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title: "FOIA Records: Florida (EFTA02854705)"
source: "FOIA Records: Florida"
sourceUrl: "https://www.justice.gov/epstein/files/Freedom%20of%20Information%20Act%20%28FOIA%29/Florida/EFTA02854705.pdf"
date: "2026-08-12"
category: "FOIA"
eftaNumber: "EFTA02854705"
ocrPages: 1
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---
Lanna Belohlavek, Esquire State Attorney's Office 401 North Dixie Highway West Palm Beach, Florida 33401
33401+4209-01 CO21
billiolidhandhlabillioidallandhdhl
Public Records Request No.: 17-295
JACK A. GOLDBERGER \*\* SCOTT N.
\*BOARD CERTIFIED CRIMINAL TRIAL ATTORNEY †MEMBER OF NEW JERSEY & FLORIDA BARS
June 22, 2006
Barry Krischer Florida State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Mr. Krischer:
I write to you to confirm our meeting with Lanna on June 14, 2006. It is our hope that in light of the recent developments in this case which we have set forth in our letter of June 5, 2006, our meetings, and herein, in particular the fact that there is no sex alleged, this case can be disposed of with, at most, an informal agreement, or more appropriately, no charges being filed at all.
the struk of some powle remain over passing is called
As you know, it was only at the June 1, 2006 meeting, after eight months of investigation, that you and I both learned, for the very first time, and I believe to our collective disbelief, that the allegation of the girl did not raise the slightest hint of actual sex. Up until that point, we had all been laboring under the assumption this girl had alleged multiple sexual encounters with my client. In fact, as you are aware, it was with this in mind that we hired slightest Slattery, a highly respected polygraph expert, who unequivocally confirmed our client's long held position both that there was no sex and that the girl clearly stated she was 18 years old. Since, we now know with certainty that there are in fact no allegations of sex, and no sex occurred between my client and this girl, I would ask you to consider your previous statements to the effect that you would not bring a "touching case" – NO sex, NO charge – in fashioning an appropriate resolution to this matter.
As we have discussed many times, the girl's credibility is highly questionable and has been severely undermined by her actions over the past few months in: (1) repeatedly changing her age on her web page (first 17, then 16, then 15) and posting graphic nude and suggestive photographs of herself; (2) boasting about shoplifting, underage drinking,
250 Australian Avenue South, One Clearlake Centre, Suite 1400, West Palm Beach, FL 33401
07/26/17
Telephone: 561.659.8300 2 Garginile: 561.835.8691 Public Records Request No.: 17-295
smoking, and having sex; (3) being observed by the police as clearly on drugs; and, (5) running away to an unsafe drug location. With this background, it has certainly taken a while to sort things out, but, the agreed to facts of this case are that: (1) this girl, was driven to my clients' home with the express and sole purpose of providing a topless massage; (2) she told my client she was 18 years old; (3) she received her agreed upon two hundred dollars; (4) before leaving she wrote down her phone number and stated next time she wanted to bring her twin sister along; (5) my client never saw her again; and, most importantly (6) no sex occurred. It was only several MONTHS later, that we are led to believe, one of her parents, both of whom have criminal records for fraud, contacted the police.
Finally, as you consider your options, I quite frankly think it unfair to give much weight to the pressure being brought to bear by law enforcement. Their comments which have been brought to my attention certainly indicate, at a minimum, a lack of objectivity. With all this in mind, I believe that it is only just, especially now that we are both certain there was no sex involved, that your office opt NOT to prosecute this case. However, given the totality of the circumstances, coupled with the fact that a "Google search" is now a "forever" reference on any job application, I believe that the girls involved, my client, and all concerned would be better served with at worst an informal resolution of this matter. Certainly it seems preferable to filing a charge that we all currently concede would likely not succeed if brought to trial. I appreciate the personal attention you have given to this matter, and look forward to you response.
Very truly yours, A. GOLDBERGER
cc: Lanna Belohlavek, Esquire
Public Records Request No.: 17-295
250 Australian Avenue South, One Clearlake Centre Suite 1400, West Palm Beach, FL 33401
Lanna Belohlavek, Esquire Office of the State Attorney 401 North Dixie Highway West Palm Beach, FL 33401
196j1423PH12:09
33401+4209-01 C021
r
, 07O6/17 Page d of 131 Public Records Request No.: 17-295
JACK A. GOLDBERGER
BOARD CERTIFIED CRIMINAL TRIAL ATTORNEY † MEMBER OF NEW JERSEY & FLORIDA BARS
June 22, 2006
Barry Krischer Florida State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Mr. Krischer:
I write to you to confirm our meeting with Lanna on June 14, 2006. It is our hope that in light of the recent developments in this case which we have set forth in our letter of June 5, 2006, our meetings, and herein, in particular the fact that there is no sex alleged, this case can be disposed of with, at most, an informal agreement, or more appropriately, no charges being filed at all.
As you know, it was only at the June 1, 2006 meeting, after eight months of investigation, that you and I both learned, for the very first time, and I believe to our collective disbelief, that the allegation of the girl did not raise the slightest hint of actual sex. Up until that point, we had all been laboring under the assumption this girl had alleged multiple sexual encounters with my client. In fact, as you are aware, it was with this in mind that we hired slighter Slattery, a highly respected polygraph expert, who unequivocally confirmed our client's long held position both that there was no sex and that the girl clearly stated she was 18 years old. Since, we now know with certainty that there are in fact no allegations of sex, and no sex occurred between my client and this girl, I would ask you to consider your previous statements to the effect that you would not bring a "touching case" – NO sex, NO charge – in fashioning an appropriate resolution to this matter.
As we have discussed many times, the girl's credibility is highly questionable and has been severely undermined by her actions over the past few months in: (1) repeatedly changing her age on her web page (first 17, then 16, then 15) and posting graphic nude and suggestive photographs of herself; (2) boasting about shoplifting, underage drinking,
250 Australian Avenue South, One Clearlake Centre, Suite 1400, West Palm Beach, FL 33401
07/26/17
Telephone: 561.659.820ge 5 Eropinile: 561.835.8691 Public Records Request No.: 17-295
smoking, and having sex; (3) being observed by the police as clearly on drugs; and, (5) running away to an unsafe drug location. With this background, it has certainly taken a while to sort things out, but, the agreed to facts of this case are that: (1) this girl, was driven to my clients' home with the express and sole purpose of providing a topless massage; (2) she told my client she was 18 years old; (3) she received her agreed upon two hundred dollars; (4) before leaving she wrote down her phone number and stated next time she wanted to bring her twin sister along; (5) my client never saw her again; and, most importantly (6) no sex occurred. It was only several MONTHS later, that we are led to believe, one of her parents, both of whom have criminal records for fraud, contacted the police.
Finally, as you consider your options, I quite frankly think it unfair to give much weight to the pressure being brought to bear by law enforcement. Their comments which have been brought to my attention certainly indicate, at a minimum, a lack of objectivity. With all this in mind, I believe that it is only just, especially now that we are both certain there was no sex involved, that your office opt NOT to prosecute this case. However, given the totality of the circumstances, coupled with the fact that a "Google search" is now a "forever" reference on any job application, I believe that the girls involved, my client, and all concerned would be better served with at worst an informal resolution of this matter. Certainly it seems preferable to filing a charge that we all currently concede would likely not succeed if brought to trial. I appreciate the personal attention you have given to this matter, and look forward to you response.
Very truly yours JACK A. GOLDBERGER
cc: Lanna Belohlavek, Esquire
Public Records Request No.: 17-295
| REST | PRIN | BERCH | m | * |
|------------------------------------------------|--------|-------|----|---------|
| Carrie and and and and and and and and and and | FL | 33681 | X. | F |
| \$0.390 \$0.<br>\$0.391 | 390 \$ | 0.390 | So | r.<br>P |
| \$0.59 | M | METER | 2 | |
| 3 JUN 22 06 | | 43979 | | 1 |
ATTERBURY GOLDBERGER & WEISS, P.A. Vian Avenue South, One Clearlake Centre Palm Beach, FL 33401 Barry Krischer, Esquire Office of the State Attorney 401 North Dixie Highway West Palm Beach, FL 33401
33401+4209-01 CO21
hiller Hadallhand Hadalah Hadalah Handhalla
250 Australian Avenue South, One Clearlake Centre
Public Records Request No.: 17-295
#### ATTERBURY GOLDBERGER & WEISS, P.A. 250 Australian Avenue South One Clearlake Centre, Suite #1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691
### FAX TRANSMITTAL COVER SHEET
DATE: June 16, 2006
TO: Lanna Belohlavek, Esquire
FAX: 355-7302
- FROM: Jessica Cadwell, Assistant to Jack A. Goldberger, Esq.
- RE: Epstein
**REMARKS:**
TOTAL PAGES: 8, including cover sheet
#### \*\*\* PLEASE NOTE - CONFIDENTIALITY WARNING \*\*\*
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Public Hdc29: 20guldin 9002291 -NOC
LAW OFFICES OF GERALD B. LEFCOURT, P.C. A PROFESSIONAL CORPORATION 148 EAST 78<sup>TH</sup> STREET NEW YORK, NEW YORK 10021
GERALD B. LEFCOURT lefcourt@lefcourtaw.com
SHERYL E. REICH reich@leicourtiew.com RENATO C. STABILE stablie@leicourtiew.com FAITH A. ffiedman@leicourtiew.com BY HAND
June 5, 2006
Lanna Belohlavek Florida State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Ms. Belohlavek:
As a follow up to our meeting of June 1, 2006, held in an attempt to resolve this matter, we write to address the following issues which have arisen: (1) the risk, were the client to plead to aggravated assault in Florida, that he might be subject to sex-offender registration statutes in other jurisdictions, now or in the future; (2) the nature of the charge of felony "aggravated assault with intent to commit a felony," and how it does not reflect the allegations herein; and, (3) whether a felony conviction itself is justified based on the available evidence.
At the outset of our June 1, 2006 meeting, we were mindful that an understanding had been reached with prior counsel. It was reached, however, with the clear and joint understanding that the client would not be subjected to sex offender registration requirements in any state or foreign jurisdiction. Moreover, the limited time provided did not allow for an opportunity to conduct an even cursory investigation or research into the ramifications. Were any charge to be brought, having now learned of the serious danger a plea to felony aggravated assault presents with regard to sex offender registration, coupled with the facts presented at our meeting and outlined below, we strongly believe that a plea to misdemeanor solicitation is the more appropriate resolution. As we discussed, this could include an agreed upon allocution, as we are mindful of your concern about labeling the girls "prostitutes." In this regard, as we discussed, the law and relevant statute are clear that the complaining witness need not be a "prostitute" in order to satisfy the elements of the offense.
Public Hecces Blauber 8002295 -NAL
TELEPHONE
(212) 737-0400 FACSIMILE (212) 968-6192
Ms. Lanna Belohlavek June 5, 2006 Page 2
in .
#### I. An Aggravated Assault Conviction Might Subject the Client to Sex-Registration
There is a likely risk that a plea to aggravated assault, F.S.A. § 784.021(1)(b), will expose the client to registration obligations under the Megan's Law statutes, either as currently written, or as likely to be amended or expanded in the future, in a number of jurisdictions, including, but not limited to, ones where he lives, works, or spends time. This is true regardless of whether the plea expressly specifies that the felony he had the intent to commit was lewd and lascivious behavior under F.S.A. § 800.04 or sexual battery under F.S.A. § 794.011.
As my client is a full time resident of the Virgin Islands, the most immediate and obvious unintended result of a plea to felony aggravated assault is the possible registration in his place of residency. The Virgin Islands statute, 14 V.I.C. § 1722 <u>et seq.</u>, is very broad, imposing a duty to register upon a "person convicted ... on or after July 1, 1994 of a criminal offense <u>against a</u> <u>minor</u>". 14 V.I.C. § 1722(a) (emphasis added). Under § 1722 (c), "a person convicted ... in a federal, military or foreign court shall have the same duty to register as any other person under this statute." Failure to register is a crime. 14 V.I.C. § 1722(d). Further, while the Virgin Islands registry is currently accessible only to law enforcement, there are ongoing discussions about opening it to the public. <u>See</u>, Virgin Islands Daily News, May 15, 2006, at http://www.virginislandsdaily news.com/index.pl/article\_home?id=17296624.<sup>1</sup>
Under current law, a plea to aggravated assault will also likely subject the client to registration in his secondary domicile of New York. The list of registrable offenses in New York under the Sex Offender Registration Act (SORA) is a long one, which continues to grow. In 1999, eight new offenses were added to the list of registrable offenses, and again on March 11, 2002, seven new offenses were added.
A non-exhaustive search has identified two other jurisdictions in which the client would appear to be subject to registration requirements simply on the basis of a plea, in Florida, to aggravated assault - Oklahoma and Montana.
Oklahoma requires the registration of persons convicted of assault with intent to commit a felony, in violation of 21 Okl. St. Ann. § 681 "if the offense involved sexual assault." See, 57 Okl. St. Ann. § 582 (A). Oklahoma law requires the registration, too, of persons convicted of an offense outside the jurisdiction which, if committed in the state, would constitute a registrable offense. 57 Okl. St. Ann. § 582(B).
Likewise, Montana requires registration of both sexual offenders and violent offenders. "Violent offenders" include persons convicted of any violent offense, which is expressly defined to include "aggravated assault" under MCA 45-05-202, or "any violation of a law of another state ... reasonably equivalent" to that crime. MCA 46-23-502(9).
AW OFFICES OF P.C. GERALD
June 5, 2006 Page 3
In New York, a person must register as a sex offender if they are required to register in the jurisdiction of conviction or, if convicted in a foreign jurisdiction, his conviction there meets "all the essential elements" of New York's enumerated sexual offenses. See, N.Y. Corr. Law §§ 168-1(2)(a)(1), (d), (3). In spite of the statutory reference to "essential elements," some New York courts have looked at the facts underlying the offense of conviction, rather than the formal elements of the offense, in determining whether registration is required. Each finding that a defendant was required to register on the basis of the underlying conduct even though the essential elements test was not satisfied. See, People v. Burden, 6 Misc.3d 1033(a)(Sup. Ct. Bronx Cty. 2005); People v. Millan, 189 Misc.2d 419, 730 N.Y.S.2d 392 (Sup. Ct. N.Y. Cty. 2001).
The same serious concern arises in other states, including California and Colorado, which authorize courts to look behind the plea, and beyond the formal elements of the offense of conviction, and enable them on a case by case basis to determine if registration is required.
Like New York, California requires an individual to register if they are required to register in the state of conviction, or pursuant to CA Penal Code § 290(a)(2)(D)(I) if that individual "... since July 1, 1944, has been, or is hereafter convicted in any other court, including any state, federal, or military court, of any offense that, if committed or attempted in this state, would have been punishable as one or more of the offenses described in subparagraph (A)". The wording of the statute leaves open the possibility that, in determining whether the offense would have been punishable as one or more of the registrable offenses, one looks at the underlying facts, and not at the formal elements of the crime to which the defendant pled. The registrable California offenses include commission of "any lewd or lascivious act ... upon or with the body of child" where the child is "14 or 15 years" of age and "that person is at least 10 years older than the child" "with the intent of arousing, appealing to, or gratifying the lust, passions, or sexual desires of that person or the child". CA Penal Code § 288(a), (c) (1). Thus, an aggravated assault plea may subject the client to a registration requirement in the State of California.
Colorado likewise has a very broad statute. It requires an individual to register within five business days of becoming a temporary or permanent resident of the state, if, among other things, the person has been convicted in Colorado or any other state of an offense involving sexual behavior (or an attempt, solicitation or conspiracy to commit such an offense), or if they are required to register in another state or jurisdiction for a sex offense. C.R.S.A. §§ 16-22-103, 16-22-108.
With regard to Florida, as you know, it is reasonably clear that under Florida's current version of Megan's Law, a plea to aggravated assault would not subject the client to registration in Florida since it is not included among the state's enumerated "sexual offender" offenses. See
Public Fiedore Faguest to 9002991-NOL
Ms. Lanna Belohlavek June 5, 2006 Page 4
F.S.A. §§ 943.0435, 784.021. However, the offense of sexual battery is on the list, as well as the charge of lewd and lascivious behavior, so there is no assurance that, in the future, a Florida prosecutor or court will not take the position that, where the aggravated assault is combined with what some states have labeled a "sexually motivated intent" registration is required.
Moreover, as you indicated at our meeting, there is no guarantee that the Florida legislature will not expand the category of persons subject to Megan's law, and expressly make persons convicted of aggravated assault subject to the law, especially where the felony the actor had the intent to commit is a sexual offense, and the victim is a minor. The trend today is towards expansion, not contraction, of these kinds of statutes, and as you noted, Florida will be no exception. <u>See, e.g.</u>, "Sex Offenders; No More Escaping Registration," 36 McGeorge L. Rev 822 2005 (Over the last twenty years expanded registration requirements, enhanced penalties for failure to register, and public notification provisions have enlarged the scope of sex offender registration laws); <u>see</u> news articles of just this past week <u>infra</u> describing many of the proscriptions being adopted around the nation. And, the ex post facto clause stands as no significant bar. <u>See were</u> v. <u>Doe</u>, 538 U.S. 84 (2003) (upholding Alaska Sex Offender Registration Act against a challenge that its application to persons whose offenses were committed prior to its enactment would violate the ex post facto clause). If this trend continues, as it likely will, the client will almost certainly be subject to sex offender registration.
Even if the client is not and will never be subject to registration requirements under Florida's laws, a plea to aggravated assault under the circumstances of this case could subject him to Megan's Law requirements in other jurisdictions. Thus, if the client pleads guilty to the proposed aggravated assault charge, there is a grave risk that under existing state and Virgin Islands law – quite apart from future expansion or expansive construction of those laws – he will be subject to sex offender registration requirements and/or criminal exposure for failure to register. There is an even graver risk still that there will be future expansion of the statutes or expansive construction of them that will mean he is covered or arguably so. <u>See. e.g.</u>, Cherry Sex Offender Ordinance Upheld, Courier Post, June 1, 2006, at http://www.courierpostonline.com/apps/pbcs.dll/article?AID=/20060601/NEWS01/606010389/1 006;<sup>2</sup> More States Move to Use GPS Tracking of Sex Offenders, Fox News, May 31, 2006, at
07/26/17 90 d Public Records Republic NOCES - NOC
<sup>006;&</sup>quot; More States Move to Use GPS Tracking of Sex Offenders, Fox News, May 31, 2006, at http://www.foxnews.com/story/0,2933,196455,00.html; Sex Offenders Sue City Over Park, Pools
<sup>&</sup>lt;sup>2</sup> This article discusses a decision handed down by a municipal court judge in New Jersey during the course of our meeting. That decision upheld a zoning restriction on sex offenders living within 2500 feet of schools, **buy**, playgrounds, public libraries, or day care centers. While other jurisdictions' zoning laws carrently restrict such individuals from living within 1000 feet of these institutions, were they to follow the lead of Charry **10**, New Jersey, the client would most certainly be faced with the added burdens of selling his residences and moving in order to be in compliance with the law.
Ms. Lanna Belohlavek June 5, 2006 Page 5
and Playgrounds Ban, Fox News, May 31, 2006, at http://www.foxnews.com/story/0,2933,197701,00.html.
Indeed, as you recognized during our meeting, many people who were advised by competent counsel to plead guilty to offenses when registration was not required have now been horrified to find themselves subjected to registration laws enacted or expanded after their guilty pleas, without any recourse. See, **1999** v. Doe, supra, 538 U.S. 84. Finally, although there is some risk that even a plea to a misdemeanor charge could trigger registration in some jurisdictions, our research suggests that this risk is considerably lower for a misdemeanor plea than for a felony plea.
#### II. Aggravated Assault is Generally Considered A Violent Felony And Does Not Apply to the Facts of This Case
Assault is generally considered an act of force. It "create[s] in the victims a well founded fear of imminent violence." <u>Velasquez v. State</u>, 654 So. 2d 1227, 1228 (Fla.2d DCA 1995). The general public is certainly not aware of Florida's unique nuanced definition. Indeed, as you will agree, in common usage, aggravated assault, on its face sounds inherently violent. Thus, at the very least, most people will consider an aggravated assault charge, even of the "intent to commit a felony" variety, to be a violent crime. In this regard, undifferentiated aggravated assault is one of only four crimes listed in the FBI's Uniform Crime Report "violent crime" category.<sup>3</sup>
More importantly, as noted, this crime clearly does not reflect what allegedly occurred since there has been no suggestion that a threat of serous bodily harm was made or a deadly weapon used. In addition, most pleas are "downward" – the defendant agrees to waive his right to trial in return for the prosecution's offer of a downward departure in charging or sentencing. Further, in the typical case a plea involves crimes that bear a close resemblance to the underlying events. The facts herein, obviously do not support a charge of aggravated assault, thus a plea to same would be inappropriate.
<sup>&</sup>lt;sup>3</sup> The UCR divides its statistics into three major categories: violent crimes, property crimes, and hate crimes. "Violent crime is composed of four offenses: murder and nonnegligent manslaughter, forcible rape, robbery, and aggravated assuult." "Violent Crime," Crime in the United States, 2004, at http://www.fbi.gov/ucr/cius\_04/offenses\_reported/violent\_crime/index.htm].
Ms. Lanna Belohlavek June 5, 2006 Page 6
#### III. Since the Meeting on February 16, 2006 When Misdemeanor Charges Were Initially discussed, the State's Case has Gotten Considerably Weaker
At the February 16, 2006 meeting, you suggested the Office was investigating a felony and you indicated you would consider pleading it down to a misdemeanor. As you are aware, since then much has happened which makes the alleged case considerably weaker and undermines the credibility of the witnesses upon which it was based. Indeed as you already know the following information has come to light severely damaging the reliability of the witnesses: (i). background, including a history of theft, confessions and repeated denials of stealing from employers and customers, lying about her age, sexual promiscuity, and boastful admission of drug use, underage drinking, sexual prostitution; (ii) activity, shoplifting, exaggeration of her income (at least \$250,000), representing herself naked on a website and as 17 years old, then 16, then 15, only changing it to her truthful age, coincidentally four days before the last scheduled grand jury. In addition, as you have acknowledged, she was found in an inappropriate place in Georgia after the police were called when she ran away from home. This is separate and apart from the Florida police report presented to you, detailing her being dropped off by the local drug dealer at 5:45 a.m., only two days after returning to West Palm Beach, and being described by the officer as clearly on drugs; and (iii) both of \_\_\_\_\_ parents' criminal history of fraud.
In stark contrast to this is the fact that, as we indicated at the meeting, the client has passed both a rigorous lie detector test, conducted by the most highly qualified expert we could find, one whose reputation is beyond reproach, and provided you copies of two psycho-sexual evaluations prepared by experts that you have agreed are well-recognized and accepted by the State.
07/26/17 20 d Public Recoge 200804 Huge 200309
Ms. Lanna Belohlavek June 5, 2006 Page 7
#### IV. Conclusion
Under the circumstances of this case a plea to felony aggravated assault is both unwarranted and presents a grave risk the client will be brandished a sex offender, bearing the attendant burdens inherent with that classification. In light of this, and the credibility issues presented by the complaining witnesses, combined with the client's two psycho-sexual evaluations and lie detector tests, we believe that at the very most, a misdemeanor plea to solicitation is appropriate.
y truly yours Gerald B. Lefc
LAW OFFICES OF
GERALD B. LEFOOTThrr,
A PROFESSIONAL CORPORATION 140 EAST 70'" NEW YORK, NEW YORK 10021
GERALD B. LEFCOURT lefCoud@lefcaxtlaw.com
SHERYL E. REICH reichelelymnlaw can RENATO C. STABILE titabdtenCOurILTA can FAITH A. OrIsdnytestauSsw Wen
BY HAND
Lamm Belohlavek Florida State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401
TELEPHONE 12121 737-0400 FACSIMILE (212/ 908-6192
June 5, 2006
Re: Jeffrey Epstein
Dear Ms. Belohlavek:
As a follow up to our meeting of June 1, 2006, held in an attempt to resolve this matter, we write to address the following issues which have arisen: (1) the risk, were the client to plead to aggravated assault in Florida, that he might be subject to sex-offender registration statutes in other jurisdictions, now or in the future; (2) the nature of the charge of felony "aggravated assault with intent to commit a felony," and how it does not reflect the allegations herein; and, (3) whether a felony conviction itself is justified based on the available evidence.
At the outset of our June 1, 2006 meeting, we were mindful that an understanding had been reached with prior counsel. It was reached, however, with the clear and joint understanding that the client would not be subjected to sex offender registration requirements in any state or foreign jurisdiction. Moreover, the limited time provided did not allow for an opportunity to conduct an even cursory investigation or research into the ramifications. Were any charge to be brought, having now learned of the serious danger a plea to felony aggravated assault presents with regard to sex offender registration, coupled with the facts presented at our meeting and outlined below, we strongly believe that a plea to misdemeanor solicitation is the more appropriate resolution. As we discussed, this could include an agreed upon allocution, as we are mindful of your concern about labeling the girls "prostitutes." In this regard, as we discussed, the law and relevant statute are clear that the complaining witness need not be a "prostitute" in order to satisfy the elements of the offense.
Ms. Lanna Belohlavek June 5, 2006 Page 2
#### I. An Aggravated Assault Conviction Might Subject the Client to Sex-Registration
There is a likely risk that a plea to aggravated assault, F.S.A. § 784.021(1)(b), will expose the client to registration obligations under the Megan's Law statutes, either as currently written, or as likely to be amended or expanded in the future, in a number of jurisdictions, including, but not limited to, ones where he lives, works, or spends time. This is true regardless of whether the plea expressly specifies that the felony he had the intent to commit was lewd and lascivious behavior under F.S.A. § 800.04 or sexual battery under F.S.A. § 794.011.
As my client is a full time resident of the Virgin Islands, the most immediate and obvious unintended result of a plea to felony aggravated assault is the possible registration in his place of residency. The Virgin Islands statute, 14 V.I.C. § 1722 et seq., is very broad, imposing a duty to register upon a "person convicted ... on or after July 1, 1994 of a criminal offense <u>against a minor</u>". 14 V.I.C. § 1722(a) (emphasis added). Under § 1722 (c), "a person convicted ... in a federal, military or foreign court shall have the same duty to register as any other person under this statute." Failure to register is a crime. 14 V.I.C. § 1722(d). Further, while the Virgin Islands registry is currently accessible only to law enforcement, there are ongoing discussions about opening it to the public. See, Virgin Islands Daily News, May 15, 2006, at http://www.virginislandsdaily news.com/index.pl/article\_home?id=17296624.<sup>1</sup>
Under current law, a plea to aggravated assault will also likely subject the client to registration in his secondary domicile of New York. The list of registrable offenses in New York under the Sex Offender Registration Act (SORA) is a long one, which continues to grow. In 1999, eight new offenses were added to the list of registrable offenses, and again on March 11, 2002, seven new offenses were added.
<sup>&</sup>lt;sup>1</sup> A non-exhaustive search has identified two other jurisdictions in which the client would appear to be subject to registration requirements simply on the basis of a plea, in Florida, to aggravated assault - Oklahoma and Montana.
Oklahoma requires the registration of persons convicted of assault with intent to commit a felony, in violation of 21 Okl. St. Ann. § 681 "if the offense involved sexual assault." See, 57 Okl. St. Ann. § 582 (A). Oklahoma law requires the registration, too, of persons convicted of an offense outside the jurisdiction which, if committed in the state, would constitute a registrable offense. 57 Okl. St. Ann. § 582(B).
Likewise, Montana requires registration of both sexual offenders and violent offenders. "Violent offenders" include persons convicted of any violent offense, which is expressly defined to include "aggravated assault" under MCA 45-05-202, or "any violation of a law of another state ... reasonably equivalent" to that crime. MCA 46-23-502(9).
Ms. Lanna Belohlavek June 5, 2006 Page 3
In New York, a person must register as a sex offender if they are required to register in the jurisdiction of conviction or, if convicted in a foreign jurisdiction, his conviction there meets "all the essential elements" of New York's enumerated sexual offenses. See, N.Y. Corr. Law §§ 168-1(2)(a)(I), (d), (3). In spite of the statutory reference to "essential elements," some New York courts have looked at the facts underlying the offense of conviction, rather than the formal elements of the offense, in determining whether registration is required. Each finding that a defendant was required to register on the basis of the underlying conduct even though the essential elements test was not satisfied. See, People v. Burden, 6 Misc.3d 1033(a)(Sup. Ct. Bronx Cty. 2005); People v. Millan, 189 Misc.2d 419, 730 N.Y.S.2d 392 (Sup. Ct. N.Y. Cty. 2001).
The same serious concern arises in other states, including California and Colorado, which authorize courts to look behind the plea, and beyond the formal elements of the offense of conviction, and enable them on a case by case basis to determine if registration is required.
Like New York, California requires an individual to register if they are required to register in the state of conviction, or pursuant to CA Penal Code § 290(a)(2)(D)(I) if that individual "... since July 1, 1944, has been, or is hereafter convicted in any other court, including any state, federal, or military court, of any offense that, if committed or attempted in this state, would have been punishable as one or more of the offenses described in subparagraph (A)". The wording of the statute leaves open the possibility that, in determining whether the offense would have been punishable as one or more of the registrable offenses, one looks at the underlying facts, and not at the formal elements of the crime to which the defendant pled. The registrable California offenses include commission of "any lewd or lascivious act ... upon or with the body of child" where the child is "14 or 15 years" of age and "that person is at least 10 years older than the child" "with the intent of arousing, appealing to, or gratifying the lust, passions, or sexual desires of that person or the child". CA Penal Code § 288(a), (c) (1). Thus, an aggravated assault plea may subject the client to a registration requirement in the State of California.
Colorado likewise has a very broad statute. It requires an individual to register within five business days of becoming a temporary or permanent resident of the state, if, among other things, the person has been convicted in Colorado or any other state of an offense involving sexual behavior (or an attempt, solicitation or conspiracy to commit such an offense), or if they are required to register in another state or jurisdiction for a sex offense. C.R.S.A. §§ 16-22-103, 16-22-108.
With regard to Florida, as you know, it is reasonably clear that under Florida's current version of Megan's Law, a plea to aggravated assault would not subject the client to registration in Florida since it is not included among the state's enumerated "sexual offender" offenses. See
Page 18 of 131
Ms. Lanna Belohlavek June 5, 2006 Page 4
F.S.A. §§ 943.0435, 784.021. However, the offense of sexual battery is on the list, as well as the charge of lewd and lascivious behavior, so there is no assurance that, in the future, a Florida prosecutor or court will not take the position that, where the aggravated assault is combined with what some states have labeled a "sexually motivated intent" registration is required.
Moreover, as you indicated at our meeting, there is no guarantee that the Florida legislature will not expand the category of persons subject to Megan's law, and expressly make persons convicted of aggravated assault subject to the law, especially where the felony the actor had the intent to commit is a sexual offense, and the victim is a minor. The trend today is towards expansion, not contraction, of these kinds of statutes, and as you noted, Florida will be no exception. <u>See, e.g.</u>, "Sex Offenders; No More Escaping Registration," 36 McGeorge L. Rev 822 2005 (Over the last twenty years expanded registration requirements, enhanced penalties for failure to register, and public notification provisions have enlarged the scope of sex offender registration laws); <u>see</u> news articles of just this past week <u>infra</u> describing many of the proscriptions being adopted around the nation. And, the ex post facto clause stands as no significant bar. <u>See v. Doe</u>, 538 U.S. 84 (2003) (upholding Alaska Sex Offender Registration Act against a challenge that its application to persons whose offenses were committed prior to its enactment would violate the ex post facto clause). If this trend continues, as it likely will, the client will almost certainly be subject to sex offender registration.
Even if the client is not and will never be subject to registration requirements under Florida's laws, a plea to aggravated assault under the circumstances of this case could subject him to Megan's Law requirements in other jurisdictions. Thus, if the client pleads guilty to the proposed aggravated assault charge, there is a grave risk that under existing state and Virgin Islands law – quite apart from future expansion or expansive construction of those laws – he will be subject to sex offender registration requirements and/or criminal exposure for failure to register. There is an even graver risk still that there will be future expansion of the statutes or expansive construction of them that will mean he is covered or arguably so. <u>See, e.g.</u>, Cherry Sex Offender Ordinance Upheld, Courier Post, June 1, 2006, at
http://www.courierpostonline.com/apps/pbcs.dll/article?AID=/20060601/NEWS01/606010389/1 006;<sup>2</sup> More States Move to Use GPS Tracking of Sex Offenders, Fox News, May 31, 2006, at http://www.foxnews.com/story/0,2933,196455,00.html; Sex Offenders Sue City Over Park, Pools
<sup>&</sup>lt;sup>2</sup> This article discusses a decision handed down by a municipal court judge in New Jersey during the course of our meeting. That decision upheld a zoning restriction on sex offenders living within 2500 feet of schools, playgrounds, public libraries, or day care centers. While other jurisdictions' zoning laws currently restrict such individuals from living within 1000 feet of these institutions, were they to follow the lead of Cherry , New Jersey, the client would most certainly be faced with the added burdens of selling his residences and moving in order to be in compliance with the law.
LAW Of /ICES or GERALD a LEPCOIIRT, P.C.
> Ms. Lamm Belohlavek June 5, 2006 Page 5
and Playgrounds Ban, Fox News, May 31, 2006, at httplAvww.foxnews.com/story/0,2933,197701,00.html.
Indeed, as you recognized during our meeting, many people who were advised by competent counsel to plead guilty to offenses when registration was not required have now been horrified to find themselves subjected to registration laws enacted or expanded after their guilty pleas, without any recourse. See, v. Doe,supra, 538 U.S. 84. Finally, although there is some risk that even a plea to a misdemeanor charge could trigger registration in some jurisdictions, our research suggests that this risk is considerably lower for a misdemeanor plea than for a felony plea.
#### IL Aggravated Assault is Generally Considered A Violent Felony And Does Not Apply to the Facts of This Case
Assault is generally considered an act of force. It "create[s] in the victims a well founded fear of imminent violence." Velasquez v. State 654 So. 2d 1227, 1228 (Fla.2d DCA 1995). The general public is certainly not aware of Florida's unique nuanced definition. Indeed, as you will agree, in common usage, aggravated assault, on its face sounds inherently violent. Thus, at the very least, most people will consider an aggravated assault charge, even of the "intent to commit a felony" variety, to be a violent crime. In this regard, undifferentiated aggravated assault is one of only four crimes listed in the FBI's Uniform Crime Report "violent crime" category.;
More importantly, as noted, this crime clearly does not reflect what allegedly occurred since there has been no suggestion that a threat of serous bodily harm was made or a deadly weapon used. In addition, most pleas are "downward" — the defendant agrees to waive his right to trial in return for the prosecution's offer of a downward departure in charging or sentencing. Further, in the typical case a plea involves crimes that bear a close resemblance to the underlying events. The facts herein, obviously do not support a charge of aggravated assault, thus a plea to same would be inappropriate.
The UCR divides its statistics into three major categories: violent crimes, property crimes, and hate crimes. "Violent crime is composed of four offenses: murder and nonnegligent manslaughter, forcible rape, robbery, and aggravated assault." "Violent Crime," Crime in the United States, 2004, at hnn://vAvw.tbi.eov/ucr/cius 04/offenses\_reported/violent crime/index.html.
LAW orrfcce or GERALD B. Lirrcourrr, PG
> Ms. Lanna Belohlavek June 5, 2006 Page 6
#### III. Since the Meeting on February 16, 2006 When Misdemeanor Charges Were Initially discussed, the State's Case has Gotten Considerably Weaker
At the February 16, 2006 meeting, you suggested the Office was investigating a felony and you indicated you would consider pleading it down to a misdemeanor. As you are aware, since then much has happened which makes the alleged case considerably weaker and undermines the credibility of the witnesses upon which it was based. Indeed as you already know the following information has come to light severely damaging the reliability of the witnesses: (i) \_ background, including a history of theft, confessions and repeated denials of stealing from employers and customers, lying about her age, sexual promiscuity, and prostitution; (ii) \_ boastful admission of drug use, underage drinking, sexual activity, shoplifting, exaggeration of her income (at least \$250,000), representing herself naked on a website and as 17 years old, then 16, then 15, only changing it to her truthful age, coincidentally four days before the last scheduled grand jury. In addition, as you have acknowledged, she was found in an inappropriate place in Georgia after the police were called when she ran away from home. This is separate and apart from the Florida police report presented to you, detailing her being dropped off by the local drug dealer at 5:45 a.m., only two days after returning to West Palm Beach, and being described by the officer as clearly on drugs; and (iii) both of Saige's parents' criminal history of fraud.
In stark contrast to this is the fact that, as we indicated at the meeting, the client has passed both a rigorous lie detector test, conducted by the most highly qualified expert we could find, one whose reputation is beyond reproach, and provided you copies of two psycho-sexual evaluations prepared by experts that you have agreed are well-recognized and accepted by the State.
LAW OI?K(t OF GERALD 13. Lraroouirr, P.G.
> Ms. Lanna Belohlavek June 5, 2006 Page 7
#### /1! Conclusion
Under the circumstances of this case a plea to felony aggravated assault is both unwarranted and presents a grave risk the client will be brandished a sex offender, bearing the attendant burdens inherent with that classification. In light of this, and the credibility issues presented by the complaining witnesses, combined with the client's two psycho-sexual evaluations and lie detector tests, we believe that at the very most, a misdemeanor plea to solicitation is appropriate.
#### MySpace URL:
http://www.myspace.com/lovelysaige
07/26/17Page 23 of 131Public Records Request No.: 17-295http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid=765527106/13/2006
#### YA FUCK YOU 2!!!!!!'s Blurbs
#### About me:
] The full name Is ] I am a twin her.. her name is amber [ ] Im the most outgoing person youll ever meet wen u get to no me [ I hate drama ( ) I LOVE TO HAVE FUN!!! [ ' I I am half cuban and half MillIrish [ ✓ ) I love tanning ( ] I don't get jealous very easily [ • ) I am the biggest flirt ever [ I love my ass [ ] I am NOT a phone person ( ' ] I am so easy to get along with [ ] lye been through more then more people think i have [ ] I smile even when i am not happy. [ ✓ ) I want a monkey someday lol [ ] I love all my georgia friends [ ' ] I love music [ ' ] I love to joke around [ • ] I laugh at the stupidest things [ ] I love to sleep ( ] I love funny people so much [ ]1 hate mean people ( ' I am a closet nerd lol jk ] I love volleyball ' ].I yeah i was a ballerina for 10 years [ 1 love to dance..no matter where i am at [ ' ) I miss you all in ga an .winslow lina britt carissa mary katie nikki lea zack .. see ya soon [ wanna talk to me .. iloveanirishboi
#### Who I'd like to meet:
' I ALREADY HAVE
EFTA02854728
Page 25 of 131
Public Records Request No.: 17-295 6/13/2006
07/26/17 http://www.myspace.com/loveh
Page 26 of 131 Public Records Request No.: 17-295 6/11/2006
Page 27 of 131 Public Records Request No.: 17-295 6/1"IncinA
EFTA02854731
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| vlove'n a<br>choquette v | June 11, 2006 9:12 AM<br>aw how cute and who introduced you guys?????<br>haha that would be me! lol love you bothomg<br>is actually kinda smiling holy shit lol |
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498 CHATTIN DRIVE
05-104607
Supplement No ORIG
Reported Date 11/24/2005 Nature of Call INFO Officer BEDOYA, BROOKE
#### (678) 493-4200
| Agency<br>CHEROKEE | OUNT | Y SH | HERI | FF'S OF | FICE | | Report No<br>05-104607 | Supplement No<br>ORIG | Reported 0 | Date 1/2005 | Reported Time<br>21:49 | |
|-----------------------------|-----------|-----------------|------------------|----------------------------|-----------------|---|----------------------------|-----------------------------|------------|-------------|---------------------------|----|
| CAD Call No<br>050174770 | Status | CELL | ANE | OUS REPO | RT | | INFORMATION | | | | | |
| Location | | | | | | | City | | ZIP | Code | | |
| Rep Dist<br>unknown az | | | From Da | ate<br>24/2005 | From Ti<br>21:4 | | Officer<br>000202/BEDO | | | - | | T |
| Assignment | | Entered<br>0002 | - | Assignment<br>WARRANT | UNI | т | RMS Transfer<br>Successful | Approving Officer<br>000202 | | | | - |
| Approval Date<br>11/28/2005 | | 1 | proval T<br>0:21 | | | | | | | | 1.20 | |
| Person S | umn | nary | | Sec. 22 | and here | | | | at see | | | |
| | Туре<br>I | Name | | 1.4.1 | | - | | MNI<br>258904 | Race | Sex<br>M | Date of Birth | |
| | Type<br>I | Mana | | and a second second second | a da anti- | | | MNI<br>258903 | Race | Sex<br>F | Date of Birth<br>03/17/19 | 69 |
| Summary | Nar | rati | ve | | | | | | | | | |
| Report Officer<br>000202/BEDOYA, BROOKE | Printed At 06/06/2006 11:21 | Page 1 of 2 |
|-----------------------------------------|-----------------------------|-------------|
|-----------------------------------------|-----------------------------|-------------|
Public Records Request No.: 17-295
| JUVENIL | E 1: | JAMES | · · · · · · · · · · · · · · · · · · · | | | | |
|----------------------------|---------------|-----------------|---------------------------------------|-------------------|--------|---------|---------------|
| Involvement | Invi No | Туре | Name | | MNI | Race | Sex |
| JUVENILE | 1 | Individua | 1 JAMES | | 2589 | 04 | MALE |
| Juvenile?<br>Yes | | | | | | | |
| | e No<br>04)31 | 6-3145 | | | 10 % | Sec. 19 | |
| OTHER 1 | : | | | | | 國家市場 | |
| OTHER 1 | | dividual | Name | | 258903 | Race | Sex<br>FEMALE |
| Date of Birth<br>03/17/196 | 9 36 | Juvenile?<br>No | | | | | |
| Type Address<br>HOME 411 | | CT | | City<br>WALESKA | | State | |
| ZIP Code<br>WALESKA | | | | | - | | |
| Phone Type Phon<br>HOME (6 | | 0-2746 | | States and states | | | |
| Narrative | | | | | | の語い語言 | |
On 11/24/05 at about 21:49 hours I went to 411 Court in reference to a suspicious person. I met with Court in reference to a who stated she has two juvenile daughters. Tonight she noticed they went across the street to a vacant house with some boys. When she went to check on them she caught the boys drinking alcohol. She knew the boys were juveniles so she took the alcohol (tequila) from them she said a couple of the boys ran off. Juvenile one got in his silver Mitsubishi and went to the end of the street. He then stopped infront of her house. The juvenile stated he wanted his tequila back and he would come back at midnight.
is concerned juvenile one might return and damage her guests vehicles. Mrs. asked her juveniles who the subject was and they were unfamiliar. I gave Mrs. a case card. I returned into service with no further incident. I informed morning watch of this address for an extra patrol for tonight only.
| | and the same part of the same and the same as a same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same of the same o | |
|-----------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------|
| Report Unicer | Printed At | |
| 000202/BEDOYA, BROOKE | 06/06/2006 11:21 | Page 2 of 2 |
| | and strategies where an appropriate the characterization is a first strategies on the P. Strategies | Contraction of the second second second second second second second second second second second second second s |
Supplement No
ORIG
05-104607
498 CHATTIN DRIVE
06-6702
Supplement No
| Reported Date |
|----------------|
| 01/21/2006 |
| Nature of Call |
| MIS PER |
| Officer |
| |
#### (678) 493-4200
| Adr | ninist | rativ | e In | forma | ation | 1 | | | 1 ALAS | all prover | | | | A STATE |
|-----------------|---------------|-------------|---------------|------------------|-------|----------------------|-----|-------------------------|--------|-----------------------|-------|--------------------|----|----------------------|
| Agency | | COUNT | TY SI | ERIFF | 's of | FFICE | | Report No<br>06-6702 | 1.1 | Supplement No<br>ORIG | | ed Date 21/2006 | | orted Time<br>9:08 |
| CADCa | No<br>011543 | Status | | T REPO | DRT | Nature of C<br>MISSI | | PERSON | (ADU | LT) | | | | |
| 411 | | - Andrewson | | CT | | | | | CAN | TON | | ZIP Code<br>CANTON | | 1 |
| From De 01/2 | ate<br>20/200 | | n Time<br>:00 | To Date<br>01/21 | /200 | 6 13: | | Officer<br>000025 | - | | | | | T |
| 2nd Otti | oer , | | | Assign | | ETENTI | ION | CENTER | | ULT DET | ENTIO | N CENTE | R | Entered by<br>000025 |
| | | ENTIC | ON CE | INTER | | Transfer<br>cessf | ul | Approving Off<br>000455 | | | | 1/23/20 | 06 | |
| Approva<br>07:0 | 10:19 | | | | | | | | | | | | | |
| Per | son S | umn | nary | 1 | | S. S. S. S. | | at state | | | 1 | | | |
| CLR | Invi No<br>2 | Туре | Name | | | - | | | | MNI<br>264217 | Race | Sex<br>F | | /17/1969 |
| VUL | Invi No<br>1 | Name | Conf | identi | al P | age | | | | | | | - | |
| Report Officer | Printed At | | |
|----------------|------------|-------|-------------|
| 000025/ | 06/06/2006 | 11:12 | Page 1 of 3 |
1 to
Public Records Request No.: 17-295
| Incident Report | | TY SHERI | FF'S OFFICE | 06-6702 | Supplement No. |
|------------------------------------------------|---------------|------------------------|--------------|---------|----------------|
| CALLER/COMPLA | | | | | |
| CALLER/COMPLAINANT | Invi No.<br>2 | Type<br>Individual | Name | | MNI<br>264217 |
| Race Sex Date of Birth<br>FEMALE 03/17 | | Age Juvenile?<br>36 No | | | Acres 10 |
| Type Address<br>HOME 411<br>ZIP Code<br>CANTON | СТ | | Chy<br>CANTO | DN GI | BORGIA |
| Type<br>SOCIAL SECURITY NUM | | ID No | | | |
| Phone Type Phone No<br>HOME (678) 880-274 | 6 | | Second State | | |
| <b>JUVENILE 1: Confi</b> | identi | ial | | | |
| Involvement Invi No Name<br>JUV 1 See Con | fiden | tial Page | | | |
| Narrative | | | | | |
While on patrol, I was dispatched to a missing person call at 411 Court. I arrived and made contact with the caller/mother of the missing juvenile female, [\_\_\_\_\_\_\_\_]. She stated her juvenile daughter left yesterday for school, and had not returned. \_\_\_\_\_\_\_]. She had spoken with her daughter around 1900 and she was going to the high school basketball game. Later on that night, some of the juveniles's friends called the mother and informed her they had not seen the juvenile at the game.
When the juvenile didn't return this morning, said she became worried and started to contact some of her daughter's friends. They told her they heard she was handing hanging around with Mr. Byron Elrod in an area known as "The Cut" which is located off Old Donaldson and Highway 140. "The Cut" is a known drug area in the county. I completed a missing person's checklist and obtained a recent picture of the juvenile. I called Detective and informed her of the situation. The mother did not want a juvenile complaint filed. I issued I is a case card and asked her to call if she found any more information regarding her daughter. D/S Ballard and I left the residence and returned to service.
After patrolling Old Donaldson Rd and the Crissler Street area, we were unable to locate any additional information as to the whereabouts of the female. Around 1200, I received a telephone call from \_\_\_\_\_\_\_ stating that she had found her daughter, and she was located at Gregory Lane Apartments off Bells Ferry Rd. The mother told me a friend of the family was going to pick the female up, and escort her back to the parents house. I told \_\_\_\_\_\_ to call 911 when her daughter returned and a deputy would be sent out to check on the well being of the juvenile.
When the juvenile returned Sgt Thompson met with the juvenile and parents at the house. The Juvenile stated she had been drinking and had done some drugs last night, and that she had been scared to call her parents. She then went to a friends house located at Gregory Lane Apartments and spent the night.
| Report Officer | Printed At<br>06/06/2006 11:12 | Page 2 of 3 |
|----------------|--------------------------------|-------------|
| | | |
| | | |
| | | |
Page 36 of 131
07/26/17
Public Records Request No.: 17-295
498 CHATTIN DRIVE
| 06-6702 |
|----------------|
| DRAFT |
| Bananda d Basa |
Supplement No 0001
Rep 01/21/2006 Nature of Call
| hucer | |
|-------|----------|
| | , AUTUMN |
| | |
(678) 493-4200
| Agency<br>CHEROKEE COUNTY SHERIFF'S OFFICE | Report No<br>06~6702 | Supplement No<br>0001 | Reported Date<br>01/21/2006 | Reported Time<br>15:30 |
|--------------------------------------------|----------------------|-----------------------|-----------------------------|------------------------|
| Officer<br>000284 N, AUTUMN | | | PERSONS UNIT | Entered by<br>000284 |
| Assignment<br>CID DAY SHIFT PERSONS UNIT | Officer | Approval | Date | |
| Approval Time | | | | |
On 012106 I was notified by dispatch to give B-43 a call. I called and spoke with D/S Ballard and he was taking a report of a missing juvenile age 15. He stated she was supposed to have went to a basketball game last night but she didn't. He stated she went off with some black males. He told they were stopped by some friends of her and they fought with the black males. D/S Ballard said the mother had contact with her daughter around 8:00 last night but had not heard from her since then.
| Report Officer | Printed At | |
|-----------------------------------------------------------------------------------------------------------------|------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 000284 J, AUTUMN | 06/06/2006 11:12 | Page 1 of 1 |
| In the second second second second second second second second second second second second second second second | | Bearing of the second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second |
## **Case Activity**
Index
#### **Case Details**
| Incide<br>06000 | | Initial<br>01/23/ | | Officer A | ssigned | Division | Asgn Area<br>P1 | Assign Date 01/23/2006 | Charge<br>MIS JUV |
|-----------------|-----------------|-------------------|------------|-------------|----------------------|-------------|-----------------|---------------------------|-------------------|
| Class<br>27 | Case C<br>27699 | ontrol | Solve<br>C | Status<br>C | Dispo<br>CLOSED/C | LEARED | EXCEPTIO | NALLY ADU | LT |
| Prosec | ute? | | Insuranc | e? | Last Act<br>01/23/20 | | Follow | v Up Due Dt | |
| Made | Date | | Prop | erty Act | | # Char<br>0 | rges | Status Date<br>01/23/2006 | |
| E-Mai | 1 | Person | P | roperty | Vehic | ele | Investigation | В | ooking |
#### New Case Activity
#### **Case Activity**
| Details | Officer<br>Assigned | Division | Asgn<br>Area | Act<br>Type | Amount | Next<br>Type | Next<br>Date | Property<br>Act | #<br>Hours | Minutes | Edit |
|---------|---------------------|----------|--------------|-------------|--------|--------------|--------------|-----------------|------------|---------|-----------|
| 102612 | | | P1 | IN | 0 | | | | 0 | 0 | 060006702 |
| 102613 | | | P1 | EA | 0 | | | | 0 | 0 | 060006702 |
Number of Activities: 2 Total Recovered Property: \$0 Total Hours: 0:0
## Additional Information
-Associated Persons: 2 ARS Narrative: 1
ARS Report Summary: 1
End of document
Public Records Request No.: 17-295
X 3
#### ALAN M. DERSHOWITZ 1575 MASSACHUSETTS AVENUE
CAMBRIDGE • MASSACHUSETTS • 02138
April 19, 2006
Ms. Lanna Belohlavek Assistant State Attorney 401 North Dixie Highway West Palm Beach, FL 33401
Dear Lanna:
Guy has asked me to provide you with the research on why it makes a difference whether Mr. Epstein pleads "nolo contendere" or "guilty". As you can see from the enclosed statute, a plea of "nolo contendere" is not admissible as an "admission against interest" in a subsequent civil case. A plea of guilty – even a so-called "best interest" plea of guilty – is admissible. That is the only real legal difference. If you need anything further, please do not hesitate to call me or Guy.
Sincerely,
In certa
Enclosure: FL ST § 90.410
FLSTS90410 West's F.S.A. § 90.410 C
Effective: (See Text Amendments]
WEST'S FLORIDA STATUTES ANNOTATED TITLE VII. EVIDENCE (CHAPTERS 90-92) CHAPTER 90. EVIDENCE CODE 90.410. Offer to plead guilty; nob contendere, withdrawn pleas of guilty
Evidence of a pica of guilty, later withdrawn, a plea of nob contendere; or an offer to plead guilty or nolo contendere to the crime charged or any other crime is inadmissible in any civil or criminal proceeding. Evidence of statements made in connection with any of the pleas or offers is inadmissible, except when such statements are offered in a prosecution under chapter 837.
CREDIT(S)
Laws 1976, e. 76-237, § I; Laws 1978, c. 78.361, § 8.
HISTORICAL AND STATUTORY NOTES
Amendment Notes:
Laws 1978, C. 78-361, deleted "for impeachment or" preceding "in a prosecution under chapter 837."
Federal Evidence Rules:
For rule relating to offer to plead guilty; nob contendere; withdrawn plea of guilty, see Rule 410, Fed,Rules Evid , 28 U.S.C.A.
Uniform Rules of Evidence:
For rule tells offer to plead guilty; nob contendere; withdrawn plea of guilty, see Rule 410, Uniform Laws Annotated, Edition, vol. 13.
West's F. S. A. § 90.410, FL ST § 90.410
Current through Chapter 362 (End) of the 2005 Special 'B' Session of the Nineteenth Legislature
O 2006 Thornson/West
END OF DOCUMENT
O 2006 Thomson/West No Claim to Orig. U.S. Govt. Works.
#### SENT VIA FACSIMILE TRANSMISSION
April 17, 2006
FROM :
Lanna Belohlavek Assistant State Attorney Office of the State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Lanna:
I am in receipt of your letter, of today's date, confirming the offer of settlement in the Jeffrey Epstein matter. Please allow this response to serve as my acceptance with the following clarifications:
1) You have agreed to allow Mr. Epstein to enter a Guilty Best Interest Plea. Additionally, you have agreed to review authority I provide concerning the effect a "guilty" plea has on a civil matter and in good faith consider allowing Mr. Epstein to plea "No Contest."
Regarding, the supervised contact, your letter refers to an 2) "approved" adult. In our meeting today, you did not mention that the supervisor had to be approved. I agree that the supervision must be by an adult, other than , with knowledge of the underlying facts. Additionally, I need to confirm that Mr. Epstein may be with his goddaughter without supervision.
3) You agreed not to object to my selecting a duly licensed and -if approved experienced psychologist to conduct the evaluation.
I accept the provision for payment of the cost of investigation for the 4) Palm Beach Police Department as long as the cost is reasonable.
Although your correspondence does not mention travel, I am 5) confirming your agreement to allow Mr. Epstein to travel for business purposes. In line with our discussions, I request that you agree to allow Mr. Epstein to travel for philanthropy as well. mot
Page 41 of 131
Pursuant to this acceptance, I trust you will cancel presenting this matter to the Grand Jury tomorrow. Please contact me as soon as possible so we can continue to work through the filing, processing and plea resolution in this matter.
Very truly yours,
Rae 10
Guy P. Fronstin, Esq.
GPF/mw Enclosures (as noted)
#### SENT VIA FACSIMILE TRANSMISSION
April 10, 2006
Daliah Weiss, ASA Office of the State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401
**Re: Jeffrey Epstein**
Dear Daliah:
Pursuant to our recent conversation and my correspondence of January 13, 2006 (attached), please allow this letter to reconfirm that I am attorney of record for Mr. Epstein. Additionally, I am clarifying that Mr. Alan Dershowitz is also counsel for Mr. Epstein.
Currently, the structure of our representation is that I will be the one in communication with you, Lanna Belohlavek and Detective Recarey regarding the investigation and prosecution of this matter. Mr. Dershowitz remains involved however, at this point, I do not anticipate him contacting you, Ms. Belohlavek or Detective Recarey to discuss any issue relevant to this investigation. I will notify you if this structure changes.
Please call me if you have any questions or concerns about Mr. Epstein's representation. Additionally, I anticipate hearing back from you on Thursday regarding the opportunity for me to meet with you and Lanna prior to this case being presented to the Grand Jury.
I look forward to continuing to work with you on this matter.
Very truly yours,
Guy P. Fronstin, Esq. GPF/mw Attachment
#### SENT VIA FACSIMILE TRANSMISSION
January 13, 2006
Lanna Belohlavek, ASA Office of the State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Lanna:
Please allow this letter to serve as formal notice that I represent Mr. Jeffrey Epstein in regard to the Investigation your office is conducting of Mr. Epstein. Additionally, Alan Dershowliz, Esq., who is a close friend of Mr. Epstein's, is serving as counsel to me in my representation of Mr. Epstein. Mr. Dershowitz is working closely with me on this matter and, in the event charges are filed, will likely petition to enter an appearance Pro Hac Vice along with other counsel.
I appreciate the dialogue you have permitted throughout this investigation. I trust you will still invite me for a pre-filing interview in the event the State decides it has enough evidence to charge Mr. Epstein with a crime.
I look forward to continuing to work with you on this matter.
Very truly yours,
Guy P. Fronstin, Esq. GPF/mw
SENT VIA HAND DELIVERY
February 17, 2006
Lanna Belohlavek Assistant State Attorney Office of the State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Lanna:
Thank you for meeting yesterday and allowing Alan and me to address your investigation of Jeffrey Epstein. Pursuant to our discussion, I am enclosing an Incident Report from Victoria Secret outlining three (3) recent incidents of theft committed by
I am submitting this Incident Report with the express understanding that it will be kept in strict confidence. Specifically, since the Report only concerns of I believe there is no good faith reason, in any contact you may have with the store to mention Mr. Epstein's name or the investigation (especially in light of reports from multiple witnesses indicating Detective Recarey is providing damaging mis-information). Please let me know if you have any questions about the report and I will do whatever I can to immediately resolve your concerns.
Additionally, I am enclosing a credit card receipt (with non-relevant information redacted) confirming the purchase of the strap-on dildo that purchased at Guys and Dolls. It will make clear that when the dildo was purchased, was over 18 years old and she charged the purchase on the strap of the strap of the strap of the strap of the had never before been to Guys and Dolls and was taken there by the indicated it was her favorite sex shop. I hope by presenting this meaningful information it will bring us closer to a resolution. If you have any questions before our next meeting on Thursday February 23, at 11:00 AM, please do not hesitate to contact me.
Very truly yours,
· ....................................
2604
Guy P. Fronstin, Esq.
GPF/mw Enclosures (as noted)
Public Records Request No.: 17-295
BARRY KRISCIIER STATE ATTORNEY
CIF -1 er
#### STATE ATTORNEY
FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY
February 9, 2006
Guy Fronstin, Esq. 515 North Flagler Drive Suite 300 Pavilion West Palm Beach, FL 33401
Dear Mr. Fronstin:
This is to notify you that certain matters suggesting possible criminal conduct on the part of your client, Jeffrey Epstein, will be presented for consideration by the current session of the Palm Beach County Grand Jury. You and your client are invited to appear before the Grand Jury in the Palm Beach County Courthouse on March 7, 2006 at 9:00 AM, or as soon thereafter as they are able to hear you.
The invitation is extended to provide an opportunity for your client to present any personal testimony you may think proper. You should understand, however, that anything your client testifies to may be used against him in a subsequent criminal prosecution.
In the event you and your client wish to present evidence or testimony of other witnesses you must submit a written list of names and addresses of potential witnesses by February 16, 2006 and make them available by February 21, 2006 for a sworn statement at the State Attorney's Office. Copies of potential physical evidence must be supplied by February 16, 2006. Keep in mind that only evidence that is relevant to the incident will be presented to the Grand Jury.
This invitation to your client is not an offer of immunity nor is it an effort to compel your client to participate in the Grand Jury proceedings in any way. Any participation on his part must be entirely voluntary, and a decision not to participate cannot be used to raise an unfavorable presumption against your client.
Thank you for your cooperation in this matter.
Sitie IfaAh~ertlym, Avedk
Assistant State Attorney Grand Jury/Crimes Against Children
lbab
xc: Clerk's File SAO File
07/26/17 Page 47 of 131 Public Records Request No.: 17-295
Alan Dershowitz 1525 Massachusetts Avenue Cambridge, Massachusetts 02138 617-939-6001
Recarey Detective Palm Beach Police Department 345 S. County Road Palm Beach, FL 33480
#### Re: Epstein matter
#### Dear Detective Recarey:
I am sending you this letter in response to the serious concern you raised at our meeting regarding an alleged claim that one of our investigators had misrepresented himself as a police officer and in fact had actually attempted to impersonate you. As I told you neither I nor my client would ever tolerate any such conduct on the part of our investigators. With that in mind, I immediately began an inquiry of our staff, and believe that the contemporaneous notes taken by our investigator, while attempting to interview
will provide the necessary explanation for your thoroughly justified consternation. It will also, I believe, provide a more troublesome and telling illustration of her character. At our meeting, you may recall, I also advised you that our investigation had discovered at least one of her web sites and I am enclosing some examples. You will note that she, herself, has chosen to go by the nickname of "pimp juice" and the site goes on to detail, including photos, her apparent fascination with marijuana. This will come as no surprise to you as I'm sure you are already aware of her recent Palm Beach arrest for both possession of marijuana and drug paraphernalia.
The following raw notes were taken by investigators (one who suffers from a quite distinct speech impediment, making, therefore, a truly innocent claim of impersonation virtually impossible). Both of them have many years experience in conducting defense investigations and debriefing witnesses. They are both well versed in the law and extremely sensitive to any potential allegations of wrongdoing especially from witnesses who may have their own agendas. In this instance, they were instructed to take statement verbatim because we feared that she, an accomplished drama student, might try to mislead them as successfully as she had misled others. They were instructed to ask detailed questions to further elucidate her previous pronouncements regarding the extreme lengths she would go to as she put it "to be rich, no, I mean really, really rich". But as you will read, they never got a chance to ask even a single question, and could not for a moment be thought of, as attempting to misrepresent themselves as police officers. In fact even though, they are both well prepared and seasoned investigators, they were quite shocked at the overwhelming, non-stop barrage of profanity being hurled at them at a furious pace and volume from what initially appeared
only to be a young woman of slight build and soft demeanor. The following is an excerpt from the investigator's report detailing her extremely short but none the less pungent statements;
"11.21.2005, my partner, Steve Kiraly, and I traveled to Orange Park (Jacksonville), Florida, in order to attempt to interview The purpose of having two people present was to act as witnesses as to whatever might have been said by """ during the course of our interview. If very with her 18 year old boyfriend, William, and his mother and boyfriend at 2768 Kiowa Avenue, Orange Park, FL. At approximately 6:30pm "" arrived home. We waited about 10 minutes and approached the residence. I knocked on the door and a woman, who I now know as Mary answered the door. I told her that we would like to speak with She said there was no there. I said there must be because her Jeep was parked out front. She then said, "I'm sorry, you mean "" and I said yes. then came to the door. The following conversation took place.
[ \_\_\_\_\_\_] \_\_\_\_, my name is Bill \_\_\_\_\_ (as I handed her my business card) and this is my partner Steve Kiraly. We are investigators from Miami working on behalf of Jeffrey Epstein.
I don't talk to fucking cops and I'm not talking to you.
] ..., we're not cops.
[^1-] You need to leave. Get the fuck off my property, leave now.
[100] ....., there is no need to be hostile. We are not cops. We are just trying to learn the truth.
Get the fuck off my property. What, you're still standing here?
] We're leaving but we don't understand why you're so hostile.
[ You have no right to be here. I moved. All that shit is behind me in another world so get the fuck out of here.
goes back inside the house and Mary came outside on the porch
we're not being hostile. We're here just to learn the truth.
[Look, \_\_\_\_\_\_ is a good girl and she left down there. We're trying to sort things out now and hire her an attorney.
I understand but we're not the bad guys and we're not cops.
[ ] Okay, but she doesn't want to talk with you and you really have no right being here on my property this time of night.
I'm sorry we're here at 6:45pm but your son, Will, told us we could come back.
] He doesn't own this property.
..... same back outside
] You're still here, get the fuck out. I'm calling the cops if you do not leave.
[ , we're talking with Mary and yes, we're leaving, but all we wanted was to learn the truth from you about what knowledge you may or may not have."
As you can gather from this, we believe her to be the source of your concern.
Our other, but we believe, less likely alternative source for the potential misunderstanding could be a close friend of Miss \_\_\_\_\_\_ named \_\_\_\_\_\_ who goes by the more outlandish self chosen moniker and complete web name of "\_\_\_\_\_\_ Fucking \_\_\_\_\_", whose web page I also enclose.
In the event that the source of the allegation is neither of the two women mentioned above, if you would provide me with the name of the person, or persons, making the claim, I will check with the relevant investigators and follow through until we are satisfied that we have gotten to the bottom of this matter.
I trust the information provided in this letter is helpful to you as we all try to bring this difficult period to a close.
Sincerely,
alan Dershowitz
Alan Dershowitz
Enclosures Barry Krischer Lanna Belohlavek Daliah Weiss
cc:
Public Records Request No.: 17-295
Alan Dershowitz 1525 Massachusetts Avenue Cambridge, Massachusetts 02138 617-939-6001
1. 1. 3.
Detective Palm Beach Police Department 345 S. County Road Palm Beach, FL 33480
Re: Epstein matter
Dear Detective Recarey:
I am sending you this letter in response to the serious concern you raised at our meeting regarding an alleged claim that one of our investigators had misrepresented himself as a police officer and in fact had actually attempted to impersonate you. As I told you neither I nor my client would ever tolerate any such conduct on the part of our investigators. With that in mind, I immediately began an inquiry of our staff, and believe that the contemporaneous notes taken by our investigator, while attempting to interview
, will provide the necessary explanation for your thoroughly justified consternation. It will also, I believe, provide a more troublesome and telling illustration of her character. At our meeting, you may recall, I also advised you that our investigation had discovered at least one of her web sites and I am enclosing some examples. You will note that she, herself, has chosen to go by the nickname of "pimp juice" and the site goes on to detail, including photos, her apparent fascination with marijuana. This will come as no surprise to you as I'm sure you are already aware of her recent Palm Beach arrest for both possession of marijuana and drug paraphernalia.
The following raw notes were taken by investigators (one who suffers from a quite distinct speech impediment, making, therefore, a truly innocent claim of impersonation virtually impossible). Both of them have many years experience in conducting defense investigations and debriefing witnesses. They are both well versed in the law and extremely sensitive to any potential allegations of wrongdoing especially from witnesses who may have their own agendas. In this instance, they were instructed 's statement verbatim because we feared that she, an accomplished to take ... drama student, might try to mislead them as successfully as she had misled others. They were instructed to ask detailed questions to further elucidate her previous pronouncements regarding the extreme lengths she would go to as she put it "to be rich, no, I mean really, really rich". But as you will read, they never got a chance to ask even a single question, and could not for a moment be thought of, as attempting to misrepresent themselves as police officers. In fact even though, they are both well prepared and seasoned investigators, they were quite shocked at the overwhelming, non-stop barrage of profanity being hurled at them at a furious pace and volume from what initially appeared
Public Records Request No.: 17-295
only to be a young woman of slight build and soft demeanor. The following is an excerpt from the investigator's report detailing her extremely short but none the less pungent statements;
"11.21.2005, my partner, Steve Kiraly, and I traveled to Orange Park (Jacksonville), Florida, in order to attempt to interview The purpose of having two people present was to act as witnesses as to whatever might have been said by
during the course of our interview. \_\_\_\_\_ lives with her 18 year old boyfriend, William, and his mother and boyfriend at 2768 Kiowa Avenue, Orange Park, FL. At approximately 6:30pm \_\_\_\_\_ arrived home. We waited about 10 minutes and approached the residence. I knocked on the door and a woman, who I now know as Mary \_\_\_\_\_\_, answered the door. I told her that we would like to speak with \_\_\_\_\_\_. She said there was no / \_\_\_\_\_\_\_ there. I said there must be because her Jeep was parked out front. She then said, "I'm sorry, you mean \_\_\_\_\_ and I said yes. \_\_\_\_\_\_ then came to the door. The following conversation took place.
[**1**] ...., my name is Bill **(as I handed her my business card) and this is my partner Steve Kiraly. We are investigators from Miami working on behalf of Jeffrey Epstein.**
I don't talk to fucking cops and I'm not talking to you.
[ ] , we're not cops.
.] You need to leave. Get the fuck off my property, leave now.
[100], there is no need to be hostile. We are not cops. We are just trying to learn the truth.
Get the fuck off my property. What, you're still standing here?
] We're leaving but we don't understand why you're so hostile.
You have no right to be here. I moved. All that shit is behind me in another world so get the fuck out of here.
... goes back inside the house and Mary came outside on the porch
we're not being hostile. We're here just to learn the truth.
[Look, 'is a good girl and she left down there. We're trying to sort things out now and hire her an attorney.
I understand but we're not the bad guys and we're not cops.
[ Okay, but she doesn't want to talk with you and you really have no right being here on my property this time of night.
I'm sorry we're here at 6:45pm but your son, Will, told us we could come back.
] He doesn't own this property.
... came back outside
You're still here, get the fuck out. I'm calling the cops if you do not leave.
[ ] ....., we're talking with Mary and yes, we're leaving, but all we wanted was to learn the truth from you about what knowledge you may or may not have."
As you can gather from this, we believe her to be the source of your concern.
Our other, but we believe, less likely alternative source for the potential misunderstanding could be a close friend of Miss anamed A source for the potential s, who goes by the more outlandish self chosen moniker and complete web name of " Fucking "s", whose web page I also enclose.
In the event that the source of the allegation is neither of the two women mentioned above, if you would provide me with the name of the person, or persons, making the claim, I will check with the relevant investigators and follow through until we are satisfied that we have gotten to the bottom of this matter.
I trust the information provided in this letter is helpful to you as we all try to bring this difficult period to a close.
Sincerely,
1. Aug.
alan Dershowitz
Alan Dershowitz
Enclosures Barry Krischer Lanna Belohlavek Daliah Weiss
cc:
Public Records Request No.: 17-295
#### Alan Dershowitz 1525 Massachusetts Avenue Cambridge, Massachusetts 02138 617-939-6001
Recarey Detective Palm Beach Police Department 345 S. County Road Palm Beach, FL 33480
#### Re: Epstein matter
#### Dear Detective Recarey:
I am sending you this letter in response to the serious concern you raised at our meeting regarding an alleged claim that one of our investigators had misrepresented himself as a police officer and in fact had actually attempted to impersonate you. As I told you neither I nor my client would ever tolerate any such conduct on the part of our investigators. With that in mind, I immediately began an inquiry of our staff, and believe that the contemporaneous notes taken by our investigator, while attempting to interview investigation. It will also, I believe, provide a more troublesome and telling illustration of her character. At our meeting, you may recall, I also advised you that our investigation had discovered at least one of her web sites and I am enclosing some examples. You will note that she, herself, has chosen to go by the nickname of "pimp juice" and the site goes on to detail, including photos, her apparent fascination with marijuana. This will come as no surprise to you as I'm sure you are already aware of her recent Palm Beach arrest for both possession of marijuana and drug paraphernalia.
The following raw notes were taken by investigators (one who suffers from a quite distinct speech impediment, making, therefore, a truly innocent claim of impersonation virtually impossible). Both of them have many years experience in conducting defense investigations and debriefing witnesses. They are both well versed in the law and extremely sensitive to any potential allegations of wrongdoing especially from witnesses who may have their own agendas. In this instance, they were instructed to take statement verbatim because we feared that she, an accomplished drama student, might try to mislead them as successfully as she had misled others. They were instructed to ask detailed questions to further elucidate her previous pronouncements regarding the extreme lengths she would go to as she put it "to be rich, no, I mean really, really rich". But as you will read, they never got a chance to ask even a single question, and could not for a moment be thought of, as attempting to misrepresent themselves as police officers. In fact even though, they are both well prepared and seasoned investigators, they were quite shocked at the overwhelming, non-stop barrage of profanity being hurled at them at a furious pace and volume from what initially appeared
only to be a young woman of slight build and soft demeanor. The following is an excerpt from the investigator's report detailing her extremely short but none the less pungent statements:
"11.21.2005, my partner, Steve Kiraly, and I traveled to Orange Park (Jacksonville), Florida, in order to attempt to interview \_\_\_\_\_i. The purpose of having two people present was to act as witnesses as to whatever might have been said by " during the course of our interview. I lives with her 18 year old boyfriend, William, and his mother and boyfriend at 2768 Kiowa Avenue, Orange Park, FL. At approximately 6:30pm arrived home. We waited about 10 minutes and approached the residence. I knocked on the door and a woman, who I now know as Mary answered the door. I told her that we would like to speak with '. . . . . . . . . . . . . . . . . . . there was no " " " there. I said there must be because her Jeep was parked out front. She then said, "I'm sorry, you mean ......" and I said yes. " then came to the door. The following conversation took place.
] , my name is Bill (as I handed her my business card) and this is my partner Steve Kiraly. We are investigators from Miami working on behalf of Jeffrey Epstein.
[ ] \_\_\_\_; we're not cops. I don't talk to fucking cops and I'm not talking to you.
You need to leave. Get the fuck off my property, leave now.
, there is no need to be hostile. We are not cops. We are just trying to learn the truth.
[\_\_\_\_] Get the fuck off my property. What, you're still standing here?
We're leaving but we don't understand why you're so hostile.
[.....] You have no right to be here. I moved. All that shit is behind me in another world so get the fuck out of here.
came outside on the porch goes back inside the house and Mary
we're not being hostile. We're here just to learn the truth.
Look, ' is a good girl and she left down there. We're trying to sort things out now and hire her an attorney.
I understand but we're not the bad guys and we're not cops.
] Okay, but she doesn't want to talk with you and you really have no right being here on my property this time of night.
I'm sorry we're here at 6:45pm but your son, Will, told us we could come back.
] He doesn't own this property.
came back outside ...
.] You're still here, get the fuck out. I'm calling the cops if you do not leave.
] ......; we're talking with Mary and yes, we're leaving, but all we wanted was to learn the truth from you about what knowledge you may or may not have."
As you can gather from this, we believe her to be the source of your concern.
Our other, but we believe, less likely alternative source for the potential misunderstanding could be a close friend of Miss "'s named , ..., who goes by the more outlandish self chosen moniker and complete web name of 'Fucking , whose web page I also enclose.
In the event that the source of the allegation is neither of the two women mentioned above, if you would provide me with the name of the person, or persons, making the claim, I will check with the relevant investigators and follow through until we are satisfied that we have gotten to the bottom of this matter.
I trust the information provided in this letter is helpful to you as we all try to bring this difficult period to a close.
Sincerely,
alan Dershowitz
Alan Dershowitz
Enclosures Barry Krischer Lanna Belohlavek Daliah Weiss
cc:
Public Records Request No.: 17-295
Jà
### LAW OFFICE OF GUY FRONSTIN 515 N. FLAGLER DRIVE, SUITE 300 PAVILION WEST PALM BEACH, FL 33401 (561) 447-4011 \* (561) 802-4121 (Fax)
#### SENT VIA FACSIMILE TRANSMISSION
January 13, 2006
Lanna Belohlavek, ASA Office of the State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Lanna:
Please allow this letter to serve as formal notice that I represent Mr. Jeffrey Epstein in regard to the investigation your office is conducting of Mr. Epstein. Additionally, Alan Dershowitz, Esq., who is a close friend of Mr. Epstein's, is serving as counsel to me in my representation of Mr. Epstein. Mr. Dershowitz is working closely with me on this matter and, in the event charges are filed, will likely petition to enter an appearance Pro Hac Vice along with other counsel.
I appreciate the dialogue you have permitted throughout this investigation. I trust you will still invite me for a pre-filing Interview In the event the State decides it has enough evidence to charge Mr. Epstein with a crime.
I look forward to continuing to work with you on this matter.
Very truly yours
GPF/mw
Guy P. Fronstin, Esq.
Page 57 of 131 Public Records Request No.: 17-295
## Law Offices of SALNICK & FUCHS, P.A.
Michael Salnick\* Jack K. Fuchs Flynn P. Bertisch
- Board Certified Criminal Trial Lawyer
- Member of Colorado, District of Columbia and New York Bara
Jennifer L. Shand Certified Legal Assistant
| ONE CLEARLAKE CENTRE |
|-------------------------------------|
| 250 SOUTH AUSTRALIAN AVENUE |
| SUITE 1203 |
| WEST PALM BEACH, FLORIDA 33401-5014 |
(561) 471-1000 Fax: (561) 659-0793 E-mail: SalnickLaw@aoi.com Fuchslaw@bellsouth.net Fbertisch@bellsouth.net
MEMO
| DATE: | JANUARY 1 | 1,2006 |
|-------|-----------|--------|
| | | |
FROM: MICHAEL SALNICK
TO: Daliah Weiss
RE: Our Client: Janusz Banasiak
One more thing: Can my client pick up his computer and related equipment before our meeting on Tuesday? Please advise and thank you.
With kindest regards,
LAW OFFICE
Michael Salnick\* Jack K. Fuchs Flynn P. Bertisch
- Board Certified Criminal Trial Lawyer
- Member of Colorado, District of Columbia and New York Bars
Jennifer L. Shand Certified Legal Assistant
| ONE CLEARLAKE CENTRE |
|-------------------------------------|
| 250 SOUTH AUSTRALIAN AVENUE |
| SUITE 1203 |
| WEST PALM BEACH, FLORIDA 33401-5014 |
(561) 471-1000 Fax: (561) 659-0793 E-mail: SalnickLaw@aol.com Fuchslaw@bellsouth.net Fbertisch@bellsouth.net
#### MEMO
DATE: JANUARY 11, 2006
FROM: MICHAEL SALNICK
TO: Daliah Weiss
RE: Investigation Re: Jeffrey Epstein Our Client: Janusz Banasiak
This shall confirm the rescheduling of the meeting with my client until Tuesday, January 17, 2006 at 11:00 a.m. at your office. In one of our conversations earlier this morning, you indicated that you would be inclined to issue him a subpoena. I would please ask that you fax a copy of that subpoena to my office prior to our meeting.
Thank you for your attention to this matter.
With kindest regards, Michael Salnick
## \*TIME SENSITIVE MATERIAL\* \*PLEASE DELIVER IMMEDIATELY\*
### FAX COVER SHEET
.....
- TO: Lanna Belohlavek, ASA
- RE: Jeff Epstein
- DATE: January 11, 2006
- FROM: Guy P. Fronstin, Esq.
#### NUMBER OF PAGES INCLUDING COVER SHEET: 2
Please see attached letter.
#### THANK YOU FOR YOUR ASSISTANCE IN THIS MATTER.
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient or the employee or agent responsible for delivery of the message to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone, and return the original message to us at the above address. FROM : ...
LAW OFFICE OF GUY FRONSTIN 515 N. FLAGLER DRIVE, SUITE 300 PAVILION WEST PALM BEACH, FL 33401 (561) 447-4011 \* (561) 802-4121 (Fax)
....
#### SENT VIA FACSIMILE TRANSMISSION
January 11, 2006
Lanna Belohlavek Assistant State Attorney Office of the State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401
Re: Jeff Epstein Third Party Attorney Fee Payment
Dear Ms. Belohlavek:
As you know I represent Mr. Jeff Epstein. Mr. Epstein's house manager, Yanush Banasiak, was asked to speak with your office regarding the matter that I represent Mr. Epstein on. In anticipation of Mr. Banasiak's meeting with your office he decided to retain legal counsel. Yesterday, he met with and retained, attorney Michael Salnick, who will be attending Mr. Banasiak's statement in your office today at 1:30 p.m.
Since your questioning of Mr. Banasiak concerns information that he may have that arises out of his employment with Mr. Epstein, Mr. Epstein will be paying Mr. Banasiak's attorneys fees. I felt it important to notify you of this third party attorney fee payment structure and confirm that you have no objection. Mr. Epstein would like to wire the payment for Mr. Salnick's representation to Mr. Salnick as soon as possible. Therefore, I would appreciate your getting back to me today on this issue.
Very truly yours.
Guy P. Fronstin, Esq.
GPF/mw cc: Daliah Weiss Michael Salnick ()
LAW OFFICE OF GUY P. FRONSTIN 515 N. FLAGLER DRIVE, SUITE 300 PAVILION WEST PALM BEACH, FL 33401 (561) 447-4011 \* (561) 802-4121 (Fax)
## \*TIME SENSITIVE MATERIAL\* \*PLEASE DELIVER IMMEDIATELY\*
### FAX COVER SHEET
- TO: Daliah Weiss, ASA
- RE: Jeff Epstein
- DATE: January 11, 2006
- FROM: Guy P. Fronstin, Esq.
#### NUMBER OF PAGES INCLUDING COVER SHEET: 2
Please see attached letter.
#### THANK YOU FOR YOUR ASSISTANCE IN THIS MATTER.
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient or the employee or agent responsible for delivery of the message to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone, and return the original message to us at the above address.
J.
LAW OFFICE OF GUY FRONSTIN 515 N. FLAGLER DRIVE, SUITE 300 PAVILION WEST PALM BEACH, FL 33401 (561) 447-4011 \* (561) 802-4121 (Fax)
#### SENT VIA FACSIMILE TRANSMISSION
January 11, 2006
Lanna Belohlavek Assistant State Attorney Office of the State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401
Re: Jeff Epstein Third Party Attorney Fee Payment
Dear Ms. Belohlavek:
As you know I represent Mr. Jeff Epstein. Mr. Epstein's house manager, Yanush Banasiak, was asked to speak with your office regarding the matter that I represent Mr. Epstein on. In anticipation of Mr. Banasiak's meeting with your office he decided to retain legal counsel. Yesterday, he met with and retained, attorney Michael Salnick, who will be attending Mr. Banasiak's statement in your office today at 1:30 p.m.
Since your questioning of Mr. Banasiak concerns information that he may have that arises out of his employment with Mr. Epstein, Mr. Epstein will be paying Mr. Banasiak's attorneys fees. I felt it important to notify you of this third party attorney fee payment structure and confirm that you have no objection. Mr. Epstein would like to wire the payment for Mr. Salnick's representation to Mr. Salnick as soon as possible. Therefore, I would appreciate your getting back to me today on this issue.
Very truly yours,
Guy P. Fronstin, Esg.
GPF/mw cc: Daliah Weiss Michael Salnick
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
#### CASE NO.: 2006CF009454AXX
#### STATE OF FLORIDA
#### NOTICE OF DEPOSITION
#### JEFFREY EPSTEIN, Defendant.
VS.
TO: Lanna Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401
RECarvED BY MAR 2 6 2008 COUNTy r,
PLEASE TAKE NOTICE that pursuant to the Florida Rules of CtrigligUocedure that on April 2.200\$ beginning at the hour of 1:30 P.M. at the Palm Beach County Courthouse. 4th Floor. 205 North Dixie Highway. West Palm Beach. Florida 33401,:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:
| COURTNEY WILDE & | |
|------------------|--|
Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue, Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 25th day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A. 250 Australian Avenue South, Suite 1400 Wet Palm Beach, Florida 33401 (5 ) 65 fa (56 691 J A. GOL i BERGER, ESQUIRE FI da Bar No. 262013
07/26/17 Page 64 of 131 Public Records Request No.: 17-295
ii414:43E.cIRCUIT COURT OF THE FIFTEENTH JUDICki. CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA,•:.
#### CASE NO.: 2006CF009454AXX
#### STATE OF FLORIDA
#### NOTICE OF DEPOSITION
JEFFREY EPSTEIN, Defendant.
vs.
TO: Lanna Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on March 24.2008 beginning at the hour of 1:30 P.M., at the Palm Beach County Courthouse, 4' Floor, 205 North Dixie Histhwav, West Palm Beach. Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:
#### COURTNEY WILDE, BRITANNY
Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as arc permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue, Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 17th day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A. 250 Australian Avenue South, Suite 1400 Wes Palm B :ch, Florida 33401 (56 65 -83 fa 91
A A. GOLDBERGER, ESQUIRE Fl Ida Bar No. 262013 07/26/17 P e 65 of 131 Public Records Request No.: 17-295
250 Australian Avenue South, One Clearlake Centre 5 1400, West Palm Beach, FL 33401
> State Attorney's Office Circuit Court Division 401 North Dixie Highway West Palm Beach, FL 33401
33401+4209 CO21
hallahallandhadalladilladilladilladilladilla
. Public Records Request No.: 17-295
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
#### CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
vs.
#### NOTICE OF DEPOSITION
JEFFREY EPSTEIN, Defendant.
TO: Lanna Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on March 24.2008 beginning at the hour of 1:30 P.M., at the Palm Beach County Courthouse. 4\* Floor. 205 North Dixie Highway, West Palm Beach. FIorkla 33401:
before Censor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:
#### COURTNEY WILDE, IUTANNY
Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue, Suite 340, Coconut Grove, Florida 33133 by via fax & mail this It day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A. 250 Australian Avenue South, Suite 1400 Wes. Palm h, Florida 33401 (56 91
A A. GOLDBERGER. ESQUIRE Fl da Bar No. 262013
07/26/17 Page 67 of 131 Public Records Request No.: 17-295
anna
VCTF
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
#### CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
VS.
#### NOTICE OF DEPOSITION
JEFFREY EPSTEIN, Defendant.
TO: Lanna Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on April 2, 2008 beginning at the hour of 1:30 P.M., at the Palm Beach County Courthouse, 4<sup>th</sup> Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:
COURTNEY WILDE
Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue, Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 25<sup>th</sup> day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 (561) 658-8300 fax: (56) 835-8691 JACK A. GOLDBERGER, ESQUIRE Florida Bar No. 262013
Page 68 of 131
P. 01/01
nn VCTp
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, EN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
#### STATE OF FLORIDA
vs.
#### NOTICE OF DEPOSITION
JEFFREY EPSTEIN, Defendant-
TO: Lamm Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on February 6.209S beginning at the hour of 9:30 A.M., at the palm Beach County CourthouseAth Floor. 205 North Dixie Highway. West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida., the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:
9:30 A.M. - • • •
Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as arc permitted under the applicable Statutes or Rules of Court.
I liFeREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee(s) by mail this 29" day of January, 2008.
> A 1 1 LRBURY, GOLDBERGER, & WEISS, P.A. 250 Australian Avenue South, Suite 1400 each, Florida 33401 00 / 1
A. LDBERGER, ESQUIRE Ion Bar No. 262013
1
n •
07.2617 Page 69 of 131 Public Records Request No.: 17-295
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
#### CASE NO.: 2006CF009454AXX
#### STATE OF FLORIDA
#### NOTICE OF DFPOSITION
vs.
JEFFREY EPSTEIN, Defendant.
TO: Lanna Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on April 11.2008 beginning at the hour of 10;00 A.M. at the Palm Beach County Courthouse, 4° Floor, 205 North Dixie Highway, West Palm Beach. Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:
Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue, Suite 340, Coconut Grove, Florida 33133 and Jeffrey M. Herman, Esquire, 18205 Biscayne Boulevard, Suite 2218, Miami, Florida, 33160 by via fax & mail this 20d1 day of March, 2008.
ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 We Palm Beach, Florida 33401 (56 659-8300 f 56 835-8691 JA LDBERGER, ESQUIRE Fl. o. 262013 e 70 of 131 Public Records Request No.: 17-295
07O6/7
10/10 16985£9199 'ON XVA
WV 99:01 NOW saow-avw
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
#### CASE NO.: 2006CF009454A3OC
STATE OF FLORIDA
vs.
#### NOTICE OF DEPOSITION
(Time change only pursuant to the rcquest of Theodore r. Leopold, Esquire)
JEFFREY EPSTEIN, Defendant.
TO: Lanna Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hwy West Palm Beach, Florida 33401
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on February 20, 2008 beginning at the hour of 2:00 P.M.. at the Palm Beach County Courthouse, 4" Floor. 205 North Dixie Highway. West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:
2:00 P.M.
Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee, Thedore J. Leopold, Esquire, 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida 33410 and Jeffrey Herman, Esquire, 18205 Biscayne Boulevard, Suite 2218, Miami, Florida, 33160 by via fax & mail this 8th day of February, 2008.
> ATTERBURY, GOLDBERGER, & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 (561) 659- 300 fax (5k1)\$ 5-86
Jd K A. GOLDBERGER, ESQUIRE Fl rida Bar No. 262013
07:26:17 Page 71 of 131 Public Records Request No.: 17-295
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
#### CASE NO.: 2006CF009454AXX
#### STATE OF FLORIDA
#### NOTICE OF DEPOSITION
(Time change only pursuant to the request of Theodore J. Leopold, Esquire)
JEFFREY EPSTEIN, Defendant.
VS.
TO: Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that on <u>February 20, 2008</u> beginning at the hour of <u>2:00 P.M.</u>, at the <u>Palm Beach County Courthouse</u>, 4<sup>th</sup> Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit:
#### 2:00 P.M.
Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee, Thedore J. Leopold, Esquire, 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida 33410 and Jeffrey Herman, Esquire, 18205 Biscayne Boulevard, Suite 2218, Miami, Florida, 33160 by via fax & mail this 8<sup>th</sup> day of February, 2008.
> ATTERBURY, GOLDBERGER, & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 (561) 659-8300 fax: (561)835-8691
JACK A. GOLDBERGER, ESQUIRE FT69912 Ba3 No. 262013 Public Records Request No.: 17-295
2008 FEB 11 AM 8 58
Office of the State Attorney Lanna Belohlavek, Esquire 410 North Dixie Highway West Palm Beach, Florida 33401
33401\$4210 CO2i
hillighthe Hale III. and had a had been the second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second
Public Records Request No.: 17-295
#### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA
CASE NO:
JANE DOE, by and through JANE DOE'S MOTHER as parent and natural guardian,
Plaintiffs,
TE JEFFREY EPSTEIN, and SARAH
Defendants.
#### COMPLAINT
Plaintiffs, JANE DOE, by and through JANE DOE'S MOTHER as parent and natural
guardian of JANE DOE, brings this Complaint against Defendants JEFFREY EPSTEIN,
and SARAH KELLEN, and states as follows:
#### Parties, Jurisdiction and Venue
1. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the age of
Formatteck indents Left: 0°, First ine:
18 years.
٩.
2. Jane Doe Doe's Mother brings this action by and through her Mother who is patent and
natural guardian of Jane Doc.
3. This Complaint is brought under fictitious names to protect the identity of the Minor
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
4. Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
5. Defendant is a citizen and resident of Palm Beach County, Florida.
6. Defendant is a citizen and resident of the State of New York.
This is an action for damages in excess of Fifteen Thousand Dollars (\$15,000), exclusive of interest and costs.
Venue is proper in this Court under section 47.011, Florida Statutes, because the causes of action brought herein accrued in Palm Beach County, Florida and one or more Defendants resides in Palm Beach County, Florida.
#### Factual Allegations
Formatted Indon: Left: 0°, First Inc.
9. At all relevant times, Defendant Jeffney Epitein was an adult male. Epitein is a financier and money masager with a secret clientele limited exclusively to billionaires. He is a man of irrinendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, S. Thomas and Palm Beach, Florida. The allegations herein concern Epitein's conduct while at his lavish estate in Palm Beach.
10. Upon information and belief, Epstein has a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and/or enterprise in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls or coerced or altempted to coerce them to engage in prostitution, and then gave them money. In or about 2005, Jane Doe, them 14 years old, fell into Epstein's trap and became one of his victims.
11. Upon information and belief, Jeffrey Epstein carried out this scheme/enterprise and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
12. An integral player in Epstein's Florida scheme/enterprise was **services**, an assistant of Epstein's, from New York, New York and Haley Robson, a Palm Beach Community College student from Lozahatchee, Florida. They recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan/enterprise, MS. Robson was contacted shortly before or soon after Epstein was at his Palm Beach residence. Epstein, Kellen,
Page 2 of 9
or someone on their behalf directed Ms. Robion to bring one or more underage girls to the sestdence.
13. Epstein's plan, scheme, and/or enterprise reflected a particular pattern and method. Upon aurival at Epstein's mansion, Mr. Robson would introduce each victim to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. would then bring the girl up a flight of stairs to a bedroom that contained a mansage table in addition to other furnishings. There were photographs of sude women lining the stairway and in the bedroom. Would then leave the girl alone in this soom, whereupon Epstein would enter wearing only a towel. He would then semove his towel, hay down naked on the massage table, and direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and sexual acts, including masturbation, touching the girl's vagina with a vibrator, or digitally penetrating the girl's vagina, and coerce or attempt to coerce the girl to engage in lewd acts and/or prostitution.
14. Consistent with the foregoing plan, scheme, and/or enterprise, **and/or** recruited Jane Doe to give Epstein a massage for monetary compensation. Ms. Robson brought Jane Doe to Epstein's mansion in Palm Beach. Jane was introduced to Sacah **and**, who led her up the flight of stairs to the room with the massage table, **and the set up the message table and laid out message** oils and told Jane Doe that Epstein would be in shortly, and than left the room. Jane Doe was alone in the room when Epstein answed. Epstein told her to remove her clothes and laid down on his stomach on the massage table. Epstein again told Jane Doe to remove her clothes. In shock, fear
Page 3 of 9
and trepidation. Jane Doe complied, removing her clothes except for her panties and bra. Shortly after starting to rub Epstein's back, Epstein told Jane Doe to sit on his back. Jane Doe, out of fear and trepidation, complied. After a period of time Epstein got up from the table and went behind the door. For several minutes Jane Doe heard loud noises and moans and believes that Epstein was masturbating. Thereafter Epstein, naked, returned to the massage table and laid face up on the table. Epstein than told Jane Doe to continue with the massage and told her to sit on top of him. Out of fear and trepidation she complied. As Jane Doe rubbed Epstein's chest Epstein began to use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane, Doe's vagina. At this same time, Epstein was masturbating. Upon reaching organs, Epstein got up from the massage table and told Jane Doe to write down her name and phone number and then left the room.
15. Jane Doe was then able to get diessed, leave the room and go back down the stairs and into the kitchen. Epstein, and and were waiting for Jane Doe. Epstein paid Jane Doe \$300. . . . . . . . . . . . . . . . . . .
16. As a result of this encounter with Epstein, the 14-year old Jane Doe experienced confusion, shame, humiliation, embarramment and the assault sent her life into a downward spiral.
#### COUNT I Sexual Assault against Defendant Epstein
17. Jane Doe, by and through her Mother, as parent and natural guardian, repeats
and scalleges paragraphs 1 through 16 above.
18. Defendant Epstein tortiously assaulted Jane Doe sexually in or about 2005.
Page 4 of 9
Formatteds Indent: Left: 0°, First line 19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane Doc.
20. As a direct and proximate result of Epstein's assault on Jane Doe, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages.
WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Purther, Plaintiff severves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law.
#### COUNT II
Civil Conspiracy against Defendants Epstein, and
21. Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, seperats\*
22. Defendants Epstein, and and conspired to subject Jane Doe to the sexual assault of Defendant Epstein.
23. Each of the Defendants committed an ovent act in pursuance of this comparacy: Defendant weed faise pretenses to lare Jane Doe to the home of Defendant Epstein so that Epstein could Sexually assault Jane Doe; Defendant delivered Jane Doe to Defendant Epstein's bedroom so that Epstein could sexually assault Jane Doe; and Defendant Epstein actually committed sexual assault against Jane Doe.
Page 5 of 9
attede Indunt: 0', First Br
Feets
24. As a direct and proximate result of Defendants' civil conspiracy, Jane Doe has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages.
WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, **Section 1998**, and **Section 1999**, for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law.
#### COUNT III
#### Intentional Infliction of Emotional Distress against Defendant Epstein
25. Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, repeats" and realleges paragraphs I through 16 above.
26. Epstein's conduct was intentional or reckless.
27. Epstein's conduct was outrageous, going beyond all bounds of decency.
28. Epstein's conduct caused severe emotional distress not only to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma
#### and damage to Jane Doc and her mother.
29. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe will continue to suffer severe mental anguish and pain.
WHEREFORE, Plaintiff Jane Doe, by and through her Mother as parent and natural guardian, demands, and Jane Doe's Mother, individually, demand judgment against Defendants Jeffrey Epstein, **Contraction**, and **Contraction** for compensatory damages, costs, attomey's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff
Page 6 of 9
Formatted Indants Lefts Ø", First Iner
Delvted
reserves the right to amend this Complaint to add a claim for punitive damages parsuant to
Florida Law.
COUNT IV Civil Remedy for Violation of Florida Statute Section 772.103 against Defendants Epstein, and and against
30. Plainiff Jane Doe, by and through her Mother, as parent and natural guardian, repeats\* and realleges paragraphs 1 through 16 above.
31. Defendants participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statute section 772.103(3)-(4).
32. Defendants engaged in this pattern of criminal activity by engaging in at least two of the following incidents of criminal activity with the same or similar intents, results, accomplices, victims, and methods of commission within a 5 year period:
- a Procuring for prostitution, or causing to be prostituted, any person who is under the age of 18 years in violation of Florida Statute section 796.03;
- b. Soliciting, inducing, enticing, or procuring another to commit prostitution, lewdness, or assignation in violation of Florida Statute section 796.07(2)(f), or aiding, abetting or participating in such acts in violation of Florida Statute section 796.07(2)(h);
- c Knowingly recruiting, enticing, harboring, transporting, providing, or obtaining by any means a person, knowing that force, frand, or coercion will be used to cause that person to engage in prostitution in violation of Florida Statute section 796.045; or
- Forcing, compelling, or coercing another to become a prostitute in violation of Florida Statute section 796.04.
Page 7 of 9
. .
07/26/17
Formatted Indent: Left: 0", First Inc. 33. Under Defendants' plan, scheme and enterprise, Defendant Epstein paid Defendant to repeate@y find and bring him underage girls, who were delivered to Epstein by Defendants Robson and in order for Epstein to solicit, induce, coesce, entice, compel or force such girls to engage in acts of prostitution and/or lewdness.
34. Plainhiff Jane Doe was the victim of Defendants' plan, scheme and enterprise. Defendant took Jane Doe to Epstein's home under the pretense that Jane Doe would be paid to give Epstein a massage. Defendant delivered Jane Doe to a room with a massage table and told that Epstein would be in shortly. Jane Doe was alone in the room when Epstein arrived. Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing only a towel. He removed his towel, and laid down on his stomach on the massage table. Epstein again told Jane Doe remove her clothes. In shock, fear and trepidation, Jane Doe complied, removing her clothes except for her panties and bra. Shortly after starting to rub Epstein's back, Epstein told Jane Doe to sit on his back. Jane Doe, out of fear and trepidation, complied. After a period of time Epstein got up from the table and went behind the door. For several minutes Jane Doe heard loud noises and moans and believes that Epstein was masturbating. Thereafter Epstein, naked, returned to the massage table and laid face up on the table. Epstein then told Jane Doe to continue with the massage and told her to sit on top of him. Out of fear and trepidation, she complied. As Jane Doe rubbed Epstein's chest, Epstein began to use a vibrator on Jane Doe's vagina. Thereafter, Epstein began to digitally stimulate and attempt to penetrate Jane Doe's vagina. At this same time, with his other hand, Epstein was masturbating. Upon reaching orgasm, Epstein got up from the massage table and told Jane Doe to write down her name and phone number and then left the room.
Page 8 of 9
Formatted Indent: Left: 0", Fest Inc 35. Jane Doe was then able to get dressed, leave the soom and go back down the stairs and into the kitchen. Epstein, and and were waiting for Jane Doe. Epstein paid Jane Doe \$300. **Source** was paid \$200 by Epstein for bringing Jane <u>Doe</u> to him. Ms. Robson brought Jane Doe home.
WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, **Section 772.104**, and **Section 772.104**, costs and attorney's fees under Florida Statute section 772.104, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complain to add a claim for punktive damages pursuant to Florida Law.
#### JURY TRIAL DEMAND
Plaintiffs demand a jury trial in this action.
Dated March \_\_\_\_ 2008
•
Respectfully submitted,
RICCI-LEOPOLD, P.A. 2925 PGA Blvd, Suite 200 Palan Beach Gardens, FL 33410 Phone: 361-684-6300 Fax: 361-697-2383
By.\_\_
THEODORE J. LEOPOLD Florida Bar No.: 705608
Page 9 of 9
Public Records Request No.: 17-295
#### APPEARANCES:
| 2 | On behalf of the State: |
|-----|------------------------------------------------------|
| 3 | DALIAH H. WEISS, Esquire<br>ASSISTANT STATE ATTORNEY |
| | 401 North Dixie Highway |
| 4 | West Palm Beach, Florida 33401<br>561.355.7100 |
| 5 | |
| 6 | On behalf of the Witness:<br>DONNIE MURRELL, Esquire |
| 7 | L.D. MURRELL, P.A.<br>400 Executive Center Drive |
| 1.5 | Suite 201 |
| 8 | West Palm Beach, Florida 33409<br>561.686.2700 |
| 9 | |
| 10 | ALSO PRESENT: |
| 11 | DETECTIVE JOE RECAREY |
| 12 | Palm Beach Police Department |
| 13 | |
| 14 | |
| 15 | |
| 16 | |
| 17 | |
| 18 | |
| | |
| 19 | |
| 20 | |
| 21 | |
| 22 | |
| 23 | |
| 24 | |
| 25 | |
| - | |
#### J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION 561.835.9738
Page 2
| | | Page 3 |
|----|-----------------------------------|--------|
| 1 | INDEX | |
| 2 | WITNESS:<br>JUAN P. ALESSI | PAGE: |
| 3 | DET.<br>EXAMINATION BY<br>RECAREY | 4 |
| 4 | | |
| 5 | EXHIBITS<br>MARKED<br>NO | |
| 6 | | |
| 7 | | |
| 8 | | |
| 9 | | |
| 10 | | |
| 11 | | |
| 12 | | |
| 13 | | |
| 14 | | |
| 15 | | |
| 16 | | |
| 17 | | |
| 18 | | |
| 19 | | |
| 20 | | |
| 21 | | |
| 22 | | |
| 23 | | |
| 24 | | |
| 25 | | |
| | | |
| | Page4 |
|----|---------------------------------------------------------|
| 1 | Sworn statement taken before Susan |
| 2 | Shelling, Registered Professional Reporter and Notary |
| 3 | Public in and for the State of Florida at Large, in the |
| 4 | above cause. |
| 5 | |
| 6 | Thereupon, |
| 7 | JUAN P. ALESSI, |
| 8 | having been first duly sworn or affirmed, was examined |
| 9 | stated as follows:<br>and |
| 10 | I just want to repeat that<br>MR. MURRELL: |
| 11 | we're here under the State investigative subpoena |
| 12 | that was served on Mr. Alessi, although it was |
| 13 | dated for, I believe, Wednesday or something. |
| 14 | This is Monday the 21st, and we are here by |
| 15 | agreement. |
| 16 | EXAMINATION |
| 17 | BY DET. RECAREY: |
| 18 | Mr. Alessi, I'm Detective Joe Recarey with<br>Q. |
| 19 | As I explained to you on the<br>the Palm Beach P.D. |
| 20 | telephone, I am conducting an investigation on a former |
| 21 | employer of yours. |
| 22 | I just spoke with your wife and she told me |
| 23 | you guys worked for Mr. Epstein for eight years? |
| 24 | A.<br>Yes, she did work for eight years.<br>I |
| 25 | worked longer.<br>I was there before my wife came. |
| | |
| | Page 5 |
|----|-------------------------------------------------------------|
| 1 | Q.<br>Before your wife came. |
| 2 | A.<br>I started full-time with him on January 1, |
| 3 | So I worked<br>1991, and we both left December 31, 2002. |
| 4 | Prior to that, prior to working<br>eleven years exactly. |
| 5 | full-time for him, I worked part-time for him, on-and-off |
| 6 | basis. |
| 7 | Q.<br>What were your responsibilities? |
| 8 | A.<br>In the full-time basis, I started as a |
| 9 | houseman, and I became a major domo and<br>and |
| 10 | We both did<br>everything else, driver, and did everything. |
| 11 | all the chores in the house, but I was in charge of the |
| 12 | I was above my wife and above the cleaning crew,<br>house. |
| 13 | So I was house manager, major<br>the gardners, pool people. |
| 14 | domo. |
| 15 | You would have been the go-to guy for the<br>Q. |
| 16 | house? |
| 17 | A.<br>And the one who would get the blame.<br>Yes. |
| 18 | We are talking about Jeffrey Epstein?<br>Q. |
| 19 | A.<br>Of course. |
| 20 | Do you remember the address of the house?<br>Q. |
| 21 | A.<br>558 El Brillo. |
| 22 | Was it in the beginning of the street<br>Q. |
| 23 | A.<br>At the end of the street, on the left-hand |
| 24 | side. |
| 25 | Q.<br>We're talking about the same house. |
| | |
| | Page7 |
|----|-------------------------------------------------------------|
| 1 | During the time that he was here, you<br>Q. |
| 2 | prepared the house, did all the chores. |
| 3 | Did you do any of the cleaning? |
| 4 | I did last two<br>A.<br>Sometimes.<br>Many times. |
| 5 | or three years the work was so much that we have to |
| 6 | hire we hire a clean-up crew that they came twice a |
| 7 | week or once a week, then it was twice a week.<br>Depends |
| 8 | upon his schedule, because he did not allow anybody at |
| 9 | So when he was<br>the house except us when he was in town. |
| 10 | in town, it was just us doing the cleaning and the |
| 11 | cooking, the driving, shopping, everything else. |
| 12 | Q.<br>Did you stay on property in the guest |
| 13 | house? |
| 14 | A.<br>Yes and no.<br>We had an apartment right |
| 15 | We had an apartment in Tower 1515 on<br>across the bridge. |
| 16 | Flagler, and we had an apartment at the house. |
| 17 | Why would you stay at the house, then?<br>Q. |
| 18 | A.<br>We stay at the house mostly when he was |
| 19 | When he was not in town, we went home.<br>there.<br>We went |
| 20 | When he was there, it was the job<br>to our apartment. |
| 21 | was just too much to go home 9 o'clock, 10 o'clock and |
| 22 | come back 5 o'clock in the morning.<br>We would just stay |
| 23 | and sleep and get up and work. |
| 24 | Q.<br>When he was in town, did he receive a lot |
| 25 | of guests at the house? |
| | |
| | Page 9 |
|----|-----------------------------------------------------------|
| 1 | girlfriend.<br>She was our immediate superior. |
| 2 | Q.<br>Did he have girls come over to give |
| 3 | massages? |
| 4 | A.<br>Yes. |
| 5 | Q.<br>How many massages would he have in a day? |
| 6 | A.<br>Sometimes one, sometimes two, three. |
| 7 | Q.<br>Was it the same girl that would come back |
| 8 | to do the massages? |
| 9 | A.<br>Yeah, yeah.<br>Not the same girl<br>I mean |
| 10 | during eleven years, I probably saw a hundred, two |
| 11 | hundred different massage therapists. |
| 12 | Did they seem young to you?<br>Q. |
| 13 | A.<br>No, sir.<br>Mostly no.<br>We saw one or two |
| 14 | young ones in the last year.<br>Before that, it was all |
| 15 | adults. |
| 16 | Q.<br>During your last year when you were working |
| 17 | with him, what do you mean that they looked young?<br>Did |
| 18 | they look like they were still in high school? |
| 19 | I remember one girl was young.<br>We never<br>A. |
| 20 | asked how old she was.<br>It was not in my job. |
| 21 | Q.<br>Right.<br>I understand. |
| 22 | But I imagine she was 16, 17.<br>In my<br>A. |
| 23 | judgment, she was 16, 17. |
| 24 | Q.<br>Where would these massages take place? |
| 25 | A.<br>All the time it was in his room.<br>Sometimes |
| | |
07/26/17 Page 89 of 131 Pudic Records Request No.: 17-295
Page 10 1 it was in the balcony of his quarters. His room has a 2 wraparound balcony facing the pool. So the massages were 3 in the balcony outside in the sun, or inside in his 4 bathroom or her bathroom. S Q. Would you set up the room for the massages? 6 A. Many times. Yes, he will tell me, Set up 7 the room inside my bathroom or in the bedroom or in 8 Elaine's bathroom, or outside on the balcony. And I 9 would go and set up or my wife would go and set up the 10 table. 11 We had a table in every room of the house, 12 the massage tables, for the different guests. Because 13 not only he got massages, all the other guests got 14 massages too. So we have a table -- massage table in 15 basically every room, guest room. 16 0. The girls that would come over to do 17 massages, they would massage him first or massage guests? 18 A. Different times. There were -- mostly they 19 was his massage. Mostly he would get massages. 20 Q. Would Ms. Maxwell be in the room with him 21 while he was getting the massage? 22 A. We don't know. Apparently we saw her going 23 upstairs, because it was -- when they went upstairs, they 24 closed -- his quarters, it had a double door, so it was a 25 door on top of the stairs -- I don't know if you've been
> J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION 561.835.9738
07/26/17 Page 90 of 131 Pudic Records Request No.: 17-295
1
Page 11 1 in the house -- and then there's another door going into 2 his room. So it was a long corridor. So everything was 3 closed and nobody saw anything. 4 Q. Would you clean up after? 5 A. Once in a while, yes, I did. Most of the 6 times I did. I did the cleanup. 7 Q. Did it appear as if there was going to be 8 more than one massage going on in the room? 9 A. More than one massage? I don't know. It 10 was massages. There was massages, because it was a hot 11 oil, and it was -- you know this vibrator, the neck 12 vibrators with the long handles. And towels, a lot of 13 towels. We used a lot of towels in the house. Used like 14 maybe 40, 50 towels a day, because every time he go in 15 into the pool, it was two or three towels. Everything 16 had to be cleaned up. I went most of the time to pick up 17 the room and get it ready. 18 Q. Did it ever appear to you that more went on 19 in the room other than a massage? 20 A. I just imagine. I never saw anything. But 21 I imagine there was more than I never saw anything 22 because it was closed doors. It was never done outside. 23 Q. Based on the cleanup? 24 A. Based on the cleanup -- at the end, I 25 cannot say there was. At the end, it was a few times
> J.CONSOR&ASSOCIATESREPORTING&TRANSCRIPTION 561.835.9738
07/26/17 Page 91 of 131 Public Records Request No.: 17-295
Page 12 1 that the bed was undone. You know, we make the beds 2 three or four times a day. And sometimes we went to 3 clean up the massage to put it back, the massage table, 4 to pick up the towels, but the bed was undone again. So 5 either he took a nap or he went for a nap, I don't know. 6 Q. Or something else occurred? 7 A. Or something else. I cannot. 8 Q. Did the girls, would they bring their own 9 stuff or they would use his stuff? 10 A. No. We had everything. We had gallons of 11 stuff, different stuff. 12 Q. Different massage oils? 13 A. Different, all kinds. 14 Q. Different massagers? 15 A. Different stuff. 16 They would buy all over the world different 17 types of -- for different -- 18 Q. Did any of these massagers look like sex 19 toys? 20 A. At the end, at the last year that we were 21 there they had like sex toys, some of them. I can say 22 maybe three or four occasions that I saw in the sink, 23 they were left out on the sink, and just -- 24 Q. Where would he keep these massagers? 25 A. When I was there, we keep all the stuff in
> I. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION 561.835.9738
07/26/17 Page 92 of 131 Public Records Request No.: 17-295
| | Page 13 |
|----|-------------------------------------------------------------|
| 1 | It was a big<br>a basket inside Ms. Maxwell's closet. |
| 2 | basket, about this round (indicating), with a cover on |
| 3 | And we used to pick up from the towel and just dump<br>it. |
| 4 | That's it.<br>That's the standard we went<br>it in there. |
| 5 | through. |
| 6 | Q.<br>What sink would you find those massagers |
| 7 | in? |
| 8 | Mostly in his sink, in his bathroom sink.<br>A. |
| 9 | Q.<br>His bathroom sink? |
| 10 | Was Ms. Maxwell still his girlfriend at |
| 11 | that time? |
| 12 | II, yeah.<br>A. |
| 13 | Q.<br>Still his girlfriend that you know of right |
| 14 | now? |
| 15 | A.<br>We left, she was still his<br>Yeah. |
| 16 | I don't know now, but she was still there.<br>girlfriend. |
| 17 | Q.<br>Why did you leave at the end? |
| 18 | It was an incredible<br>A.<br>It was a hard job. |
| 19 | Hours were terrible, from<br>hard job.<br>So demanding. |
| 20 | 5 o'clock in the morning to 10 o'clock at night. |
| 21 | Constantly on your feet. |
| 22 | My health went down the<br>I got very sick. |
| 23 | drain.<br>I was diagnosed with cancer, polycythemia, a kind |
| 24 | It was just too<br>of blood cancer, and we had to leave. |
| 25 | much for me. |
| | |
a
| | Page 14 |
|----|-------------------------------------------------------------|
| 1 | Sounds like a lot.<br>Q. |
| 2 | For me and my wife, we both left.<br>A.<br>Yeah. |
| 3 | Q.<br>It was very demanding when he was here in |
| 4 | town? |
| 5 | A.<br>It was terrible.<br>Bad job.<br>Pay was good, |
| 6 | but we had enough. |
| 7 | Q.<br>I know you guys had a falling out a couple |
| 8 | of years ago; I guess you weren't working with him |
| 9 | You guys had a<br>anymore.<br>This would have been in 2003. |
| 10 | falling out, remember? |
| 11 | A.<br>Yeah, we settled that. |
| 12 | That was settled?<br>Q. |
| 13 | A.<br>That was settled with him between us. |
| 14 | Was that<br>Q. |
| 15 | It was an amicable it was an agreement,<br>A. |
| 16 | mutual agreement.<br>It was a mistake on my part. |
| 17 | Are there any questions you have of me?<br>Q. |
| 18 | I told you the truth.<br>A.<br>No. |
| 19 | We just imagined things that could have |
| 20 | I used to talk to my wife all day, working and<br>happened. |
| 21 | under that environment.<br>But we didn't know for sure what |
| 22 | was going on. |
| 23 | We never heard anything.<br>We never heard a |
| 24 | complaint, or a girl crying. |
| 25 | Q.<br>Would these massage girls, especially |
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| 1 | towards the end, would they come alone or would they come |
| 2 | with other people? |
| 3 | Mostly they would come alone.<br>It was one<br>A. |
| 4 | girl, one of the young girls, the one I can't think of |
| 5 | it, she would bring somebody else.<br>She'd bring other |
| 6 | But I didn't even know the names.<br>girls. |
| 7 | Q.<br>All of them would go downstairs? |
| 8 | A.<br>Yes. |
| 9 | Q.<br>Or would one stay downstairs? |
| 10 | Most of the times when that girl came, it<br>A. |
| 11 | So after dinner after dinner, they went<br>was at night. |
| 12 | And by the time they went to the movies,<br>to the movies. |
| 13 | we clean up right away and tried to get out of there. |
| 14 | And that was about 8, 9 o'clock at night. |
| 15 | After, when they come back, I don't know |
| 16 | Our quarters were a different I don't<br>what happened. |
| 17 | know if you've been in the house, but our quarters were |
| 18 | separate. |
| 19 | Q.<br>It's separate. |
| 20 | that building is new.<br>A.<br>Separate.<br>Before |
| 21 | They build the building in 2001. |
| 22 | Q.<br>The guest quarters? |
| 23 | A.<br>Yeah, the guest quarters. |
| 24 | Before, we had an apartment upstairs. |
| 25 | They have the laundry and a little office<br>Q. |
| | |
07/26/17 Page 95 of 131 Public Records Request No.: 17-295
41111111a.
Page 16 1 and the bedroom? 2 A. Yes. That was 2001. Before that, we had 3 an apartment upstairs in their house, in the main house. 4 Q. In the little rooms upstairs across from 5 his bedroom? 6 A. Right. 7 Q. Was there ever any photographs that you can 8 recall around the house? 9 A. Girls, girls' photographs and guests' 10 photographs, yes. 11 Q. Were they dressed or were they naked? 12 A. Most of them were dressed. It was a lot of 13 entertainment in the pool, around the pool area. But 14 most of them were dressed. 15 Q. When was the last time you spoke with 16 Mr. Epstein? 17 A. The last time I spoke with Mr. Epstein was 18 about a week ago, when you left me the card. I got 19 scared because of that fallout that we had, and I thought 20 it was a consequence of that. And I called and says, 21 Jeffrey, what's going on, what's happening? Because I 22 thought it was an investigation against me on his part. 23 Q. I'm sorry if I gave you that impression. 24 A. That's why I called him. That's the only 25 reason that I called.
> 3. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION 561.835.9738
| | Page 17 |
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| 1 | Before I even spoke to you. |
| 2 | Q.<br>Just when you found the card? |
| 3 | When I find the card, I get scared.<br>A.<br>I |
| 4 | said, What's going on now?<br>Why are you bothering me now |
| 5 | in my house? |
| 6 | That's why I called him. |
| 7 | He said, John, there is an investigation |
| 8 | going on. I have nothing to talk to you.<br>That's it. |
| 9 | I said, Okay. |
| 10 | Q.<br>He didn't give you any information as to |
| 11 | A.<br>No, not a word. |
| 12 | Q.<br>Has anybody else contacted you from |
| 13 | Mr. Epstein or his organization, his assistants, his |
| 14 | attorney? |
| 15 | A.<br>No, no, no. |
| 16 | Q.<br>Anyone that works for his attorney? |
| 17 | A.<br>For his attorney?<br>Yes.<br>For his attorney, |
| 18 | the present attorney?<br>Yes.<br>That was an investigator |
| 19 | that it was investigated on his side, I can't remember |
| 20 | his name, but I understand it was from Roy Black's |
| 21 | And he this<br>office.<br>That was his attorney. |
| 22 | investigator basically asked me the same questions, |
| 23 | exactly the same questions:<br>What did I know, what did I |
| 24 | know. |
| 25 | Q.<br>When did this happen? |
| | |
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| 1 | This happened about ten days ago about a<br>A. |
| 2 | week ago, ten days ago.<br>I'm not sure what date. |
| 3 | Q.<br>Was his investigator's name |
| 4 | A.<br>It's the date after I contacted you. |
| 5 | Paul, first name Paul?<br>Q. |
| 6 | A.<br>Paul, Paul, yes. |
| 7 | You have the last name? |
| 8 | Q.<br>No. |
| 9 | A.<br>He asked me exactly the same questions. |
| 10 | Q.<br>Did he offer you any money? |
| 11 | A.<br>Absolutely not.<br>I would not take it. |
| 12 | Q.<br>Did he tell you not to speak to me? |
| 13 | He says no, he told me not to speak<br>A.<br>No. |
| 14 | He didn't say that to me.<br>to you.<br>He says, It's your |
| 15 | choice.<br>You make that decision. |
| 16 | And he says, If you hire a lawyer, you make |
| 17 | that decision. |
| 18 | And we feel that was important for us.<br>I |
| 19 | don't want to be involved with this thing.<br>I'm out of |
| 20 | the job three years ago, and that's why we hired |
| 21 | Mr. Murrell.<br>He suggested that. |
| 22 | Q.<br>Did he ask you if anybody else has been |
| 23 | contacted? |
| 24 | A.<br>No. |
| 25 | Q.<br>Did he tell you that to call him back after |
0'1126/17 Page 98 of 131 Public Records Request No.: 17-295
Page 19 1 our meeting? 2 A. No, no. 3 Q. Were you to have any contact with him at 4 any time after our meeting? 5 A. If I will have a contact? I have no reason 6 for it. I have no reason to call Jeffrey or anybody 7 else. This is over, I hope. 8 Q. Well, Mr. Alessi, this is basically an 9 ongoing investigation, so obviously anything that we 10 discuss hopefully will stay between us. Because it is 11 still ongoing, I wouldn't want this out until the 12 investigation is complete. 13 A. It's not going anywhere. Even my kids 14 don't know it. 15 Q. He contacted you after you called 16 Mr. Epstein? 17 A. Yes. 18 When I call him and I said, Jeffrey, what's 19 going on? 20 He said, John, I don't know what's going 21 on. There's an investigation against me. 22 So then I said, Whew, thank God. I don't 23 know what's happening. 24 And then he says, I have an investigator 25 that is investigating, the same thing the police
> 3. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION 561.835.9738
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| 1 | department is doing.<br>He's going to contact you. |
| 2 | And that was the end of it. |
| 3 | I think his name was Paul.<br>I only met him |
| 4 | for about fifteen minutes, ten minutes. |
| 5 | Q.<br>You met at your house? |
| 6 | A.<br>No, no.<br>I don't want him at my house.<br>We |
| 7 | met at Carrabas restaurant, but it was not open, so we |
| 8 | met outside Carrabas.<br>It took about ten minutes. |
| 9 | Q.<br>Going back to the items that were found in |
| 10 | the sink, can you describe any of those massagers? |
| 11 | I only saw two things:<br>It was a big,<br>A. |
| 12 | Big (indicating). And it was<br>big I think a vibrator. |
| 13 | a long I hate to I'm sorry.<br>It was a long dick, I |
| 14 | And there was a thing you used it<br>think.<br>Rubber thing. |
| 15 | in the back, the vibrator in the back. |
| 16 | What color?<br>Q. |
| 17 | A.<br>We always had those.<br>Not those toys. |
| 18 | Vibrators, we have different types, one for the neck, one |
| 19 | You know the one that has a battery and<br>for the back. |
| 20 | they move, with balls on it, vibrator.<br>That's it. |
| 21 | That's what I find there.<br>I never find anything else. |
| 22 | Those two things. |
| 23 | Q.<br>Do you remember any names of the girls that |
| 24 | might have come over for massages? |
| 25 | A.<br>Yes.<br>I remember some of them.<br>From the |
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| 1 | beginning?<br>From the end? |
| 2 | As many as you can remember.<br>Q. |
| 3 | A.<br>As many as I can remember. |
| 4 | Q.<br>I know it's been a while. |
| 5 | And it was<br>A.<br>It was Jody.<br>It was Donna. |
| 6 | it was Virginia.<br>It was how many?<br>Virginia, Lana. |
| 7 | It was also a young girl, but she was not a |
| 8 | massage therapist.<br>She came to the house as a friend, I |
| 9 | think.<br>I don't think she was a massage therapist.<br>Her |
| 10 | name was as a matter of fact, she's in a soap opera |
| 11 | now, she's a star.<br>Just give me a minute. |
| 12 | Nadya Jorlin, J-O-R-L-I-N. |
| 13 | There also were men masseuses. |
| 14 | Q.<br>There were men too? |
| 15 | A.<br>A few.<br>Not that many.<br>A<br>There were men. |
| 16 | few.<br>I can't remember. |
| 17 | Allison.<br>There was an Allison.<br>There was |
| 18 | a Dina.<br>I think every name girls' names.<br>In |
| 19 | eleven years, I cannot remember. |
| 20 | That's fine.<br>Q. |
| 21 | A.<br>There were girls coming and going.<br>There |
| 22 | were girls traveling with him as massage therapists. |
| 23 | They would travel with him all over the world, because he |
| 24 | was in the plane, he got massages on the plane, |
| 25 | because I know because I used to supply the oils and |
| | |
07/26/17 Page 101 of 131 Public Records Request No.: 17-295
1
Page22 1 the towels for the plane. 2 Q. Would you clean his plane too? 3 A. No, no. 4 Q. Did you ever travel with him anywhere? 5 A. No, no. 6 Q. When he went to New York or Arizona or his 7 private island? 8 A. I've been on his island. I've been as a 9 guest, as a vacation. We just took vacations, and I went 10 to his island in the Caribbean. And I've been in New 11 Mexico. I've been at his house in London. But not as a 12 worker, just vacation. 13 Q. As a vacation? 14 A. Uh-huh. 15 We went to New Mexico for -- it was kind of 16 a symposium about how to clean homes. It was this lady 17 who make -- teach all the house people, housemen, and 18 they invited us to Santa Fe, New Mexico, to teach us how 19 to clean homes. That was kind of stupid. 20 Q. How he wanted it to be cleaned? 21 A. Yes. We didn't get that much. 22 Q. Can you think of anything that I haven't 23 asked you that might be relevant to this? 24 A. I can't think of anything. Basically it's 25 the same questions that the other investigator asked me.
> J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION 561.835.9738
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Page 23 1 Exactly the same. 2 I wish I could give you more names. 3 Allison -- 4 Q. I'm not going to ask you to do that because 5 I know it's been a long time. I can't think of stuff I 6 did last week. 7 A. It's been a long time. 8 Q. If by any chance you are contacted again by 9 his investigator again for any more questions or anything 10 or any packages that he may deliver to you -- 11 A. They have to go to Mr. Murrell. 12 Q. I was going to say, have him contact your 13 attorney. 14 MR. MURRELL: Packages? Are we expecting a 15 delivery of something? 16 DET. RECAREY: No. I'm just saying -- 17 MR. MURRELL: Okay. Just making sure there 18 wasn't something I didn't know about. 19 DET. RECAREY: I.e., gifts, et cetera. 20 That kind of thing. 21 THE WITNESS: No. 22 DET. RECAREY: I would appreciate a phone 23 call just to give me a heads up. 24 THE WITNESS: I do not intend to contact 25 him at all.
> CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION 561.835.9738
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| 1 | I appreciate it.<br>Okay.<br>DET. RECAREY: |
| 2 | And that's it. |
| 3 | (Thereupon, the sworn statement was |
| 4 | concluded at 1:05 p.m.) |
| 5 | |
| 6 | |
| 7 | |
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Page 25 THE STATE OF FLORIDA, 1 ) 2 COUNTY OF PALM BEACH. ) 3 4 5 I, the undersigned authority, certify that Juan 6 P. Alessi personally appeared before me and was duly 7 sworn. 8 9 WITNESS my hand and official seal this 5th day of December, 2005. 10 11 12 13 14 Susan Shelling, RPR Notary Public - State of Florida 15 My Commission No. DD 098441 My Commission expires 3/7/2006 16 17 18 . # DD098441 Expires March 7, 2006 Bonded Thre 19 ntic Bonding Co. 20 21 22 23 24 25
Page 105 of 131
| | Page 26 |
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| 1 | CERTIFICATE |
| 2 | The State Of Florida, ) |
| 3 | County Of Palm Beach. ) |
| 4 | |
| 5 | I, Susan Shelling, Registered Professional<br>Reporter and Notary Public in and for the State of |
| 6 | Florida at Large, do hereby certify that Juan P. Alessi<br>was by me first duly sworn to testify the whole truth; |
| 7 | that I was authorized to and did report said sworn |
| 8 | statement in stenotype; and that the foregoing pages,<br>numbered from 1 to 24, inclusive, are a true and correct |
| 9 | transcription of my shorthand notes of said sworn statement. |
| 10 | I further certify that said sworn statement<br>was taken at the time and place hereinabove set forth and |
| 11 | that the taking of said sworn statement was commenced and |
| 12 | completed as hereinabove set out. |
| 13 | I further certify that I am not an attorney or<br>counsel of any of the parties, nor am I a relative or |
| 14 | employee of any attorney or counsel of party connected<br>with the action, nor am I financially interested in the<br>action. |
| 15 | The foregoing certification of this transcript |
| 16 | does not apply to any reproduction of the same by any means unless under the direct control and/or direction of |
| 17 | the certifying reporter. |
| 18 | IN WITNESS WHEREOF, I have hereunto set my hand<br>and seal this 5th day of December, 2005. |
| 19 | |
| 20 | |
| 21 | Susan Shelling Notary Public<br>In and for the State of Florida |
| 22 | My Commission No. DD 098441<br>My Commission Expires 3/7/2006 |
| 23 | / Hy COMMISSION EXPILES S/1/2000 |
| 24 | |
| 25 | |
| press mayo | |
Page 106 of 131
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#### k A Absolutely 18:11 action 26:14,14 Adam 8:11 address 5:20 adults 9:15 affirmed 4:8 ago 6:5 14:8 16:18 18:1,2,2,20 agreement 4:15 14:15,16 Alessi 1:6 3:2 4:7 4:12,18 19:8 25:6 26:6 Allison 21:17,17 23:3 allow 7:8 amicable 14: 15 and/or 26:16 Annie 8:20 anybody 7:8 17:12 18:22 19:6 anymore 14:9 apartment 7:14 7:15,16,20 15:24 16:3 Apparently 10:22 appear 11:7,18 APPEARANCES 2:1 appeared 25:6 apply 26:16 appreciate 23:22 24:1 area 16:13 Arizona 22:6 arrangements 6:24 asked 9:20 17:22 18:9 22:23,25 assistant 2:3 8:5 8:18,19,22 assistants 8:3,4 17:13 Associates 1:24 attorney 2:3 17:14,16,17,17 17:18,21 23:13 26:12,13 authority 25:5 authorized 26:7 B B 3:5 back 7:22 9:7 12:3 15:15 18:25 20:9,15 20:15,19 Bad 14:5 balcony 10:1,2,3 10:8 balls 20:20 Based 11:23,24 basically 6:7 8:24 10:15 17:22 19:8 22:24 basis 5:6,8 basket 13:1,2 bathroom 10:4,4 10:7,8 13:8,9 battery 20:19 Beach 1:1,4,11 2:4,8,11 4:19 25:2 26:3 bed 12:1,4 bedroom 10:7 16:1,5 beds 12:1 beginning 5:22 21: <sup>1</sup> behalf 2:2,5 believe 4:13 big 13:1 20:11,12 20:12 Black's 17:20 blame 5:17 blood 13:24 boss 6:14 8:25 bothering 17:4 bridge 7:15 Brillo 5:21 bring 12:8 15:5,5 build 15:21 building 15:20,21 5:9 buy 12:16 C C26:1,1 call 18:25 19:6,18 23:23 called 16:20,24,25 17:6 19:15 cancer 13:23,24 card 16:18 17:2,3 Caribbean 22:10 Carrabas 20:7,8 cause 4:4 Center 2:7 certification 26:15 certify 25:5 26:6 26:10,12 certifying 26:17 cetera 23:19 chance 23:8 charge 5:11 chef 8:7,7,13,15 chef's 8:9 choice 18:15 chores 5:11 7:2 clean 11:4 12:3 15:13 22:2,16 22:19 cleaned 11:16 22:20 cleaning 5:12 7:3 7:10 cleanup 11:6,23 11:24 clean-up 7:6 closed 10:24 11:3 11:22 closet 13:1 color20:16 come 6:21 7:22 8:17,17 9:2,7 10:16 15:1,1,3 15:15 20:24 coming 6:22 21:21 commenced 26:11 Commission 25:15,16 26:22 26:22 complaint 14:24 complete 19:12 completed 26:11 concluded 24:4 conducting 4:20 connected 26:13 consequence 16:20 Consor 1:24 Constantly 13:21 contact 19:3,5 20:1 23:12,24 contacted 17:12 18:4,23 19:15 23:8 control 26:16 cooking 7:11 correct 6:19 26:8 corridor 11:2 counsel 26:13,13 County 1:1 25:2 26:3 couple 14:7 course 5:19 cover 13:2 crew 5:12 7:6 ming 14:24 D D3:1,5 DALIAH 2:2 date 18:2,4 dated 4:13 day 9:5 11:14 12:2 14:20 25:9 26:18 days 18:1,2 DD 25:15 26:22 deal 6:8,14 December 5:3 25:10 26:18 decision 18:15,17 deliver 23:10 delivery 23:15 demanding 13:19 14:3 department 2:11 20:1 Depends 7:7 describe 20:10 DET 3:3 4:17 23:16,19,22 24:1 Detective 2:11 4:18 diagnosed 13:23 dick 20:13 Didier 8:13 different 9:11 10:12,18 12:11 12:12,13,14,15 12:16,17 15:16 20:18 Dina 21:18 dinner 15:11,11 direct 26:16 direction 26:16 directly 6:8,15 discuss 19:10 Dixie 1:10 2:3 doing 7:10 20:1 domo 5:9,14 Donna 21:5 DONNIE 2:6 door 10:24,25 11:1 doors 11:22 double 10:24 downstairs 15:7,9 drain 13:23 dressed 16:11,12 16:14 Drive 2:7 driver 5:10 driving 7:11 duly 4:8 25:6 26:6 dump 13:3 E E 3:1,5,5 26:1,1 eight 4:23,24 either 12:5 El 5:21 Elaine 6:17 Elaine's 10:8 eleven 5:4 6:21 9:10 21:19 employee 26:13 employer 4:21 English 8:15,20 entertainment 16:13 environment 14:21 Epstein 4:23 5:18 6:9 16:16,17 17:13 19:16 especially 14:25 Esquire 2:2,6 et 23:19 exactly 5:4 17:23 18:9 23:1
J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION 561.835.9738
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| a the second second | | | | |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------|---------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| EXAMINATION | girls 9:2 10:16 | 22:19 | I.e 23:19 | look 9:18 12:18 |
| 3:3 4:16 | 12:8 14:25 15:4 | hope 19:7 | | looked 9:17 |
| examined 4:8 | 15:6 16:9,9 | hopefully 19:10 | J | lot 7:24 8:21 |
| Executive 2:7 | 20:23 21:18,21 | hot 11:10 | January 5:2 | 11:12,13 14:1 |
| expecting 23:14 | 21:22 | Hours 13:19 | Jeffrey 5:18 16:21 | 16:12 |
| expires 25:16 | give 9:2 17:10 | house 5:11,12,13 | 19:6,18 | L.D 2:6 |
| 26:22 | 21:11 23:2,23 | 5:16,20,25 6:24 | job 7:20 9:20 | |
| explained 4:19 | go 7:21 8:17,17 | 7:2,9,13,16,17 | 13:18,19 14:5 | М |
| | 10:9,9 11:14 | 7:18,25 10:11 | 18:20 | M 3:5 |
| F | 15:7 23:11 | 11:1,13 15:17 | Jody 21:5 | main 16:3 |
| F 26:1 | God 19:22 | 16:3,3,8 17:5 | Joe 2:11 4:18 | major 5:9,13 |
| facing 10:2 | going 6:7 10:22 | 20:5,6 21:8 | John 17:7 19:20 | making 23:17 |
| fact 21:10 | 11:1,7,8 14:22 | 22:11,17 | Jorlin 21:12 | manager 5:13 |
| falling 14:7,10 | 16:21 17:4,8 | households 6:11 | Juan 1:6 3:2 4:7 | 6:11,11 |
| fallout 16:19 | 19:13,19,20 | houseman 5:9 | 25:5 26:6 | massage 9:11 |
| Fe 22:18 | 20:1,9 21:21 | housemen 22:17 | judgment 9:23 | 10:12,14,17,17 |
| feel 18:18 | 23:4,12 | hundred 9:10,11 | J-O-R-L-I-N | 10:19,21 11:8,9 |
| feet 13:21 | good 14:5 | | 21:12 | 11:19 12:3,3,12 |
| fifteen 20:4 | gourmet 8:7 | I | | 14:25 21:8,9,22 |
| financially 26:14 | go-to 5:15 | imagine 9:22 | K | massagers 12:14 |
| find 13:6 17:3 | guess 14:8 | 11:20,21 | K3:5 | 12:18,24 13:6 |
| 20:21,21 | guest 7:12 10:15 | imagined 14:19 | keep 12:24,25 | 20:10 |
| fine 21:20 | 15:22,23 22:9 | immediate 9:1 | kids 19:13 | massages 9:3,5,8 |
| first 4:8 10:17 | guests 7:25 8:1,2 | important 18:18 | kind 13:23 22:15 | 9:24 10:2,5,13 |
| 18:5 26:6 | 10:12,13,17 | impression 16:23 | 22:19 23:20 | 10:14,17,19 |
| Flagler 7:16 | 16:9 | inclusive 26:8 | kinds 12:13 | 11:10,10 20:24 |
| Florida 1:1,11,23 | guy 5:15 | incredible 13:18 | know 8:11,14 | 21:24 |
| 2:4,8 4:3 25:1 | guys 4:23 14:7,9 | indicating 13:2 | 10:22,25 11:9 | masseuses 21:13 |
| 25:15 26:2,6,21 | guys 4.25 14.7,9 | 20:12 | 11:11 12:1,5 | 16:5 |
| fly 8:19 | Н | inform 6:22 | 13:13,16 14:7 | matter 21:10 |
| follows 4:9 | H 2:2 3:5 | information | 14:21 15:6,15 | Maxwell 6:17,18 |
| foregoing 26:7,15 | hand 25:9 26:18 | 17:10 | 15:17 17:23,24 | 8:22 10:20 |
| former 4:20 | handles 11:12 | inside 10:3,7 13:1 | 19:14,20,23 | 13:10 |
| forth 26:10 | happen 17:25 | intend 23:24 | 20:19 21:4,25 | Maxwell's 13:1 |
| found 17:2 20:9 | happened 14:20 | interested 26:14 | 23:5,18 | mean 9:9,17 |
| four 12:2,22 | 15:16 18:1 | investigated | | means 26:16 |
| 8:13 | happening 16:21 | 17:19 | L | meeting 19:1,4 |
| friend 21:8 | 19:23 | investigating | lady 22:16 | men 21:13,14,15
> This document was truncated for web display. See the linked source PDF for the complete record.
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