EFTA00792500

Pursuant to Civil Rights Law § 50-b, the identities of the victims, who 
are the victims of sex offenses, shall be confidential, and this 
document shall not be made available for public inspection. 
To be argued 
DEBORAH L MORSE 
Petu Pork i§uprente Court 
Appellate Division - First Department 
THE PEOPLE OF THE STATE OF NEW YORK, 
Respondent, 
- against - 
JEFFREY E. EPSTEIN 
Dcfendant-Appellant. 
BRIEF 
FOR RESPONDENT 
CYRUS R. VANCE, JR. 
District Attorney 
New York County 
Attorney for Respondent 
One Hogan Place 
New York, New York 10013 
(212) 335-9000 
danyappeals®dany.nyc.gov 
GINA MIGNOLA 
DEBORAH L MORSE 
ASSISTANT DISTRICT ATTORNEYS 
Of Counsel 
EFTA00792500

TABLE OF CONTENTS 
Page 
TABLE OF AUTHORITIES 
ii 
INTRODUCTION 
1 
POINT 
THE SORA COURT'S DESIGNATION OF 
DEFENDANT AS A LEVEL-THREE OFFENDER 
WAS SUPPORTED OVERWHELMINGLY BY THE 
RECORD. THE PROCESS BY WHICH THE COURT 
REACHED AND DELIVERED THAT 
DETERMINATION WAS ENTIRELY FAIR AND 
PROPER 
33 
CONCLUSION 
63 
EFTA00792501

TABLE OF AUTHORITIES 
CASES 
Contrast People v. Ferguson, 53 A.D.3d 571 (2d Dept. 2008) 
57 
58 
43 
36 
35 
People v. Belter, 84 A.D.3d 905 (2d Dept. 2011) 
People v. Brensic, 70 N.Y.2d 9 (1987) 
People v. Conway, 47 A.D.3d 492 (1st Dept. 2008) 
People v. Guaman, 8 A.D.3d 545 (2d Dept. 2004) 
People v. Johnson, 77 A.D.3d 548 (1st Dept. 2010) 
38, 49 
People v. Kello, 96 N.Y.2d 740 (2001) 
39 
People v. Knox, 12 N.Y.3d 60 (2009) 
36 
People v. Mendez, 45 A.D.3d 429 (1st Dept. 2007) 
36 
People v. Mingo, 12 N.Y.3d 563 (2009) 
36-37, 40 
People v. O'Neal, 35 A.D.3d 302 (1st Dept. 2006) 
36 
People v. Pettigrew, 14 N.Y.3d 406 (2010) 
36 
People v. Roland, 292 A.D.2d 271 (1st Dept. 2002) 
38 
People v. Smith, 75 A.D.3d 1112 (4th Dept. 2010) 
58 
People v. Vasquez, 20 Misc.3d 37 (App. Term 1st Dept. 2008) 
37 
People v. Windham 10 N.Y.3d 801 (2008) 
36, 38 
STATUTES 
Corrections Law § 168-1 
29, 35 
Correction Law § 168-n(3) 
36, 58 
Correction Law § 169-8(3) 
36 
Fla. Stat 796.03 
1 
EFTA00792502

Ha. Stat. 796.07 
 1 
EFTA00792503

SUPREME COURT OF THE STATE OF NEW YORK 
APPELLATE DIVISION: FIRST DEPARTMENT 
THE PEOPLE OF THE STATE OF NEW YORK, 
Respondent, 
-against-
JEFFREY EPSTEIN, 
Defendant-Appellant. 
BRIEF FOR RESPONDENT 
INTRODUCTION 
Defendant, Jeffrey Epstein, appeals from an order of the Supreme Court, New 
York County (Ruth Pickholz, J.), entered on January 18, 2011, adjudicating him a 
level-three sex offender pursuant to the Sex Offender Registration Act ("SORA"). 
By the underlying judgment, defendant was convicted in Palm Beach County, Florida, 
by his plea of guilty, of Procuring a Person Under 18 for Prostitution (Fla. Stat. 
796.03) and Felony Solicitation of Prostitution (Fla. Stat 796.07). On June 30, 2008, 
defendant was sentenced to serve consecutive jail terms of 12 months and 6 months, 
to be followed by a 12-month term of Community Control. 
Defendant has 
completed his sentence. 
EFTA00792504

Apart from various other residential properties, defendant maintains homes 
both in Palm Beach, Florida, and on the Upper East Side of Manhattan. The SORA 
risk-level designation that defendant received in New York is the subject of this 
appeal. 
The criminal conduct underlying the SORA designation occurred in 
defendant's Palm Beach home. 
On March 15, 2005, a 14-year-old girl and her family made a report to the Palm 
Beach Police Department about sexual misconduct committed against her by then 51-
year-old defendant. For almost a year—from March 2005 to February 2006—the 
Palm Beach Police Department conducted an extensive investigation of defendant 
and two accomplices who had helped him lure young girls to the seclusion of his 
home. On May 1, 2006, a Palm Beach detective swore out a 22-page probable-cause 
affidavit detailing the results of dozens of police interviews as well as the first-hand 
observations of Palm Beach detectives. 
Among other things, the investigation revealed that defendant had been paying 
young girls—many from 
who were 16 years of age or 
less—to come to his home and give him a massage as he lay naked, masturbated, and 
engaged in sexual contact with them. The sexual contact during these "massages" 
included vaginal intercourse, mouth to vagina sodomy, touching of the girl's breasts 
and vagina, placing his fingers inside the girl's vagina, and using a vibrator on the girl's 
vaginal area—always as he masturbated to climax. During certain time periods, 
defendant was receiving these "massages" two or three times a day. The girls were 
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EFTA00792505

paid anywhere from $200 to $1,000 per massage, depending upon the nature of the 
sexual contact that they permitted. 
In July of 2006, five months after the investigation had concluded, the Palm 
Beach County State's Attorney's Office obtained an indictment charging defendant 
with one count of Felony Solicitation of Prostitution. Defendant was taken into 
custody. Almost two years later, on June 26, 2008, the State's Attorney's Office filed 
an information charging defendant with an additional crime—namely, Procuring a 
Person Under 18 For Prostitution. Four days later, on June 30, 2008, defendant 
pleaded guilty to both accusatory instruments—namely, one count each of Procuring 
a Person Under 18 for Prostitution and Felony Solicitation of Prostitution. That same 
day, defendant was sentenced to serve consecutive jail terms of 12 months and 6 
months, to be followed by a 12-month term of Community Control. 
Because one of the crimes required that defendant register in Florida as a sex-
offender, the fact that he also maintained a residence in Manhattan meant that he had 
to register in New York State as a sex offender as well. Following an investigation, 
the State of New York Board of Examiners of Sex Offenders ("The Board') 
recommended that, on the three-tier SORA classification scale, defendant be classified 
as a level-three sex offender. The Board reached that conclusion after having 
calculated defendant's risk assessment score at 130—solidly above the 110 qualifying 
number for level three. 
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EFTA00792506

On January 18, 2011, after having received the appropriate notice months 
earlier, two attorneys—the ones who are representing defendant on appeal—
appeared before Justice Ruth Pickholz on defendant's behalf for a hearing to 
determine defendant's risk level; defendant chose not to attend the proceedings. At 
the hearing, defendant urged that a proper application of the SORA guidelines to his 
conduct warranted a level-one classification. 
Apparently misapprehending the 
governing legal standards, the People expressed concern about assessing points 
against defendant on the basis of the victim-accounts detailed in the probable-cause 
affidavit; the People seem to have based that position largely on the mistaken notion 
that only sexual conduct for which defendant had been formally charged could be 
considered when calculating his risk-assessment score. After hearing argument from 
both parties, and reviewing all the materials that had been submitted, the court 
adopted the recommendation made by the SORA Board and found defendant to be a 
level-three sex offender. 
On appeal, defendant contends that he was incorrectly classified a level-three 
offender and should have been classified a level-one offender instead. 
More 
particularly, defendant contends that the level-three designation lacked the support of 
clear and convincing evidence, and was based instead on improper considerations. 
Defendant further complains that the court rendered its ruling without affording the 
parties an opportunity to present evidence on disputed issues, and issued an order that 
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EFTA00792507

lacked the requisite findings and conclusions. 
THE MATERIALS PROVIDED TO THE SORA COURT 
The Florida Probable-Cause Affidavit 
Among the materials provided to the SORA court was the probable-cause 
affidavit prepared by detectives of the Palm Beach Police Department (A6-27). This 
22-page document, sworn to by a detective, outlined the findings of a "sexual battery" 
investigation beginning on March 15, 2005, and extending through February of 2006 
(A6).' The numerous interviews conducted by the Palm Beach Police produced 
sworn, tape-recorded statements from what the police denominated as five victims 
and seventeen witnesses. 
The statements concerned "massages" provided to 
defendant by high school girls in exchange for money, and "other unlawful sexual 
activity" by defendant involving those young girls, in defendant's Palm Beach home 
(A6). 
Defendant was 51 years of age at the time of four of the specified criminal 
incidents, and 52 years of age at the time of the fifth (A27). 
The affidavit revealed that defendant had set up, and maintained, a highly 
organized operation to satisfy his compulsive need for young girls. Most of the 
victims were students at 
(A6). And, defendant had 
Parenthetical numerical references preceded by "A" are to the pages of Defendant's 
Appendix. 
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EFTA00792508

maintained a steady and orderly stream of these girls with the aid of various 
employees. For the equivalent of a finder's fee, 
a student at 
recruited classmates to perform these so-called "massages." 
=, 
defendant's adult assistant, regularly was present at defendant's house at 
the time of the massages, recorded the girls' names and contact information for future 
reference, and set up appointments for the girls to come to the house at regular 
intervals on each day that defendant was in town (A6). 
The affidavit further revealed that most of the "massage" sessions themselves 
followed a regular routine. Upon arrival at defendant's house, the victim was escorted 
to defendant's bedroom, where defendant entered the room wearing nothing but a 
towel and instructed the girl to remove her clothes as well (A6). As the girl provided 
the massage in some state of undress, which usually consisted of only panties, 
defendant subjected her to some sort of sexual contact—including rubbing her vagina 
with his fingers or a vibrator, or inserting his penis or fingers into her vagina (A6). At 
the conclusion of the massage, the girls were given cash in sums ranging from $200 to 
$1,000, depending upon the extent of the sexual contact (A6). More particularly, the 
affidavit related the following specific accounts: 
The Statements By Girls Who Had Provided "Massages" 
During an interview that was sworn and tape-recorded, 14-year-old S G a 
student at 
reported to detectives that 
had 
-6-
EFTA00792509

offered her an opportunity to make money, and then had picked her up at home and 
driven her to defendant's house (A6-7). The two entered the house through the 
kitchen door, and were met shortly afterwards by defendant and 
(A7). 
escorted S.G. up a flight of stairs, past walls lined with photographs, to a room 
containing a massage table and a "hot-pink and green" sofa (AD. There was a mural 
of a naked woman in the room, and on a shelf there were several photographs of 
naked women (A7). 
Defendant entered the room wearing only a towel, and, speaking "stem[ly]," he 
commanded S.G. to remove her clothes as well (A7). Not knowing "what to do," 
since she "was the only one there," S.G. removed her shirt (A7). Defendant, who had 
removed the towel and was naked, directed S.G. to take off everything, and she 
complied—leaving on only her thong panties (A7). Pointing to a particular container 
of lotion, defendant instructed S.G. to massage his back (AD. Defendant then 
directed S.G. to sit on his back, and as S.G. straddled defendant's back, her exposed 
buttocks were touching his (AD. 
After a while, defendant turned over on his back and instructed S.G. to 
massage his chest (AD. As S.G. complied, defendant held the small of S.G.'s back 
with one hand and masturbated with the other (AD. Retrieving a purple vibrator, 
defendant held the vibrator on her vaginal area, on top of her underwear (A6-7). 
Defendant ejaculated, used the towel to wipe himself, and left the room (A8). 
Downstairs, defendant gave S.G. $300 and told her to leave her telephone number 
-7-
EFTA00792510

(A8). As they left the house, 
said that she had received $200 for having 
brought S.G. to defendant's house that day (A8). 
In a statement that was sworn and tape-recorded, M.L. reported that she was 
16 years of age when Y.L. asked if she wanted to "make money for Christmas"; she 
agreed (A23). Y.L. drove M.L. to defendant's house, where a white woman with long 
blond hair led her up a spiral staircase to a bedroom containing a massage table; there 
was a steam room and shower in the bathroom next door (A23). The woman said 
that massage oils would be there, and that defendant would select the one he wanted 
(A23). Defendant was wearing only a towel, and he selected the oils that he wanted 
M.L. to use (A23-24). 
M.L. began by rubbing defendant's feet, legs, and back (A24). At defendant's 
direction, M.L. removed her clothes and continued massaging while wearing only 
underwear (A24). Turning onto his back, defendant told M.L. to rub his chest and 
pinch his nipples (A24). As M.L. complied, defendant reached up, unsnapped her bra 
(which opened in the front), and began rubbing her breasts (A24). Defendant asked if 
M.L. liked that, and she said she did not (A24). Removing the towel and lying naked, 
defendant then masturbated while continuing to touch M.L.'s breasts (A24). 
Next, defendant rubbed M.L.'s vaginal area over her panties (A24). When M.L. 
tensed up, defendant said, "Relax, I'm not going inside" (A24). But then, defendant 
moved her panties aside, stroked her clitoris, and inserted two fingers into M.L.'s 
vagina and began stroking (A24). M.L. pulled back, trying to free herself, and finally 
-8-
EFTA00792511

defendant removed his fingers and apologized (A24). Keeping his hand on her 
vagina, defendant rubbed her "very hard" while masturbating until he climaxed into 
the towel (A24). Defendant left $200 on the dresser for M.L. and $100 to be given to 
Y.L. for having brought M.L. there (A24). M.L. knew that what had happened to her 
was "wrong," and they did not contact her again (A24). 
During a statement that was sworn and tape-recorded, Y L. reported that, at 16 
years of age, in September of 2004, 
had offered her a chance to make money 
(A13). From conversations with friends at 
Y.L. knew 
"what 
did for [defendant]," and Y.L. agreed (A13). 
drove Y.L. to 
defendant's house, where they entered through the kitchen and met defendant (A13). 
escorted Y.L. upstairs—past many photographs of naked girls—to a 
bedroom, where 
set up a massage table and oils (A13). Entering the room 
wearing only a towel, defendant selected an oil and instructed Y.L. to rub his legs, the 
area under his buttocks, his back, and chest (A13). 
Defendant removed the towel and lay naked (A13). Defendant told Y.L. to 
"get comfortable," but she did not undress (A13). As Y.L. rubbed defendant's chest, 
he tried to reach down her pants and touch her buttocks, but he did not succeed 
because her clothing was too tight (A13). Defendant began to masturbate and tried to 
reach up her shirt and touch her breasts, but Y.L. pulled back (A13-14). Defendant 
continued masturbating to climax, cleaning himself with the towel (A14). 
Y.L. 
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received $200 in cash, and gave her telephone number to 
on the way out of the 
house (A14). 
Y.L. did not provide a massage for defendant on any other occasion, but she 
accompanied 
to defendant's house on two occasions when 
brought 
other girls there (A14). One of those girls was Y.L.'s friend, M.L., who was sixteen 
years of age (A14). The time they took M.L., the three entered the house through the 
kitchen, where they were met by 
(A14). 
and 
both escorted 
M.L. to the upstairs bedroom, and later 
gave Y.L. $100 for having brought 
M.L. to defendant's house (A14). 
During a statement that was sworn and tape-recorded, A.H. reported that, at 
the suggestion of a classmate at 
she had given 
defendant massages at his house when she was 16 years of age (A16). On the first 
visit, the classmate took her to defendant's house, where they entered through the 
kitchen and were met by 
(A16). As 
led her upstairs, A.H. saw that, on 
the wall and on tables, there were photographs of naked women (A16). Once in the 
bedroom, 
set up a massage table and oils, and shortly afterwards defendant 
emerged from a steam room and shower area wearing only a towel (A16). Defendant 
lay on the table, and at his suggestion A.H. removed all but her panties (A16). After 
A.H. had rubbed defendant's legs and feet, he turned onto his back, touched her 
breasts, and masturbated until he ejaculated (A16). The massage ended at that point 
-10-
EFTA00792513

(A16). A.H. was given $200 that day, and defendant asked her to leave her cell phone 
number so he could contact her "when [he] was in town" (A16). 
A.H. returned to defendant's home "hundreds of times" over the course of the 
next two years to provide these massages; she became defendant's "number one girl" 
(A16). Every time defendant was in Palm Beach, 
called A.H. and scheduled 
appointments for A.H. to "work" for defendant (A17). A "routine" was established—
A.H. entered the house and "g[o]t naked" in the bedroom; she began by massaging 
defendant's back, after which he rolled over and she rubbed his chest; defendant 
masturbated, and with the other hand inserted his fingers into her vagina; defendant 
continued this process until he ejaculated, and then used a vibrator on her vagina until 
she climaxed (A16). During her visits, defendant asked A.H. how old she was, and 
she said she was 16; defendant told her not to tell anyone her real age (A16). 
At some point, "things escalated" during the massage sessions: at defendant's 
instruction, A.H. had intercourse with defendant's female friend 
the intercourse included using "strap-on 'lidos," "large rubber penises," and "other 
devices" that defendant had in his home (A16). 
Defendant watched and 
masturbated; occasionally, he joined in by providing oral sex to A.H. and 
(A17). These episodes took place during the time when A.H. was 16 years of age 
(A17). Defendant sometimes photographed the naked sex sessions between A.H. and 
and he displayed the photographs in his home (A17). 
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Things "continued to escalate," and A.H. received additional money whenever 
something new was introduced into the routine (A17). A.H. had an "understanding" 
with defendant, however, that he would not penetrate her vagina with his penis (A17). 
Defendant's penis was "deformed"—when erect, it was "thick" toward the base, but 
"thin and small" toward the head; it was shaped like an "egg" or an "oval" (A17). 
During one massage, A.H. and 
kissed and fondled each other's breasts as 
defendant watched (A17). Later, as the massage continued, defendant "grabbed" 
A.H., turned her over on her stomach, and held her head down "forcibly" as he 
inserted his penis into her vagina and repeatedly "pump[ed]" his penis into her (A17). 
A.H. "screamed," "No!" and defendant stopped (A17). 
Defendant apologized and 
gave her $1,000 that day (A17).2
During a statement that was sworn and tape-recorded, C L. related that, at 15 
years of age, she was approached by 
a classmate at 
and asked about modeling lingerie at the home of a wealthy Palm Beach 
man (A24-25). When they arrived at defendant's home, C.L. and 
were served 
dinner by defendant's personal chef (A25). After dinner, defendant and 
took 
C.L. to an upstairs bedroom, where there was a massage table (A25). When defendant 
2 A.H. had been arrested by the Palm Beach Police Department on September 11, 
2005, for misdemeanor possession of marijuana; during that arrest, she had told the arresting 
officer that she had information about sexual activity at defendant's house (A15-16). As 
noted on pages 26-27, infra, the police subsequently found A.H.'s name and cell phone 
number on discarded papers that were retrieved from defendant's trash (A16), and recovered 
a copy of her high school transcript from defendant's bedroom desk (A23). 
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entered wearing only a towel, 
said she and C.L. were going to give defendant a 
massage (A25). C.L. asked why they were doing that instead of modeling, and 
said it was defendant's "routine" (A25). C.L. undressed at defendant's direction, until 
she was wearing only panties (A25). At first, C.L. rubbed defendant's legs and feet; 
then, when he turned onto his back, defendant instructed her to rub his chest and 
nipples, and she complied (A25). Defendant masturbated, while alternately touching 
C.L.'s breasts and stroking her vagina, until he ejaculated into the towel (A25). 
Defendant paid C.L. $200 (A25). He said that "bad things could happen" if 
she told anyone what had taken place in his house (A25). Defendant's "houseman" 
drove C.L. and 
home, and C.L. was afraid about the fact that defendant knew 
where she lived (A25). When 
called her several days later to set up another 
appointment for "work," C.L. agreed (A25). Once at defendant's house, 
escorted C.L. to the bedroom and prepared the room for the massage (A25). 
Defendant entered the room wearing only a towel and directed C.L. to perform the 
massage naked, which she did (A25). C.L. began by rubbing defendant's feet and legs, 
and defendant later turned onto his back and masturbated with one hand and with the 
other rubbed her vagina with his fingers (A25). Once defendant had ejaculated into 
the towel, the massage was over (A25). C.L. was paid $200, and defendant threatened 
her again— saying that "bad things would happen" if she talked about what had 
happened (A25). C.L. wanted to notify the authorities but was afraid of what might 
happen to her or her family (A25). 
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In a statement that was sworn and tape-recorded, M.D. related that she was 16 
years of age when a fellow student at 
said M.D. could 
make $200 by providing massages to defendant while topless (A21-22). Entering the 
house through the kitchen, M.D. was escorted upstairs to a bedroom that had a 
massage table and a large pink couch (A22). Defendant entered the room wearing 
only a towel, lay face-down on the table, and selected the oils to be used (A22). 
Wearing only thong panties, M.D. rubbed defendant's legs, back, and feet for 40 
minutes (A22). Defendant turned onto his back and M.D. rubbed his chest while he 
masturbated to climax, ejaculating into the towel (A22). 
M.D. was given $200 for 
that massage (A22). 
During a return visit, M.D. again was led to the upstairs bedroom, and 
defendant entered wearing only a towel (A22). 
At defendant's direction, M.D. 
performed this massage naked (A22). She rubbed his back first; when defendant 
rolled over and began masturbating, she rubbed his chest (A22). After a while, 
defendant retrieved a large gray vibrator with a large head, and he rubbed her vagina 
with it for about two or three minutes (A22). M.D. continued rubbing defendant's 
chest until he climaxed, ejaculating into the towel (A22). The massage was over at 
that point, and M.D. received $200 that day (A22). M.D. did not provide any more 
massages (A22). 
During a tape-recorded statement, S. related that, when she was sixteen years 
of age, her classmate 
took her to defendant's house on two occasions (A11). 
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EFTA00792517

The first time, 
drove, they entered through the kitchen door, and they were 
met there by defendant and 
(A11-12). 
escorted her to a bedroom, 
where 
set up a massage table and oils, and entered the room wearing only a 
towel (Al2). Defendant lay on the table, selected an oil for J.S. to use, and she began 
the massage (Al2). When defendant tried to remove J.S.'s shirt, she became upset 
and discontinued the massage (Al2). J.S. left the house and did not receive any 
money (Al2). 
had told her to tell defendant if she was "uncomfortable" and 
defendant would "stop" (Al2). J.S. also knew that "the more you do, the more you 
get paid" (Al2). 
Several weeks later, J.S. agreed to return to defendant's house with 
(Al2). Again they entered through the kitchen, J.S. was escorted upstairs by 
and 
set up the massage table and oils (Al2). During the massage, defendant 
tried to reach into J.S.'s pants and touch her buttocks, but her clothing was too tight 
and he was unable to do so (Al2). Rolling over on his back, defendant tried to touch 
J.S.'s breasts, but she became upset, said she did not want to be touched, and 
discontinued the massage (Al2). Defendant gave her $200 that day, and J.S. did not 
return (Al2). 
During a statement that was sworn and tape-recorded, a student whose 
birthdate was 2/08/1987 reported having been approached by 
and offered 
money to provide a "massage" to "a wealthy man in Palm Beach" (Al2). 
drove the girl to defendant's house, where they entered through the kitchen and met 
-15-
EFTA00792518

defendant and 
(Al2). 
took the girl upstairs to a bedroom, where 
set up a massage table and oils, and defendant entered the room shortly afterwards 
wearing only a towel (Al2). Removing the towel and lying on the table naked, 
defendant chose a lotion for the girl to rub on his thighs and back (Al2). 
At defendant's request, the girl undressed and continued the massage wearing 
only thong underpants (Al2). The girl straddled defendant's back, her bare buttocks 
touching his, and later he turned onto his back and masturbated as she rubbed his 
chest (A13). The girl, who had "just turned seventeen," "did not want to look at 
[defendant's] penis area" because she "was uncomfortable" (A13). 
Retrieving a 
"large, white vibrator," defendant rubbed the vibrator on her vaginal area over her 
underwear until he ejaculated (A13). Defendant got up from the table, took a shower, 
and paid the girl either $350 or $400 (13). The girl did not return to defendant's 
house (13). 
During a statement that was sworn and tape-recorded, a girl whose birthdate 
was 
related that she had been told she could make some "quick money" 
by providing a massage while dressed only in underwear (A18). The girl was driven to 
defendant's home, where she and the other girl entered through the kitchen door and 
went to an upstairs bedroom, where there was a massage table near a sauna/shower 
area and photographs of naked women throughout the room (A18). 
Defendant 
entered wearing only a towel, and at defendant's direction the two girls undressed as 
well (A18). Wearing only panties, the girls rubbed defendant's legs and feet (A18). 
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