMENT 
Page: 
12 
Time: 11:36:35 
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Program: CMS301L 
Case No 
• 1-05-000368 
(Continued) 
her sister 
resides with Mr. 
. Both 
and 
are 
currently attending High Ridge vocational school, !RI is an 
facilit during the week and comes homes on the week. '  According to 
, she was admitted to the school because of disciplinary 
involuntary admitted juvenile educational facility. 
stays at the 
problems that recently escalated. The facility also coordinates with 
the families to provide one on one as well as family counseling. 
According to Mrs. 
, she believes the incident occurred on 
Sunday, Feb 6, 2005. A friend of 
named III. picked her up at 
their house and left. They believe 
instigate the relationship 
with the older gentleman though they o not have any proof. 
lives close by with her mother. Mrs. 
further explaillilhat 
was introduced to 
by 
, a boy she was dating. 
Goes to Summit Christian, plays ase a 
. Mrs. 
continued 
that on Sunday, 
picked up IIII, and drove toill'illach where 
they met the man. Supposedly, tEi-Man has a lot of money and often 
has young girls come over to his house. I. 
offers these girls a 
way to make fast cash. The man starts wit a massa e. If he likes 
them, he keeps them around and does more. The 
did not have 
any information on 
other than she lives on 7 n 
ace North, the 
last house on right si e (north side). 
Mrs. 
talked of the conversation that she had with the mother 
of 
. MrS. 
stated that Nuevo was a former friend 
of 
. S e found it strange that they were no longer friends 
until s e received the call from her mother telling her of the 
conversation she overheard between Sheens and a boy named Zach. 
Mrs. 
told me of an incident that occurred on 02/09/2005. 
IIII got into a fight at school (Eclyal Palm HS). Mrs. Brown assistant 
principal, found over $300.00 in IIII s purse. !III gave different 
explanations for the large sum of money. Initia y the school 
administration thought it was drug related but then dismissed the 
claim. Since that day, 
did not return to school; she ran away 
Thursday, 02/10th or Fri ay 02/11 and returned to her mother's house 
later that night after midnight. It was not until after 
received the call from Sheena's mother, 
that she learned Sheena wastegr 
ta got into the 
fight with 
. The fight was instigated when Sheena 
being a prostitute. 
who has legal joint custody of his daughter 
, signed the affidavit of prosecution indicating he 
to 
prosecute against the inappropriate sexual behavior with his 
fourteen-year-old daughter. 
Mr. 
stated that he had no objections with our agency speaking 
with his aughter 
about the incident. Mr. 
mother 
is aware of the allegations and also was willing to 
cooperate. Accor ing to Mrs. 
, she does not believe her 
daughter had any additional contact with the suspect as she was with 
accused 
of 
EFTA00176273

Date: 2/17/06 
PALM BEACH POLICE DEPARTMENT 
Page: 
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Time: 11:36:35 
Incident Report 
Program: CMS301L 
Case No 
• 1-05-000368 
her mother and then placed into High Ridge. 
I contacted the School Board Police who provided me the information 
for Sable Palm, also known as High Ridge Family Center 840 - 4540. 
4200 N Australian Avenue, West Palm Beach, Florida. 
Checking the 
school board records for  
, there is no 
disciplinary record found. I was advised if no disciplinary action 
was taken for a fight, such as an expulsion or detention, the incident 
may not have been recorded. This was at the discretion of the 
individual school security and principal. 
03/15/2005, I called the Palm Beach County Sheriff's Office and left a 
, Child Abuse Unit. 
to High Ridge/Sable Palm where I met with white 
Also present was 
audiotaped interviewee 
wit 
that were made. 
initiall 
enie 
only admitting to going with a 
later 
) to Palm Beach to pick up money 
was 
as the cousin of her ormer 
She u timate y admitted to knowing that 
man and possibly did sexual favors for him. 
had offered her an opportunity to make 
message for PBSP Sgt. 
On 03/15/2005, I went 
female
therapist. During an 
about the allegations 
anything had happened 
identified as 
owed. 
boyfrien 
worked for a wea t 
also admitted that 
money. 
(Continued) 
identified 
boss as a white male named "Jeff who 
1 ved in Palm Beach Later positively identified as Jeffrey Epstein). 
explained that she was first 22,Emached by 
to go with 
her to Jeff s house, when they were at IIIII s house. According to 
li 
, she was not sure exactl what was going on with 
but 
s boyfriend) became angry when 
he heard 
inviting 
to accompany her.
believed 
agreed to ii with her. 
it was to pick up money t e man owed 
. 
s a e 
told her that she would pick her up a 
er house on unday. 
was not sure of the exact dates but knew it was a Sunday. According 
pic ed er upl  
along with an unknown, possibly His anic female, 
!'llir father s house on 76th Lane. 
told her 
to 
, 
father that they were going 
i shopping. It was laterconfirmed by 
that 
picked his daughter up. According to Mr. 
drove a pick up truck. 
drove S. 
Sometime on the wa 
whereas 
) age, she 
along with the unknown female to Palm Beach. 
there, a conversation occurred between 
and 
MiliMEM told 
that if Jeff asked her 
mmm!!!uld say a e was eighteen. 
recalled that the Jeff's house was on a dead end street. All 
three girls walked up a drivewa 
ast what appeared to be a small 
guard/security room. In fact, 
recalled a male approaching 
them asking what they wanted. 
stated they were there to see 
Jeff. The male allowed them to continue walking up to the house. 
EFTA00176274